HOLLANDS FARM DEVELOPMENT BRIEF 6Th January 2021 to 17Th

HOLLANDS FARM DEVELOPMENT BRIEF

6th January 2021 to 17th February 2021

KEEP BOURNE END GREEN

CONSULTATION RESPONSE

17 February 2021

Keep Bourne End Green (“KBEG”) is a Charitable Incorporated Organisation (charity no. 1169057) that was set up in 2016 to conserve and improve the natural and physical environment and to promote sustainable development within Bourne End and its surrounding areas.

KBEG actively campaigned during preparation of the Wycombe District Local Plan (the “LP”) and afterwards to resist the unnecessary release of land from the Green Belt. During this period, KBEG received signed mandates from over 3,000 residents and households to represent their interests in pursuit of our charitable objectives.

1 Introduction and Summary

1.1 This response is provided in reply to the Buckinghamshire Council (the “Council”) public consultation on the Draft Development Brief for Hollands Farm (the “DDB”). It is mostly organised to mirror the structure of the online survey to assist the Council review. Within this response KBEG recommends amendments to the Draft (marked in green boxes) and proposes related actions for the Council (marked in orange boxes).

1.2 Having reviewed all the Consultation documents alongside the LP evidence base and recent updates, KBEG recommends the Draft Development Brief is modified to deliver a reduced capacity of dwellings in line with the overall sustainable growth target set for Bourne End and Wooburn. This adjustment will materially address core issues with regard to net available land, housing density, landscape and character, coalescence of communities, open space and green buffers. Critically, a detailed traffic forecasting assessment is required to confirm whether the Principal Route through the site will still deliver the slight benefits modelled during plan-making. A further detailed assessment of all access routes into the site must be undertaken to provide robust guidance that will inform the transport mitigation package. Such modification to housing numbers may obviate the need for a single form entry primary school. This potentially creates more space for an exemplar sustainable and attractive development that will become the first step in the Council’s new commitment to a net zero carbon future.

1.3 The principal issues (in no particular order) are:

• The Principal Route link road is undeliverable due to physical restrictions that will prevent a safe two-way access route through the site capable of supporting buses and HGVs and other large vehicular traffic while also maintaining safe pedestrian footpaths and cycle facilities;

• The alternative principal access route at Millboard Road is in private ownership where the business stakeholders have plainly stated their opposition to the proposed access and, regardless of the private ownership issue, has road safety concerns resulting from regular HGV vehicular movements which invariably must reverse in/from the road. This road is considered undeliverable as a principal access route;

• The improvement required to create a new four arm roundabout at Princes Road will not comply with highway standards (and would result in loss of designated Green Space at ‘Brookbank’);

• A new junction at Hedsor Road is not feasible within the identified site, and would have adverse effects on the heritage setting if required land was taken and important buildings lost;

• The Council only intended the indicative supply as a high-level capacity assessment, which proposed a range between 321 and 467 homes, that required further work to confirm estimates and conclusions. There is no sound basis for the high level of supply proposed;

• The indicative housing supply of 467 homes will exceed the sustainable growth target for Bourne End and Wooburn adopted in the LP;

• To achieve the indicative supply over the proposed net developable area demands an average housing density much higher than the surrounding residential areas that precludes it being cohesive or well-integrated within the existing context;

• The site location and access routes (considered deliverable) are demonstrated to be greater than 800m which will not provide easy access to the services provided at the village centre;

• The housing density required to deliver the indicative supply will average 40 dph which is out of character with all existing residential areas surrounding the site at Hawks Hill/Harvest Hill (1.3 dpa), Hedsor and Riversdale Conservation Area (4 to 18 dph), Bourne End (12.9 dph), and Cores End (32 pdh). This would altogether shift the centre of gravity for Bourne End;

• Proposed buffer zones are inadequate which do not provide substantial physical or visual separation between Hawks Hill/Harvest Hill, or separation with the heritage setting at Hedsor, or safeguard existing residential areas at Cores End;

• The proposed development framework would result in the effective coalescence of Bourne End (including Cores End) settlement and Wooburn settlement with Upper Hedsor Road which is part of the Hedsor settlement;

• Bourne End and Wooburn combined has a significant deficiency in meeting open space requirements and falls below standard – the development must prioritise the deficiency;

• Existing residential development at the end of Bridgestone Drive looks over the site and does not back onto it, and the dwellings on Hellyer Way form a robust development pattern that is not unfinished or requires completing;

• An outline application with all matters reserved is not a suitable planning vehicle for this site which has a policy designation for residential development and will have site-specific supplementary planning guidance in the Development Brief when it is adopted;

• The development will result in a reduction in net biodiversity in the immediate area, which must not be mitigated off-site at the distant Little Marlow Country Park (which has not progressed as a “country park” during the decades it has benefitted from the policy designation and is frequently justified as a mitigation area, including from development at High Wycombe and Marlow);

• Estimates over pedestrian walking and cycling routes are inaccurate – these are far in excess of 800m from the site;

• The public right of way at Princes Road and at the existing Hollands Farm entrance extend over the full width of the untarred tracks and any diversion or amendment must retain the same amount of width;

• The public right of ways which cross the site are ancient well-trodden tracks and any loss, harm or diversion must be resisted;

• The end of the existing Princes Road is a narrow residential track that requires all but the very smallest of vehicles to reverse back and onto at the existing Princes Road junction which raises highways safety concerns;

• The proposed location of the primary school in an area of identified surface water flooding on the site is contrary to Council guidance;

• The proposed location of the primary school adjacent to the busy industrial estate on Millboard Road with has frequent HGV vehicle movements raises safety concerns and concerns over adverse effects from noise and pollution;

• The Development Brief omits guidance over opportunity to deliver adopted Policy BE3 which envisages “a new health centre could be facilitated on the housing allocations at … Hollands Farm (BE2)”.

2 Community engagement

2.1 The present public consultation is welcomed; however, it is regrettable that the community engagement up to this point is characterised as unnecessarily imperfect.

2.2 It was alarming and disappointing that Wycombe District Council (“WDC”), as it was then, did not commit upfront to a broad community engagement, specifically with Bourne End and Wooburn residents who will have to live with the outcome of the new development on the site long after the developers have disbursed their profits and Council officials have left office.

2.3 The absence of any public workshops or other community activity before the Hollands Farm Liaison Group (the “LG”) convened in late 2019 was disappointing; this form of early community engagement has invariably been the first step towards preparation of development briefs elsewhere in the District. Omitting public workshop(s) from the initial process was a missed opportunity which might otherwise have allowed local residents to influence the development process and to establish and prioritise ideas and principles to be considered by the LG.

2.4 Social limitations arising from the global COVID-19 pandemic do, of course, presently restrict public workshops, but this was not the case in 2019 when work began on the development framework and when the LG was formed.

2.5 Next, WDC overlooked the chance to ensure there was appropriate representation of interests within the LG. To this end, it is prominent that only a single local resident was called upon as a non-elected representative for the local community inevitably resulting in a disproportionate balance of interests within the steering group.

2.6 Once convened, minutes of meetings and other material were kept private and only published shortly before this consultation which divorced the local community from monitoring progress. Further, the current public consultation was advertised by letter to only those residents whose streets immediately surround the site rather than being notified to everyone in Bourne End and Wooburn. It should not be overlooked that the current proposals for Hollands Farm are significant as this site alone has designs to increase the local population by 18%1, and it is therefore reasonable to consider the impact has much wider community interest than the few streets adjacent to the site.

1 ONS (2011) Bourne End-cum-Hedsor recorded a population of 5,531 residents in 2011.

Council’s Consultation Statement

2.7 The Council’s Consultation Statement (January 2021) was published no earlier than 18th January 2021, nearly two weeks into the current consultation, without any fanfare (hence the actual date of publication is unknown). As this document has only just come to light KBEG has not had sufficient opportunity to digest the statement in full. However, we would like to address an immediate matter seen on page 5 which wrongly asserts KBEG was contacted by the Council as an “external consultee” when preparing the Draft Development Brief.

2.8 We can clarify that the Council did not approach or otherwise contact or extend invitation to KBEG to provide a consultation response to assist preparation of the Draft Development Brief. The earliest opportunity for KBEG to provide a response is within the present public consultation framework. The reference at paragraph 3.2 is misleading and factually without basis.

Fast tracking

2.9 It is not necessary to dwell on the purpose for the Development Brief which has a vital site-specific role to ensure an acceptable framework exists for development.

2.10 It was alarming and disappointing to find the DDB needlessly fast-tracked to the current public consultation without taking time to ensure it adequately addressed unresolved matters raised by the LG, or provided clear positive guidelines to overcome identified weaknesses / threats for the site. Such matters include, inter alia, confirming deliverability and guidance for the principal access routes and junction improvements which are vital planning matters to achieve a successful outcome.

2.11 There is certainly no rush from a housing supply perspective: The most recently published 5 Year Housing Land Supply (the “5YHLS”)2 demonstrated sufficient capacity for the period, and in August 2019 the adopted Wycombe District Local Plan (the “LP”) confirmed an excess supply of up to 974 dwellings from the assessed housing delivery to 2033 (which oversupply is more than twice the proposed contribution supply from this Green Belt site). Therefore, there is no pressing shortfall in either housing supply or 5YHLS trajectory to justify the current rush to adopt a premature development brief.

2.12 At the time of writing, the LG had convened for just four meetings prior to publication of the DDB. These four meetings ran between 7 October 2019 and 3 November 2020

2 Wycombe 5YS Position (1 March 2019) confirmed 5.7 years supply using the Local Housing Need standard method, equivalent to 8 years supply using the adopted Local Plan 10,925 housing target.

covering an elapsed period of 374 days, though it is suspected this timeline would have been shorter but for the impacts of COVID-19.

Table 1: Comparison of the preparation for Hollands Farm Development Brief with preparation of development briefs at other allocated sites within the District.

GROSS INITIAL NO. FIRST MEETING LAST MEETING ELAPSED SITE AREA WORKSHOP MEETINGS DATE DATE DAYS (ha)

Terriers Farm 23 Yes 9 27.01.2015 06.03.2018 1,135

Slate Meadow 10.7 Yes 14 23.02.2015 18.09.2017 939

Abbey Barn North & South 33 & 1.47 Yes 9 12.02.2015 08.03.2018 1,121

Gomm Valley & Ashwells 73 Yes 13 26.01.2015 02.08.2018 1,285

AVERAGE YES 11.25 1,120

Hollands Farm 23 NO 4 07.10.2019 03.11.2020 374

2.13 The speed to publish the DDB is at odds with the timeline at other strategic sites which have also prepared development briefs as demonstrated in Table 1.

Community representation in the Liaison Group

2.14 It is considered that lack of proportionate representation within the LG has allowed the LG to promote an agenda which has fast-tracked preparation of the DDB and suppressed vital work necessary to resolve key weaknesses and threats associated with development.

3 2.15 Of the twenty-three members of the LG there was only one non-elected representative for the local community. In contrast, the Terms of Reference had set out that four members would be from the developers/site promoters but the minutes show six were eventually present.

2.16 Wooburn and Bourne End Parish Council (including members of the NDP working party) were allotted the role of community representation on the LG, though their representatives have been so anxious over shortcomings in the preparation of the DDB and their views being overlooked that the Parish Council has been forced to write open letters expressing its concerns.

3 Members of the Hollands Farm Liaison Group: District Council – 8; Wooburn & Bourne End Parish Council – 5; Developers – 6; County Council – 1; Highways Authority – 1; Hedsor Parish – 1; Local community – 1.

2.17 It is generally bewildering why the balance of representation in the LG favours the site promoters compared to non-elected local representatives given their vested interest in the site: It’s akin to asking a student to set their own exam papers. It would be futile to consider the overarching interests of the site promoters have not been advancing their business interests rather than embrace the best possible solutions.

2.18 We consider this is amply demonstrated with the suppression of key matters impacting the success for the development and prevalence of weak aspirational terms in the DDB such as ‘could’ or ‘should’ rather than ‘must’ and ‘will’. Moreover, the site promoters seem to have adversely advanced their objective for a future outline planning application [DDB 7.1.2; 7.2.1; 7.3.7] which undermines the ability of the Council or public to assess the application in full with all matters unreserved and on the table, and rather allows the developer to deal with the tricky issues in a less than optimal way once outline planning permission has been granted. Certainly, Catesby Estates has made no secret of this planning goal.

Proposed consultation on a redrafted Development Brief

2.19 It has invariably been the case that preparation of a development brief in the District has been influenced by two public engagements: first, commencement workshop(s) and subsequently a consultation on the prepared draft development brief. For Hollands Farm, there was no initial engagement which was prejudiced against with the local community and denied opportunity for views and priorities to be considered by the LG to inform the foundation of the Development Brief. As result, the current consultation is the first opportunity for the public to provide their ambitions and views for the new development.

2.20 KBEG urges the Council to give serious consideration to the present opportunity for mitigation, if for no other reason than the unnecessary omission of advance workshop(s) or alternative community engagement in preparation of the DDB. The next phase should be exceptionally amended to accommodate a further public consultation on proposed modifications to a second draft of the Development Brief. Inevitably this would need to follow the Council’s review of all matters arising from this first consultation and after publication of additional assessments deemed necessary to inform the redraft. An additional consultation will reset the balance of community engagements, and as already described above, there is no demonstrable rush to promote an incomplete or immature development brief.

2.21 We suggest the following action:

The Council should hold a further consultation on the proposed modifications to the redrafted Development Brief after it has reviewed community responses from the current consultation and completed additional assessments.

2.22 It would also be advantageous to formally extend the second consultation to the whole Bourne End and Wooburn community, and in the current COVID-19 climate to delay such public engagement until a date when public health advice allows face-to-face events as it would otherwise prejudice members of the local community.

2.23 We note that a second public consultation on the updated draft Development Brief will not eliminate the need for a subsequent pre-application consultation by the site promoters before the final planning application is submitted.

Catesby Estates public consultation

2.24 It is common sense to consider any pre-application public workshop(s) / consultation(s) related to a future planning application for development of the site would be premature in advance of an adopted development brief. And for such engagement to be timetabled without allowing any breathing room following a public consultation on the DDB exhibits total contempt for the logical order of proceedings.

2.25 Yet this is precisely what the site promoters have announced. In that regard, it is wholly premature for Catesby Estates to consider starting their public consultation for the proposals at Hollands Farm on 18th February 2021 - just one day after the current consultation on the DDB finishes!

2.26 Their proposed schedule is far too assertive which overlooks progress and fully dismisses the purpose and role of a development brief and the purpose and role of the pre-application consultation. The comments KBEG has received from the community over Catesby Estate’s announcement during the Council’s consultation has been one of shock, disgust, distrust in the process, outrage, and confusion over the two consultations.

2.27 In the context that a pre-planning application consultation should be based on details for the planning application, it suggests the land promoters have already made strategic decisions well in advance of the adopted Development Brief which speaks volumes about their general regard for the weight of issues, community engagement and framework / objectives that will be set out within the supplementary planning guidance.

2.28 Their design for a premature consultation defies rational logic. It makes no sense to hastily bring forward a pre-application consultation before adoption of the Development Brief, unless this course of action does not reflect the actual progress of decision-making for Hollands Farm. In an alternative light, which the community has raised, the situation goes to reinforce public concern over transparency of the decision- making process which makes more sense in current circumstances if the public consultation on the DDB has been a hollow exercise where politically influenced decisions have already been made and committed in private.

2.29 In response to Catesby Estate’s announcement of their pre-application consultation, Cllr Julia Adey, a member of the LG, stated the Council are following up on the matter on social media, and we note the Council has been forced to provide clarification on its own consultation website. KBEG calls upon the Council to write an open letter which formally requests the site promoters halt and postpone their premature consultation until such a time as appropriate following adoption of the Development Brief. For otherwise the site promoter’s pre-application consultation must be given very limited weight as it corrupts the fundamental aspects and positive principals for public engagement.

2.30 The DDB must be updated with:

The Council will give very limited weight to pre-application public consultations undertaken prior to adoption of the Development Brief.

2.31 As with the proposed second consultation on the revised DDB, it is suggested that the site promoters are advised to undertake their pre-application consultation when government health advice deems it safe to hold public meetings.

Outline planning application

2.32 When it comes to allocated sites that benefit from an adopted development brief, planning applications made in outline form with all matters reserved are a failing of the planning system and such an outcome must be resisted for Hollands Farm.

2.33 Policy BE2 establishes the principle for residential development meaning there is no demand upon the developer to test the site’s suitability using a limited outline application (with all matters reserved). The combination of adopted policy and guidance, Development Brief and pre-application consultation altogether provide a very competent framework to identify and scope the planning matters to which a subsequent planning application should respond. Indeed, a Development Brief strengthens the

need for a full planning application since all planning matters are laid down before the developer. In this context very little remains unknown and any other approach indicates an adverse strategy is at hand.

2.34 A full planning application affords a holistic assessment that will maintain the Council’s best negotiating position to achieve the optimum solution that will realise the policy ambitions, vision and development objectives. In the alternative scenario, once the site promoter has secured outline permission there will be no appetite to seek the best solution in subsequent reserved matters applications where any qualitative objectives in the adopted Development Brief will variably be watered down or fall by the wayside.

2.35 The DDB makes several references to ‘outline planning application’ as the de facto course of action (undoubtedly advanced by Capreon and Catesby Estates membership in the LG) but this trespasses on legitimacy and promotes an agenda that is prejudiced against the vision and development objectives laid out by the Development Brief. The Council has a duty to ensure the supplementary planning guidance is achievable and represents the preferred outcome for the Hollands Farm site. A full planning application will ensure that all matters can be assessed in concert and there is no practical reason for not proceeding on this basis. The DDB must be updated to remove all references to ‘outline planning application’.

2.36 The Council has successfully negotiated submission of full planning applications at other allocated sites where it has prepared development briefs and the same approach must also apply for this site.

2.37 KBEG proposes the following modification to the DDB:

Change all references of ‘outline planning application’ to ‘full planning application’.

2.38 It has been mentioned the site promoter has already demonstrated contempt for due process and has made no secret over their proposed aggressive strategy for the planning application phase. In this regard a planning application made in outline with all matters reserved will fail to demonstrate the scheme can meet the requirements of the policy designation or the vision and development objectives in the Development Brief. It introduces a very real risk that a piecemeal approach to permission will fail to allow a joined-up assessment. It is vital that all vagueness is removed from the DDB, key objectives are tightened to provide greater control, and unambiguous guidance is issued for the new development, otherwise this Development Brief and consultation

will be diluted, and history judge it an ineffective exercise to which motivated, canny and experienced site promoters can run rings around.

2.39 The Council must refuse an outline planning application which fails to provide necessary detail to demonstrate acceptability against adopted policy and guidance and the relevant planning requirements held in the vision and objectives of the adopted Development Brief.

2.40 KBEG proposes the following modification to the DDB:

The submitted planning application must demonstrate an acceptable scheme that meets adopted policy and the Development Brief objectives. Applications made in outline, including with all matters reserved, will be refused where insufficient information is provided.

3 Site analysis

3.1 Policy BE2 and the DDB both state the gross site area of Hollands Farm is 23.74 ha, while Wycombe District Council’s earlier Green Belt Site Assessments Development Capacity4 report (the “GBSA”) and Urban Design Capacity Report5 (the “UDCR”) both stated the gross area at 23.6 ha. These are not significant discrepancies, but an accurate measurement of the site area should be applied.

3.2 In preparation of its own (premature) pre-application consultation, Catesby Estates published a flyer to 775 local residents6 which is provided at Appendix 1. This document included a red line map of Hollands Farm which identified the “OUTLINE PLANNING APPLICATION BOUNDARY” shown in Figure 1. The red line map excludes a section of the development site to the south west corner which is included in Policy BE2 and shown in the Development Brief to form part of the site.

Figure 1: Catesby Estates pre-application consultation red line map

4 Wycombe District Council - Development Capacity of Green Belt Residential Sites (20 June 2016) 5 Wycombe District Council - Urban Design Assessment Development Capacity AONB & Green Belt Sites (September 2017) 6 The distribution is stated on Catesby Estates website which states: “A letter drop will be distributed to over 775 homes surrounding the site, and is expected to land via Royal Mail w/c 8th February 2021. The letter details when the consultation starts, how to access the information and how to submit feedback using a variety of methods.”. The website page is found at http://www.catesbyestates.co.uk/land/hollands-farm-bourne-end

3.3 Given the context for the Catesby Estate document and large distribution we do not believe this is clumsily done, so proceed on the basis that it is a genuine reduction of the gross site area by 1.5 ha.

3.4 The red line map further reveals the proposed access to Hedsor Road is altered from the site area identified in Policy BE2 and the DDB which takes from adjacent existing residential properties, including a building important to the historic setting. It is not reasonable to alter the site boundary without it being factored in the Development Brief, so the extent of the site boundary must be clarified if it is to be amended in such a way.

3.5 KBEG suggests the following action:

The extent of the red line site boundary must be clarified in the Development Brief.

Land owned by the Cores End United Reform Church

3.6 At the north east corner of the site is a rectangular piece of land of approximately 0.21 ha which belongs to the Cores End United Reform Church that is incorrectly included as a part of the developable site in Policy BE2 and DDB. This must be excluded from the DDB site area.

3.7 Notably, Figure 1 approximately shows this land excluded from the yellow line area.

3.8 The minutes from ‘Meeting 1’ of the LG confirm this matter was raised for action but it is plainly evident the error has still not been resolved in the published DDB.

Gross site area

3.9 In light of the error over the Cores End United Reform Church land and discrepancy in site area, KBEG re-measured the gross site area marked by the red line extent of the site illustrated in the LP and also indicated on the Policy Map for Bourne End and Wooburn. This exercise was undertaken using scaled maps and a calibrated planimeter. Excluding the church land, the gross site area was measured to be 22.8 ha.

3.10 With regard to Catesby Estate’s published red line plan, the gross site area is reduced down to 21.3 ha.

3.11 KBEG suggests the following action:

A survey of the development site should be undertaken, and the gross site area confirmed and updated in the DDB.

INDICATIVE HOUSING SUPPLY

3.12 There can be no doubt that plain reading of the policy designation considers 467 homes to be an ‘indicative supply’ and in that context the word ‘indicative’ does not mean ‘minimum’, ‘certain’, or ‘guaranteed’.

3.13 The first known indication of housing supply from Hollands Farm was published in the Viability Assessment7 (the “VA”) (2016) which considered approximately 402 homes using a density of 30 dph. Around the same date, the GBSA summarised potential delivery of 428 dwellings also using a density of 30 dph. The assessment acknowledged 5.22 ha of open space would be required from this quantum of development but excluded provision of land for, inter alia, a single form entry primary school or community facilities such as a surgery.

3.14 Later, the UCDR provided high-level capacity advice for various sites including Hollands Farm. It summarised potential supply over a net developable area of 14.60 ha of 394 dwellings and applied two different density areas within the site with a combined average density of 27 dph. The relevant extract from the UCDR is provided at Appendix 2.

3.15 It is noticeable that the UCDR only evaluated the site in terms of residential development, since at that time, the site was still being promoted for mixed use.

3.16 The Housing and Economic Land Availability Site Assessment (the “HELAA”) for Hollands Farm increased the housing supply to 467 homes over the medium and low- density areas using a combined average density of 32 dph. Inevitably, to achieve 467 dwellings will require the medium density area to have a higher density and the reduced density part to be less “reduced” than the UCDR envisaged.

3.17 The HELAA assessed supply was carried forward unchanged into Policy BE2 and thereafter copied into the DDB which retains the two different density areas first identified in the UCDR.

Urban Design Capacity Report

3.18 It is relevant to briefly dwell on the UDCR as it goes to form the foundation and origin for the indicative supply referenced in the Development Brief. The report provided background to the capacity analysis of sites [UDCR pg.2] where it stated:

“It should be noted that this assessment is for high-level development capacity setting purposes only and further assessment work will be required to confirm the

7 Wycombe District Council – Viability Assessment (July 2016)

conclusions reached and finalise the urban design principles for each site.” (Our emphasis)

3.19 The report outlined a methodology for the capacity assessment, including how to calculate the developable area which it noted excluded land for the link road, school, strategic open space, structural landscape, and buffers for planning constraints such as Ancient woodland and Conservation Areas. Unsurprisingly these reductions were only rough estimates which could not have foreseen current progress in the DDB.

3.20 The UCDR determined a range of housing densities for the site “based on the surrounding area” and “adjacent existing residential areas”. No indication was given in the report that the site assessment undertook any meaningful analysis of the existing densities in the surrounding residential areas, and frankly the UCDR was not envisaged to do such work given the “high-level” context and “further assessment work” that would be required to confirm conclusions. However, the UCDR did identify the need for a separate area of lower housing density within the site and estimated that 25 dph was representative of the low-density surroundings.

3.21 The capacity assessment applied a combined average density of 27 dph across the two density areas within the Hollands Farm site, which was the midpoint in a range of densities between 22 to 32 dph. The range was would result in an equivalent housing supply of between 321 and 467 dwellings.

Indicative development areas

3.22 KBEG has measured the proposed residential areas illustrated in the UCDR for Hollands Farm, which plan was copied unchanged into Policy BE2 [LP Figure 38]. After duly discounting the undeliverable land belonging to the United Reform Church the net developable area was measured to be 13.7 ha, though this includes the link road excluded from the UCDR net developable area (estimated at 0.8 ha by the UCDR).

3.23 After a deduction for the link road, the range of housing densities previously considered by the UCDR would result in an indicative housing supply between 284 homes and 412 homes, though to deliver 467 dwellings would require a greater average density than envisaged by any Council assessment.

Indicative supply: Policy BE2

3.24 It is striking that the highest estimated density from the UCDR range was used to inform the indicative supply adopted by the HELAA site assessment and thereafter carried forward unchanged into the policy designation. Critically, no explanation is provided by plan-makers over why the UCDR estimated density midpoint was rejected,

or that any “further assessment work”, advised as necessary by the UCDR, was ever undertaken in support of the decision.

Indicative supply: Development Brief

3.25 KBEG has also measured the proposed residential areas illustrated in the consultation draft [DDB Figure 6.1]. Again, after discounting the land belonging to the United Reform Church the net developable area was measured to be 14.3 ha including the link road (estimated at 0.8 ha by the UCDR). The development framework therefore proposes a net development area 0.6 ha larger than the policy designation, and there is the question of Catesby Estates red line map which results in further reduction of 1.5 ha in the gross site area.

3.26 After deduction of the link road, the range of housing densities previously considered by the UCDR would result in an indicative housing supply between 290 homes and 432 homes. Clearly, therefore, to achieve the indicative supply of 467 dwellings would mean significantly increased density over the developable area.

3.27 A rise in overall site density also raises concern over the validity of assessments undertaken in the Sustainability Appraisal8 (the “SA”) which has tested sustainable density options and a significant rise in density to meet the indicative supply could see a future proposal divorced from, and unsupported by, the SA work.

Review of the indicative supply

3.28 Potential errors exist in the measurement of the overall gross site area (reductions of between 0.4 and 1.9 ha) as well as changes to previous capacity estimates from, inter alia, the school site area and additional required space for parent/coach drop-off area [DDB 6.9.1] (increase of more than 0.4 ha), open space requirements [DDB 6.6.10 & 6.6.11] (increase of 0.54 ha), substantial landscape buffers (unknown ha), and from the reduction of undeliverable land belonging to Cores End United Reform Church (reduction of site area by 0.21 ha). There is further discrepancy raised between the net developable area assessed by the UCDR with that measured by KBEG, and the consequential impact of the land take required to fulfil the Development Brief vision and objectives.

3.29 In concert, the consequential impact to the site provides legitimate grounds (if any were needed) to undertake the “further assessment work” previously advocated by the Council. It is also relevant that the highest housing delivery take was applied from the capacity assessment without any further justification when it was adopted into the

8 Buckinghamshire Council - Sustainability Appraisal (SA) of the Hollands Farm Development Brief Supplementary Planning Document (SPD), January 2021

HELAA which ignored the Council’s midpoint estimate (for a supply of 394 dwellings) advanced for the site.

3.30 Presently, there is a real risk the “high-level” indicative supply estimate of 467 homes is promoting an unrefined capacity assessment into the Development Brief which carries explicit forewarning by the Council that “further assessment work will be required to confirm the conclusions reached and finalise the urban design principles for each site”. The absence of further work weighs heavily against the soundness of the indicative supply figure.

3.31 It is the role for the Development Brief to confirm the best level of housing supply for the site which can contribute to delivering local housing while also positively responding to meet the vision and development objectives. This is, above all other things, the most important supplementary guidance planning matter to be resolved by the Development Brief. Mostly everything else hangs on the housing supply figure, apart from requirements set within the policy designation but even these might reasonably be reviewed in light of a revision to the indicative housing supply.

3.32 Of course, it is possible to progress the Development Brief without review, ignore the Council’s recommendations and adopted the high-level housing supply as stated. This is undoubtedly what the site promoter desires and possibly underpins their enthusiasm for a premature pre-application consultation and intent to secure outline planning permission for 467 homes as soon as possible, for once permission has been granted the rest of the reserved matters applications will have less priority and likely to result in delay with the Council negotiating over inadequate mitigation and degrees of compromise in order to deliver the approved supply.

3.33 KBEG recommends:

The Council must undertake further assessment work to validate the indicative supply is justified and whether it continues to marry with the vision and development objectives set out in the Development Brief.

HOUSING DELIVERY AT BOURNE END AND WOOBURN

3.34 Policy CP2 in the LP establishes the overall spatial strategy for the Wycombe Area will be achieved through its policies and allocations. CP2 (a) states the Council will:

“Meet as much of the District’s need for housing and employment land as it is sustainable to do so (as set out in Policies CP4 and CP5) whilst protecting areas where development should be restricted. …” (our emphasis)

3.35 Policy CP4 (1) sets the housing target for the Wycombe Area at 10,925 dwellings. It is not necessary to dwell further on the policy background other than underline the local context for the Wycombe Area is a typically constrained district significantly protected by AONB and Green Belt land designations. For this reason, the sustainable housing target is a capacity-based ceiling rather than a minimum threshold.

3.36 This is plainly set out in CP4 policy text which states [LP 4.41]:

“Having considered and tested all the reasonable options a housing capacity of 10,925 was identified for within the plan period to 2033. Development above this level would cause significant and demonstrable harm or be contrary to specific national policies that restrict development. …” (our emphasis)

3.37 Policy CP4 (2)(b)(iii) sets a housing delivery target of 800 homes from Bourne End and Wooburn through to 2033 (which is an increase up from 750 homes in the Wycombe District Local Plan Consultation Draft). The distribution is not a target merely plucked from thin air, but rather based on the plan-makers thorough review and assessment for sustainable growth “having considered and tested all the reasonable options” for this part of the District. For instance, eight hundred additional dwellings will result a population increase of around 1,700 people, which is a 30% growth in the size of these villages. The LP makes clear that housing delivering significantly above the growth target will have adverse consequences given greater housing growth in the villages was not considered to be the best sustainable option adopted by the LP.

3.38 By way of example, Marlow, which is a considerably larger town in all regards, was deemed by Policy CP4 (2)(b)(ii) to have very limited capacity for growth above 350 additional dwellings, and the same planning judgment to growth applies at Bourne End and Wooburn.

3.39 Policy CP4 (4) and DM21 are wholly complementary. These policies confirm dwellings will be delivered through existing completions and commitments; site allocations (in the LP or Local Neighbourhood Plans), and; windfall development. The LP creates no preference or priority to one source of housing supply over another.

Neighbourhood Development Plan

3.40 It would be remiss not to mention the third Draft Neighbourhood Development Plan (March 2020) was prepared for Consultation last year, though progression of the consultation was delayed due to COVID-19 restrictions.

3.41 This Plan, recently updated to its fourth Draft, applies the adopted Policy CP4 capacity growth target of 800 homes.

Annual monitoring

3.42 National planning policy and guidance and the LP require frequent monitoring of progress in the planning system against the Development Plan. The LP sets out in its Appendix H how the Council will monitor performance of CP4 (1) to deliver 10,925 homes, and CP4 (2)(b)(iii) to deliver 800 homes at Bourne End and Wooburn to 2033. In both cases the LP directs development progress will be reviewed and controlled by annual monitoring assessments.

3.43 The last published Annual Monitoring Report for the Wycombe Area was for the period to 31 March 2017. It is known that partial analysis of monitoring information up to 31 March 2018 was applied to update the LP during Examination which confirmed an excess supply of up to 974 dwellings (total identified supply up to 11,899 dwellings), but that partial period has yet to be published in final form. No monitoring data has been published for Wycombe Area since 31 March 2017 including for the most recent periods ending 31 March 2019 or 31 March 2020.

3.44 It is striking that the Council has not published annual monitoring analysis over the past three years, and as result, there is a fog of uncertainty over the current housing delivery situation across the Wycombe Area and specifically at Bourne End and Wooburn. (By way of contrast, Aylesbury Vale has consistently published annual monitoring data which is up-to-date including to the most recently ended period).

3.45 In lieu of Council monitoring records, KBEG has undertaken local analysis of activity in the planning system9 to determine the current housing supply within Bourne End and Wooburn. Our analysis is believed to be the only up-to-date monitoring information available to the Council.

3.46 The analysis finds that housing delivery currently stands at 560 dwellings which are either completed, under construction, or are committed deliverable sites. This tally includes 150 homes at Slate Meadow but excludes supply from Hollands Farm and is plotted in Figure 2.

3.47 The analysis demonstrates housing delivery for Bourne End and Wooburn is 70% of the CP4 (2)(b)(iii) capacity target after eight years, which is 240 homes below the 800 dwellings growth target.

3.48 Should housing supply from Hollands Farm add a further 467 homes then it would raise housing delivery to beyond 1,000 homes and see the population of the villages increase by around 2,200 people, equivalent to 40% growth.

9 Appendix 3 – KBEG - Analysis of housing delivery in Bourne End and Wooburn, January 2021

3.49 The LP asserts development above the prescribed sustainable growth target would cause significant and demonstrable harm or be contrary to specific national policies that restrict development. Amongst other matters, exceedance of the supply in Bourne End and Wooburn will raise fundamental questions over the soundness of the “exceptional circumstances” cited during plan-making to justify removing the land at Hollands Farm from the Green Belt.

Figure 2: Bourne End and Wooburn Housing Supply, 31 January 2021

Bourne End and Wooburn Housing Supply "Completed, In Progress, and Deliverable Sites" 1100 1000 900 800 700 600 500 400 300 200 100 0

3.50 Supplementary, there are no published assessments, evidence or related analysis by the LP, DDB or related SA to support that 40% growth at Bourne End and Wooburn is a sustainable growth option amongst the considered alternatives, especially given the significant constraints and weaknesses for new development in the villages.

3.51 It is common sense that unplanned growth in the number of households resulting from new development will have implications. For instance, what is the impact on services? Can the local highways network sustain high growth – especially with some junctions already operating at capacity before either Slate Meadow or Hollands Farm are delivered? Should the single form entry school proposed at Hollands Farm be increased to allow for a two-form entry school? What impact will a further rise in population have on local public services and health services? Would a larger medical centre be required?

3.52 Acceptable housing delivery is confirmed by Policy CP4 (4) and DM21 – and in that regard the policies make clear the windfall supply which has come forward (somewhat unexpectedly by the plan-makers) contributes to the target. Accounting for the present

housing delivery, it is a sound and robust assessment that a reduced ceiling exists for Hollands Farm to deliver around 240 homes to meet the villages’ growth target.

3.53 The DDB must be updated to reflect progress in the planning system to ensure there is controlled sustainable growth at Bourne End and Wooburn which will meet the LP objectives and not cause significant and demonstrable harm or be contrary to specific national policies that restrict development.

3.54 The following amendment text is proposed:

Up-to-date monitoring of housing delivery at Bourne End and Wooburn has confirmed that existing completions and commitments at allocated sites and from windfall development have resulted in a greater housing supply than forecast. It is important that new development does not cause significant or demonstrable harm to the villages, and to ensure that the preferred sustainable growth option is monitored and controlled during the Local Plan period 2013 – 2033. Allowing for some flexibility in supply from unfulfilled commitments, the present unmet housing need for Bourne End and Wooburn is between 240 and 260 dwellings.

Any proposals for development at Hollands Farm above a maximum supply of 250 dwellings will not be supported. A reduction in the required supply from this allocated site provides the best opportunity for Hollands Farm to contribute to the Development Plan’s vision for sustainable growth and achieve the important objectives set out in this Development Brief.

3.55 The up-to-date information on housing delivery should not be dismissed by the Council as it will provide the best opportunity to resolve the key issues identified for the site in Policy BE2, the DDB and GBSA. A reduction in the quantum of housing will reduce the built density and provide a golden opportunity for a spacious medium and low- density development in keeping with the existing character of the villages and afford better strategic open spaces and green buffers necessary to maintain adequate separation with Hawks Hill/Harvest Hill and Hedsor. These circumstances provide opportunity for improvement that will enable the new development to meet the DDB objectives.

3.56 It is worth briefly reiterating here that Bourne End’s provision in open space is below District average and below proposed local standards according to the Open Spaces Audit10. The Audit states there is a shortfall in all typologies and the lack of larger

10 Wycombe Open Spaces Framework (Open Space Audit)

multi-functional open spaces is of particular concern. Parts of Bourne End are deficient in play and teen facilities and there are only a few open spaces in the southern part of Bourne End. Open spaces, as they exist, are generally rather small. There is a strategic and local open space deficiency in this area.

3.57 Amongst other necessary work, the Hollands Farm SA must be revisited to assess the sustainable alternatives between delivering 240 homes to meet the capacity target, and a supply of 467 homes which will exceed the growth target by 28%. Related to this additional theme, a separate assessment must consider the wider context for sustainable growth at Bourne End and Wooburn with growth at 600 homes, 800 homes, 1,000 homes, and 1,200 homes where the latter is the possible level of growth before 2033 from further windfall developments in concert with Hollands Farm.

4 Vision and development objectives

4.1 It is commended that the vision and development objectives identify seven priority goals for the new development. We encourage the Council to fortify the wording in places to ensure that the future planning application is fully able to meet these objectives to deliver a successful development proposal.

Housing density

4.2 We welcome the objectives: “Objective 1” to adopt a landscape-led approach to site layout and green infrastructure which responds sensitively to the surrounding environment; “Objective 2” that requires Hollands Farm will create a sense of place and identity, promoting community cohesion, and; “Objective 3” that the new development will sensitively integrate with the existing residential areas to form a cohesive area.

4.3 We have grouped these three objectives as altogether they are affected by two common planning issues – housing supply and housing density. Both planning matters act in concert and are the greatest influence that will predetermine the success or failure of these key objectives over new development at Hollands Farm. We have already discussed the indicative housing supply above, and in terms of related housing density, it is of great concern that the DDB is void of any meaningful guidance.

4.4 It is not necessary to dwell on the elementary concept that the level of housing density is a major factor that affect site layout and ability to successfully meet the Development Brief objectives. This principle is touched on in the SA which states [SA 5.26], “the density of housing development across the site has potential implications in terms of its landscape and historic environment impact.”.

4.5 To understand the existing character areas (and the existing built densities) it is necessary to put the settlements under the magnifying glass rather than focus only on those areas immediately surrounding Hollands Farm to ensure the development responds in a holistic way. The settlement area appraisal [DDB 4.8] characterises four broad residential areas despite the associated narrative plainly describing local variance, particularly at Bourne End and Cores End. It is awkward that detailed assessment of the local character areas and their relative densities has been omitted, given the DDB objectives require the site to “5.2.3 (a) establish a variety of appropriate residential character areas within the development” and “5.2.3 (b) ensure the new development makes a positive contribution to local character and distinctiveness”.

4.6 How can the future planning application be expected to propose “appropriate residential character areas” or “make a positive contribution to local character” when

the full range of local character areas have not been robustly defined in the Development Brief?

The Council must provide a detailed assessment of all local character areas across the villages to ensure the development responds in a holistic way.

4.7 It is prominent that the DDB has not sought to determine housing densities over the four residential areas which are presented in Figure 4.7 illustration and summarised as ‘low-density’ at Hawks Hill and to the south of Bourne End, and ‘medium density’ everywhere else. Exactly how many dwellings per hectare is ‘low-density’ and ‘medium density’ in this context? How do the dph figures relate to the proposed development areas on the site and in the existing residential areas of Bourne End and Wooburn? How are the site promoters expected to interpret this illustration without quantitative information? It is imperative the Development Brief provides answers to these questions.

4.8 In this regard, there is no national guidance to apply over the meaning of either ‘low- density’ or ‘medium-density’, and the concept of minimum density was usurped by National Planning Policy Framework (the “NPPF”) (2012). At a local level, the LP does not take a standard approach to the application of site densities – as demonstrated across all allocated sites where planning officer assessments envisaged densities ranging from 16 to 300 dph.

4.9 Policy 122 in the NPPF (2019) considers “the efficient use of land” when determining appropriate densities, though this is not an isolated judgment. The policy bullet (c) clearly requires appropriate density must have regard to “the availability and capacity of infrastructure and services”, and bullet (d) “the desirability of maintaining an area’s prevailing character and setting (including residential gardens)”, and bullet (e) “the importance of securing well-designed, attractive and healthy places” which are each robust planning considerations for new development. And this policy operates in concert with the NPPF’s golden thread and principles for sustainable development.

4.10 Three housing density bands are referenced in the SA which assert “low-density” to be less than 20 dph and medium density between 25 and 30 dph. While no direct cross- refence is made from the DDB to the SA, these documents are intended to be read together, therefore on plain reading of Figure 4.7 in the DDB, the ‘low-density’ labelled for Hawks Hill / Harvest Hill and southern part of Bourne End could be envisaged to be around 20 dph and the rest of the illustrated ‘medium density’ character areas between 25 and 30 dph.

4.11 However, it is a criticism of the SA that it makes no attempt to explain the chosen housing densities within its ‘baseline’ or provide any narrative to establish the three bands are appropriate and justified for use at this site. Rather, on plain reading of the SA, it is unmistakable that references to density are made comparatively with character areas surrounding the site and that the density bands for the assessment have just ‘appeared’ without any basis.

4.12 The SA narrative variously provides ‘relative’ references between the existing residential areas and the qualitative density, including but not limited to the following examples:

“tranquillity around lower density housing to the east”,

“Hawks Hill and Harvest Hill … is typically of lower density”,

“low-density rural housing in the east and denser village development in the north. It is recognised that development will ultimately merge these varying character areas.”. (our emphasis)

4.13 With reference to the last of these quotes [SA 9.41], the phrase “merging these varying character areas” plainly envisages a melding of the densities between Hawks Hill and at Bourne End across the Hollands Farm site. From this and the other examples in the narrative it can be determined that the density bands applied in the SA assessments should have imitated the existing housing densities found in the surrounding character areas and across the villages; for example, “low-density” means the level of housing density found at Hawks Hill / Harvest Hill and to the south of Bourne End at the riverside development areas. These comparative density values should be prescribed over the Figure 4.7 illustration in the DDB.

4.14 In determining the indicative supply, the Urban Capacity Assessment estimated the low-density area would have a density of 25 dph, which would put it in the medium density area of the SA’s three density bands. Moreover, this density was only an estimate of existing housing density in the surrounding residential areas.

4.15 The Development Brief must provide clear and unequivocal guidance over housing density for the identified areas on the site. This should either be in quantitative dph values, or fortify the existing qualitative guidance on the landscape-led approach which at paragraph 6.2.2 requires “new development to respond sensitively to the existing landscape/townscape, respecting local character areas and either integrating with them or providing a sensitive transition between them”. Exemplar references must be provided to surrounding character areas; for example, low-density areas to the east and on the slopes should reflect the existing housing density at Hawks

Hill / Harvest Hill. And the medium density areas to the south and north should reflect the existing housing density at Upper Hedsor Road.

4.16 KBEG recommends:

The Council must establish the correct baseline housing density for the existing built form in the local character areas, and which surround the Hollands Farm site. This baseline must be conveyed as firm guidance with a range of prescriptive dph figures.

4.17 To assist the Council, KBEG has undertaken a detailed audit of local character areas across the villages to understand the residential density which it offers the Council to include in the DDB and inform the SA assessment. A summary of the audit is provided at Appendix 4. This audit grouped similar streets or areas together which have a distinct character, feel and appearance according to architectural style, layout, form and build date. It then measured the net development size of each area and counted letterboxes (with the help of government Council Tax records). The results have been catalogued and are illustrated in Figure 3.

4.18 It is evident that Bourne End and Wooburn is encapsulated by ultra low-density housing that reflects the historical growth of the hamlets at Hawks Hill / Harvest Hill (1.3 dph) and very low-density residential areas along the Thames riverside (4.8 dph), the verdant Abbotsbrook Estate (4.9 dph), Well End (4.9 dph), spacious cul-de-sacs off upper Blind Lane (5.1 dph), and Grange Drive / Brookhouse Drive (5.6 dph).

4.19 Pockets of medium to high density are found north of Hollands Farm at Cores End (28 - 40 dph) and to the west at Furlong Road (26 dph) and Fieldhead Gardens (24 dph).

4.20 Elsewhere the residential development areas are predominately low-density (between 10 dph and 20 dph) which makes up the significant proportion of housing in the villages.

4.21 At the centre of the former hamlets of Cores End (34 dph), Hedsor (18 dph), and Well End (21 dpa) are terraces of old cottages which characterful dwellings form linear patterns of development that contribute to the sense of local history while the compact nature of the dwellings raises each areas’ particular density pattern.

Figure 3: Bourne End and Wooburn character areas (dwellings per hectare figures rounded for legibility)

4.22 The average housing density of the 27 assessed character areas is 19.65 dph (including Slate Meadow which proposes 32 dph).

4.23 However, this drops to 11.11 dph when calculating the average density for the whole settlement, which calculation divides the total number of dwellings by total built-up area (including residential gardens). The resulting low density figure accounts for the proportionate size of the ultra-low and very-low density character areas.

4.24 The audit means it is possible to collate a summary representation of the average housing density across the village areas (albeit each area represents one or more identified character areas in the audit), which is presented in Table 2.

4.25 It is a matter of fact that to achieve 467 homes at Hollands Farm over the net developable area demands an average density greater than 32 dph (as envisaged by plan-makers). We have calculated the likely required densities for the two density areas (as illustrated in the DDB development framework [DDB Figure 6.1]) and these are applied at Figure 4.

Table 2: Summary existing housing density across the villages (some figures rounded and may not total)

RESIDENTIAL RESIDENTIAL DWELLINGS AVERAGE AREA DWELLINGS AREA (HA) AREA (%) (%) DPH

Bourne End 134.95 48.8 1,741 56.6 12.90

Coldmoorholme Lane 8.93 3.2 48 1.5 5.38

Cores End 15.76 5.7 510 16.6 32.36

Hawks Hill 67.62 24.4 88 2.8 1.3

Upper Hedsor Road 4.50 1.6 84 2.7 16.67

Well End 19.49 7.0 142 4.6 7.29

Wooburn 20.88 7.5 310 10.1 14.85

TOTAL FOR BUILT CHARACTER AREAS 272.13 98.3 2,923 95.1 10.74

Slate Meadow (BE1) 4.56 1.6 150 4.9 32.89

TOTAL ACROSS ALL CHARACTER AREAS 276.69 100.0 3,073 100.0 11.11

4.26 The average density over the greater proportion of the site necessary to achieve the indicative supply is around 40 dph. It is important to grapple with the concept that the site will deliver a mixture of dwellings from 1-bedroom flats to 5-bedroom houses across “a variety of appropriate residential character areas”. To achieve this there will inevitably be fluctuation in the density and because of this expected variance the current supply is forecast to introduce peak housing densities unlike anything that immediately surrounds the site or generally within the wider settlement area. It is striking that the new development will be prominent in the setting in contrast to the spaciousness of the existing residential character which goes to form an integral part of the charm that makes Bourne End and Wooburn a popular place to live, and upon which the site promoters aim to profit.

Figure 4: Bourne End and Wooburn character areas with Hollands Farm proposal

4.27 Undoubtedly there will be some commentary between the proposed new development and the built development at Bridgestone Drive / Hellyer Way (40 dph), so it is important to look down the correct end of the telescope when drawing comparison. Apart from a small cul-de-sac of nine properties at the end of Bridgestone Drive which face out over Jackson’s Field, the existing built character area is chiefly formed of small maisonettes which goes to explain the above average built density, though if considered altogether with the rest of Cores End, which has lower density character areas, would average at 32 dph. The housing density at Bridgestone Drive / Hellyer Way is above the average in the immediate context and marks the upper ceiling of

adjacent lower built densities. In the wider context of the settlement, these two streets do not reflect the average density across all character areas which is less than 20 dph.

4.28 Chalklands (17 dph), including the upper streets of Greenside / Clifford Way / Goddington Road, is the second largest a planned enlargement of Bourne End by area and supply. It was built circa 1950/60 and has 331 houses on a net site area of 18.8 ha. By contrast, 467 dwellings are proposed in the indicative supply at Hollands Farm over a net developable area of 14.3 ha – this makes the former Green Belt site around 5 ha, or 25%, smaller than Chalklands and yet proposes 40% more housing.

4.29 Similarly, the former Council estate (18 dph) is the largest expansion of the village by area and supply which spans from Blind Lane / Roman Road across to New Road. This area extends to 24 ha with a housing supply of 433 dwellings. This character area may have 34 fewer houses than the indicative supply at Hollands Farm, but notably it is over an increase area 10 ha larger (over 70% bigger) than Hollands Farm.

4.30 It is plain that the indicative supply of 467 homes will necessitate housing densities unlike anywhere else in Bourne End including found at the previous major residential expansion areas.

4.31 From the outset, the ambition for the housing delivery weighs against the site delivering the Vision [at 5.1.1] “to create an attractive and sustainable residential neighbourhood that is well-integrated with the landscape, with neighbouring communities and is a place people happily choose to live”, or able to truly adopt a landscape-led approach, or make a positive contribution to local character and distinctiveness, or sensitively integrate with the existing residential area, or form a cohesive area within the existing villages.

4.32 The Council must reset the housing supply expectation in conjunction with providing clear guidance on residential densities appropriate to the setting.

4.33 To assist the Council, KBEG offers its own analysis of the current housing delivery situation across Bourne End and Wooburn, though invites the Council to produce its own up-to-date monitoring data (including for the whole District).

4.34 Policy CP4 (2)(b)(iii) provides the LP sustainable capacity for the villages. The Council must determine the level of supply required from Hollands Farm balanced against housing need, and together with some clear joined-up-thinking on the sustainable growth for the villages while interweaving known local issues and constraints (not least the physical pinch points and defined ‘at-capacity’ junctions in the local road network with absence of any practical mitigation – Hollands Farm does not pretend to solve these issues). Should the Council propose a level of housing growth above the LP

capacity target (adopted only two-years ago), then it must be soundly evidenced including with a new sustainability appraisal and open to further public consultation.

4.35 A short appraisal provides a guideline for the review: The remeasured gross site area is 22.76 ha, of which 60% would result in a net developable area of 13.65 ha. The average residential density measured across the villages is less than 20 dph, which would sensibly allow a variety of appropriate residential character areas within the site and achieve a housing supply of around 273 dwellings. Development above this level will concede overdevelopment that will fail to deliver the Vision from the outset or capable of achieving the Objectives.

4.36 KBEG endorses our amendment:

Any proposals for development at Hollands Farm above a maximum supply of 250 dwellings will not be supported. A reduction in supply provides the best opportunity for Hollands Farm to deliver the Objectives set out in this Development Brief.

5 Landscape character and placemaking

5.1 The landscape character and placemaking objectives are generally applauded. We welcome that the Development Brief confirms the importance of the landscape-led approach to require the new development responds sensitively to the existing landscape/townscape and will safeguard green corridors including to retain existing trees and hedgerows within the site. We welcome the use of generous green corridors as the basis for a footpath/cycle network throughout the site and to link together areas of public open space.

Green buffers

5.2 It is commended the Development Brief prescribes considerable landscape buffers are required to separate the new development from existing residential areas. The DDB states at paragraph 6.2.4:

“6.2.4 (e) Use a substantial landscape buffer of trees and open space on higher ground to provide physical and visual separation between Hawks Hill / Harvest Hill / Hedsor Road Conservation Area and development within the site.”

5.3 However, all existing residential areas surrounding the site would benefit from buffer, including the houses at the end of Bridgestone Drive which front onto the site. We therefore recommend additional guidance:

Use a private landscape buffer (Figure 6.5 Option 2) to safeguard the integrity of the existing residential areas at Bridgestone Drive and Hellyer Way and reinforce existing tree lines. A mixed open space and woodland landscape buffer no less than 20m at the small cul-de-sac at the end of Bridgestone Drive to provide a physical and visual separation. Any trees removed at the boundary or within the site to facilitate the development must be replaced with an equivalent species of better or equal value, particularly at Princes Road.

5.4 At bullet (h), we recommend removing the “where appropriate” clause to ensure the guidance is applied:

6.2.4 (h) Retain and protect existing mature trees and hedgerows within the site and at the site perimeter, incorporating these into public open spaces and green corridors. Use new tree planting to protect/reinforce the setting of nearby heritage assets, where appropriate;

5.5 Before going further, it is perhaps noteworthy that at the adjacent site, the Slate Meadow Development Brief also demanded a degree of separation between the new development and Cores End to avoid coalescence which was applied as a green infrastructure buffer measuring around 50m in width. Reasonably, given very similar objectives a similar buffer should result around Hawks Hill / Harvest Hill and to separate Upper Hedsor Road to the south; not least because of the heritage setting, but also to prevent the coalescence of Bourne End (including Cores End) and Hedsor settlements by the new development that would otherwise form a contiguous built up area.

5.6 The Development Brief provides welcomed clarification to Policy DM32 (Landscape Character and Settlement Patterns) that requires new development to protect and reinforce the positive key characteristics of the landscape and existing settlement patterns. The policy states [LP pg.358]:

“6.132 Some areas of the District, such as the Hawks Hill/Harvest Hill area, display a semi-rural character and this should be protected from development that would introduce an urban character through its design, density or layout. Features such as sunken lanes and low density development are more characteristic of a rural area and development proposals that introduce features that have urban characteristics would not be appropriate as they are likely to have an adverse impact on these semi-rural areas.”

5.7 The Development Brief prescription, however, only goes to state a qualitative measurement of buffer as “substantial” requiring “physical and visual separation”, and the Draft must provide firm quantitative guidance to ensure the objective is soundly met. This ambiguity is demonstrated, for example, in the options for landscape buffers proposed for Hawks Hill [DDB Figure 6.4] and Hedsor Road [DDB Figure 6.5] which are without dimension and for that reason can only be reasonably interpreted as indicative illustration. However, it is evident that the illustrated buffer options for Hawks Hill are inferred to be of around three times the size than those at Hedsor which overlooks the equally sensitive nature, albeit for different reasons, of both the eastern and southern site boundaries.

5.8 It is also of great concern that the buffer zones which are proposed in the development and landscape frameworks [DDB Figure 6.1 and 6.2] exclude parts of Hawks Hill that directly abuts into the site. Our Figure 5 shows the extent of the existing residential area for Hawks Hill / Harvest Hill from which it can be plainly seen the irregular boundary that projects into Hollands Farm. While it might be inconvenient to the site

promoters, this western side of Hawks Hill is not in any way divorced from Hawks Hill but instead forms an important part of the existing residential area and its character.

Figure 5: Hawks Hill / Harvest Hill existing residential area and Hollands Farm site

5.9 KBEG proposes the following clarification to the Development Brief:

At Hawks Hill/Harvest Hill a substantial woodland landscape buffer must provide a physical and visual separation to safeguard the existing residential development. The width of the Hawks Hill/Harvest Hill green landscape buffer must be no less than 50 metres and fully encompass all existing residential development at Hawks Hill which is identified (at Figure 5). The Ancient woodland, which is a designated Green Space in the LP, already goes to provide this buffer and may be discounted.

At Hedsor Road a substantial woodland landscape buffer must provide a physical and visual separation to safeguard the existing heritage setting and prevent coalescence between Bourne End (including Cores End) and Hedsor settlements. The width of

the buffer to the rear gardens of existing development on Hedsor Road must be a minimum of 50 metres green landscape buffer.

Substantial buffers will provide green infrastructure corridors, which will assist achieving a net biodiversity gain within the site and allow opportunity for accessible multi-user footpaths.

5.10 The use of wide buffers to surround parts of the new development will assist limiting the impact of the development on surrounding landscape. There are both public and private views over Hollands Farm which will benefit from robust green buffers.

5.11 It is also recommended that the Development Brief is updated:

Early planting of the green buffers and woodlands must form part of the pre- commencement access strategy to allow these to mature during the build out phase and provide high-quality multi-user rights of way to residents otherwise adversely affected by disruption to the existing well-trodden public rights of way over the site.

5.12 Development Brief guidance must also clarify the qualifying measurement of the green buffer areas:

The measurement of width of green buffers must not include existing or new private gardens.

Green routes

5.13 In line with recent government guidance, we recommend the following addition to the Development Brief:

All new estate roads, including the link road, must be tree lined.

Future maintenance

5.14 It is fundamental to the success of the green buffers and open spaces that they are maintained for the purposes to which they have been envisaged. For this reason the landscape assets should be conveyed to Parish Council with appropriate funding

commitments to ensure these buffers and open spaces endure to provide value to the local residents and wider community.

11 5.15 In terms of funding, the updated Viability Assessment reported the present value of surplus (as of June 2016) was £7,415,238 from the proposed development (excluding CIL income of £3,174,050), albeit with an estimated housing supply of 402 homes. The surplus at completion was expected to rise to £9,489,524. An extract of the appraisal is provided at Appendix 5.

5.16 The following addition is proposed to the Development Brief:

All green buffers and strategic open spaces must be conveyed to Wooburn and Bourne End Parish Council with appropriate funding commitment to ensure these spaces endure for the public benefit as envisaged by this Development Brief.

6 Urban design

6.1 We do not agree with paragraph 6.3.4 which refers to 3 storey buildings which envisages widespread use throughout the site. There are a limited number of tall buildings within Bourne End and Wooburn, and those dwellings which do provide accommodation over three storeys do so within the roof space i.e. the buildings are two storeys plus a roof rather than being three storeys plus a roof.

6.2 KBEG resists proposals for widespread use of three storey buildings – especially close by existing residential areas. The buildings at Bridgestone Drive . Hellyer Way are 8m in height and would be adversely affected by new 11m tall dwellings adjacent. This would be totally out of keeping with all surrounding developments.

6.3 We do not agree with paragraph 6.3.5 which is in conflict with the local setting at Bourne End and Wooburn – where the average density is less than 20 dph and general spaciousness to the built up areas. It is not necessary to reinforce urban character in a landscape-led approach to develop the site, rather it is necessary to reinforce attractive green open spaces and verdant rural setting which is reflects the site location and surroundings.

11 Wycombe District Council – Viability Assessment (May 2017)

7 Conservation and heritage

Site Analysis, Section 4.9 – Conservation & Heritage

7.1 The Draft Development Brief fails to fully appreciate matters of Conservation and Heritage with regard to the various settlement areas adjacent to the Hollands Farm site. Appendix 6 describes the history of Bourne End, notable its historic location predominantly based around the Upper Hedsor Road and Ferry Lane junction on the south side of the site. Many points raised will also be applicable to Cores End on the northerly part of the Hollands Farm site.

7.2 The Draft Development Brief is generally weak on both research and analysis of the Conservation and Heritage matters in the vicinity of the Hollands Farm site. As a result, it is equally uncertain on what mitigation measures need to be taken to fully acknowledge such matters. As a Supplementary Planning Document, it is vital that it provides sufficient detail and direction for those presuming to submit a planning application prior to development of the site.

7.3 The Development Brief should contain a detailed appendix for all matters in relation to Conservation and Heritage at Hollands Farm, including the Hedsor Road and Riversdale Conservation Area Appraisal and the supporting documents listed therein.

7.4 Conservation Areas are designated and protected under the Planning (Listed Buildings and Conservation Areas) Act 1990.

7.5 Guidance is also provided within the following two Advice Notes:

• Historic England Advice Note 1: Conservation Area Designation, Appraisal and Management (2016) • Historic England Advice Note 3: The Setting of Heritage Assets (2017)

The relevant extracts from the Conservation Area Appraisal are included at Figure 6.

Figure 6: Extracts from Hedsor Road & Riversdale Conservation Area Assessment (pg.38)

Preservation of existing character - Design Guidance for new development and extensions:

9 Listed and other significant buildings are identified on the Appraisal Map and their specific qualities are described in the text above. Any new development must not harm the buildings or their settings or any special architectural or historic features that they may contain. It should be recognised that new development may not be acceptable if it is considered to harm the designated heritage asset significance of the conservation area or listed buildings or non-designated heritage assets.

10 Applications for development adjoining but beyond the conservation area boundary will be assessed for their impact on the special interest of the conservation area and any other heritage asset affected. Taking into account the requirements of the NPPF, applications may be refused permission if this affect is considered adverse. (Our emphasis in underline)

7.6 Paragraph 4.9.6 is welcomed in the Development Brief and strongly supported, particularly with special regard to the settings of Designated and Undesignated Heritage Assets:

“4.9.6 Listed Buildings lie in close proximity to the site at Cores End, Heavens Lea and Hedsor Road (see Figure 4.13). There are also several Designated and Undesignated Heritage Assets in the surrounding area and it will be important to have special regard to their settings.”

7.7 However, with the exception of naming said properties, the DDB contains little guidance as to what these special regards intend to achieve. Nor does it commit to how the Heritage Assets must be protected from the required junction improvements.

7.8 The paragraph states that listed buildings are in close proximity to the site. However, it neglects to mention a locally listed building present on site.

7.9 The Development Brief paragraphs 4.9.13 and 4.9.14 are welcomed and broadly supported, notably the recognition of non-designated heritage assets and their historic value. Does non-designated in paragraph 4.9.13 have the same meaning as undesignated in paragraph 4.9.14?

“4.9.13 Locally Listed Buildings and historic buildings that contribute to the special interest of the Conservation Area may be considered non-designated heritage assets.”

“4.9.14 While no undesignated heritage assets are located on site, there are several surrounding it, worthy of particular mention: Southfields, Long Boyds, …”

7.10 However, the wording at the start of Paragraph 4.9.14 “While no undesignated heritage assets are located on site…” is incorrect. The non-designated heritage asset within the

site and Conservation Area is a Barn, located at the southern entrance to the site which can be seen in Figure 7.

Figure 7: Barn within Conservation Area and Site

7.11 The Barn has (at minimum) the following Conservation and Heritage attributes:

• Falls within the Conservation Area;

• Is a non-designated heritage asset;

• Is partially within the buffer for the Grade II listed building “Hollands”.

7.12 We also understand that there have been recorded instances of bats nesting in the Barn.

7.13 The Development Brief identifies the Barn in Figure 4.13 (albeit easy to miss as it overlaps the red line site boundary) but has demolished it in Figure 6.1 development framework showing the area to be open Space. This Barn should have specific mention within Section 4.9 and how new development must preserve this heritage asset within Section 6.4 of the Development Brief. The risk is that if overlooked at this stage, it will likely be omitted from a planning application. All maps should accurately reflect the location of this Barn within the context of the overall site and the Conservation Area.

The Development Brief must be updated to show the Barn and provide guidance in Section 6.4 for its preservation.

7.14 For information relevant extracts from the CA assessment showing the significance of the Barn are provided in Figure 8.

Figure 8: Extracts from Hedsor Road & Riversdale Conservation Area Assessment (pg.16,17)

Activity and land use and influence of these on the plan form and building types

The two surviving farmhouses, Hollands and Old Bartons (Ferry Lane Farmhouse), are no longer connected to the fields they worked in times past and farmers occupy neither. The former farm buildings have either been demolished entirely (Ferry Lane Farm) or replaced by modern ones beyond a retained barn that forms the conservation area boundary (Hollands Farm)

Hollands, Hedsor Road is a fine house and dated ‘IH 1702’ and has a two storey frontage block with an earlier 19th-century rear. It is however likely that it incorporates parts of a 17th-century house, judging by the frontage block’s roof which has curved wind braces to heavy purlins. It was a farmhouse for many years with its main fields to the north and its farm buildings to its east, now mostly demolished, apart from a 19th- century fourbay weatherboarded barn which is within the conservation area.

Barn north-east of Hollands 19th-century. Timber-framed and weatherboarded with modern sheet roof. Four bays with queen strut trusses. It has significance as the last remaining older farm building to Hollands Farm.

(Our emphasis in underline)

7.15 Section 4.9 must also highlight that there is potential for significant damage to Conservation & Heritage assets, due to the two junction improvements required in Hedsor Road.

Figure 9: Extract from Sustainability Appraisal, January 2021

9. Historic environment

9.33 The Hedsor Road and Riversdale Conservation Area will ultimately be a key consideration for development proposals. Whilst a diverse mix of building styles and quality surround the site, it is recognised that there is a consistent and distinctive form and architectural character of the Conservation Area and listed buildings and development at the southern extent of the site will directly affect the setting of the designated area – particularly affecting identified views but also through new road access and the potential loss of open space adjoining it.

(Our emphasis in underline)

7.16 Under the DDB Section 4.9 heading “Hedsor Road and Riversdale Conservation Area” it would be appropriate to add a new paragraph recognising this inevitable damage to the heart of this Conservation Area. We suggest the following additional paragraph:

“4.9.15 Junction improvements intended within the Conservation Area will damage the setting of many Heritage Assets. Layout and a minimum footprint size will be important in having special regard to their setting”

7.17 The Development Brief should also recognise that the open space on the corner of Ferry Lane and Hedsor Road also forms part of the Conservation Area and Green Belt. The likely harm to these junctions (currently considered off-site) needs to be recognised and guidance provided in the Development Brief with firm proposals to minimise damage done to these Heritage assets. We recommend the following addition:

“6.4.5 Design of off-site junction improvements as part of the mitigation package should be designed to have the least impact on the Conservation Area, its setting and the setting of the nearby listed buildings and heritage assets, including to preserve or enhance existing open spaces within the Conservation Area.”

Site Analysis, Section 4.10 - Archaeology and Find Records

7.18 KBEG considers Section 4.10 in the Development Brief should be updated with key site analysis identified in the following matters:

a) Plain reading of Section 4.10 gives the overall impression that the chance of notable Archaeology finds is low.

7.19 This is contrary to what is stated within the SA where trial trenching is recommended; see Figure 10 which provides the relevant extract.

Figure 10: Extract from Sustainability Appraisal, January 2021

9. Historic environment

9.34 The draft Brief draws on archaeological evidence existing within and surrounding the site (limited to scattered finds with no pattern of deposits), identifying that whilst a recent geophysical survey did not identify any anomalies of archaeological potential, trial trenching is still recommended prior to any development taking place.

10. Conclusions

10.3 Two recommendations are made within the assessment as follows:

• To better secure positive effects in relation to archaeology, it is recommended that the observed need for trial trenching prior to development is further established as a development principle to ensure this is carried through to development proposals.

(Our emphasis in underline)

7.20 The requirement for trial trenching must be brought forward into the Development Brief with the focus being the western side of the site closest to the Wye, and the

northern and southern edges of the site, that have been longest inhabited. We recommend the following amendment and additional paragraph:

“4.10.8 A geophysical survey carried out in 2019 did not identify any anomalies of potential archaeological features, however trial trenching is still recommended prior to any development taking place.”

“6.4.6 Trial trenching must be completed prior to any development taking place to determine the archaeological potential in the site. Particular attention should be made to the western side of the site closest to the Wye and the northern and southern edges.”

b) Section 4.10 overlooks the local Find Records

7.21 We welcome paragraph 4.10.5 though consider this would benefit from specific mention of local find of a Mesolithic Flint Pick not far from to the southern site entrance onto Upper Hedsor Road, under what is now the garden centre. Figure 11 refers to the location.

Figure 11: Mesolithic Flint Pick find under garden centre (SU 899 865 (51.570213, -0.704262)

7.22 KBEG recommends the following amendment:

“4.10.5 A small number of scattered finds occur from the Palaeolithic period to the Bronze Age, mostly to the south, suggesting activity in the local area. A Mesolithic Flint Pick was discovered adjacent to the site under what is now the garden centre.”

c) Archaeological Notification Area

7.23 DDB Figure 4.13 incorrectly identifies the yellow area as the extent of the “Conservation Area” rather than the “Archaeological Notification Area”, which is an understandable error given the one largely follows the footprint of the other.

7.24 The Buckinghamshire Heritage Portal validates the extent of the Archaeological Notification Area.

Update Figure 4.13 to replace the legend label “Conservation Area” with “Archaeological Notification Area”.

7.25 The land is previously undisturbed with the exception of ploughing and the laying of some past foul sewers [DDB Figure 4.26]. This combined with the land’s proximity to the rivers Wye and Thames demonstrate that the SA had good reason to highlight the need to establish that the items of Archaeological need greater attention than presently emphasised in the DDB.

Development Framework, Section 6.4 - Conservation and Heritage

7.26 KBEG commends Paragraph 6.4.1 with regard to the conservation of the historic environment which reinforces the local character and distinctiveness, and Development Brief guidance that design solutions must sustain and enhance heritage assets and their settings.

7.27 We consider the existing heritage extends to include the ancient footpath tracks that have been well-trodden for over 200 years and recommend the following addition:

“6.4.7 The historic environment includes the ancient footpath tracks represented in the current rights of way across the site. Design of the site layout should seek to preserve these ancient footpaths with no less than 4.0 metre width buffer on either side.

7.28 We also welcome and strongly support paragraph 6.4.2 providing a sympathetic approach to Cores End. Reference should be made to the use of the Council “Highway Protocol for Conservation Areas” to ensure a sympathetic approach in design. This design guidance is noted in the Development Brief’s Appendix D (Issues Log) at listed item 1.5 (How should the Cores End road junction improvements mitigate impacts on the setting of United Reformed Church listed building?) which stated “AVCD/BCC’s

Highway Protocol for Conservation Areas, should be used to ensure a sympathetic approach is design.”

7.29 This design guidance is strongly supported, and the recommendation must be reflected in the Development Brief both under paragraph 6.4.2 and as a reference document within Section 3 (Planning Policy Framework).

7.30 KBEG recommends:

“6.4.2 e) Use Buckinghamshire Council’s Highway Protocol for Conservation Areas to ensure a sympathetic approach is design.

7.31 Paragraph 6.4.3 in generally commended in the support it provides to the Conservation Area, in particular limiting the ridge heights of the new houses to being lower than that of the houses on Hesdor Road in the adjacent Conservation Area.

7.32 However, we consider the buffer noted at 6.4.3 (c) is insufficient to protect the CA from adverse harm inevitably resulting the scale of development proposed. The generally regarded 25m planning notification buffer zone surrounding the CA would provide additional depth between the existing and new development (and eliminate the need for future CA notifications from the newly built properties), though this falls short of providing a sufficient buffer to prevent coalescence between Bourne End (including Cores End) settlement with Hedsor settlement.

7.33 We are cautious over the suggested guidance “a substantial landscape buffer by way of extended gardens to some existing houses and generous plots for new housing” which infers a narrower private buffer would result between back-to-back housing that likely will be diluted in a planning application to domestic landscaping within the rear gardens of the new development and would fail to achieve a “substantial” buffer. This particular guidance requires better clarification to direct the developer over their expected commitment or removed entirely.

7.34 If guidance is suggesting the developer should pass ownership of all or some of the substantial buffer to existing houses at Upper Hedsor Road then this approach could be welcomed though requires further detail and firm clarification from the Council within the Development Brief; the developer is unlikely to want to give away any land unnecessarily.

7.35 KBEG echoes our previous recommendation for the landscape buffer at Upper Hedsor Road for the reasons previously stated, including interpretation of the term “substantial” as applied at BE1 Slate Meadow. We propose the following amendment:

“6.4.3 c) In order to retain the distinctive linear character of this part of the conservation area, incorporate a substantial landscape buffer by way of extended gardens to some existing houses and generous plots for new housing, both of which will include a significant proportion of structural tree planting; A minimum width of 50m green landscape buffer should be provided by the development.”

7.36 It is noticeable that paragraph 6.4.4 does not convey the same sympathetic approach that is afforded to Cores End at paragraph 6.4.2. The Development Brief should be bolstered to be “as sympathetic as possible given its location” within a CA and adjacent to identified heritage assets.

7.37 In addition to rephrasing paragraphs (a) to (d) we propose the follow additional guidance:

6.4.4 Design of the Hedsor Road / Principal Route Junction should consider the following: (e) Signage, road markings, and highway-related features should be kept to the minimum necessary so that it is not over engineered; Finger Sign posts should be used where possible in keeping with heritage; (f) The two junctions should be designed to accommodate the movement of motor vehicles but also meet the needs of pedestrians, cyclists and public transport users, so that growth in these modes of travel is encouraged, whilst following required design standards for road construction; (g) The design should have minimal impact on the existing hedges and field immediately south-west of the ferry lane junction, the area is in Green Belt and within the Conservation Area where Map 1 key designates it as “Important Open Space”; (h) Use Buckinghamshire Council’s Highway Protocol for Conservation Areas to ensure a sympathetic approach is design.

7.38 Having some regard to the proposed on-site and off-site junction improvements at Hedsor Road, these will both be within the Buckinghamshire Council Archaeological Notification Area and due account must be had for archaeology in planning the junction changes. See Figure 12.

Figure 12: Proposed junctions highlighted within the Archaeological Notification Area

Alternative principal access route

7.39 An alternative approach which could alleviate the considerable heritage issues, proximity to Green Belt, and archaeology is to assess deliverability of Wessex Road as the Principal Access route at the south side of the site.

7.40 The Wessex Road / Hedsor Road junction falls outside the CA and Archaeological Notification Area as shown in Figure 13.

Figure 13: Comparison of Hedsor Road and Wessex Road junctions

Red: Junctions impacted by Hedsor Road access Wessex Road: Junction outside Archaeological Green: Junctions impacted by Wessex Road access Notification Area

7.41 Plainly, a transport assessment including traffic forecast modelling and robust assessment of the access would be required, and it would be imperative to confirm

deliverability as this is a private road, though on balance might be simpler matters to overcome and result in the less harm that is envisaged to result to the existing heritage setting.

7.42 A priority T-junction or roundabout at Wessex Road could be less harmful to the existing local character and distinctiveness, and might prove a safer option than two junctions in close proximity. The advantages to the heritage setting could mean ‘Southfields House’ would not be harmed (or demolished) by necessary road widening to create the Principal Route.

7.43 We recommend:

The Council should include an alternative ‘scenario’ featuring Wessex Road as the southern Principal Route during required traffic forecast modelling for Hollands Farm and the separate assessment on access routes to the site.

8 Access and transport movement

Hollands Farm Transport Appraisal

8.1 Wooburn and Bourne End Parish Council and KBEG commissioned a Transport Appraisal12 to provide an assessment of the transport matters and issues affecting the site and whether the Draft Development Brief meets the objectives required of it. The report considers general matters, pedestrian access and design, public transport provision, and highways access. A copy of the report is provided at Appendix 7.

8.2 The report welcomes the pedestrian access points and confirmation that the footways will be required to comply with national standards. It points out that the 400m/800m walking distances in DDB Figure 4.15 are as the crow flies and not an accurate reflection of the distances; walk catchment analysis is provided in the Transport Appraisal’s Appendix B which shows “very little of the site is located with an 800m walk of the railway station”.

8.3 In terms of the ancient public rights of way, the report identifies that the Development Brief should explain why it is necessary to relocate these rather than ensure they are designed into the site layout, and provide guidance regarding an alternative configuration of the site in the circumstance that the rights of way cannot be diverted.

8.4 The report commends that the Development Brief supports the provision of accessible public transport according to national guidance, though the report considers site specific requirements for public transport would give greater benefit.

8.5 However, the report identifies “a severe and fundamental design flaw for a new development” in the proposed bus service along the principal access route at Princes Road which the DDB confirms is an insufficient width for two-way bus traffic. The report recommends urgent action:

An urgent review is required for the approach to serving the Site by public transport and either: a) further guidance provided in the Development Brief on how Princes Road and its junction at Cores End Road can be improved to enable access, or; b) a new access route proposed which avoids Princes Road.

12 Motion – Hollands Farm Draft Development Brief Transport Appraisal (February 2021)

8.6 The report is critical that conflict exists in the design parameters over highways access at Princes Road. It recommends providing clarity in the Development Brief:

Clarity is required in the Development Brief regarding a conflict in the design parameters for the width of the Principal Route at Princes Road.

8.7 The report welcomes the intentions at paragraph 6.4.4 guidance over the Hedsor Road Principal Route Junction, though notes the guidance is entirely inconsistent with the requirements of the highway brief and current highway design guidance and set an idealistic picture of what can be achieved.

8.8 The Transport Appraisal concludes that there are severe site-specific constraints relating to delivery and promotion of sustainable transport modes, safe and suitable access, and highway safety.

8.9 The Development Brief must provide guidance on how these constraints could be acceptably resolved. The Transport Appraisal recommends:

1) The Development Brief Site Plan must be amended at Hedsor Road to include the land to deliver the junction improvement, which necessarily includes land a take from existing houses.

2) Delete references to “Hedsor Road / new Principal Road” from 6.5.22. 3) Update Figure 4.15 to show accurate walk catchment analysis for 400m/800m distances.

4) Identify direct deliverable pedestrian routes between the Site and village centre and railway station.

5) The existing ancient public rights of way should be retained, and the site layout adapted accordingly, or the Council should amend the Development Brief to include an alternative configuration of land uses for the Site for consultation.

6) Reword 6.5.14 to require the developer to secure a bus service to a minimum specification.

7) The developer should be required to undertake assessment of and minimise loss and/or harm to existing bus users or providing a new or diverting an existing bus service.

8) Reword various requirements of the Development Brief at the Hedsor Road Principal Access and Hedsor Road / Ferry Lane junction so that there is consistency in the design requirements.

9) The Development Brief must provide design guidance for the form of junction at the Principal Route access points into the Site at Hedsor Road and for the safe, four-armed roundabout at Princes Road / Cores End Road.

10) Update 6.5.24 to include Hedsor Road on the approaches to the new access junction and in particular the section between Ferry Lane and the access. The paragraph should also be more explicit over the outcomes of the on-street parking review.

8.10 In light of the concerns over principal access routes to the site, the Council must undertake an authoritative assessment of access and transport proposals, including for improvements and mitigation at Princes Road to allow for two-way bus and HGV traffic. This approach was adopted and applied by the Council for the Terriers Farm Development Brief in a commissioned report13 (notably after the draft development brief consultation) that assessed site access, and the same assessment work must be undertaken for Hollands Farm.

The Council must commission AECOM (its preferred supplier) to provide an assessment of access routes for Hollands Farm to form part of the Development Brief.

Hollands Farm Spine Road

8.11 Proposals for a link road through the Hollands Farm site were first announced in the draft consultation document for the LP in June 2016. The first airing of Policy BE2 included at 1 (a):

“Provide a link road through the site linking to the Cores End Road roundabout and Ferry Lane”

8.12 Later, in 2017 three separate transport assessments were produced by Jacobs as part of local plan-making which are discussed below.

13 AECOM - Assessment of Access Routes for Terriers Farm Reserve Site, High Wycombe (March 2018)

a) Countywide Local Plan Phase 2 Modelling

14 8.13 The Jacobs Countywide Local Plan Modelling Phase 2 report (“CLPM2”) (March 2017) updated earlier Phase 1 work and set out four forecast scenarios for Buckinghamshire including the Wycombe Area. The updated CLPM2 ‘do minimum’ scenario was based on housing growth of 2,180 homes inherited from the earlier Phase 1 work. In the ‘do something’ scenarios housing growth in the Wycombe Area was modelled to increase to 10,644 homes.

8.14 During the modelling work, Wycombe District Council put forward the link road at Hollands Farm as a mitigation scheme to tackle congestion at Bourne End shown in the ‘do minimum’ and ‘do something’ scenarios. It is assumed the link road was put forward as mitigation scheme because of the earlier reference made in the draft consultation for the LP.

8.15 CLPM2 stated “This scheme involves the introduction of a single carriageway spine road through the Holland Farm development from Hedsor Road to Princes Road.”, though as the CLPM2 plainly forewarns about the modelling outcome [CLPM2 5.1] “it is not possible to accurately isolate the effects or impacts of any individual development or individual mitigation scheme”.

8.16 CLPM2 concluded for Bourne End [CLPM2 5.2.2.3]:

“For the majority of routes in Bourne End there is relatively little change in congestion in the DS scenario over the DM scenario, as shown in Figure 5-O, with constrained areas remaining the same in both scenarios.

With the Holland Farm Link Road in place in the DS+mitigation scenario, there are decreases in congestion on the A4155 to Marlow and the A404 and on Sheepridge Lane. However there are still minor increases in travel time on Hedsor Rd, at the Ferry Lane Junction, and at the Wooburn Common Rd/ Broad Ln Junction, compared with the DM.”

b) Countywide Local Plan Modelling Phase 3 Technical Note

8.17 In August 2017, Jacobs published the Countywide Local Plan Modelling Phase 3 Technical Note15 (“CLPM3”) (August 2017) which revised the earlier Phase 2 work in light of progress in local plan-making, and given the short passage of time following the Phase 2 work (5 months) it was stated as an addendum.

14 Jacobs - Countywide Local Plan Modelling: Phase 2 Forecast Modelling Report (8 March 2017) for Buckinghamshire County Council 15 Jacobs - Countywide Local Plan Modelling Phase 3 Technical Note (16 August 2017)

8.18 The forecast modelling of the Hollands Farm link road was carried over from the previous Phase 2 work and housing supply for the ‘do something’ scenario for Wycombe was increased by 1,360 to a total growth of 12,004 houses by 2033, which resulted in a 1% increase in vehicle trips. This is unexplained growth since at that date a Memorandum of Understanding had already been signed between the four District Councils resulting in a housing distribution at Wycombe of 10,925, as is now reflected in adopted Policy CP4.

8.19 Figure 14 provides a comparison of the forecast modelling between the ‘do minimum’, ‘do something’, ‘do something 1 (with mitigation)’ and ‘do something 2 (with mitigation)’ for Bourne End. The latter two models include mitigation package with the Spine Road which is seen as an “S” link over the Hollands Farm site.

8.20 Table 3 references the colour of the traffic link flow bands shown in Figure 14, and it is noted that the green band means travel times are up to 50% greater than an uncongested situation rather than they are ‘good’.

Table 3: Red-Amber-Green congestion ratio criteria shown in the forecast modelling

CONGESTION COLOUR OF THE BAND INTERPRETATION RATIO

Transparent 1 Link experiences free flow conditions

Travel times are up to 50% greater than in the uncongested Green 1-1.5 situation

Travel times are between 50% and 100% (i.e. two times) higher Yellow 1.5-2 than in the uncongested situation

Travel times are two to four times higher than in the Orange 2-4 uncongested situation

Travel times are more than four times higher than in the Red >4 uncongested situation

Figure 14: Jacobs Phase 3 Technical Note; Buckinghamshire countywide forecast modelling for Bourne End

8.21 It is evident from viewing the link flows in Figure 14 that congestion remains largely consistent with or without the link road mitigation across all four scenarios on the main routes within Bourne End and Wooburn: at Hedsor Road, Ferry Lane, Cookham Bridge, The Parade, Blind Lane, A4155 Marlow Road, and along A4094 (including to Wooburn)

8.22 Cores End Road shows a decrease in congestion from orange to yellow on parts of the route with the link road mitigation in place but congestion remains at the Cores End roundabout junction. Furlong Road also sees some improvement in the AM peak with the addition of the link road, though locally it is common knowledge this road suffers significantly from chaotic on street parking which makes it less predictable to accurately model. Similarly, Station Road has variance in the AM peak, though this too suffers from local disruption with at least one 14m roadblock in the form of a bus parked on the north bound side every 20 minutes, which is also not modelled.

8.23 With the link road mitigation in place it is plain that the forecast modelling envisages significant congestion within the Hollands Farm site on the link road approach to both principal access routes at Princes Road / Cores End roundabout junction, and at Hedsor Road junction. It is reasonable to conclude that while there is some limited reduction in traffic Furlong Road and on parts of Cores End Road, it is merely relocates traffic congestion to the new link road.

8.24 Critically, the modelling does not account for local circumstances at Furlong Road or Station Road, and it excludes detailed assessment of the necessary junction improvements which form part of the proposed link road mitigation, including that Princes Road is insufficient to allow two-way bus and HGV traffic which requires an undisclosed ‘technical solution’ that will likely impede free flowing traffic further. The implications of all these matters are entirely unknown.

8.25 The CLPM3 does not provide overwhelming evidence that a link road through Hollands Farm will provide the local benefits envisaged by plan-makers. There might be some ‘modelled’ benefit to the wider network, though arguably this is negated by the continued adverse harm to the immediate local roads and lack of flexibility in the forecast modelling to fully take account of local circumstances.

8.26 Further local traffic assessment work must be done to determine whether the link road alone is the best mitigation package for Hollands Farm, or whether a range of different or complementary measures might impact traffic congestion with or without the link road. For instance, an off-street bus stop at Bourne End Railway Station would likely have considerable benefit to free flowing traffic (which might now be deliverable following demolition of the ruined café); or a one-way traffic scheme at Furlong Road;

or new mini roundabouts at Furlong Road; or use of parking restrictions within the main thoroughfares.

8.27 KBEG recommends:

The Council, Parish Council and NDP working party should collectively consider a range of further appropriate traffic mitigation measures to alleviate congestion that will either strengthen the proposed link road, or to replace it. This assessment must inform the Development Brief guidance and proposed transport mitigation package.

c) Wycombe Local Plan Sites Modelling

8.28 About the same time, Jacobs also prepared the Wycombe Local Plan Sites Modelling report16 to provide sound plan-making evidence for selected development sites. The scope of this assessment included Hollands Farm in all ‘do something’ scenarios, notably with a housing supply estimated at 510 dwellings and principal access routes to the site at Hedsor Road and Millboard Road with new priority T-junctions; in this forecast modelling Princes Road was not the considered access route.

8.29 The model output for Hollands Farm plainly exhibited bias in the traffic flows towards the north of the District due to the underlying forecasting model17 which, the Jacobs Phase 3 report confirmed [CLPM3 5.2.2.3]:

“It should be noted that the separate Wycombe Local Plan Sites modelling work (referred to at the end of section 5.2.2.2) did not identify a significant congestion issue on the approach to Cookham Bridge on the A4094; however, Cookham/ Bourne End is outside of the study area for that piece of work, and therefore the network and associated junction coding is not as detailed as that which is included for this work. As a result the Wycombe Model does not provide as reliable an indicator of congestion in that area as does the Countywide model.”

8.30 This warning does not go far enough to underline that the detailed study area, which formed the basis of the traffic forecasting model, excluded any specific assessment of the highway network at Bourne End and Wooburn, or considered restrictions at Cookham Bridge, or wider traffic flows to the south or east. The forecasting model was chiefly focused on traffic flows to/from High Wycombe for the purpose of “the continued assessment of the High Wycombe Town Centre Masterplan”, and Bourne

16 Jacobs - Wycombe Local Plan Sites Traffic Modelling (26 June 2017) 17 Jacobs – High Wycombe Highway Assignment Model, Local Model Validation Report (2016)

End and Wooburn were merely wrapped up as part of a generic “wider buffer” surrounding the detailed study area.

8.31 Given the forecasting model was stated not to provide a “reliable” indicator of congestion for Bourne End and Wooburn, it is striking that the Wycombe Local Plan Sites modelling work made no mention of this shortcoming or raised any concern over reliability of the modelled output. The plan-making evidence to promote the Hollands Farm link road mitigation package must be considered unreliable and should not be include in the Development Brief without confirmation.

8.32 The evidence base and related conclusions for the link road mitigation package at Hollands Farm overlooked:

• The modelling was based on unreliable forecasting data;

• The modelling was considered Millboard Road as the principal access route rather than Princes Road which necessarily will have overstated traffic flows on Cores End Road;

• Significant congestion results on the link road at Princes Road / Cores End roundabout junction, and at Hedsor Road junction;

• Excludes detailed assessment of the access routes and necessary junction improvements;

• Ignores width restriction at Princes Road preventing two-way bus and HGV traffic, and modelling made no allowance for the undisclosed ‘technical solution’;

• Ignores known local circumstances (including at Station Road, Furlong Road);

• The mitigation does not address the issue at the River Thames crossing at Cookham Bridge.

8.33 Plainly, the traffic modelling work to support the link road is unreliable and ignores specific issues which are likely to have impact on the forecast link flows. A reduction in the housing supply from Hollands Farm down to 250 homes, as recommended previously, will necessarily also have an impact.

8.34 For these reasons, as well as the shift in the baseline ‘do minimum’ and ‘do something’ data, it is recommended that a site-specific traffic modelling assessment it undertaken to inform the Development Brief, using a valid transport model adjusted for local circumstances. This will confirm the question whether a link road is the most beneficial mitigation package for the site.

8.35 KBEG recommends:

In conjunction with the range of alternative traffic mitigation measures, the Council must commission Jacobs to provide an updated site-specific traffic modelling forecast assessment to confirm a sound basis for the link road between Princes Road and Hedsor Road.

9 Green and blue infrastructure

9.1 The Development Brief should stipulate that existing features, particularly hedgerows and trees should be incorporated into the public areas wherever possible rather than within private gardens, to ensure their continued protection and maintenance.

10 Ecology

10.1 At paragraph 6.7.2 the Development Brief needs to stipulate that all trees and hedgerows within and bordering the site must be preserved and enhanced. This includes the ancient hedgerows alongside Princes Road and dividing the current fields.

10.2 The Development Brief should stipulate that all hedgerows have a minimum 5 metre margin on either side that is left green and undisturbed so that the hedgerows can serve their purpose as wildlife corridors.

11 Flood risk and sustainable urban drainage systems (SuDS)

11.1 All changing climate matters must be clearly factored into the Development Brief with the most conservative standards applied to issues such surface wate and ground water levels and management.

11.2 The Development Brief requires use of SuDS, but also recognises high ground water levels will be a barrier [DDB 4.15.4], and this will only become more of challenge in the coming years. The Brief must be more specific and directive to prevent developers reverting to traditional methods. Houses and infrastructure should be required to minimise runoff through maximising greenspace, building water recycling/attenuation

into each property and minimising impermeable hard standing (driveways, patios) [DDB 6.8.3]. Measures should be required to educate homeowners and ensure a long term, integrated management approach to ensure this is not compromised (restrictions on modifications by homeowners, management of swales etc..).

11.3 In terms of water supply, the Development Brief should ensure that no developments commences before Thames Water can fully supply the proposed number of houses [DDB 4.17.1], and the supply issue could be eased by mandating rainwater harvesting and grey water use. The Development Brief should set leading standards for domestic water use (e.g. 90 or 110 litres per household per day) to address supply issues and align with net zero future [DDB 6.11.7 (h)].

11.4 We recommend the Development Brief reinforces water supply issues:

The planning application must include the outcome of early engagement and agreement with Thames Water to resolve known supply issues. The proposed development must embrace leading standards for domestic water use (e.g. 90 or 110 litres per household per day) and include sustainable proposals for rainwater harvesting and grey water use.

11.5 The site is subject to both surface water and ground water flooding. It is necessary to identify appropriate mitigation as early as possible to inform the development framework and suitability of an indicative site layout. The two principal access routes at Princes Road and Hedsor Road are both affected by flooding issues, as is the proposed location of the school.

11.6 KBEG recommends the Development Brief is updated to ensure early engagement with the Council and that necessary mitigation measures are defined before the planning application is submitted:

The planning application must include the outcome of early pre-application consultation and agreement with the Council as Lead Local Flood Authority to address flooding and drainage issues within the site and surrounding areas affected by the development. The LLFA must recommend the preparation of a Flood Risk Assessment and Drainage Strategy/Statement at pre-application stage to inform the subsequent development proposals.

12 Services and amenities

12.1 It is commonly understood that the local water supply is overwhelmed with issues and which is significant impacted by new development. Considering this we recommend the Development Brief adopts some early engagement principles from Thames Water:

The Council must consult with Thames Water in order to establish: a) whether there is sufficient capacity in the system; b) the most appropriate means of ensuring the new development is served appropriately, and; c) that there is a clear, costed and agreed plan to deal with any of the existing services within the site. It must be stipulated that the developer will contribute towards system upgrades where necessary and in line with legislation.

12.2 We welcome that the provision of strategic open space will include much needed local facilities including [DDB 6.6.12] football pitches and multi-user games area. The practicalities of these facilities require additional facilities.

12.3 KBEG recommends the Development Brief is updated to include:

Accessible public toilets, ideally with changing facilities, must be provided in connection with delivery of the football pitches and multi-use games area.

13 Noise, vibration and air quality

13.1 At Section 6.10, a full air quality report must be submitted at the pre-application stage. The outline Development Brief suggests routing the principal road alongside the school. This should not be considered a principal route and any road, other than the main school access road should be routed away from the school in order to preserve the air quality in and around the school.

13.2 KBEG recommends the Development Brief is updated to include:

A full air quality report must be submitted at the pre-application stage.

14 Climate change and sustainability measures

14.1 It is accepted that we are in a climate and ecological crisis and there is a need for urgent action and new, innovative solutions. The UK has committed in law to a “net zero” carbon position by 2050, and Buckinghamshire council has also committed to net zero by 2050. Yet the Development Brief is silent on the climate crisis and does not refer to these two commitments which is both an oversight and opportunity missed [DDB 5.1.1, 6.11.1]. Neither does the Development Brief appear to recognise the rapidly changing weather conditions in the UK, driven by climate change. We are seeing more extreme conditions and are likely to see even more so during the planning and build phase of the development and certainly in the use phase. The Development Brief must require consideration of worst-case climate and environmental scenarios, especially those that will be experienced by the future homeowners.

14.2 In its current form the Development Brief will merely compound the problems with outdated approaches that exacerbate climate and ecological issues with only tokenistic mitigation, which enables the developers to prioritise profit over environmental and social aspects [DDB 5.2.2]. The forthcoming Environment Bill is expected to mandate high levels of biodiversity net gain for housing developments and potential wider environmental net gain. The Development Brief must recognise these aspects and growing public desire and planetary requirement for truly sustainable development.

14.3 Hollands Farm must be seen as an exemplar development, a blueprint for a sustainable development in Buckinghamshire and beyond. It can be a sustainable legacy for the Council and all involved; where development leads to net zero carbon [DDB 6.11] in embodied and whole-life terms, biodiversity net gain within the perimeter of the site, embracing green and blue infrastructure and both mitigating the impacts of a changing climate on new and existing residents. The site should aim to be energy positive, with microgeneration at properties, with battery storage [DDB 6.11.7 (f)].

14.4 The Development Brief must set out a holistic sustainability vision for the site, and be bold, ambitious and challenging. In that form developers can be required to design and build homes for the future. There are many sites in the UK and globally where developers have responded positively to the challenge and embraced solutions; most which exist today and are tried, tested and effective, but not more widely used because development brief’s do not mandate it.

14.5 The UK Green Building Councils “Net Zero Carbon Buildings: A Framework Definition” [DDB 6.11.7 (c)] provides clear guidance and should be used to shape the Development Brief, as should PAS2080 Carbon Management in Infrastructure. The Future Homes Standard will tighten requirements, but the Development Brief should

demand the standards defined at Level 6 of the Code for Sustainable Homes [DDB 6.11.7 (e)]. Whilst that document might have be abruptly and inappropriately withdrawn the ambition remains good and provides a good baseline for the Brief. Embedding these frameworks, principles and approaches will mandate high levels of ecological, carbon and other sustainability objectives.

14.6 We recommend the Development Brief is amended to include:

The development must commit to construction that achieves the highest sustainable development standards and net zero carbon buildings.

14.7 There is clear opportunity and need to focus the Development Brief to enable and prioritise active travel over traditional car use. Hollands Farm should be developed to keep cars on the periphery of the development, or event be car-free [DDB 6.4.2 (c), 6.5], providing a safer and cleaner environment [DDB 5.2.6]. The development should require and enable new models of car ownership, for example providing and promoting an electric car, van and e-bike shared ownership model, and embracing the use of autonomous vehicles. The site should be established and enforced as a zero carbon zone, ensuring facilities exist for carbon free last mile delivery.

14.8 Developers must be required to ensure that effective zero carbon public transport options exist and crucially that these connect key destinations including Beaconsfield, Bourne End and Maidenhead railway stations.

14.9 The Development Brief should determine and enforce a high level of biodiversity net gain and mandate that any required mitigations are delivered within the boundaries of the development [DDB 5.2.2 (g), 6.7.3, 4.19.4 l].

14.10 KBEG recommends modification to paragraph 6.7.3:

“6.7.3 New biodiversity net gain is required and should be demonstrated through biodiversity accounting. The development proposals must demonstrate a net gain of at least 20% in new biodiversity.”

14.11 A natural capital assessment could be undertaken, or better still an integrated capital assessment. It is inappropriate and unacceptable to propose improvements at Little Marlow Country Park as biodiversity offsets [DDB 5.2.2 (i)]. Existing ecological assets (e.g. hedgerows, trees) must be maintained as these ancient landscapes cannot simply be replaced [DDB 4.13.5]. The brief must clearly state that any damage or

removal of these assets would result in the developer being expelled from site and being required to pay appropriately punitive damages. The brief must require the use of only locally native species of plants (not traditional ornamental plantings) [DDB 6.7.2 (d)] with a biodiversity strategy designed to proactively support local and national wildlife priorities. There should be advance planting at the site in the very early stages to maximise benefits.

14.12 We echo our previous recommendation:

15 Character areas

15.1 We have discussed character areas already in the Vision and Development Objectives section.

16 Planning and development delivery

16.1 KBEGs views are included elsewhere within this document.

17 Draft Appropriate Assessment

17.1 KBEGs views are included elsewhere within this document.

18 Draft Sustainability Appraisal

Theme 1: Connectivity and movement

18.1 We welcome the SA test, though consider that the principal routes assessment does not assess Route B + Route C combined.

18.2 Principal routes assessment does not consider the alternative for no link road (which we understand is contrary to Policy BE2, but nevertheless there might be justification given the insurmountable weaknesses and threats identified at Princes Road and confirmation required from an updated traffic forecasting model. We consider this comparable to Theme 2 (Locating the new primary school) assessed option E which assessed the merits for an off-site location in spite of school provision forming part of the policy designation.

18.3 The preferred approach for sub-theme 1a is wrong in its consideration that Option A or B are suitable for bus traffic. The DDB is clear of its assessment at Princes Road that the required road with of 6.5m cannot be achieved and that two-way bus traffic is not feasible. Possible mitigation might be a “technical solution” which could result in some traffic control to allow buses to pass but would unlikely provide no such advantage to HGV or other wide vehicles (such as tractors and other farm equipment which frequently use the local highways – more so now that this site deletes the existing farm), and the solution is not identified by the DDB but rather kicked down the line to the planning application which the site promoters have already confirmed will not be dealt with in the outline application, so a less than optimum solution is likely to result. The SA assessment should be reviewed in light of the plain fact that Princes Road is not suitable for two-way bus traffic.

18.4 It is confusing why the preferred approach for Sub-theme 1b rejects Wessex Road because being outside of developer ownership and therefore having deliverability issues are the exact same scenario which applies to Millboard Road (also outside of developer ownership and has deliverability issues) which also applies to preferred approach for sub-theme 1a, Option B). Further, both are industrial roads which suffer frequent HGV vehicular movements and have valid safety issues. The criticism levelled at Wessex Road equally applies to Millboard Road and further SA assessment is required to delineate in this regard.

18.5 The same confusion is directed at sub-theme 1c preferred options which propose active travel over land outside the developer ownership, such as Options I and K which not only would require access to the Wessex Road industrial area (previously dismissed in sub-theme 1b due to deliverability issues) but also somehow cross to the River Wye through private residential gardens or private industrial sites.

18.6 The SA must also be reviewed having consideration that the Transport Assessment walk analysis shows very little of the site falls within 800m of the railways station or village centre, further away.

18.7 Part 2 narrative on transport and traffic largely is supported with the exception that it entirely overlooks the access issues identified at Princes Road and Hedsor Road and the summary [9.60] that “the addition of 500 homes in this area is still considered likely to affect local roads to some degree and minor long-term negative effects are anticipated in this respect.”

Theme 3: Open space boundary treatment

18.8 It is unclear whether any landscape assessment or visual impact assessments have been undertaken for the location of new strategic open space and whether the options have been test in the SA.

18.9 We question the summary conclusion that delivery of new open space is considered to support “minor long-term positive effects in relation to community well being (for both existing and new communities), bio diversity, climate change, natural resources, landscape and historic environment.”

Theme 4: Housing density

18.10 The theme starts with an erred statement. It states [SA pg.21 (and pg.xviii)] that “Whilst the level of growth at the site is set through the WDLP …”, but this is misleading which misrepresents the matter of fact as explained in the following paragraphs:

18.11 Housing delivery is detailed by Policy CP4, which at (2)(b)(iii) sets the growth target for Bourne End and Wooburn. CP4 (4) and DM21 work in concert to confirm housing supply will be delivered through existing completions and commitments, site allocations set in the LP and Neighbourhood Development Plans, and through windfall development.

18.12 In this instance, Hollands Farm was released from the Green Belt and allocated for residential development as it was envisaged to make a contribution to the District’s housing supply since, at that time, the Council could not identify alternative sources of supply for Bourne End and Wooburn.

18.13 The small text for Policy BE2 (summarised in Table 20 [LP pg.261]) merely indicates a planning officer’s assessment for the indicative housing supply [LP 5.4.17], which has already been mentioned, contrasts with the Council’s GBSA and UCDR summary. The policy does not provide any commitment to any level of housing delivery as matters can and do arise which go to alter the initial indicative supply assessment. This is a well understood concept. For example, the small text makes explicit reference to “a number of issues and constraints that will need to be taken into account” which could impact the amount of supply.

18.14 The site allocation confirms the Council has assessed the Hollands Farm site as being suitable for development, though having regard to some of the “issues and constraints” there is plainly doubt over the suitability of Princes Road for two-way traffic which impacts deliverability of the link road (a matter which must be soundly addressed before the Development Brief is adopted). Moreover, as demonstrated above, other

sources of supply have come forward which changes the circumstances and the contribution required to the District’s housing supply.

18.15 The first sentence of SA Theme 4 should therefore be re-written to “Whilst the level of growth at Bourne End and Wooburn is set through the WDLP …”.

18.16 The SA states three density options are assessed:

• Higher density 35 dph +

• Medium density 25 – 30 dph

• Lower density < 20 dph

18.17 Further SA assessment is revealed in Part 2 narrative on landscape, which considers [SA 9.41] the “low-density rural housing in the east and denser village development in the north. It is recognised that development will ultimately merge these varying character areas.”.

18.18 In terms of housing density, plain reading of the narrative’s phrase “merging these varying character areas” conjures the form of average gradient from the low-density area at Hawks Hill (1 dph average) across to Bourne End (20 dph average). It does not infer an atypical increase in density (40 dph) between the two.

18.19 It is alarming the SA concedes a landscape-led approach will result in coalescence given the specific objectives in policy designation is to “maintain a sense of separation” which the DDB echoes to “provide a physical and visual separation between Hawks Hill, Hedsor Road and the new development”.

Conclusions

18.20 In terms of Climate Change it is frankly absurd that the SA concludes minor long-term positive effects are anticipated for the site. There is so much we could write to underline why this is a crass conclusion but will resist devoting the next 20-pages to the topic. Rather we will summarise that the DDB embraces no commitment for a low carbon development to meet the sustainable homes targets, that tarring and hard surfacing will inevitably contribute to existing surface water and ground water flooding issues, that increase car journeys will add to noise and pollution, that the SA ranks tree planting at the buffers as least desirable option (in spite of the Natural England scoping response), that the local area is already above recommended air quality levels.

Church land

18.21 The Policy BE2 red line map site area applied in the SA is invalid as it includes land belonging to Cores End United Reform Church which is not a deliverable component of the site (a matter previously raised during LP Examination but ignored).

18.22 This adversely impacts upon the SA which assessments have been undertaken against a different site area.

The Council must update the Sustainability Appraisal from AECOM (authors of the SA Report) accordingly with all assessments reviewed after excluding land owned by the United Reform Church which does not form part of the development site.

Catesby Estates pre-application consultation

18.23 The red line map published by Catesby Estates in its flyer to local residents shows an altered site boundary. KBEG has measured this area which removes around 1.5 ha from the west side of the site area illustrated in Policy BE2 and the Development Brief.

18.24 This loss of this area not only impacts the proposed development framework, but also adversely impacts upon the SA which assessments have been undertaken against a different site area.

The Council must update the Sustainability Appraisal from AECOM (authors of the SA Report) accordingly with all assessments reviewed after making corrections to reflect the modified extent of the development site now proposed by Catesby Estates.

19 Additional Comments

19.1 KBEG would welcome opportunity to participate with the Council and LG in the continued preparation of the Development Brief. for Hollands Farm.

Appendices

Appendix 1 - Catesby Estates Hollands Farm pre-application consultation flyer (8 February 202)

Appendix 2 - Wycombe District Council Development Capacity of Green Belt Residential Sites (20 June 2016) - Extract

Appendix 3 – KBEG Analysis of housing delivery in Bourne End and Wooburn (January 2021)

Appendix 4 – KBEG Assessment of housing densities across Bourne End and Wooburn (January 2021)

Appendix 5 - Wycombe District Council Viability Assessment (May 2017)

Appendix 6 - Bourne End History

Appendix 7 - Transport Appraisal of Draft Development Design Brief 2021-02-17