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HOLLANDS FARM DEVELOPMENT BRIEF 6Th January 2021 to 17Th

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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 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’); 2 • 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; 3 • 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)”. 4 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. 5 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.
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