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Mayfield House 256 Banbury Road Oxford Mr G Winwright OX2 7DE Planning Policy Team T: 01865 511444 South Bucks District Council F: 01865 404433 Capswood Oxford Road Your ref: Denham Our ref: LP/csw/1078787 UB9 4LH

12th December 2016

Dear Mr Winwright

CHILTERN AND SOUTH BUCKS LOCAL PLAN GREEN BELT PREFERRED OPTIONS CONSULTATION – LAND AT MIDDLEGREEN ROAD, WEXHAM, SLOUGH

1.0 Introduction

1.1 Carter Jonas has been instructed by Taylor Wimpey, who have an option agreement on the land at Middlegreen Road, to prepare representations to the Chiltern and South Bucks Local Plan Green Belt Preferred Options consultation.

1.2 Land at Middlegreen Road (the ‘Site’) lies in South Bucks District and immediately adjoins the administrative area of Slough Borough Council.

1.3 This consultation response should be read in conjunction with the nomination which was made to the Call for Sites consultation in February 2016, and the representations which were made to the Local Plan Issues and Options consultation in March 2016, on behalf of the landowner (Mr R Offer).

1.4 This representation provides a response to the:

• Green Belt Preferred Options Consultation Document; and • Draft Green Belt Assessment Part Two.

1.5 The Green Belt Development Options Appraisal, which is also published as part of the evidence base for the consultation, assesses the sites which were recommended for further consideration in the Green Belt Part One Assessment. This document does not refer to Land at Middlegreen Road.

1.6 Other comments are made specifically in support of the promotion of Land at Middlegreen Road.

2.0 Site Description

2.1 The Site covers an area of approximately 8.5 hectares and comprises predominantly young woodland, with some more open areas which are used for cattle grazing. In the north east corner of the Site is an area which is currently used for commercial purposes, renovating

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and restoring telecommunications equipment. Vehicular access to the commercial area and wider Site is from Middlegreen Road. The topography of the Site is largely level.

2.2 The main west coast railway line and the Grand Union Canal are both to the south of the Site. The boundary of the Site to the west is formed by Rochfords Gardens, a 1980’s housing development. To the north of the Site is land owned by Slough Nurseries, which comprises a plant nursery, accommodated in extensive greenhouses and ancillary buildings. The boundary to the east is formed by Middlegreen Road and Nursery Lane, and to the south by Lavender Farm, which is accessed from Nursery Lane.

2.3 To the north of Slough Nurseries lies a 25ha active sand and gravel quarry, which was granted planning permission in 2014, and is accessed from the A412 Uxbridge Road. Once the mineral extraction has been completed, the site will be restored to agriculture and nature conservation uses.

2.4 A plan showing the Site is attached at Appendix 1 to this letter.

3.0 Issues and Options Consultation

3.1 The response submitted to the Issues and Options consultation, in relation to the Land at Middlegreen, stated:

• Support for the intention of Chiltern and South Bucks District Councils to meet their full, objectively assessed need for housing; • Under the Duty to Cooperate, South Bucks and Chiltern Districts should not dismiss the potential need to accommodate unmet housing needs from adjoining areas, in particular Slough Borough; • The HELAA is a central part of the Joint Local Plan evidence base, and will assist in determining the amount of development that needs to be accommodated on land currently in the Green Belt; • The HELAA and related policy decisions should take full account of longstanding community concerns over the impact of urban intensification on townscape character. A balance needs to be struck between making more efficient use of urban land and the extent of land released from the Green Belt for development; • Support for the inclusion of Land at Middlegreen Road in the built area extension option identified at page 36 of the Issues and Options document; • There are exceptional circumstances to warrant a review of the Green Belt; and • The need for a hierarchical approach to identifying sites and meeting development needs; firstly sites in urban areas, then built area extensions adjacent to the principal settlements within and adjacent to the Plan area (particularly Slough).

3.2 In summary, if released from the Green Belt, Land at Middlegreen Road could make an important contribution to meeting housing need in the District (where they arise), and / or contribute to meeting the unmet housing need from Slough Borough.

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4.0 Green Belt Preferred Options Consultation

Development Needs in Chiltern and South Bucks District

4.1 To inform further work on the Joint Local Plan, Chiltern and South Bucks District Councils have undertaken a joint further review of their Housing and Economic Development Needs Assessment (HEDNA, September 2016), which also covers Aylesbury Vale and Wycombe District Council areas. The updated HEDNA identifies a need for 14,700 new homes in Chiltern and South Bucks Districts over the plan period (2014-2036).

4.2 Paragraph 1.2 of the Green Belt Preferred Options document states that the Councils believe that this housing figure cannot be met in full, despite opportunities that are likely to be found through a Green Belt review and increasing densities for development opportunities. The Councils have therefore been in discussion with Aylesbury Vale District Council, to explore the potential for some of Chiltern and South Bucks needs to be met outside the Plan area. An in-principle agreement has been reached for unmet needs to be provided in the emerging Vale of Aylesbury Local Plan, subject to further evidence to justify the amount of development and the Vale of Aylesbury Local Plan being able to identify sufficient capacity.

4.3 Based on the work Chiltern and South Bucks District Councils have undertaken to date, the Councils estimate an unmet need of some 5,800 units.

4.4 However, the Green Belt Preferred Options document notes that the Green Belt Assessment Part Two is only a draft document, and will not be completed until the outcome of this consultation and other work is known. The opportunity for the Councils to identify further sites for development therefore clearly still remains, and therefore even an initial estimate of the quantum of unmet housing need to be accommodated in Aylesbury Vale seems premature at this time.

4.5 The “Update” section of paragraph 1b) of the Green Belt Preferred Options consultation document states that:

‘Chiltern and South Bucks District Councils’ position remains that our needs as a first priority should be met through sustainable development opportunities within Chiltern and South Bucks but that full needs will not be able to be met, despite opportunities that are likely to be found through a Green Belt review and increasing densities for development opportunities.’

4.6 The Councils do not seem to be open to the possibility that their unmet housing need could be reduced, or even removed altogether, if sufficient land is released from the Green Belt within Chiltern and South Bucks Districts.

4.7 The HEDNA calculation of housing need recommends that in Aylesbury Vale, the housing target should be increased by 10% above the projected household growth rates to take account of market signals and lack of affordability. In Chiltern and South Bucks Districts, a 20% increase is recommended. The intention to ‘export’ some of the Chiltern and South Bucks housing need to Aylesbury Vale will perpetuate, and indeed exacerbate, the issue of poor affordability in South Bucks and Chiltern Districts.

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4.8 The Duty to Cooperate requires neighbouring local authorities and local authorities in a single housing market area to work together, to jointly meet their housing need. Slough Borough Council has a significant housing target of 970 homes per annum, and its options for where these homes can be delivered are significantly constrained by flood plain in the south of the Borough, and a tightly drawn Borough boundary.

4.9 Slough Borough Council has requested through representations to the Chiltern and South Bucks Issues and Options consultation (March 2016) that Green Belt land is released in South Bucks, to enable the development of an urban expansion to Slough in the form of a ‘Garden Suburb’. However, none of the Preferred Options sites in the current consultation are particularly close to Slough, and indeed, there is nothing in the Green Belt Preferred Options consultation document that indicates that Chiltern and South Bucks Councils are seeking at this time to factor in accommodating any unmet needs arising from Slough Borough.

4.10 As Officers will be aware, under the Duty to Cooperate, Chiltern and South Bucks Councils will need to demonstrate to a Planning Inspector that they have effectively cooperated with their neighbouring authorities, including Slough. There is an opportunity here for the Draft Green Belt Part Two assessment to be amended to respond to the housing need arising in Slough, by identifying further sites adjacent to Slough for release from the Green Belt.

4.11 Land at Middlegreen Road lies immediately north east of the boundary with Slough, and is well placed to contribute to assist in meeting Slough’s housing need. If the site were released from the Green Belt, it would provide a sustainable location for development, which relates well to existing residential development, and to facilities and services in the town (and nearby local centres).

4.12 As well as needing to take account of their own housing need and the housing need of neighbouring authorities, Chiltern and South Bucks Councils should also be making provision to ensure that they have the flexibility to accommodate the additional development pressures arising from planned expansion of Heathrow, and indeed, to assist in addressing any unmet needs arising from the London Plan Review.

4.13 Overall, there is, and will continue to be, considerable development pressure in the area, particularly in the south of South Bucks District.

Spatial Strategy

4.14 We note that fifteen sites have been identified as Preferred Options in the Green Belt Preferred Options consultation document. There does not, however, appear to be a strategy which underpins the identification of these sites.

4.15 The proforma used to assess each site assesses the sites against a range of criteria, including Green Belt, landscape, traffic modelling, infrastructure provision and Sustainability Appraisal. However, there is no criterion (or commentary) addressing how development would fit with one of the spatial strategy options set out in the Chiltern and South Bucks Issues and Options consultation document.

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4.16 Some of the Preferred Options sites could form Built Area Extensions to the principal settlements of Amersham, Beaconsfield, Little Chalfont and Chalfont St Peter, as proposed by Option C in the Issues and Options consultation document.

4.17 However, there are no significant Preferred Options sites which could be said to form Built Area Extensions to the principal settlements outside the Plan area, as proposed by Option D of the Issues and Options document. Two relatively small sites are identified adjacent to Holmer Green and Hazelmere, which could assist in meeting some of High Wycombe’s unmet housing need; and some sites in the south east of South Bucks District could be construed to make a small contribution to assisting in meeting Slough’s unmet housing need – but the fact of the matter is that Chiltern and South Bucks District Councils would appear to be seeking to retain all of the housing capacity identified in the Green Belt Preferred Options consultation document to meeting their own needs.

4.18 Fundamentally, we believe that Chiltern and South Bucks District Councils ought to be actively engaging with the issues arising around the likely unmet housing needs from Slough Borough. The Issues and Options Consultation identified a Built Area Extension option centred on the Land at Middlegreen, and more can and should be done to find opportunities to deliver development in this area, to assist in addressing the significant need for housing and to deliver sustainable development.

Part Two Green Belt Assessment

4.19 We note that the scope of the Part Two Green Belt Assessment has been considerably widened to include not just the sites which were recommended to be carried forward from the Green Belt Part I Assessment, but also:

• Strategic options and areas of search involving Green Belt land that formed part of the Regulation 18 public consultation document; • Submissions made in response to previous Call for Sites public consultations; and • Submissions made to the Regulation 18 public consultation on the Chiltern and South Bucks Local Plan.

4.20 Land at Middlegreen Road is included in the Part Two Green Belt Assessment on the basis that it was part of one of the Regulation 18 Built Area Extension Options considered in the Part One Green Belt assessment, and because it has been nominated as a site for consideration through the Call for Sites process.

4.21 There are three stages to the Green Belt Part Two Assessment: Potential Boundary Assessment, Green Belt Purpose Assessment and Exceptional Circumstances Assessment.

4.22 In the Part 1 Green Belt Assessment, Land at Middlegreen Road lies within Land Parcel 88, which covers an extensive area to the north east of Slough, between Slough and Iver. The assessment noted that much of this land parcel contributed strongly to the unspoilt, rural character of the countryside. The land parcel was therefore not taken forward for further consideration on the basis of this strong contribution.

4.23 However, paragraph 3.7 of the Draft Green Belt Part Two Assessment document recognises that the Part Two study considers smaller areas of land than the General Areas

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identified in Part One. This may result in the need to adjust sub-area scores differently, when these smaller areas are considered in isolation from the rest of the General Areas.

Potential Boundary Assessment

4.24 Land at Middlegreen Road is identified in the Draft Green Belt Assessment Part Two report as Site no. 4.322, on Map 55. The assessment of the site notes that:

‘It is not possible to identify a boundary that is permanent and defensible in accordance with NPPF requirements..… Its boundaries appear to follow existing property boundaries rather than natural features, although the property boundary itself follows the course of Middlegreen Road at the east of the options. The general absence of natural features around the option means that it is not possible to identify a permanent and defensible boundary.’

4.25 We respectfully submit that the last sentence of the assessment is factually incorrect. The NPPF does not require natural features to be the permanent and defensible boundaries referred to in the Green Belt Assessment. Paragraph 85 of the NPPF states that Local Planning Authorities should:

‘…..define boundaries clearly, using physical features that are readily recognisable and likely to be permanent.’

4.26 The Chiltern and South Bucks Green Belt Part 1a Methodology, paragraph 4.2.3, notes that in respect of the General Areas, in addition to natural features, motorways, A and B roads and railways were used to define boundaries. Paragraph 4.3.5 of the Green Belt Part 1a Methodology identified additional durable boundary features which would be considered, such as unclassified public roads and private roads and existing development with strongly established, regular or consistent boundaries. The lack of natural features should not therefore mean that, in principle, permanent and defensible boundaries cannot be identified.

4.27 We believe there are various opportunities to create permanent and defensible boundaries that incorporate the Land at Middlegreen Road. A Green Belt release could incorporate any land currently in the Green Belt to the south and west, up to the existing built up area of Slough to the south and west. To the east, Middlegreen Road / St Marys Road could provide a permanent and defensible boundary and to the north, there are existing hedgerows and tree belts that could be used (and reinforced), or alternatively, within the previously identified Built Area Extension delineation, there is George Green Road.

4.28 We believe that Land at Middlegreen Road should therefore be considered further through Parts 2 and 3 of the Green Belt Assessment.

Green Belt Purpose Assessment

4.29 The first purpose of the Green Belt is to check the unrestricted sprawl of large, built up areas. The Site lies adjacent to the edge of the distinct built up area of Slough. It is relatively contained by built form, with existing residential development to the west, Middlegreen Road to the east, existing residential properties to the south, and existing

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hedgerows and tree belts to the north that could be used (and reinforced), with George Green Road beyond.

4.30 As set out above, permanent and defensible boundaries could be defined to prevent sprawl into the wider Green Belt.

4.31 The second purpose of the Green Belt is to prevent neighbouring towns merging into one another. The Green Belt Part One methodology identified the towns which were considered in respect of this purpose; the relevant settlement close to Slough is Iver Village. The gap between Slough and Iver is 0.95 miles at its narrowest point, which occurs between the eastern extent of Langley and Iver. Development of Land at Middlegreen Road, which is to the west of the gap between the settlements, would not reduce the physical gap between Slough and Iver. Release of the Site from the Green Belt would therefore have no adverse impact on this second purpose.

4.32 The third purpose of the Green Belt is to assist in safeguarding the countryside from encroachment. Land at Middlegreen Road makes a weak contribution to this purpose of the Green Belt. The site has a semi-urban character, which contains a mix of urban and rural land uses. It contains areas of built form (barns, outbuildings, hard standing and commercial plant). Its character is heavily influenced by the large, glass buildings which comprise the plant nursery immediately to the north, and it is overlooked by existing residential development in Rochfords Garden.

4.33 The fourth purpose of the Green Belt is to preserve the setting and special character of historic towns. Land at Middlegreen Road makes no contribution to this purpose of the Green Belt. The development which surrounds it is all post war development which has no heritage value.

4.34 The fifth purpose of the Green Belt was excluded from the South Bucks and Chiltern Assessment.

4.35 In summary, the site either makes no contribution, or a very limited contribution to the five purposes of the Green Belt. It should therefore be taken forward to consider whether exceptional circumstances exist to justify the release of the site from the Green Belt.

Exceptional Circumstances Assessment

4.36 We note that the Councils have used the Exceptional Circumstances assessment to identify whether the release of a site from the Green Belt would accord with the Spatial Strategy options previously put forward by the Council, and to assess the sustainability of potential development on the site.

4.37 Land at Middlegreen Road would fit with Spatial Strategy Option D, ‘Built Area Extensions within Chiltern/South Bucks administrative area on the edge of principal settlements outside the Plan area – Wycombe, Uxbridge, Slough and Maidenhead.’

4.38 The site lies in a highly sustainable location, adjacent to existing residential development and within walking and cycling distance of existing shops and services.

4.39 Further, exceptional circumstances can be demonstrated through the significant housing need in Slough, which cannot be met within the boundaries of the Borough.

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5. Summary

5.1 Chiltern and South Bucks Councils have a high housing need, as identified in the HEDNA Update (October 2016). The Councils should be doing all they can to meet their own housing needs; the preparation of the Local Plan 2014-2036 provides an opportunity for areas of land to be released from the Green Belt to meet that housing need.

5.2 In considering which areas should be released from the Green Belt, Chiltern and South Bucks Councils should also take account of the housing needs of the neighbouring authorities, which are unable to meet their own housing targets because of physical, environmental and boundary constraints.

5.3 The evidence base to support the identification of the 15 Preferred Options sites is not considered to be robust. The selection of these sites does not reflect any one, or any combination of the spatial strategy options identified in the Chiltern and South Bucks Issues and Options document.

5.4 Further Green Belt sites that do not strongly fulfil the purposes of the Green Belt should be identified for release. Chiltern and South Bucks District Councils should focus their attentions on opportunities at the principal settlements within and adjacent to the Districts (including on land in South Bucks District adjacent to Slough).

5.5 We believe Land at Middlegreen Road should be released from the Green Belt, to assist in meeting local housing needs arising in South Bucks and / or Slough Borough.

5.6 The Part Two Green Belt Assessment discounts Land at Middlegreen Road from further consideration for release from the Green Belt on the basis that the Council believes that here are no natural, permanent and defensible boundaries to the Site. These representations have demonstrated that there are permanent and defensible boundaries to the site, which mean that the site should be carried forward for assessment against the five purposes of the Green Belt.

5.7 Further, the representations demonstrate that Land at Middlegreen Road makes either no contribution or a weak contribution to fulfilling the five purposes of the Green Belt.

5.8 The exceptional circumstances exist to justify removal of Land at Middlegreen Road from the Green Belt. Development of the Site would accord with Option D of the Spatial Options, as set out in Council’s earlier consultation on Issues and Options.

5.9 The Site lies in a highly sustainable location.

5.10 Housing need in Slough (and South Bucks) is such that Land at Middlegreen Road, either alone or as part of a wider release from the Green Belt, could provide much needed housing on the edge of the Town, on a site which weakly fulfils the aims of the Green Belt. The exceptional circumstances can therefore be demonstrated to justify the release of the Land at Middlegreen Road.

5.11 It is recommended that land at Middlegreen Road, either alone or as part of a wider area, is considered further for release from the Green Belt and is allocated for development in the Preferred Options document, which is due to be published in autumn 2017.

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5.12 We intend to submit further information over the course of the coming months, to assist Chiltern and South Bucks Councils in appraising the merits of the Site (and adjoining land).

5.13 Please do not hesitate to contact me if you require any further information at this time.

Yours sincerely,

Ian Gillespie MRTPI Planning Partner

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Appendix 1 – Site Plan

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