12/06261/R4OUT APPENDIX 1
Consultations and Notification Responses
Ward Councillor Preliminary Comments
Councillor L M Clarke No comments received Councillor A Hill No comments received Councillor M Hussain (Bhatti) JP No comments received
Parish/Town Council Comments/Internal and External Consultees
High Wycombe Town Unparished
County Council Archaeological Service
The application site is not thought to have archaeological potential.
County Council Environmental Service
Natural Environment
The County Council recommends that if significant harm resulting form the development cannot be avoided or mitigated, then provision should be made through a legal agreement to off set any loss by means of financial contribution towards the conservation, enhancement and restoration of natural features in the vicinity of the site.
Green infrastructure
The County Council welcomes the documentation that states that provision will be made for open space, ecological areas and SUDS. All of these can contribute positively to green infrastructure networks.
The Chilterns AONB Planning Officer
The Board does not object to the redevelopment of the Handy Cross site. However, the board remains concerned that the buildings that are on the southern side of the site, closest to the M40, are to be tall and bulky (up to six stories high), because the AONB is located immediately to the south of the M40 and the development may have impacts on its setting and enjoyment.
The application contains no real detail about the design, mass, bulk, materials and lighting for the main elements of the proposed development and also fails to provide any details about the wind turbines. All of these elements could affect the setting of the AONB and the tranquillity of the area. The Board considers that great care will be needed in the treatment of the design and materials for this important site.
It has previously been shown that the site is visible from some distance and the Board stressed that it would be important to have landscape and visual impact assessments prepared for any planning application. The Board considered that these should also take account of the numerous wind turbines and great care should also be taken with the type, height and number of turbines. The need for them will be negated by the inclusion of other sustainability measures such as district combined heat and power based on wood fuel.
Based on assessment of the details submitted in connection with the proposal, the Board objects to the application for the following reasons:
1. The application lacks sufficient detail to enable a proper assessment of the likely impacts on the Chilterns AONB. 2. The submitted landscape and visual assessment fails to take proper account of what is actually proposed and does not fully assess the likely implications. There is confusion between the assessment and the parameter plan. The assessment is based on a 5 storey hotel whilst the parameter plan details a 6 storey hotel. Furthermore, the assessment is based on a single storey sports centre and foodstore which the parameter plan show as being up to 4 storeys. Finally, the proposed wind turbines (11 in number) are not subject to any assessment at all. The Board is particularly concerned about this element as the application claims that these should be visible from the M40 in order to allow advertising somewhere below the hub. 3. Although the visual assessment includes some long distance view points, it has failed to take account of the impacts on one right of way that is within the Chiltern AONB and which is about 800m south of the site. From here, the site is clearly visible. The Board considers that, despite the intervening overhead electricity wires, the development proposed would be clearly visible, would break the skyline and would have a significant detrimental and overbearing impact on this right of way and its users. Being located within the AONB, this visual receptor is therefore highly sensitive to any proposal in the locality, including that at Handy Cross. 4. The Board cannot agree with the landscape and visual assessment’s conclusion (within the summary) that the proposed development will be a ‘significant visual benefit’ in the long term. 5. The Design and Access Statement includes a number of visuals which show the main elements of the proposals as artists’ impressions. This is about the only detail in connection with design and potential materials and does not provide enough information by which to judge the likely impacts. However, from an initial assessment, the designs and materials do not take account of the context of the site and its proximity to the Chilterns AONB. They also fail to take account of the fact that this is an important gateway to High Wycombe. 6. The Board considers that as detailed at present, the proposal would neither conserve nor enhance the natural beauty of the Chilterns AONB and its setting and as a result asks that the application be refused. 7. The Board’s objections could be overcome by the provision of a lot more information (design, materials, lighting and turbines in particular), a full and proper landscape and visual impact assessment and revisions to the bulk, mass, design and materials of the key elements that are on the southern side of the site. We would be happy to comment on any changes that are made to the application.
Additional comments following the submission of an amended appendix;
1. The plan on p.11 still shows the inconsistency that the Board mentioned in its response in connection with the proposed heights of the food store and leisure centre buildings. 2. There is still no assessment of the proposed wind turbines. 3. The montage on p.14 clearly shows the majority of the buildings breaking the skyline, albeit in the distance. 4. The montage on p.17 also illustrates this breaking of the skyline. 5. The suggested viewpoint on Monkton Lane has not been included. 6. The Board’s comments remain as in the letter dated 10 th July 2012.
Crime Prevention Design Adviser
There are no police objections to this application, but there will be the opportunity to design out crime as further details become known. My initial comments are;
• This site, with its proposed use, large amount of parking spaces and being located on the motorway roundabout, will be very vulnerable to car crime. Vehicles unattended in this location, adjacent to the motorway, with numerous escape routes, will undoubtedly attract attention from criminals who specialise in car crime. I understand that the intention is to achieve Park Mark accreditation for at least the coachway parking area. I also note the intention to install a barrier and ANPR for this parking area and these measures should go some way in deterring this type of crime. • Hotels are particularly vulnerable to car crime as residents are likely to have valuables in their cars, satellite navigation, laptops etc with the vehicles being left unattended overnight. The basic layout for the hotel shown in the application would appear to make it a simple process to secure the car parking area. This should be designed in from the start and should be reflected in any future applications. • There is a large amount of undercroft parking areas for the proposed offices and these can cause problems, out of hours, during the evenings and weekends. Being large partially enclosed areas with a lack of any natural surveillance, they are spaces that can generate anti-social behaviour and encourage crime. Undercroft areas are easily secured and reasonable security measures should be included in the final design.
Development Sustainability
Insufficient detail has been given on how much each recommended technology could reasonably expect to generate given the estimated energy demand. The Biomass option should be reassessed
WDC Economic Development Service
This development is strongly supported by the Economic Development Service as it will help to promote Wycombe and, with the location being adjacent to the M40 motorway, delivers a new and attractive gateway to the town and the District showcasing Wycombe as an attractive place to do business.
This development is very welcome as it supports the Council’s Economic Development Strategy (2012-2015) which has an overall aim of the creation of 2,000 new jobs by March 2016. The inclusion of up to 34,791 sq. m. of offices (Class B1) in this development will be a significant contributor to delivering this jobs target.
The wider development also has our endorsement as it provides complementary services that businesses will welcome, namely the Sports and Leisure facility, the Park & Ride, the hotel and food store. These services all deliver a well- rounded offer for businesses and their employees.
There are some suggestions for consideration as part of this development:
a) Supporting local jobs. The office space and the wider development aims to provide opportunities that will offer a good mix of jobs so as to benefit local residents and help reduce the district’s level of unemployment. In May 2012, 2,524 residents claimed unemployment benefit from Jobcentre plus. By encouraging a wide range of jobs, some of these residents will be able to access work. It is also encouraged that this development helps to attract businesses that require higher level skilled jobs. Research from the Department of Business Innovation and Skills shows that these jobs create a greater number of additional local jobs in the local service sector which will help to offer further employment opportunities for Wycombe’s residents;
b) Supporting cluster. This development can help to increase the clusters of business sectors already prevalent in the District. The Council’s Economic Development Strategy seeks to build the strengths of businesses in the sectors of Advanced Engineering, Bio Pharma, ICT & software engineering and Food & Drink, while recognising there are other significant global companies in Wycombe like Hyundai, Biffa Dreams etc. It is encouraged that the development has the flexibility to accommodate businesses from these sectors to meet their particular requirements, as relevant and appropriate.
c) Supporting neighbouring business parks. This development can bring benefit to businesses located elsewhere in the district. It is requested that consideration be given for encouraging this development to work with a wider Wycombe context and benefit neighbouring business areas such as Cressex Business Park.
Energy Strategy Assessment – Blewburton Partners
Benchmark data
The inclusion of the energy reduction methodology statement within the report as suggested will help the reader to understand the figures and approach used. Consideration of the use of the recently issued updated version of CIBSE Guide F (2012) in future reports of this type, which makes use of much more recent building benchmark data, may help to give more confidence in the estimates of energy demand and CO2 emissions.
Ground source heat pumps
The additional detail given by Hoare Lea of Building Services envisaged for each building type provides useful clarification on this point. It is recommended that this information is included in the report.
Air source heat pumps
Using the latest carbon emissions factors from Defra for natural gas and grid supplied electricity, the seasonal CoP of an air source heat pump would need to be greater than 2.5 to show any carbon emissions savings over the equivalent heat supplied by a modern gas boiler. A significant carbon emissions reduction over gas boiler supplied heat might be 25%,suggesting a seasonal CoP from the heat pump of around 3.5 – is this a reasonable expectation of air source heat pump performance for this development in practice?
Wind turbines
A client and architect aspiration might suggest that this technology is thought of as important in giving a visual statement of a site’s green credentials rather than providing any useful reduction in carbon emissions. The original report stated that the average wind speed at the site is 4.8m/s at 10m agl, however there is some confusion as this does not correspond to the data provided by the wind speed chart from DECC as shown in the report which suggests 5.5m/s. It is recommended that the predicted average wind speed for the site at 10m agl is confirmed. An assessment of the site’s macro conditions as mentioned in the original report will be essential to determine whether any significant renewable electricity will be generated by vertical axis wind turbines when located within the proposed surrounding built environment.
Biomass
• delivery distance – agreed that this would need further investigation to assess the predicted fuel consumption against the local availability of material. • carbon emissions of biomass fuel delivery – as stated, the economics will usually determine the viable distance, a 25 mile radius from the site may be the outer limit and this takes in a very large wooded area of the Chilterns. • ash disposal – agreed. • land use – agreed. • NOx emissions – agreed that biomass vehicle movements will increase NOx emissions, however these should be small compared to those associated with food store deliveries. • biomass vehicle delivery movements – suitable design of biomass delivery vehicle reception area to allow minimal impact on the local amenity, and scheduling of biomass deliveries to avoid food delivery slots and store opening periods in the daytime will minimise the impact. Agreed that a spatial re- planning exercise and vehicle movement strategy may be required.
Carbon emission options reduction appraisal
• food store – as stated, HP and tri- generation are currently being used in new food stores where no third party waste heat is present, and in the case of biomass fuelled units via a modular approach using 4 x 140kWth generators. • energy centre number and location – agreed.
BBP recommendations
Noted and agreed, with the note regarding the use of the latest version of CIBSE Guide F should improve the prediction of energy demand.
Environment Agency (south-east)
We have no objections to the proposed development subject to the following condition;
“Before each phase of the development approved by this planning permission, no development shall take place until such time as a surface water drainage scheme for the site, based on sustainable development principles and an assessment of the hydrological and hydro- geological context of the development has been submitted to, and approved in writing by, the local planning authority.
1. Details of how the scheme shall be maintained and managed after completion in consultation with the local authority. 2. All surface water from the site is to be discharged using soakaways, including further detailed infiltration tests for the detailed design. 3. The drainage system is to include the use of permeable paving, attenuation ponds, swales and filter trenches as shown on drawing ZHANDYCROSS.10A/10 REV. A produced by Mayer Brown included within the FRA dated 25 May 2012. 4. Details of any proposed informal flooding between the 1 in 30 years and up to the 1 in 10 year plus climate change rainfall event, showing the location, depths and velocities to demonstrate it is appropriate and safe.
The scheme shall be fully implemented and subsequently maintained, in accordance with the timing/ phasing arrangements embodied within the scheme, or within any other period as may subsequently by agreed in writing, by the local planning authority.
Reasons: 1. To ensure the proposed scheme can be maintained for the lifetime of the development to prevent increase in flood through as a result of lack of maintenance. 2. To ensure surface water can be disposed of in an appropriate manner to ensure no increase in flood risk to the site and the surrounding area. 3. To ensure all volumes of surface water can be attenuated within the site for all rainfall events ensuring other environmental benefits such as water quality, biodiversity and amenity. 4. To ensure the proposed drainage scheme will not increase flood risk through informal storage of surface water”.
Advice to applicant and LPA – surface water drainage
Although we are satisfied at this stage that the proposed development could be allowed in principle, the applicant will need to provide further information to ensure that the proposed development can go ahead without posing an unacceptable flood risk to the site and the surrounding area.
Whilst the SUDs approval body has not yet been commenced under the Flood and Water Management Act 2010, we advise the applicant liaises with the Local Authority and the Lead Local Flood Risk Authority to ensure they are satisfied with the proposed maintenance of the selected SUDs techniques as there is a possibility they may be expected to adopt the scheme retrospectively.
The car and coach parking area of the development should be drained via a Class 1 oil separator to reduce the risk of oil pollution. The developer should consult Agency Pollution Prevention Guidelines No 3 to ascertain the appropriate type.
Emergency Planning
The principles of surface water management on the site are acceptable in that all surface water is proposed to discharge to soakaway with excess water being diverted to existing highway drains.
The applicant is reminded that under the Flood & Water Management Act 2010, responsibility for surface water is transferred to the Lead Local Flood Authority and therefore previous advice from the EA should only be taken as guidance and not acceptance of the proposals.
The applicant needs to demonstrate that the scheme complies with the current draft national standards for sustainable drainage systems published by Defra and that the assessment of flood is in accordance with BS 8533: 2011 Assessing and Managing Flood Risk in Development – Code of Practice.
Prior to the submission of the detailed scheme, the applicant will need to demonstrate that at all stages of the development, the discharge of surface water on site will meet the national standards, particularly during the construction of the spine road and the new leisure centre.
Environmental Services
Issues: • Increased air pollution • Light pollution • Noise pollution
Air pollution
The applicants assessment indicates that properties in Fair Ridge will experience a slight increase in pollutant concentrations due to vehicles accessing the development. In addition levels in the vicinity of Marlow Road and Marlow Hill will see only minimal change. The applicants 2010 base level for assessment is lower than the know concentrations in 2012. It is important to establish that the proposed development site is included within the proposed high Wycombe AQMA and so measures to help implement an air quality action plan will be necessary.
Light pollution
All external lighting will need to be designed to minimise light spill. Details will be needed.
Noise pollution
Noise from any plant to be installed for the buildings will need to be assessed for noise levels.
The noise from the M40 will be a particular concern for the hotel and acoustic glazing and mechanical ventilation will be needed.
Recommendation: No objection subject to planning conditions:
Section 106 agreement
To include an allowance to mitigate air pollution impacts. The recommendations for mitigation include: • Assistance with measures to help implement the air quality action plan • Cycle racks • Vehicle electric charging points • Free parking for electric vehicles • Signage to promote green travel • Extra trees to help bund the site
Conditions
Noise levels of plant at the Nearest Residential Properties No development shall take place before a scheme has been submitted to and approved in writing by the Local Planning Authority which specifies the provisions to be made for the control of noise emanating from the any plant to be installed. The target levels for the plant would be that the rating level (as defined in BS4142) be at least 5dB below the background noise level at the nearest residential properties. In the event of tonal emissions, a 5dB penalty shall apply therefore making the specific noise level at least 10dB below the minimum background (LA90) level. Thereafter, the use shall not commence until the approved scheme has been fully implemented. Reason – To protect nearby occupants from noise and disturbances.
L07V Sound Insulation - Hotel - Traffic Noise (Noise Exposure Category C) A scheme to protect the proposed hotel from traffic noise from the M40 shall be implemented before any part of the accommodation hereby approved is occupied, unless the Local Planning Authority otherwise agrees in writing. The scheme shall ensure the indoor ambient noise levels in living rooms and bedrooms meet the good standard in BS 8233:1999 of 30dB LAeq. Unless otherwise agreed in writing with the Local Planning Authority it shall be assumed that the existing noise level at the façade of the proposed development is 72dB LAeq. The scheme shall include mechanical ventilation to meet the requirements of the Noise Insulation (Amended) Regulations 1988. Reason – To protect the occupants of the new development from noise disturbance.
Floodlighting Condition The floodlighting scheme of the development hereby permitted shall be carried out in accordance with the submitted details unless otherwise agreed in writing by the Local Planning Authority. Reason: To safeguard the amenities of nearby residents.
County Highway Authority
I refer to the above planning application which has been under consideration by the County Council since its submission in May 2012. You will be aware that this application follows a 2009 planning application (09/07309/R4OUT) for a similar development which comprised a Coachway/Park and Ride, a business development with up to 33,105 sq. m. of offices and up to 914 car parking spaces, a 150 bed hotel with up to 50 car parking spaces, associated accesses, landscaping and open space and new access layout for the retained leisure centre.
This application is seeking outline planning permission only and a number of matters are therefore reserved for later consideration. However, means of access is not a reserved matter and as such the access points to the highway, along with the network impact of all modes, needs to be considered in detail at this stage. My comments are on this basis.
The 2009 application was granted planning permission by decision notice issued on 19 th May 2011 following the completion of a S106 Agreement and could therefore be implemented. It therefore represents the benchmark against which this current planning application should be considered from a highways and transportation perspective. The transportation submission for this application therefore concentrates on the differences between the consented and proposed developments comparing how the traffic generation potential from the proposed scheme impacts on the network against the accepted impacts of the permitted scheme.
The following table outlines the differences between the consented scheme and that now proposed in terms of development quantum and mix.
It can be seen from the above table that the significant changes between the consented and proposed scheme relate to the addition of a new 3,600 sq. m. food store and a 600 sq. m. nursery or health facility building.
Transport Policy Context
The Coachway and Park and Ride is identified within Buckinghamshire County Council’s Local Transport Plan 3 (LTP3) as an objective to increase sustainable travel within this area, following on from the High Wycombe Town Centre Parking and Access Strategy (2004). The Urban Strategy for High Wycombe as set out in LTP3 outlines the TRIM approach ( Transfer, Re-route, Intercept and Manage) to tackling congestion. Under the heading of Intercept, specific reference is made to “intercepting car journeys using existing Park and Ride, Coachway or Rail Services”. The LTP sets out “key schemes for further consideration or development” including “High Wycombe Regional Coachway”.
Policy CS 4.3 of the adopted Wycombe Development Framework Core Strategy sets out Wycombe District Council’s vision for the key areas of change in High Wycombe and includes the M40 Gateway. It states that the key areas of change will include; iii) Better use of public transport
Providing new and improved facilities to remedy existing deficiencies and to improve the sustainability of new developments; iv. Coachway and Park and Ride
Providing facilities to tap into the potential for the regional coach network support the town centre and M40 gateway area development/redevelopment proposals and the role of the town as a proposed regional transport hub;
This policy is supported by the narrative that follows where it is stated that;
4.26 The area is particularly well placed to provide a regional coachway/park and ride interchange to enable enhanced inter-urban coach services. This is supported by the Regional Transport Strategy, but needs to be supported by improved public transport provision linking this new transport hub to the centre of High Wycombe.
Policy CS 16 states that the Wycombe District Council will work with the County Council and other relevant agencies to deliver a transport hub on the south side of High Wycombe that includes a regional coachway and improved public transport links.
It can be seen from the above that the principle of a Coachway and Park and Ride at this site is something that both the District and County Council’s policies support from a transportation point of view. The principle of the development was also accepted as part of the consideration of the previous, now consented, application.
Our approach to this planning application is therefore on the basis of the benefits to modal choice and potential modal shift that this infrastructure could bring.
I understand that the previous scheme was to be primarily funded by the Department for Transport via their Major Scheme funding. However, in light of public sector funding pressures, that funding opportunity has now been removed and as such the applicant has needed to change the scheme in order to make the development financially viable to be able to deliver the requirement of a Coachway and Park and Ride.
A Transport Assessment has been submitted with the application which sets out the change in traffic generation potential associated with this application compared to the consented scheme. The approach to the study taken in the Transport Assessment is stated as “forming an update to the 2009 Transport Assessment”.
Access Arrangements
The development will be accessed from the A404 Marlow Road from three signal controlled junctions as illustrated below;
Extract from Figure 12-3 of Transport Assessment
Junction 1 – Existing Sports Centre Access
The existing sports centre access junction with A404 Marlow Hill will be widened to incorporate two right turn lanes and a left turn lane for exiting traffic on the side road. The A404 arm will include minor changes to stop line positions along with changes to the left turn filter lane into the sports centre access road for southbound traffic.
The junction will allow traffic movements from all directions and will continue to provide primary access to the Fair Ridge area. The proposed junction will incorporate pedestrian and cycle crossing facilities.
Junction 2 – Proposed Coachway/Park & Ride access road.
This junction will take the form of a new signal controlled junction with A404 Marlow Hill. This junction will allow access only to the Coachway/Park & Ride and car park. The junction will include a dedicated 80m long right turn lane to allow northbound traffic exiting M40 Junction 4 to access the site. Southbound traffic will also have a dedicated left turn slip from the A404 to ensure that delays caused by turning traffic to through traffic movements are minimised.
This junction was previously restricted for use by bus only traffic in the 2009 application, but now allows general vehicular traffic use. On entering the site buses will travel straight ahead and on into the Coachway/Park & Ride concourse, whilst general vehicular traffic will filter right into the car park.
The revised junction arrangement will assist in spreading the impact of general vehicular traffic away from only one general vehicular access point as proposed in 2009. This means that the traffic impact at the Sports Centre Access Junction (Junction 1) will be reduced when compared to the previous scheme.
This junction does not incorporate signal controlled pedestrian crossings as these are better catered for at Junctions 1 and 3 which align with pedestrian desire lines.
Junction 3 – Hub Exit.
This junction is located at the south western end of the site and will take the form of a signal controlled junction. The primary purpose of this junction is to allow vehicles exiting the site southbound towards M40 Junction 4. The proposed junction will incorporate pedestrian and cycle crossing facilities to link with the footway network on the western side of A404 which continues round to Marlow Road. The junction will also allow buses only to turn right out of the site towards the Town Centre.
Development Components & Traffic Generation
The traffic generation potential associated with the proposed Coachway facility has been determined by the County Council’s Regional Model. Traffic generation associated with the Park & Ride facility was calculated using the local Wycombe transport model.
The traffic generation potential of the remaining land use components of the site has been calculated based on data obtained from the TRICS database ( Trip Rate Information Computer System). This is the nationally accepted tool for determining the traffic generation potential associated with specific land uses as part of development proposals. This approach is consistent with the approach taken in the 2009 planning application and with most other development proposals which the Highway Authority considers at the planning application stage.
On the basis of the above, the following trip generation potential has been determined for the revised development proposals.
Weekday AM Peak Hour
Weekday PM Peak Hour
It should be noted that there are some minor errors in the tables in relation to the trip generation figures quoted for the food store and crèche, however, these do not materially change the total traffic generation levels used for analysis.
Given that this application is an alternative development to that already granted planning permission, a comparison of traffic generation potential has been carried out, which for clarity compares the traffic generation potential from the current scheme with that of the consented scheme. The following tables show the traffic generation comparison;
Weekday AM Peak Hour
Weekday PM Peak Hour.
It can be seen from the above that the proposed development has the potential to increase the traffic generation potential associated with the site when compared to the consented scheme by 134 movements (two-way) during the weekday morning peak hour and 243 additional movements (two-way) during the evening peak hour.
Impact and Mitigation
The analysis of network performance with the inclusion of the revised development proposals has been carried out by the applicants using Paramics microsimulation software consistent with the approach taken for the 2009 application. The previously accepted models have been updated to take into account the following;
• Revised internal layout reflecting that shown on the masterplan; • Inclusion of additional traffic demand associated with the revised scheme; • Revision to junction 3 to include a signalised left exit for all traffic and a right exit for buses only.
The extent of the transport network assessed in this application is the same as that assessed as part of the 2009 application and includes the network from and including M40 Junction 4 northwards to the A404 Marlow Road gyratory. The assessment includes all accesses to the development site.
The Paramics model provides visual queue length information for the junctions within the study area. This has been compared against the same data from the consented development in order to provide an understanding of how the conditions would change.
The results of the modelling indicate that at Junction 1 (Sports Centre Access), the following changes to queuing occur compared to the consented scheme.
It can be seen that the development proposal has a neutral affect on conditions compared to the consented scheme.
At the other end of the site (Junction 3) the revised modelling suggests the following changes to queuing during the network peak hours occur.
Again it can be seen that that proposed changes to the development have a reasonably neutral affect on queuing at this junction.
The Marlow Road gyratory system is a sensitive location in terms of congestion and delays and as such it is essential that we understand the comparative assessment of queuing at this junction. This information is set out in the following table;
Again it can be seen that the changes in development on the site do not materially change the queuing conditions at the junction.
Whilst queuing is a useful tool for understanding network congestion it should not be considered in isolation. Notwithstanding the fact that the modelling suggests only modest changes to queuing conditions within the study area, information has also been provided by the applicant, again extracted from the Paramics model, which shows how journey times between various points on the boundaries of the study area will change.
A supplementary journey time analysis was requested from the applicants by BCC and information was submitted in a supplementary note produced by Jacobs dated 07 th November 2012. This note identified the following journey time comparisons between the “Do minimum” (consented development) and the “Do Something” (proposed development) scenarios;
For ease of understanding the following diagram sets out the various start and finish points used in determining the above journey time information.
It can be seen from the information contained in Tables A and B above that the proposed development does not lead to a material change in journey times across the network when compared to the existing consented situation.
On this basis, it can be concluded that in the absence of material changes to queuing levels or journey times across the network, then there is no basis to recommend refusal of planning permission on the grounds of network impact and capacity. I understand that this is a position which is also accepted by the Highways Agency with regard to the impact on Junction 4 and the M40 Motorway.
Pedestrian and Cycle provision.
The development proposals will be expected to provide adequate pedestrian and cycle linkage within the site and connecting to the sites eastern boundary where there are proposals for a public transport link connecting the Handy Cross Hub site to Daws Hill Lane. This connection, subject to the Link coming forward at a later date, will provide a footway/cycleway link between the site and existing and proposed development to the northeast.
As explained earlier in this consultation response, the applicant proposes pedestrian and cycle crossings at the Sports Centre access junction (Junction 1) and the south western junction (Junction 3) close to Handy Cross. These controlled crossing points will allow connections with the existing footway network on the western side of the A404.
To complete the site’s pedestrian and cycle connections to the west of the A404, the applicant is proposing a to widen the section of existing footway between the site access (Junction 3) signal controlled crossing and the existing footway network at Marlow Road just north of the Handy Cross junction to 3.0m.
S106 requirements
I would like to identify at this stage that should Wycombe District Council be prepared to grant planning permission, the County Council will be seeking the following S106 contributions in order to improve site accessibility by non-car modes of travel. This is necessary to ensure that the site becomes well linked to the town centre and therefore compliant with the policy requirements of the National Planning Policy Framework, WDC Core Strategy, the aims of BCC’s LTP3 and the emerging Southern Quadrant Transport Strategy (SQTS).
Bus Subsidy.
It is envisaged that the existing Park and Ride bus service serving Cressex Island will be relocated to the application site. When this happens it is predicted that there will be an immediate dip in passenger numbers, associated with the loss of patronage from the Cressex Business Park and other local uses estimated to be up to 35%. This will mean a shortfall in funding in the early stages of the new Coachway & Park and Ride site. It is unlikely that any operator will want to operate the service commercially because of this and therefore other sources of funding will need to be brought to bear.
My Passenger Transport colleagues have estimated on this basis that over a 5 year period the shortfall in funding could amount to £625,000. This shortfall should be provided by the applicant in order to ensure that a frequent bus service between the site and the town centre, via the railway and bus stations is achieved.
Marlow Hill Bus Priority Measures.
Modelling shows that the Coachway/Park and Ride site and other developments covered by the emerging Southern Quadrant Transport Strategy (SQTS), will lead to an increase in traffic through the Abbey Way Gyratory system. To minimise any additional delay to the Park and Ride, and other bus services and to make theses services an attractive and viable alternative to the private car, engineering measures must be put in place to give priority to bus services.
These priority measures will need to be flexible and adaptable to be both effective in the short term and to align with the High Wycombe Masterplan Proposals in the future.
As part of the Town Centre Masterplan a signalised crossing is proposed across the A404 from Wycombe Abbey School. This crossing can be used as a bus pre-signal to strategically hold back general traffic and give a significant advantage to buses travelling down Marlow Hill. This works using existing on-bus technology to activate the signals when buses reach a critical point on Marlow Hill. To maximise priority for buses travelling in both directions, this would be supplemented by additional pre- signals on the Gyratory.
The total cost of the Crossing, including detailed scheme design, is estimated at £100,000, with the additional pre-signals a further £100,000. In order to bring this scheme forward in a timescale that can help to mitigate the impact of the Coachway development the applicants are required to make a contribution of £100,000 toward the advancement of the scheme, or other appropriate bus priority measures between the site and town centre. It is expected that a further £100,000 would be sought on the same basis from the developer of the RAF Daws Hill site should that come forward.
Bus, Pedestrian and Cycle Link Connecting Handy Cross Hub to Daws Hill Lane contribution.
In addition to the above, in order to provide improved pedestrian and cycle linkage between the site and the existing built areas to the northeast, the Council is seeking the provision of a bus, pedestrian and cycle link between the rear of the Coachway site and Daws Hill Lane. The scheme is currently estimated to cost in the region of £1,000,000 and it is anticipated that the majority of funding for the scheme will come from development related contributions, given that it is essential to achieving non-car site accessibility between various areas. Whilst I do not consider it reasonable for this development to make a contribution towards the bus link itself, given that the Coachway site will benefit from a direct high frequency bus link to the town centre (subject to the other obligations above), it is entirely appropriate for this development to contribute towards the footway/cycleway element.
With the provision of a food store, employment and enhanced leisure uses, the site will become an attractive and realistic destination for those within the built up areas to the northeast who are able, and should be encouraged, to walk and cycle. On this basis the applicant is required to make a contribution of £58,800 towards the link scheme in order to enhance site accessibility by non-car modes of travel. This contribution is based only on the footway and cycleway element of the link.
Travel Plan
The Travel Plan submitted with the application provides a framework which seeks a reduction in single occupancy car journeys associated with the site. Whilst there are a number of outstanding matters which need to be resolved following comments received from my sustainable travel colleagues, I am satisfied that these can be addressed through the detailed approvals and S106 Agreement stage. I would however advise that the applicant should be aware that as part of the S106 Agreement they will be required to meet the Council’s Travel Plan Annual Review fees which are £1000/annum for the first five years.
Parking Management Plan
The site comprises a number of different and independent uses along with the Coachway and Park & Ride itself.
It is essential that access to restricted areas, such as the Coachway concourse, is effectively managed throughout the life of the development. Similarly it is essential that the Park & Ride car park is used by Park & Ride customers and not visitors to the hotel, food or employment uses on the site. These uses will also need to manage their car parking areas efficiently.
The applicants have also agreed to accommodate drop off and pick up movements associated with the local schools in order to remove these movements from the roads within Fair Ridge. Whilst this is welcomed it is again essential to understand how this will be accommodated within the site, alongside all of the other parking constraints.
All of these details and measures can be set out in a site wide Parking Management Plan which must be approved prior to the occupation of any development on site with the exception of a replacement Leisure Centre.
Summary & Conclusion
It is concluded that in the absence of a material increase in queuing and delay across the study area when compared to the consented situation that there is no basis to object to this application on highways and transportation grounds. This is of course subject to the S106 obligations set out in this response to improve site accessibility by non car modes of travel, the highways infrastructure proposed as part of this application and the following conditions.
The Highway Authority suggests a number of planning conditions. [These have been included within the report ].
Highways Agency
The Highways Agency directs that conditions be attached to any planning permission that may be granted as follows:
1 No part of the development shall be occupied until the western new signalised access shall be completed as shown on the Masterplan, with a system of queue detection linked to the new signal control. The system shall be designed and installed such that northbound queues on the A404 Marlow Hill at the junction shall not exceed 90m at any time. Reason: To avoid causing congestion on the Handy Cross roundabout.
2 No more that 13,400 sq. m. gross external floor area of offices shall be occupied unless the Crest Road/John Hall Way junction has all arms signalised, including a queue detection system. The system shall be designed and installed such that queues back towards Handy Cross roundabout shall not exceed 120m at any time. Reason: To avoid causing congestion on the Handy Cross roundabout.
3 The coachway/P&R parking shall not be brought into use until a scheme has been approved by the Local Planning Authority to ensure that at least 275 parking spaces are used solely for coach service passengers within the hours of 08.00 to 18.00 Monday to Friday Reason: To allow the effective operation of the coachway.
WDC Landscape and Ecology Officer
LANDSCAPE COMMENTS
Landscape and Visual Impact Assessment (LVIA) The LVIA has been revised to take account of my previous comments. ‘Typos’ have been corrected and more information has been supplied such as the wireframe diagrams showing both the previously approved scheme and the revised scheme, which is very helpful. Appendix 2 has been added outlining a useful response to the issues raised in my previous comments.
Disagreement on the significance of the impacts remains. I still believe that the LVIA underestimates the landscape & visual impact from selected viewpoints and I also still believe that there is an over-estimation of the impact of planting.
The additional information confirms that the development will break the skyline when viewed from Winter Hill. Whilst this viewpoint is several miles away it has always been considered a key view. The previously approved scheme also broke the skyline but the current scheme appears to do this to a larger degree, i.e. over a larger proportion of the site. Being an outline application no information with regard to lighting and night time visibility has been supplied but this will be an important factor when considering the impact on views. The impact of the development will depend on design, materials and fenestration of the development blocks and I therefore recommend that a condition is added that ensures that design, materials and fenestration are agreed at detailed planning stage. Green roofs should also be considered in this context as they will help in reducing visibility in long-distance views.
Landscape Design Despite the applicant’s reassurance on the effect of the proposed planting I remain of the view that the development will by its nature be dominated by buildings and car parking. Although perimeter planting and planting within the car parks will help to soften the impact I believe it will only have limited effect in the context of the proposed hard standing and building mass.
As mentioned in my previous comments much of the quality and effectiveness of the landscape treatment will depend on the detail. It is important to ensure that all proposed planting is feasible. Having reviewed the master plan again I am concerned that in some areas planting is given insufficient room to ensure its growth and survival. For example the trees within the coachway car park are shown to be planted into the hard surface between the parking bays without any dedicated room given to them. Whilst such planting is theoretically possible, e.g. by using urban tree soil or similar, it never seems very successful in practice as trees tend to be vulnerable to damage by cars as well as having less opportunity to grow to a meaningful size. This often results in planting/trees being omitted from car parks completely. In addition, service runs often conflict with planting requirements putting further constraints on tree planting. To provide confidence that planting will be implemented at the level proposed on the plans I recommend that the parking layout of the coachway car park is revised to allow the integration of planting areas for trees. This might have a knock on effect on the footprint of some of the buildings, however, some of these appear to have increased slightly from the previous scheme so that a small reduction in their footprint might be possible.
If such a change in layout is not possible, I recommend that a number of conditions are added to any potential planning consent to ensure the feasibility and implementation of planting as indicated on the plans. Conditions should ensure that: a) planting, in particular tree planting, is implemented at a minimum level as shown on the master plan (drawing. M12/SK183 – Masterplan with Squareabout). Trees should be of medium-size or larger. b) Tree planting in areas of hardstanding such as the car parks and in particular the coachway car park should be required to use a cellular planting system (e.g. Silvacell) and appropriate measures to ensure protection from cars (where necessary). Tree planting details should be submitted to and approved by the local planning authority at detailed planning stage.
Open Space I don’t agree with the open space calculation outlined on Amenity Area Plan Breakdown plan (drawing. 378 D112 Rev A). Roads and pavements should not be counted as open space. Whilst I accept that pedestrianised urban spaces can contribute to the open space provision I do not agree that the ‘plaza’ should be counted since it forms part of the access to two large car parks.
Similarly I don’t agree that the ‘nature’ trail can be counted as open space since it only comprises a narrow soft-landscape verge between the M40, the A404 and the proposed development. The water feature in front of the landmark building is surrounded by roads and thus is in fact a roundabout. Whilst it can be made visually attractive I believe it can only deliver limited ecological benefit. Whilst all these areas are important I consider them more as a setting for the buildings than as public open space.
In my view only the most easterly open space with the play provision should be counted as open space, however, it is my understanding that even this space might potentially be compromised by a future road alignment.
I therefore consider that the development to deliver less open space than stated.
ECOLOGICAL COMMENTS
I note that the applicant will not provide an update on the existing bat survey from 2009. This is disappointing, particularly since the 2009 survey report recommended further surveys to be carried out to provide more confidence in the findings.
Whilst the survey did not find any bats emerging from the sport centre building in 2009 it does not rule the presence of bats out (hence the requirement for more survey information). Paying due regard to these findings and to bat behaviour I recommend that a condition is added to any potential planning consent, which requires an update of the ecological survey prior to demolition of the sports centre building. In addition, I recommend that a condition is added that requires the location and detail of the wind turbines to be agreed in writing at detailed application stage.
CONCLUSION
From a landscape point of view I would have preferred a lower-density scheme that retains more space for planting and open space. I have some concerns with regard to the height and bulk of the buildings in views, the dominance of car parking and buildings, the limited space for planting within site and the small amount of open space. However, many of these principles have already been established and accepted with the previous application. Suitably worded conditions will help to minimise impacts.
Proposed Conditions or Informatives: • Design, materials and fenestration of all buildings • Detailed landscape scheme that secures the amount of planting as approved at outline as a minimum • Details of tree planting in areas of hardstanding. The use of a cellular planting system and appropriate measures to protect planting from cars are required. • Updated ecological survey prior to demolition of the sports centre building • Design and location of wind turbines • Lighting condition to minimise ecological, and landscape and visual impact.
Leisure and Community Services
Community Services is encouraged to see that the planning application includes a building comparable to the existing sports centre in terms of the range of sports facilities that will be available.
Natural England
The proposed development is adjacent to the AONB. This application is for outline permission only, and therefore does not provide details of the detailed layout, materials, bulk, mass or lighting, all of which will affect the setting of the AONB, and have an impact on the tranquillity.
It is Natural England’s advice that, when reserved matters are addressed, the Chilterns AONB Design Guide should be consulted for appropriate materials to use in the construction. The development should be designed so that the buildings are less tall closer to the M40 (and the AONB boundary), and ideally the taller buildings should be broken up by smaller buildings to lessen the impact of the development on the setting of the AONB. The design and layout of any lighting should be considered in terms of the impacts on the tranquillity of the AONB.
Your Authority should also seek the view of the Chilterns Conservation Board prior to determining this application, as they may have more detailed comments to make on the location, nature or design of this development.
Protected species
It is noted that an ecological report has been submitted as part of this application. From this, it appears that European Protected Species are unlikely to be affected by the proposed development; however more details may be required at the reserved matters stage.
Natural England has produced standing advice, which is available on our website Natural England Standing Advice to help the local planning authorities to better understand the impact of particular developments on protected or BAP species should they be identified as an issue. The standing advice also sets out when, following receipt of survey information, the local planning authority should undertake further consultation with Natural England.
Biodiversity enhancements This proposal presents the opportunity to incorporate features into the design which are beneficial to wildlife such as the incorporation of roosting opportunities for bats, the installation of bird nest boxes or the use of native species in the landscape planting. We recommend that should be Council be minded to grant planning permission, measures to enhance the biodiversity of the site are secured from the applicant. This is in accordance with Section 40 of the Natural Environment and Rural Communities Act (2006) which states that ‘Every public authority must, in exercising its functions, have regard, so far as is consistent with the proper exercise of those functions, to the purpose of conserving biodiversity’. Section 40 (3) also states that ’conserving biodiversity includes, in relation to a living organism or type of habitat, restoring or enhancing a population or habitat’. Biodiversity 2020: A strategy for England’s wildlife and ecosystem services and Making Space for Nature (2010) also provide strong drivers for the inclusion of biodiversity enhancements through the planning process.
Nathaniel Lichfield and Partners (Retail advisers to Local Planning Authority)
Have considered the applicant’s retail assessment and conclude:
Methodology: The applicant has adopted higher local expenditure estimates than NLP. Further assessment has therefore been carried out by NLP.
Retail and wider impacts: Will have an average impact of 6.6% upon the convenience stores in Wycombe town centre. Tesco will be the store that will be most vulnerable to this impact. There will be a 0.3% impact on comparison shopping in the town centre and as a result of reducing linked comparison and convenience town centre shopping trips this impact could rise to 0.7%. On balance NLP advise that the impact on the town centre is not considered to be significant, to an extent where the impact would significantly and demonstrably out-weigh the benefits of the development. The conclusion assumes Tesco remains trading and there are no other proposals for food store development emerging in the town centre that could be jeopardised.
Sequential approach: The proposed site is out of centre. All town centre and edge of centre sites should be considered. The minimum size of store that is viable and large enough to meet the need would be around 3,500 sq. m. gross. The only opportunities in High Wycombe town centre that could accommodate this size of store would be the gas works site in Lily Walk. The sequential approach has not provided sufficient evidence to discount this site. The site could not be discounted until the owners aspirations for the site are fully explored or until the council concludes that a foodstore would not be considered suitable at Lilys Walk.
Royal Borough of Maidenhead and Windsor
The RBMW has no objection to the proposed development.
Sport England
It is understood that the development is likely to prejudice the use, or lead to the loss, of land being used as playing field; or on land that forms part of, or constitutes a playing field, as defined in the Town and Country Planning (Development Management Procedure) (England) Order 2010 Schedule 5. Sport England responds to this application as a statutory consultee on the basis that the land has been used as a playing field at any time in the last five years and remains undeveloped; or has been allocated for use as a playing field in a development plan; or involves replacement of the grass surface of a playing pitch on a playing field with an artificial surface. Sport England’s policy, ‘A Sporting Future for the Playing Fields of England’ is available from our website: www.sportengland.org/ Facilities & Planning > Our Policy on Playing Fields. The aim of this policy is to ensure that there is an adequate supply of quality pitches to satisfy the current and estimated future demand for pitch sports within the area. The policy seeks to protect all parts of the playing field from development and not just those which, for the time being, are laid out as pitches. The policy states that;
“Sport England will oppose the granting of planning permission for any development which would lead to the loss of, or would prejudice the use of, all or any part of a playing field or land last used as a playing field or allocated for use as a playing field in an adopted or draft deposit local plan, unless, in the judgement of Sport England, one of the specific circumstances applies”.
Reason; “Development which would lead to the loss of all or part of a playing field, or which would prejudice its use, should not normally be permitted because it would permanently reduce the opportunities for participation in sporting activities. Government planning policy and the policies of Sport England have recognised the importance of such activities to the social and economic well- being of the country”.
The site is an 8.7 hectare triangular shaped site. A leisure centre is currently located in the north east corner of the site. There is also a flood-lit all-weather sports pitch and an athletics track. It is proposed that the existing Sports Centre will be replaced with a new facility in the south eastern corner of the site. The facility will be smaller than the existing building. It is proposed that the new Leisure Centre will be built in a different location from the existing Leisure Centre to enable continuity of use whilst the new facility is constructed. As part of the proposals, the existing athletics track and synthetic turf pitch will be relocated to alternative sites. It is proposed that the synthetic turf pitch goes to the John Hampden Grammar School on the opposite side of the A404 Marlow Hill. A separate planning application has been submitted for the construction of a flood-lit synthetic turf pitch with associated fencing, landscaping and additional car parking at John Hampden School.
At this stage, a site for the relocation of the athletics track has not yet been confirmed.
The existing leisure centre comprises a number of different uses, the main ones being;
• 50 metre swimming pool • 25 metre teaching pool • 8 court sports hall • Group fitness studio • 100 station gym • 4 squash courts • 6 rink bowls hall
This application is in outline only at this stage, and therefore the exact mix of proposed uses has not been confirmed. However, Sport England seeks further clarity on whether the maximum footprint of the new leisure centre is defined as part of this application.
Key to Sport England’s consideration of this application is the relocation of the existing synthetic turf pitch and the athletics track. It is proposed the STP will be relocated to the John Hampden School, however the new STP is to be located on an existing playing field and therefore there is still a net loss of playing field. This net loss may be remedied as part of the relocation of the athletics track, albeit given the absence of a strategy for the relocation of the athletics track at this stage, I am unable to confirm whether an overall loss of laying field would exist. If, like the STP, the athletics track were to be relocated onto an area of existing playing field, then there would still be a net loss of playing field overall.
With this in mind, Sport England is unable to confirm whether the proposed development at handy Cross is acceptable at this outline stage. The applicant has suggested that a Grampian condition be attached to any consent granted or permission to ensure that redevelopment of the Handy Cross site does not commence until planning permission is in place for the replacement of both the athletics track and synthetic turf pitch.
Given the circumstances, this seems a sensible approach and one Sport England supports subject to seeing the wording of such a planning condition. The condition needs to be written in such a way that it meets relevant tests as set out in Circular 11/95. Sport England requests to see and agree the condition wording in advance. It might be more appropriate to secure the replacement provision via legal agreement. It is also important to emphasise that the disaggregation of the existing sports onto separate sites limits opportunities for cross flow of users from one sport facility to another. As such, in considering the appropriateness of any future proposals for the relocation of the athletics track, it will be important to ensure suitable supporting facilities are available and that the new location creates a viable and appealing destination for sport.
In addition, and whilst Sport England is unable to comment on the detailed mix of facilities to be contained within the new leisure centre, it does have a number of concerns. In particular, Sport England is aware that the existing Sub Aqua facility may not be re- provided as part of the new leisure centre. If this were the case, solutions should be considered in terms of the relocation of this facility. Sport England is also aware that the amateur Swimming Association has commented formally on this application and has raised concerns regarding the level of poolside spectator seating and whether this represents the most efficient use of space. There are also on-going discussions with the Bowls community regarding the bowls re provision that needs to be provided and this discussion is very much live and on- going. All of these issues will need to be adequately addressed at the reserved matters stage.
Whilst Sport England has a number of concerns, it is acknowledged that, at this outline stage, much of the detail has yet to be worked up. Sport England therefore anticipates providing more detailed comments at the reserved matters stage should this application be approved.
Therefore, appropriate mechanisms, in the form of legal agreements and/ or planning conditions need to be put in place to ensure no development can commence until the following information has been submitted and approved:
• details of the layout and facility mix of the new leisure centre; • details of the layout and size of the indoor bowls centre; • details of the location, design and layout of the relocated athletics track and any ancillary facilities; • details of the location, design and layout of the relocated synthetic turf pitch and any ancillary facilities, including floodlighting.
Subject to the above being secured, Sport England raises no objection to this application strictly subject to appropriately worded planning conditions and/ or a legal agreement which requires the above submissions and approvals prior to the commencement of any development.
Clearly, Sport England reserves the right to amend its position to one of objection should it consider that the above items are not adequately and robustly secured through the planning system.
As such, if this application is to be presented to a Planning Committee, we would like to be notified in advance of the publication of any committee agenda(s), report(s) and committee date(s). We would be grateful if you would advise us of the outcome of the application by sending us a copy of the decision notice.
Thames Water Utilities Ltd
No comment received.
Representations The High Wycombe Society We welcome the proposal to replace the ageing sports centre. However, whilst understanding the desire of the Council for additional commercial construction to fund the sports centre construction, we consider the scale of the development proposed to be excessive and likely to overload the highway network, particularly being in mind other upcoming developments in the Southern Quadrant area. We offer the following specific comments.
Sports Centre
We note the phrases ‘promotes healthy living’, ‘provides sports facilities in a new building’ and ‘incorporate the majority of existing uses’ in the D&A statement. Also in the Sports Statement: 1.6 The facility will be smaller than the existing building 1.11 The overall internal area of the leisure centre is proposed to increase from approximately 9,400 sq m (existing GEA) to approximately 10,000 sq m.
Whilst this is only an outline application, and the detail will come later, unnecessary worry and objections will be avoided if the Council make a clear statement that all existing clubs and groups which wish to continue will be provided for in the new sports centre or the nearby amenity building.
Currently a number of sporting activities are located on the Handy Cross sports centre site. This allows advantageous sharing of facilities and also benefits users. For example, parents can deliver their children to the swimming pool and then go for a run. We also understand that swimming clubs regularly use the track for warm-up before competitions. The proposal to relocate the synthetic turf pitch across the road to the John Hampden school retains its nearby but occupies Green Space in conflict with policy DM10 of the upcoming DSA document. Furthermore, figure 8 of that document defines the sport centre site as part of the “Green Infrastructure Network” and hence the major areas of concrete and tarmac will conflict with policy DM10.
Transport Statement
On page 26 is the statement “Red Eagle currently have three buses operating in and around Aylesbury”. Such information, if correct, is irrelevant. However, the following table lists three Red Eagle school services to Marlow Hill so presumably it should have said High Wycombe. That this error occurred and was not corrected reminds us that the document was probably prepared in Aylesbury by someone with no knowledge of the Wycombe District. As such, its contents should be given little weight. Instead, weight should be given to the views of local residents and regular users of the roads in the area, who are aware that the system is at or near capacity and look in horror at the suggestion of a major peak hour destination on the site.
We offer the following detailed comments on specific sections of the Transport Statement:
Car Parking Standard
The existing WDC Parking Standards arise from a policy of previous Government which naively believed that reducing parking spaces would cause owners to give up their cars and travel by bus or bicycle. WDC therefore set “maxima” and routinely allowed developers to provide parking spaces at around 60% of these levels. The result has been for surrounding roads to be swamped with overflow parking to the great inconvenience of existing residents. The policies of the present Government allow WDC to independently set parking standards and this they will do in due course. As an interim measure, announced as part of the RAF Daws Hill Development Brief, WDC are proposing that their current tables of parking requirements should remain but that they should now be regarded as “minima”. Accordingly, the proposals in Jacobs table 2-B (which show parking levels of around 70% of the WDC standard) are no longer acceptable.
Bus Services
The inclusion of school services in table 4-G is misleading as they are not useful as transport for local residents or for the sports centre site. The table then reduces to two lines.
Park & Ride
We consider the present site to be entirely satisfactory. The principal motivation for its relocation seems to be so that the present site can be sold to NEXT.
The present bus route provides services from the P&R site and from the Cressex Business Park to the town centre. The data provided shows that only half of the passengers are attributable to P&R, the remainder to Cressex. The penultimate paragraph on p.37 implies that the proposal is to continue using the current route but extend it to the new coachway. This would seem to be essential if there is to be sufficient patronage to sustain the service. However, the suggestion that this extension would take only 3 minutes (through several sets of traffic lights) seems wishful thinking. The service as originally organised took 22 minutes for the round trip and the 15 minute service frequency could be provided by two vehicles. With the recent extension to include a stop at the rail station, the round trip takes 31 minutes and the frequency has been reduced to 20 minutes (another issue where the transport statement is in error). The proposed extra time would doubtless reduce the frequency to half hourly which would make the service unattractive to many.
Coachway
The original proposal for a coachway arose from the South East Plan which envisaged this as the first of a network of such facilities and would presumably encourage coach companies to establish inter node services. It was anticipated that the building would be funded by the Government. In the event, no money was forthcoming and the South East Plan has now been abandoned.
Whilst there may have been a case for building this with Government funding as part of a larger scheme, we can see no case for proceeding now with council tax payer’s money. If tapping into the coach services from Oxford along the M40 has been seen as viable, a stopping place at the present Park & Ride site could have been cheaply provided. The proposed coachway location is a slightly longer distance from the motorway and would involve two more sets of traffic lights. The likelihood is that, if the coach operators are persuaded to divert, they would operate a service for a few months then, finding that the annoyance to their main customers outweighed the miniscule extra custom, abandon the coachway. Travel to Heathrow is already catered for by the Carousal A40/ 740 service which more conveniently starts from the bus station and picks up at other stops in the town. The Oxford to Stansted service 767 serves Stokenchurch and hence approaches the town along the A40. It also often avoids town centre congestion by leaving along Hamilton Road (towards its next stop at Hemel Hempstead). A diversion to Handy Cross and back would add 10 minutes or more to the journey and be unsustainable. North/ south fast services between Aylesbury and Reading have been tried twice in the past and failed through lack of patronage.
In conclusion, we believe that, if the coachway idea (a bus stop next to a car park) was commercially sound, it would have already been tried using the present P&R site. If successful, then a case for an enlarged site would have merit. Without that, we believe it to be a vanity project and potentially an expensive white elephant.
Offices
We note that reports from commercial estate agents attached to a number of recent planning applications observe that High Wycombe is not seen as an attractive location for offices and that there is a 20 year supply already in existence BUT that a ‘headquarters’ type iconic building adjacent to the Handy Cross roundabout does have marketing potential. Accordingly, we do not object to this part of the proposals, though we support the concerns of the Chiltern Conservation Board concerning height and its effect on the AONB.
We consider the other proposed office blocks to be unnecessary and unwanted.
Supermarket
Whilst a proposal for a small shop to provide services to sports centre users and on- site workers would be reasonable, the proposal for a supermarket three quarters the size of Morrisons is excessive and an inappropriate use of an existing sports facility site. We note that the proposed supermarket car park is significantly larger than required by WDC parking standards, further emphasising that the majority of expected custom will not be associated with other uses of the site. The proposal for the supermarket should be considered on stand-alone merits without pretence that it is primarily to benefit the sports centre users.
National Grid
National Grid is the owner of the Former gas Works site in Lily’s Walk. GL Hearn has submitted a 15 page objection letter to the proposal on behalf of National Grid. The objection letter is detailed and builds a planning case for the refusal of the proposal. The argument is detailed and not easily summarised. The representation can be viewed on line for the full text. The comments are restricted to the policy background to the case and to the sequential test. The conclusions in the letter are as follows:
• The proposed development of the food store as part of the mixed use development is contrary to national and local planning policy. • The office, hotel and leisure facilities are considered to be acceptable in principle at Handy Cross. • There is no policy basis for a food store in this location. • The Council’s policy documents do not anticipate a food store at this location • The Nathaniel Lichfield Retail Study for the Council of March 2012 considers that there is no need to allocate out of centre sites for retail use in the foreseeable future. • The proposal goes against the aims and objectives of the Council to regenerate and direct retail development towards High Wycombe town centre. • The application lacks any justification for the inclusion of a food store in the mix of proposed land uses. • The applicant has failed to demonstrate that the application proposal is the only way of securing the suggested regeneration benefits. • The gas works site is a sequentially preferable site and is suitable, available and viable.
National Grid is keen to ensure that planning decisions taken by the District Council do not prejudice the bringing forward of the Gas Works site for development in the interests of the economy of the town centre and the delivery of key town centre objectives, including new highway infrastructure.
Representations
34 letters received, commenting and objecting on the following grounds;
• the development would result in a substantial increase in traffic in the area, which is already very busy: the level of traffic would be unacceptable; • the increase in traffic and exhaust fumes will have an adverse environmental impact; • there have already been a number of near misses/ accidents on the immediate roads in the area: the situation will worsen; • the traffic, pollution and noise would make life for the Fair Ridge area residents almost intolerable and make car egress from the Fair Ridge area dangerous; • the traffic noise from the surrounding roads is bad: the development would worsen the situation, particularly during the construction period; • the traffic modelling and assumptions are flawed and not all options appear to have been considered; • although a travel plan is proposed, there does not appear to be any enforcement measures to ensure that traffic generation is capped to the levels assessed within the transport assessment; • the park and ride facility will generate a significant increase in the number of traffic movements in what is already a saturated area; • this proposed scheme would exacerbate the issues that have arisen from the high density housing development on land opposite the site; • the school drop off area would not work: parents would drop children off at the entrance to the Spinney estate in order to shorten their journey: a new access road should be introduced to counter this; • any loss of grassed playing fields should, as a matter of policy, be strongly resisted, particularly as school populations are expected to increase, so the need for such fields will increase; • the density of the proposed development is excessive, unsustainable and will create gridlock on the surrounding roads and health problems for the local community; • planning permission has already been refused for a house along Daws Hill Lane, near the motorway, on the grounds of air pollution and houses in Fair Ridge had to be constructed with built-in air-conditioning filters as a condition of planning; • gridlock on Marlow Hill and the surrounding major routes occurs several times each year and this will increase with the massive increase in traffic on Marlow Hill due to the proposed development; • the residents of Fair Ridge, Foxleigh, Spinney and John North Close will become landlocked: traffic from Fair Ridge should be segregated from the traffic entering the new site; • this area is a gateway to High Wycombe: great care needs to be taken with the detail of the design including, in particular, the car parks; • the new development is not environmentally friendly as it entails covering large areas of grass and trees with tarmac and concrete, replacing a large area of playing fields with a synthetic pitch, and digging up uncultivated land in order to lay a replacement running track; • this is clearly a money making scheme • what happed to taking into account the quality of life of the residents opposite the running track? • there is no need for more empty office blocks to be built, or more food halls, or even a hotel; • there would be an adverse effect on property prices; • the Sports Centre proposal, the Daws Hill redevelopment and the Southern Quarter proposals should all be look at in conjunction with each other as they would seriously affect the use of the roads and the residents’ enjoyment of their environment; • the current plans for the redevelopment are quite different to those granted some years ago: the new proposals would have a major impact upon residential access and safety; • the development would result in increased parking on the surrounding residential roads, which would further obstruct emergency services reaching some properties; • the existing parking on the double yellow lines in the area is not enforced; • there would be a loss of established trees; • there would be insufficient parking for the hotel; • there are concerns over the business viability of the scheme; • the planning application has not been remotely thought through: a cursory examination of it shows that it will be to the detriment of the local residential and business communities and the whole town of High Wycombe; • it will not make the town more attractive as a place to invest or live in – it would in fact have the opposite effect; • the opportunity to put in place a first class sports facility in being overshadowed in favour of more offices; • this part of the district is currently an attractive open space: why fill it with offices and a hotel? • demand for the sports club is falling: why is there the need to replace the facilities? • the proposal would represent overdevelopment of the site: it would be overbearing, out of scale and out of character in terms of its appearance compared with the existing sports centre; • additional tree planting should be included in order to help alleviate noise and visual impacts arising from the development; • the introduction of the retail element of the proposal is contrary to existing guidance and the Council’s vision for the redevelopment of Handy Cross; • the proposed mix of uses is inappropriate for in this location: the retail element should be directed to High Wycombe town centre; • the retail element of the proposal will contribute significantly to the adverse impacts that the development will have on the local transport network, as well as impacting on the vitality and viability of the town centre; • the survey data for bats and dormice is not up- to- date and should not therefore be used for to inform a planning decision; • the information regarding the translocated reptiles is incomplete and needs updating; • the scheme is ill- considered in conjunction with the planned re- development of the sports centre.