Classification: OFFICIAL PORep1502 (REDACTED) PART A – YOUR DETAILS
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Page 1 of 45 Classification: OFFICIAL PORep1502 (REDACTED) PART B – RESPONSE
Green Belt Options – Please Provide your Comments The Councils have concluded that land within the Green Belt will need to be released in order to contribute to meeting development needs to 2036. This is despite maximising opportunities on ‘brownfield land’ or sites within the built areas and on previously developed land in the Green Belt.
The Councils have identified 15 preferred options for development in the Green Belt after taking account of views expressed in a consultation earlier this year and testing a full range of options. All of these preferred options if suitable for development will be needed to contribute to our development needs. They are ‘preferred’ options at this stage as work is on-going to test their suitability.
Further testing following this consultation will establish what infrastructure (e.g. highway improvements, schools, medical facilities etc.) will be needed to support the options moving forward taking into account current pressures and circumstances.
We are consulting on these 15 preferred options to: a) Seek views to help determine their suitability for development; b) Help understand views on what type of development should be sought if suitable and what type of requirements (other than infrastructure) should be secured as part of development; c) Enable comments on the draft technical work supporting the selection of the preferred options; and d) Provide the opportunity for alternative options to be put forward.
Evidence and background documents are available here: www.chiltern.gov.uk/planning/localplan2014- 2036/evidence and www.southbucks.gov.uk/planning/localplan2014-2036/evidence.
When commenting please clearly indicate which preferred option(s) you are commenting on.
Please do not provide any personal information you do not want to be made publically available as these comments may be published at a later date.
Please see attached representations and accompanying reports containing our comments on Fourells Paddock, Richings Park, Iver (Site Ref: 4.334). The reports comprise:
Main representations document by Land & Partners Ltd
Sustainable Transport Review by Mayer Brown, including Site Location Plan, Location Plan and Accessibility/Sustainability Plan.
Assessment of Agricultural Use & Quality by Land Research Associates.
Page 2 of 45 Classification: OFFICIAL PORep1502 (REDACTED) Representations by Land and Partners Ltd re: Site 4.334, Fourells Paddock, Richings Park, Iver
South Bucks and Chesham Green Belt Preferred Options Consultation - December 2016
Representations by Land & Partners Ltd with regard to Fourells Paddock, Richings Park, Iver (Site Ref: 4.334).
This document contains the main representations. It should be read in association with two accompanying technical reports:
• Sustainable Transport Review by Mayer Brown, including Site Location Plan, Location Plan and Accessibility/Sustainability Plan.
• Assessment of Agricultural Use & Quality by Land Research Associates.
South Bucks and Chesham Green Belt Preferred Options Consultation December 2016 1 Page 3 of 45 Classification: OFFICIAL PORep1502 (REDACTED) Representations by Land and Partners Ltd re: Site 4.334, Fourells Paddock, Richings Park, Iver
1.0 THE PROMOTED SITE
1.1 Our promoted site is Fourells Paddock, Richings Park at Iver (Green Belt Study Part 2 Ref: 4.334). The site was nominated by way of a Call for Site submission/Regulation 18 consultation (Ref: 667 in the Council’s Summary of Responses – Volume 2 p365). Land and Partners Ltd are now the planning agent for the site. Appendix A contains an oblique aerial photograph.
1.2 The site overlaps with a wider parcel of land in the Green Belt Part 2 Assessment Ref: 1.30 (Area South of Richings Park (Along Richings Way). In the Buckinghamshire Green Belt Assessment Part 1 this wider parcel was identified as a Recommended Sub Area Ref: RSA-31 and the report contains some very strong wording by Arup on how little this RSA contributes to the Green Belt purposes. It specifically states that the RSA is ‘effectively enveloped within the non-Green Belt settlement of Richings Park’. The analysis describes its ‘strong relationship with the settlement edge’ and its ‘severance from the wider countryside’.
1.3 Site 4.334 is a rectangular strip of land in single ownership that covers 3.14 ha. The site is primarily in commercial/hobby use, with a cluster of buildings and hardstanding at the site entrance onto Richings Way and a group of stables on the eastern boundary. Most of the site comprises a number of small paddocks for grazing associated with the stables. The overall appearance and character of the site is ‘urban fringe’. A third of the site non- agricultural and the remaining two-thirds has potential for agriculture but has not been used to grow crops for some considerable time, if at all.
1.4 The site lies in a highly accessible location, close to Iver Rail Station. The station is currently served by local services operated by Great Western Railway and provides direct services to Reading (up 4 an hour) and London Paddington (up to 4 an hour). From December 2019 passengers will be able to travel right through central London on Elizabeth Line services without having to change trains. Overhead electric wires will be installed on the line in preparation for new, electric trains and extensive track and signaling work will improve reliability and increase capacity.
1.5 The station itself will benefit from a number of improvements in preparation for Elizabeth Line services, including a new information system, security systems and lifts. Therefore, it is in precisely the kind of location around a transport node into London that the forthcoming Housing White Paper is expected to favour for potential Green Belt release (as reference in various speeches and interviews by Communities Secretary Sajid Javid over the autumn period).
South Bucks and Chesham Green Belt Preferred Options Consultation December 2016
2 Page 4 of 45 Classification: OFFICIAL PORep1502 (REDACTED) Representations by Land and Partners Ltd re: Site 4.334, Fourells Paddock, Richings Park, Iver
2.0 SUMMARY OF REPRESENTATION
2.1 The representation has three related aspects:
1. The emerging Plan strategy to displace significant amounts of growth out of the District to Aylesbury Vale;
2. A Green Belt assessment process that appears to have been devised to justify this displacement of strategic growth out of the District; and
3. The particular assessment of the promoted Green Belt Site 4.334 which does not fairly and accurately assess its development potential.
2.2 With regard to the assessment of the potential of the site for development, there are three main problems with the Council’s assessment, as set out in the Green Belt Preferred Options Consultation and draft technical work.
Accessibility
2.3 Firstly, the accessibility of the site to a rail station has not been given sufficient weight. Option J of the Issues and Options consultation considered sustainable growth options in the Green Belt close to rail stations. However, the limitation in the Green Belt Review of just 400m radius around rail stations is grossly inadequate. The Council’s own Sustainability Appraisal quotes a distance of 1km. Within the assessment Sustainability Appraisal objective 9 it states the following:
“For the purpose of this assessment, in line with Barton (Barton et al,2010), 400m is the recommended distance for travelling to a bus stop, and 1km is used for train stations. 800m is recommended the distance given by Barton for trams and it is assumed that people would travel further for a train station.
2.4 It is assumed that bus stops correspond with low magnitude as impact is likely to be short term, and at a local scale. Train stations are assumed to correspond with medium magnitude as impact is likely to be long term, and at a regional scale.”
2.5 We have commissioned a Sustainable Transport Review of the form of Technical Note by the multi-disciplinary consultants Mayer Brown. The 650m walking distance from the site to Iver rail station is considered to be in the acceptable category and very close to desirable. This demonstrates a fundamental weakness in the Council’s draft technical work; the areas of search based on rail stations has not been sufficient.
Agricultural Land
2.6 The Green Belt Review does not consider the individual site of Fourells Paddock, Richings Park at Iver (Ref: 4.334). Instead it only considers the wider site of 1.30 (Area South of Richings Park (Along Richings Way), which was RSA-31 in the Part 1 Study. As set out in
South Bucks and Chesham Green Belt Preferred Options Consultation December 2016
3 Page 5 of 45 Classification: OFFICIAL PORep1502 (REDACTED) Representations by Land and Partners Ltd re: Site 4.334, Fourells Paddock, Richings Park, Iver more detail below, the failure to consider the sub-division of RSA-31/Site 1.30, as required by the agreed Green Belt methodology, is a serious failing.
2.7 We have assessed Site 4.334 in terms of its agricultural land quality (see accompanying report). This shows that the site is not Grade 1 it is Grade 3a, which is an entirely normal scoring for land in this area.
2.8 The sustainability appraisal of the Chilterns and South Bucks Local Plan (January 2016) states that the Search Area in general is part of an area of grade 1 agricultural land. This statement is based on very low resolution obsolete mapping which is not appropriate for the appraisal of individual sites. The whole basis of the Green Belt Development Options Appraisal (October 2016) is consequently wrong. This states that the specific site Ref: 1.30 is unsuitable for development, with the assessment summary stating ‘Grade 1 agricultural land’. All these reports should be urgently reviewed and updated with the correct information.
Potential for Green Belt boundary
2.9 Site 4.334 is almost completely enclosed by the curtilages of existing housing, save for part of the eastern boundary forming a countryside edge. However, a tall, mature hedgeline in this location forms a strong, clear barrier here. Moreover, whilst a small part of site 4.334 abuts the countryside, this surrounding countryside fall within a Recommended Sub-Area of the Buckinghamshire Green Belt Assessment Part 1. This is the Area South of Richings Park (Along Richings Way) (RSA-31). In the Part 2 Study RSA-31 has an Assessed Ref of 1.30. The Part 1 Study contains some very strong wording by Arup on how little this sub- area contributes to the Green Belt purposes. It specifically states that the sub-area is ‘effectively enveloped within the non-Green Belt settlement of Richings Park’. The analysis describes its ‘strong relationship with the settlement edge’ and its ‘severance from the wider countryside’.
2.10 Surprisingly, the wider sub-area (1.30) nor even the smaller promoted parcel (4.334) progressed past Stage 1 of the Part 2 Green Belt Study. This means they were not considered to have boundary features which had the potential to be permanent and recognisable. Yet parcel 4.334 has a tall, mature hedgeline in this location which forms a strong, clear barrier on the only boundary exposed to the countryside. And whilst not as strong, the outer countryside edge of 1.30 is defined by major roads and field boundaries with normal agricultural hedgerows. The remaining boundaries are defined by the curtilages of established housing, which is one of the most permanent and recognisable features that it is possible to have!
2.11 We have reviewed various recent Part 2 Green Belt assessments by other Local Authorities and have found that the South Buck and Chesham approach to the permanence of boundaries to be at odds with these. The other studies do not rule out established hedgerows and tree-belts when considering whether a boundary is permanent and defensible in accordance with NPPF requirements.
South Bucks and Chesham Green Belt Preferred Options Consultation December 2016
4 Page 6 of 45 Classification: OFFICIAL PORep1502 (REDACTED) Representations by Land and Partners Ltd re: Site 4.334, Fourells Paddock, Richings Park, Iver
2.12 The potential boundary assessment methodology set out in Paragraphs 3.3 to 3.6 of the Part 2 Green Belt study does not reflect good practice in establishing Green Belt boundaries. In the case of hedgerows (and woodland) it arbitrarily states these should be already ‘protected’. This misunderstands the nature of Green Belt boundaries; the requirement is for physical features that are readily recognizable and ‘likely to be permanent’. There is nothing in the NPPF or PPG to suggest that existing protection is required for hedgerow to qualify as a readily recognisable physical feature which is likely to be permanent once it has been defined as a Green Belt edge.
2.13 Furthermore, as a ‘Category 3’ weakly performing sub-area in the Part 1 Green Belt Study, the site has, by definition, already been assessed as having clear scope for sub- division. The categorisation already takes account of the presence of boundary features which have the potential to be permanent and recognisable (see paragraph 6.1.2 of the Part 1 Study).
“Category 3: Medium or strongly scoring General Areas where there is clear scope for sub-division to identify weakly performing ‘sub-areas’, including the presence of boundary features which have the potential to be permanent and recognisable”.
2.14 In any event, it is reasonable to expect the Councils to look at the different parts of the sub-area for potential Green Belt release rather than assess it only as one indivisible parcel, particularly where it would otherwise fail on a boundary definition point.
2.15 The whole methodology appears to have been devised on a linear, staged, tick-box approach, in which if it does not pass a stage early on the site is rejected. Instead, the potential sites should have been assessed ‘in the round’, with existence of unprotected hedges and woodland being a factor to be taken into account, not causing a site to be automatically ruled out. For example, where sites are very well enclosed on three sides by development, the fact that the fourth edge is not currently protected should not be fatal to the assessment.
2.16 In summary, the reasons for the site not progressing beyond Stage 1 of the Part 2 Green Belt Study are not considered to be at all satisfactory. And as the site has been assessed in the Part 1 Study as likely to have a very weak Green Belt purpose, in all probability it would have passed Stage 2 and 3 of the Part 2 Study had the suitability of its boundaries been correctly assessed.
3.0 THE EMERGING PLAN STRATEGY – OVERVIEW OF OBJECTION
3.1 The Preferred Options are based on an emerging spatial strategy that is not sound having regard to the context and needs of the District. In particular, the proposed location of housing is not sound having regard to local needs and constraints and the requirements of national policy.
3.2 The fundamental failing is to not give sufficient weight to the need to promote sustainable patterns of development and in particular to consider the adverse South Bucks and Chesham Green Belt Preferred Options Consultation December 2016
5 Page 7 of 45 Classification: OFFICIAL PORep1502 (REDACTED) Representations by Land and Partners Ltd re: Site 4.334, Fourells Paddock, Richings Park, Iver consequences for sustainable development of channelling development towards locations beyond the outer Green Belt boundary (Paragraph 84 of the NPPF).
3.3 The strategy claims to prioritise meeting housing needs within the Plan area. However, in flat contradiction to this precept, it is then proposed that much of the housing needs will not be met within the Plan area, requiring Aylesbury Vale District to absorb the overspill. The need for the housing relates to the District therefore displacing it to another Local Authority is less sustainable in terms of travel patterns and infrastructure provision. It will inevitably lead to unnecessary in-commuting from Aylesbury Vale.
3.4 Moreover, the strategic locations for growth within Aylesbury Vale to potentially accommodate this unmet need is some considerable distance from the Plan area. It does not lie just beyond the administrative boundary, as is often the case with cross-boundary planning; Wycombe District lies to the west, which also has its own shortfall. So essentially the unmet need must leap-frog the Green Belt and be located further north where there is scope for an urban extension or new settlement in Aylesbury Vale District. This conflicts with paragraph 84 of the NPPF which provides clear advice to decision makers to take into account the consequences for sustainable development of any review of green belt boundaries. As part of that patterns of development and additional travel are clearly relevant.
3.5 An additional concern is whether this growth is deliverable, given that Aylesbury Vale District has not committed to receiving it. The Councils must establish, in collaboration with neighbouring local planning authorities, whether its unmet need can be met across the wider housing market areas, as required by paragraph 179 of the Framework. The Memorandum of understanding with Aylesbury Vale District falls short of establishing the amount of housing that will be received. Indeed, as revised by the ‘addendum’ of January 2016 to add South Buckinghamshire it is a peculiar document indeed, as it merely states the fact of South Buckinghamshire being added, but then adds no substantive text under the headings of the 2015 Memorandum relating to it so as to illuminate its interrelationship with the other Councils.
3.6 It is widely expected that the Housing White Paper in January will put much greater emphasis on redefinition of Green Belt boundaries around transport hubs and to allow release of Green Belt in accessible locations in return for compensatory Green Belt designation in less accessible locations. Communities Secretary Sajid Javid has been referencing such possible changes in national policies in various speeches and interviews therefore the strategy of the Plan should be fundamentally re-examined once the Housing White Paper is issued.
4.0 THE DUTY TO CO-OPERATE – CURRENT CONCERNS
Introduction
4.1 There are currently considerable doubts as to whether the Councils are going to be able to discharge their Duty to Co-operate with other Local Planning Authorities adequately. South Bucks and Chesham Green Belt Preferred Options Consultation December 2016
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Obviously there is some way to go until the Plan is submitted for examination, but having regard to the Planning Practice Guidance (“PPG”) there is evidence that the co-operation is not maximising the effectiveness of policies for strategic cross boundary matters (see in particular Paragraph: 002 Reference ID: 9-002-20140306 and Paragraph: 018 Reference ID: 9-018-20140306).
The Memorandum of Understanding
4.2 There were indications that at a very early stage that Aylesbury Vale District Council was contemplating making a generous provision to offset the unmet need from the surrounding Local Planning Authorities in Buckinghamshire. This was on the basis that they were located in the ‘relatively unconstrained part of the HMA lying outside the Green Belt and the Area of Outstanding Natural Beauty (AONB)’ as indicated in the Memorandum of Understanding signed June 2015. However, this agreement was made before the draft HELAA or HEDNA was available, nor any up-to-date assessment of the Green Belt or the AONB undertaken. It was used as the basis for the wording of the VALP Issues and Options Consultation Document (October 2015) – again, before the technical work such as the Part 1 Green Belt Review had reported.
4.3 The wording in the Memorandum pre-dates the inclusion of South Bucks in the Strategic HMA, who were only added as a signatory in January 2016. Its functional links are closer to the HMA to the south (Reading and Slough HMA) than they are to Aylesbury Vale District, from which it is separated by Chiltern and Wycombe. The original HMA study proposed a hierarchy for the “best fit” for South Bucks supported by the data on both commuting and migration flows; with the first preference being London, the second being Berkshire and the third being with the rest of Buckinghamshire (see para 6 of ‘HMAs and FEMAs in Buckinghamshire: The Impact of a Joint Plan for Chiltern and South Bucks’ (January 2016). This further weakens the case for transferring growth from the Plan area to Aylesbury Vale.
4.4 Therefore, when the Memorandum was drawn up the relevant technical work was not in place to determine whether the Green Belt or AONB should act as a constraint on meeting the housing requirement within the individual Districts. And the Memorandum of Understanding clearly says that ‘..the housing need within each HMA will first fall to be met within each Councils area based on needs of each individual district, but if that is not possible then the need should be met elsewhere within the HMA’. It is also stated, as an axiom, in the first paragraph of the 2015 memorandum under the heading ‘Introduction and Context’ that ‘collective development needs are (to be) planned for in the most sustainable ways.’ (emphasis added). Plainly it would score poorly in sustainability terms if development to meet needs in South Buckinghamshire’s district were to be leap-frogged beyond Wycombe and into Aylesbury. The sustainability deficit would of course principally arise in terms of transportation and commuting issues.
4.5 The current Green Belt Preferred Options Consultation is the first time that any comprehensive evidence has been put forward touching upon the issue of whether it is indeed demonstrable, rather than being a convenient assumption, that Chiltern and South Bucks cannot accommodate their own housing needs. It is an important step in the Plan South Bucks and Chesham Green Belt Preferred Options Consultation December 2016
7 Page 9 of 45 Classification: OFFICIAL PORep1502 (REDACTED) Representations by Land and Partners Ltd re: Site 4.334, Fourells Paddock, Richings Park, Iver making process as for the first time the Councils are setting out a case for a strategy that was formulated at the start of the Plan making process.
The role of Aylesbury Vale District Council
4.6 Paragraph 1.2 of the current Preferred Option Consultation Document states that the Councils ‘have been in discussions to explore the potential’ for the displacement of unmet need to Aylesbury Vale District but that the agreement in principle to do this is ‘subject to further evidence to justify the amount of development and the Vale of Aylesbury Local Plan being able to identify sufficient capacity’.
4.7 The VALP Draft Plan for Summer 2016 Consultation notes in paragraph 1.13 that the Council “..will be robustly challenging the level of unmet need, but this draft local plan has to be based on this requirement as a worst case scenario.” It is instructive that many of the settlements identified for growth had a shortfall between the target number and the amount of capacity identified through the HELAA. AVDC’s stance of robustly challenging patently supersedes any historic indications of lenient accommodation and creates an imperative if conflict between it and the other three authorities is to be avoided that they do their utmost to achieve the fullest measure of provision within their own boundaries. In turn this renders it imperative that they do not reject the release of appropriate sites from Green Belt owing to the application of excessively stringent or mistaken criteria.
4.8 The Vale of Aylesbury Local Plan Scrutiny Committee of 7 November 2016 presented a report on the Draft VALP responses, progress and unmet need. Aylesbury Vale Members sought clarification and made comments on how the proposals would affect the areas ‘struggling to find capacity’. Members were also concerned that a number of sites had been reviewed in Chiltern and South Bucks but were still not being put forward for inclusion as potential sites. Members felt that in comparison the infrastructure in the south of the County was far superior to AVDC’s. It was resolved that officers should summarise the main issues to be addressed and the main points of the GL Hearn reports, and bring their conclusions back to the next meeting of the VALP Scrutiny Committee on 19 December 2016. This suggests that there is a considerable way to go on a firm commitment to accommodate the unmet need, before the AVDC Plan is projected to be submitted in June 2017.
Conclusions on the Duty to Co-operate
4.9 The Councils are at Preferred Option stage without having yet achieved a satisfactorily resolution of their strategic cross boundary matters. Thus they are relying on circumstances beyond their control to deliver the strategy of the Plan. This predicament is increased because the imperative for Plan delivery is against a very tight timetable, as specified by Central Government.
4.10 There does not appear to be a firm basis for concluding that Aylesbury District can take the Chiltern and South Bucks unmet need in the amounts envisaged by them. Unlike Wycombe, who have recently radically cut back their unmet need figure, the Green Belt Preferred Options position of Chiltern and South Bucks District Councils is that an unmet South Bucks and Chesham Green Belt Preferred Options Consultation December 2016
8 Page 10 of 45 Classification: OFFICIAL PORep1502 (REDACTED) Representations by Land and Partners Ltd re: Site 4.334, Fourells Paddock, Richings Park, Iver housing need of 5,800 dwellings be displaced to Aylesbury Vale District. So the whole strategy of the Chiltern and South Bucks Plan as presented in this Preferred Options consultation depends upon: a) Chiltern and South Bucks showing it is not possible to accommodate needs within their Plan area; and b) Aylesbury Vale District showing that it is willing and able to accommodate the unmet needs within its Plan area.
4.11 Neither of these two elements are yet in place. Whilst there is general agreement in principle for Aylesbury Vale District to take unmet needs, this is subject to the Vale of Aylesbury Local Plan (VALP) being able to identify sufficient capacity in the form of suitable and deliverable sites, which it has not yet done.
4.12 Even if this can be demonstrated, Aylesbury Vale District Council is only likely to be willing to take the unmet needs if it is convinced that Chiltern and South Bucks District Councils have proven they genuinely cannot accommodate their own needs within their Plan area. As will be seen from the representations below, there are reasonable alternatives available to the Councils which provide a more appropriate strategy that deals with the need where it is generated. To reiterate, the Councils should make all possible efforts to meet their needs within their own boundaries and should not apply disproportionately stringent criteria in order to turn away sites capable of contributing to the meeting of the needs.
5.0 SOUNDNESS – CURRENT CONCERNS
Whether the Plan is positively prepared and effective
5.1 There is an interrelationship between the tests of a Plan’s “soundness” and the Duty to Co-operate as noted in Paragraph: 002 Reference ID: 9-002-20140306 of the PPG. This states that ‘In assessing whether the Local Plan is effective the Inspector will assess whether it is deliverable within the timescale set by the Local Plan and if it demonstrates effective joint working to meet cross boundary strategic priorities’.
5.2 As noted under the Duty to Co-operate section above, the whole strategy of the Plan is predicated on a large displacement of unmet need into a Local Planning Authority (Aylesbury Vale District Council) that has not yet confirmed if it is willing and able to receive it. Clearly, the effectiveness of the Plan is in some doubt and it will fail the test of soundness if this joint working does not succeed and the housing requirement is not deliverable. Whilst is the Duty to Cooperate does not impose a duty to agree, the lack of agreement would bring down the strategy of the South Bucks and Chiltern Plan.
South Bucks and Chesham Green Belt Preferred Options Consultation December 2016
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Whether the strategy of the Plan is justified
5.3 The focus of this representation is on the justification for the displacement of the unmet need, instead of meeting the needs within the Local Authority Area. Paragraph 182 of the NPPF states that the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence.
Background
5.4 Paragraph 84 of the NPPF is clear that when reviewing Green Belt boundaries local planning authorities should take account of the need to promote sustainable patterns of development. They should consider the consequences for sustainable development of channeling development towards locations beyond the outer Green Belt boundary. IM Properties Development Ltd v Lichfield DC [2014] EWHC 2440 (Admin) states [98] that NPPF paragraph 84 “is clear advice to decision makers to take into account the consequences for sustainable development of any review of green belt boundaries. As part of that patterns of development and additional travel are clearly relevant.”
5.5 The IM Properties case also provided [96] a useful summary of the Gallagher Homes Ltd v Solihull Borough Council [2014] EWHC 1283 (Admin) case, worded as follows:
“What is clear from the principles distilled in the case of Gallagher is that for revisions to the green belt to be made exceptional circumstances have to be demonstrated. Whether they have been is a matter of planning judgment in a local plan exercise ultimately for the inspector. It is of note that in setting out the principles in Gallagher there is no reference to a falsification doctrine [that the basis on which land was excluded from the Green Belt has been falsified] or that any release of green belt land has to be seen as a last resort.”
5.6 The Gallagher case confirmed that the test for redefining a Green Belt boundary has not been changed by the NPPF. National guidance has always dealt with revisions of the Green Belt in the context of reviews of local plans (e.g. paragraph 2.7 of PPG2: paragraph 83 above), and has always required "exceptional circumstances" to justify a revision. The NPPF makes no change to this. It should be noted, of course, that it has been judicially recognized that the bar set by the ‘exceptional circumstances’ criterion is not as high as the ‘very special circumstances’ test restricting development in Green Belt where the question of a change to its boundaries is not in play. Lack of a Full OAN is patently an exceptional circumstance justifying boundary changes and all of the Plan proposals being advanced by the four central/south Buckinghamshire Councils are predicated on that understanding.
The lack of justification for accommodating unmet need in Aylesbury Vale District
5.7 The Memorandum of Understanding, prepared with the other Buckinghamshire HMA Local Authorities, states that the housing need within each HMA will first fall to be met within each Council’s area based on needs of each individual district, but if that is not possible then the need should be met elsewhere within the HMA. Therefore, there is a presumption in favour of meeting needs within the Local Planning Authority Area. Clearly South Bucks and Chesham Green Belt Preferred Options Consultation December 2016
10 Page 12 of 45 Classification: OFFICIAL PORep1502 (REDACTED) Representations by Land and Partners Ltd re: Site 4.334, Fourells Paddock, Richings Park, Iver there are good reasons for this; the need is likely to be met closest to where it is being generated so it is likely to result in the most sustainable travel patterns.
5.8 Sometimes a City or large town is constrained by its administrative boundaries and the most sustainable option is for new sustainable urban extensions to cross into the adjacent Local Planning Authority. This is clearly the case within Oxfordshire and Cambridgeshire, where the needs of the City are having to be met within the surrounding Local Authorities. Moreover, these Cities have their own Green Belt and in most cases the Local Authorities are proposing to cut the Green Belt close to the City rather than allowing the growth generated from the City to leapfrog into a more remote location. The obvious problem with putting the growth into a more remote location is that the many of the new residents will wish to commute to where the jobs are and the transport infrastructure may not be able to cope.
5.9 Buckinghamshire is not an obvious candidate for the displacement of large amounts of unmet need across Local Authority boundaries. It does not have a dominant urban centre like Oxfordshire and Cambridgeshire which needs to spill over administrative boundaries in order to ensure houses are sustainably located close to jobs. Rather the reverse; like Berkshire it is an elongated polycentric authority and the London Metropolitan Green Belt covers a significant proportion of the more urbanised ‘inner’ section in contrast to the more traditional rural settlement pattern and transport infrastructure of the ‘outer’ section of the County. The geography of the County does not support moving large amounts of housing need across administrative boundaries. The ‘inner’ section of the Housing Market Area is clearly subject to the Greater London Housing Market where the availability of jobs is a major factor driving household growth. In these circumstances, putting houses close to major transport nodes into London is the obvious sustainable strategy.
5.10 It is perhaps worth noting that no other London Metropolitan Green Belt authorities are proposing to send their unmet need long distances to the edge of other settlements in the outer, more rural parts of their HMA. Either they have accepted the inevitability of housing needs being met close to and/or very accessible to where the need is being generated or they are found to be heading for unsoundness unless they withdraw the Plan. For example, Windsor and Maidenhead have recently issued their Draft Local Plan. They are in a very similar geographical location to South Bucks and Chiltern in respect of the location within the Metropolitan Green Belt. Yet there is no question of them trying to displace a significant chunk of their housing requirement some distance into the rest of of Berkshire; nor are there any Berkshire non-Green Belt authorities offering to take it.
5.11 In the circumstances, the emerging strategy of the Buckinghamshire authorities is looking increasingly as if it has been fundamentally misconceived. The Memorandum of Understanding has provided a political justification for redistributing some considerable distance the new households that are projected to form, principally in order to ‘save’ Green Belt and AONB. This decision appears to have been made very early into the Plan process, and effectively prematurely, i.e. before the technical evidence had been assembled as to whether the growth could more sustainably be met by cutting Green Belt and finding major growth opportunities in AONB. The evidence for this is the wording of the VALP Issues and Options Consultation Document in October 2015. This stated: South Bucks and Chesham Green Belt Preferred Options Consultation December 2016
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“Environmental constraints
2.5. Constraints like Green Belt or AONB designation mean some areas cannot accommodate all of their need within their areas. The Government has stated that such unmet need should be met in less constrained parts of the HMA or outside the HMA, if capacity cannot be found within it. In relation to the HMA, which covers Aylesbury Vale, it is unlikely that the other districts of Wycombe and Chiltern will be able to meet all their housing and/or employment need, so their unmet need will have to be accommodated in Aylesbury Vale.”
5.12 This paragraph misrepresents the Government’s position on environmental constraints. The ‘Positively prepared’ aspect of the soundness test in paragraph 82 of the NPPF is that the Plan strategy should meet unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development. Furthermore, when paragraph 179 of the NPPF requires joint working from local authorities to meet development requirements which cannot wholly be met within their own areas the examples given are:
a) a lack of physical capacity in their own areas; and
b) to meet it in their own areas would cause significant harm to the principles and policies of this Framework.
5.13 With regard to physical capacity, there are many cities and towns like Oxford, Cambridge, Luton, Stevenage, Slough, Harlow where their administrative boundaries are so tightly drawn that they do not have sufficient space to sustainably grow without crossing administrative boundaries or major physical features like rivers and associated floodplains. The Chiltern and South Bucks Plan area is clearly not in that situation. It is only existing policy constraints that are preventing growth, not physical constraints.
5.14 With regard to the significant harm to the principles and policies of the NPPF, this is something that can only be assessed through detailed technical work then the careful weighing up of competing options. It is not something that can be asserted in advance of this, as the Councils have effectively been doing.
5.15 Now that the Green Belt Preferred Options Consultation has been issued, the strength of its case can be assessed with regard to how accommodating the growth within the Plan area would cause significant harm to the principles and policies of the NPPF and displacing the growth to Aylesbury Vale instead would be reasonable and consistent with achieving sustainable development. In particular, whether – in accordance with the Memorandum of Understanding –it is simply ‘not possible’ to meet housing needs within the Plan area.
5.16 Paragraph 1.2 of the Green Belt Preferred Options Consultation states that the 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 and Chesham Green Belt Preferred Options Consultation December 2016
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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”. This view is based on evidence reports that include the draft Housing and Employment Land Availability Assessment (HELAA), Buckinghamshire Green Belt Assessment Part 1, draft Green Belt Assessment Part 2 and Green Belt Development Options Appraisal report. These will be commented on in turn.
6.0 TECHNICAL REPORTS
Buckinghamshire Green Belt Assessment Part 1 (March 2016)
6.1 The Part One report explains that the areas tend to be concentrated in the south and east of the county as a result of settlement growth and piecemeal development in rural areas which has fragmented the countryside, creating small, isolated areas of Green Belt which tend to make little contribution to the integrity of the wider Metropolitan Green Belt and contribute weakly to NPPF purposes. Our site falls within such a small, isolated area of Green Belt as a result of the 20th Century suburban growth of Richings Park which has fragmented the countryside in this location.
6.2 We note an intrinsic weakness of a study as geographically extensive as Arup’s that the large size of the general areas identified (the boundaries of which must inevitably be arbitrary to a degree) will mask the fact that small sub areas within them will perform radically differently in terms of the 5 criteria adopted (based on the first 4 Green Belt Purposes) than does the General Area as a whole. Thus the very methodology contrives simultaneously to conceal and also to militate against the identification as suitable for release of smaller sites.
6.3 Our promoted site lies within a Recommended Sub-Area from the Buckinghamshire Green Belt Assessment Part 1 (RSA-31). The wider General Area that was assessed is Ref: 99. The Parcel Proforma description specifically states that the land parcel “wraps around Richings Park”.
6.4 Clearly the parcel has a purpose in checking the unrestricted sprawl of a large built- up area (Green Belt Purpose 1) as it sits on the eastern edge of the large built-up area of Burnham / Slough. However, there are already major barriers between this built-up are and London in the form of the M25, and the wider countryside in terms of the M4. Hence a score of 3/5 is appropriate.
6.5 However, with regard to preventing neighbouring towns from merging (Green Belt Purpose 2) the wording states that “Despite the overall importance of this parcel for preventing the merging of settlements, as a result of the configuration of the parcel, the south-eastern area plays a lesser role with respect to preventing coalescence”. This is referring directly to the part of the land parcel that is wrapped around by Richings Park. A score of 5/5 is clearly an error here as this reduced purpose leads to a Recommended Sub Area for possible release.
South Bucks and Chesham Green Belt Preferred Options Consultation December 2016
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6.6 With regard to assisting in safeguarding the countryside from encroachment (Green Belt Purpose 3) the wording states that “..the configuration of development on the south side of Richings Park is such that substantial areas of open land feel enclosed and severed from the wider countryside. The M4 to the south reduces this connectivity further”. Hence a score of 3/5 is appropriate.
6.7 Purpose 4 (To preserved the setting and special character of historic towns) scores 0 as the parcel does not directly abut an identified historic core and does not meet this Purpose.
6.8 Overall, we believe General Area 99 should have a score of 9/20 rather than 11/20. This means that the overall score should be medium not strong, with scoring moderately (3) against at least one purpose and failing to score strongly against any purpose.
6.9 Nevertheless, we support the identification of Recommended Sub Area RSA-31 (South of Richings Park (Along Richings Way) within General Area 99, which is taken forward in the Part 2 Study with the Ref 1.30.
6.10 In Arup’s Summary Assessment Pro-Formas (Table) dated 15th January 2016, for General Area 99 under the heading ‘Recommended for further General consideration?’ it states ‘Yes (area bounded by Richings Park, Old Slade Lane and Poynings Way). It is described in the main Part 1 report as a small identified area in the eastern half of the General Area. Paragraphs 6.4.66 and 6.4.67 note that despite the strategic importance of General Area 99 in checking the unrestricted sprawl of large built-up areas (Burnham/Slough), preventing neighbouring towns merging into one another and the coalescence of settlements (including with West Drayton in Greater London), the sub-area itself may contribute weakly to the NPPF purposes and should be considered further.
6.11 A number of reasons are given for why the sub-area may score weakly and could be considered further:
• The area is effectively enveloped within the non-Green Belt settlement of Richings Park. In isolation, this sub-area makes little contribution to the separation of Richings Park from West Drayton to the east, or Slough to the west and would not contribute to Purpose 1 or 2.
• As a result of its severance from the wider countryside and strong relationship with the settlement edge, has the potential to score weakly against Purpose 3.
• The area does not score at all against Purpose 4.
6.12 It should be noted that as a ‘Category 3’ weakly performing sub-area, the site has already been assessed as having clear scope for sub-division. This categorisation already takes account of the presence of boundary features which have the potential to be permanent and recognizable (see paragraph 6.1.2 of the Part 1 Study).
South Bucks and Chesham Green Belt Preferred Options Consultation December 2016
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“Category 3: Medium or strongly scoring General Areas where there is clear scope for sub- division to identify weakly performing ‘sub-areas’, including the presence of boundary features which have the potential to be permanent and recognisable”.
Draft Green Belt Assessment Part 2 (October 2016)
6.13 The report was not undertaken by independent consultants on behalf of the wider HMA. It was undertaken in-house by the Councils and applies further tests to the area identified in the Green Belt Assessment Part 1 as well as other options and sites. We have serious concerns about the standard of this draft work and whether it has been carried out rigorously and robustly. As it stands, the emerging strategy of the Plan is not considered to be sufficiently evidence-based as required by paragraphs 150-185 of the NPPF.
6.14 The Part 1 Study made clear that its role was to objectively examine the performance of the Green Belt against the purposes set out in the NPPF and to recommend General Areas which perform weakly as well as sub-areas that are likely to perform weakly if considered separately. The premise for the latter was that suitable defensible boundary features can be identified to enclose such areas (paragraph 7.1.3). Essentially the role of the Part 2 Study was to undertake more detailed assessment to determine the appropriateness and feasibility of any adjustments to the Green Belt boundary and whether, in accordance with the NPPF, there are any ‘exceptional circumstances’ that justify the alteration of the Green Belt boundary through the preparation of new local plans. As noted above, the required level of detail has not been achieved. Rather, the exercise appears to bear the hallmarks of the traditional, pre-NPPF, LPA approach of seeking to reject as many sites as possible regardless of the exceptional circumstances represented by the acknowledged OAN deficiency.
6.15 Essentially, the boundary assessment of Site 1.30 in the Part 2 Study has been incorrectly carried out. It states (our emphasis:
“It is not possible to identify a boundary that is permanent and defensible in accordance with NPPF requirements. To the east is the M25, which would be a permanent and defensible boundary. To the north is Richings Way which would also meet NPPF requirements. The western boundary would be formed by the rear of back gardens on Old Slade Lane; and the southern boundary by the rear of back gardens on the Poynings and the line of a drain. Neither the western or southern boundaries would meet NPPF requirements.”
6.16 The exclusion of the back gardens of a settlement edge is simply wrong. The Draft Green Belt Assessment Part 2 Methodology (July 2016) was issued on behalf of all The Buckinghamshire Councils. Paragraph 1.5 explains that the methodology identifies how Part 2 of the Green Belt assessment will assess the ‘general areas’ and ‘sub-parcel areas’ that have been identified in Part 1 of the assessment as warranting further consideration for potential removal from the Green Belt. Paragraph 3.6 specifically includes existing development with strongly established, regular or consistent boundaries.
South Bucks and Chesham Green Belt Preferred Options Consultation December 2016
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6.17 A key point is the identification of the RSA in the Part 1 Study involved consideration of whether it would be possible to define a revised Green Belt boundary that is permanent and defensible in accordance with NPPF requirements. RSA-31 is a ‘Category 3’ weakly performing sub-area which has already been assessed as having clear scope for sub-division. This categorisation already takes account of the presence of boundary features which have the potential to be permanent and recognizable (see paragraph 6.1.2 of the Part 1 Study).
6.18 The particular wording of the Part 1 Study is very clear about how well enclosed the site is from the surrounding countryside. It specifically states that the area is effectively enveloped within the non-Green Belt settlement of Richings Park. Richings Park wraps around the sub-area to the south, to visually enclose most of it from long distance views. The analysis describes its ‘severance from the wider countryside’ and ‘strong relationship with the settlement edge’. The edge of this parcel is defined by residential curtilages, roads and a short stretch of a standard field boundary to round it off.
6.19 There Is nothing in the NPPF or PPG to suggest that a settlement edge is not an appropriate Green Belt boundary. Paragraph 85 of the NPPF states that when defining boundaries, local planning authorities should define boundaries clearly, using physical features that are readily recognisable and likely to be permanent. They should also not include land which it is unnecessary to keep permanently open.
6.20 With regard to the southern edge of RSA-31/Site 1.30 which is not bounded by development or road (the short stretch of agricultural field boundary that rounds off the whole parcel), our view is that this needs to be considered in context of the weakness of the parcel as a whole in terms of Green Belt purpose and the lack of justification to keep this permanently open. We note that there is considerable flexibility on this point with some of the parcels that have been recommended for Green Belt release having some agricultural field boundaries justified by the overall assessment (see comments below).
6.21 In addition, our view is that the potential boundary assessment methodology set out in Paragraphs 3.3 to 3.6 of the Part 2 Green Belt study does not reflect good practice in establishing Green Belt boundaries. In the case of woodland and hedgerows it arbitrarily states these should be ‘protected’. This misunderstands the nature of Green Belt boundaries; the requirement in the NPPF is for physical features that are readily recognisable and ‘likely to be permanent’. There Is nothing in the NPPF or PPG to suggest that existing protection is required for hedgerow or woodland to qualify as a readily recognisable physical feature which is likely to be permanent when defined as a Green Belt edge.
6.22 Our promoted site Ref. 4.334 has an even stronger case than the wider Recommended Sub Area and we cannot understand how the Part 2 Study fails to notice its potential for sub-division. There is no wording at all about this land even though it has been separately promoted and does not completely overlap the wider Recommended Sub Area. Site 4.334 itself has particularly strong, established landscaped boundary, but the Part 2 Study has simply considered the whole sub-area rather than looking properly at site 4.334 and the strength of its individual boundary. This is contrary to the Council’s own Part 2 methodology (Para 2.3 of the Part 2 Study) which says that each area of land has been South Bucks and Chesham Green Belt Preferred Options Consultation December 2016
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6.23 Site 4.334 is bounded to the north and west by the settlement edge of Richings Park and to the south by extended domestic gardens that are likely to be excluded from the Green Belt when the detailed boundaries are reviewed. The north eastern part of the site is also bounded by the settlement edge, with large domestic properties in generous, deep curtilages running for more than half its length. Because of this arrangement, there only needs to be a short stretch of new Green Belt boundary which will run along the eastern edge of the site. this is formed by a very strong landscaped edge in the form of a mature tree belt. It is a physical feature forms a clear distinction between the non-agricultural land within the site and the open countryside beyond.
6.24 The site has not been in agricultural use for considerable time (at least 17 years), and there is evidence to suggest it may never have been used as cropland under modern agriculture (see our accompanying report on agricultural land quality). The current use of the site is as a hobby and domestic use with an urban fringe character. There are buildings and trees scattered across the site. There is a clear contrast in terms of character and appearance between the land within the site and the surrounding countryside.
6.25 We have reviewed various recent Part 2 Green Belt assessments by other Local Authorities and have found that the South Buck and Chesham approach to the permanence of boundaries to be at odds with these. They do not rule out established hedgerows, tree belts and woodland blocks when considering whether a boundary is permanent and defensible in accordance with NPPF requirements. Some examples are as follows:
Welwyn Hatfield
The Stage 2 Green Belt Review (October 2014) and Addendum (June 2016) as summarised in the Local Plan Housing Sites Selection Background Paper (June 2016) http://www.welhat.gov.uk/CHttpHandler.ashx?id=11440&p=0.
Paragraph 8.22 states that as part of the Site Selection process, an appraisal was made of Green Belt boundaries comparing, on a site by site basis, the relative strength of existing and proposed boundaries. Table 2: Strength of Green Belt boundaries shows the following:
Strong boundaries include extensive woodland.
Moderate strength boundaries include small woodland and established tree belt/hedgerow (continuous or with minor gaps)
Weak strength boundaries include fragmented hedgerow/tree belt, ditches and small clusters of trees.
South Bucks and Chesham Green Belt Preferred Options Consultation December 2016
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North Hertfordshire
North Hertfordshire Green Belt Review (July 2016) http://www.north- herts.gov.uk/sites/northherts- cms/files/NHDC%20Green%20Belt%20Review%20July%202016.pdf
Paragraph 69 states that as part of this assessment the review considers what boundaries would result from potential allocation of any of these sites for development in the Green Belt. A boundary is a physical feature, easily recognisable and likely to be permanent. A strong boundary would be a road, railway line or possibly an established hedgerow. A weak boundary would be a ditch, fence or footpath.
Wycombe
The Part 2 Green Belt Review does not rule out sites where there is one ‘weak’ boundary but it is enclosed on the other three sides by strong boundaries such as development and highways. https://www.wycombe.gov.uk/uploads/public/documents/Planning/New-local- plan/Green-belt-assessment-part-2-individual-site-assessments.pdf
The Land at Clappins Lane, Walters Ash (SNH0019) is a good example and comparable to the Land North of Pheasant Rise, Chesham in that it is strongly enclosed on three sides and therefore is relatively disconnected from the wider countryside. However, (unlike the Land North of Pheasant Rise, Chesham) the Clappins Lane, Walters Ash site has only a field boundary and no woodland as its weakest boundary. Nevertheless, the Site is recommended for Green Belt release. On p265 it is recognised that boundaries can be strengthened: “The north-eastern field boundary marks a line that is continuous with the established edge to build development on both sides of the site, where the existing trees/hedgerow could be supplemented with additional planting to form a natural limit to development in this location.” This Is in stark contrast to the Land North of Pheasant Rise, Chesham where a block of woodland planted more than 20 years ago is not considered to have matured sufficiently.
Other sites in Chesham and South Bucks
It has not escaped our attention that sites recommended for Green Belt release in this Green Belt Preferred Options consultation have not consistently applied the criteria for Green Belt boundaries.
For Site 7. National Epilepsy Centre, Chalfont St Peter (1.10A) the Draft Green Belt Assessment Part 2 recommends release for development a site with plenty of standard agricultural boundaries consisting of hedgerows as well as unprotected woodland. The apparent justification is that the land has a different character to the rest of the countryside.
South Bucks and Chesham Green Belt Preferred Options Consultation December 2016
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For Site 8. Area South East of Chalfont St Peter (1.11) is states “There is a small portion of the southern boundary (approx. 140m), alongside the Paccar Scout Camp extending from the woodland to Denham Lane, which is formed of a single, sparse line of trees. Although this is not strongly defined, it would form only a small part of the southern boundary extending in a logical line from the more defensible woodland boundary and in this instance it is considered suitable as an extension of a clearly defined boundary.”
Green Belt Development Options Appraisal (October 2016)
6.26 This should be urgently reviewed and updated with the correct information on agricultural land quality. It wrongly states that Site 1.30 is Grade 1 Agricultural Land. This statement is based on very low resolution obsolete mapping which is not appropriate for the appraisal of individual sites. Our site-specific report on the agricultural land quality of Site 4.334 should be referenced, which demonstrates the site is only Grade 3a.
6.27 The conclusion of the Green Belt Assessment ‘Unable to identify a defensible Green Belt boundary and exceptional circumstances not demonstrated’ needs to be updated in the context of the analysis above about the definition of Green Belt boundaries and the sustainable location of the site next to a settlement with an important rail station within walking distance, which serves major employment centres.
Sustainability Appraisal Initial Consultation (Regulation 18) Incorporating Issues and Options (January 2016)
6.28 Section 3.30 (Richings Park 1 Area of Search) should be more precise with regard to the agricultural land quality (para 3.30.6). It should also recognise the programmed improvements to Iver Rail Station (para 3.30.4). The landscape assessment (3.30.2) should recognise how Richings Park wraps around part of the Area of Search and how the M25 and M4 already sever the countryside. The scores should be updated to reflect these aspects.
Tom Hutchinson BA MA MRTPI Head of Projects
Land and Partners Ltd 8 High Bois Lane Amersham Bucks HP6 6DG
m e
Comments submitted 11 December 2016 South Bucks and Chesham Green Belt Preferred Options Consultation December 2016
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APPENDIX A – OBLIQUE AERIAL PHOTOGRAPH OF SITE 4.334 (LOOKING SOUTHWARDS)
South Bucks and Chesham Green Belt Preferred Options Consultation December 2016
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APPENDIX B – SKETCH LAYOUT CONCEPT OF SITE 4.334
South Bucks and Chesham Green Belt Preferred Options Consultation December 2016
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AGRICULTURAL USE & QUALITY OF LAND EAST OF OLD SLADE LANE RICHINGS PARK
Report 1272/1
9thDecember, 2016
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AGRICULTURAL USE & QUALITY OF LAND EAST OF OLD SLADE LANE, RICHINGS PARK
M W Palmer, MSc, PhD, MISoilSci
Report 1272/1 Land Research Associates Ltd Lockington Hall, Lockington, Derby DE74 2RH
9thDecember, 2016
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SUMMARY An agricultural survey has been undertaken of 3.14 ha of land east of Old Slade Lane, Richings Park.
The land includes a number of small paddocks in long term use as horse grazing. Associated land at the site is occupied by buildings, hard standing and woodland and does not have any agricultural potential.
The land with agricultural potential at the site is limited by soil wetness to subgrade 3a quality. It has not been used for agriculture for a long period of time and would require the installation of modern field drainage to achieve this potential.
Land Research Associates Report 1272/1– Soils and agricultural quality of land east of Old Slade Lane
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1.0 Introduction
1.1 This report provides information on the soils and agricultural quality and use of 3.14 ha of land east Old Slade Lane, Richings Park, Berkshire. The report is based on a survey of the land in December 2016.
SITE ENVIRONMENT 1.2 The land investigated comprises a strip of small fields/paddocks and associated buildings, stables and hard standing. Areas on the western border of the site are occupied by mature trees. The land is bordered to the north, south and west by the gardens of residential properties adjoining North Park, Old Slade Lane, and The Poynings respectively. The land is separated from agricultural land to the east by an over-mature hedgerow. The land is level to gently sloping at an average elevation of approximately 25 m AOD.
AGRICULTURAL USE 1.3 At the time of survey the land was used as horse paddocks and associated storage buildings. Historical aerial imagery indicates the site to have been under the current (non-agricultural) use for at least the last seventeen years. The land is not registered under any agri-environment schemes.
PUBLISHED INFORMATION 1.4 1:50,000 scale BGS information records the geology of the site as mudstone of the Oxford Clay Formation, overlain in the southern half of the site by sand and gravel deposits of the Shepperton Gravel Member.
1.5 The National Soil Map (published at 1:250,000 scale) records the land as Hamble 2 Association, comprising deep stoneless silty soils, with associated thin silts over clay or gravel1.
1.6 The national Agricultural Land Classification (ALC) map shows the land as grade 1 and urban. However, this map was published by the former Ministry of Agriculture, Fisheries and Food (MAFF) in the 1970s, based on the obsolete 1960s Classification system. It is currently only reproduced at 1:250,000 scale, reflecting the reconnaissance nature of the information involved in its creation. Natural England are the statutory consultees on agricultural land quality issues and state in their published guidance (TIN 049) that:
1Jarvis, M.G. et al., 1984.Soils and their use in South East England.Soil Survey of England and Wales Bulletin No. 15, Harpenden.
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1.7 “These maps are not sufficiently accurate for use in assessment of individual fields or development sites, and should not be used other than as general guidance”.2
1.8 In 1988 the ALC guidelines were revised, substantially changing the criteria for land grading, and introducing subgrades 3a and 3b, to further differentiate land capability. Land of grade 1 to subgrade 3a, according to the 1988 guidelines, is recognised under the planning system for England and Wales through being designated ‘Best and Most Versatile’ agricultural land.
1.9 No detailed survey of the site (to the current guidelines) has been published.
2 Natural England, (2012). Agricultural Land Classification: Protecting the Best and Most Versatile Agricultural Land. Natural England Technical Information Note TIN049.
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2.0 Soils
2.1 The National Planning Practice Guidance states that the planning system should protect and enhance valued soils and prevent the adverse effects of unacceptable levels of pollution. This is because soil is an essential finite resource that provides important ecosystem services, for example as a growing medium for food, timber and other crops, as a store for carbon and water, as a reservoir of biodiversity and as a buffer against pollution.
2.2 A detailed soil resource and agricultural quality survey was carried out in December 2016. Observations were made at intersects of a 50 m grid, giving a sampling density of four observations per hectare. During the survey, soils were examined by a combination of pits and augerings to a maximum depth of 1.2 m. A log of the sampling points and a map (Map 1) showing their location is in an appendix to this report.
2.3 Soils were found to be uniform across the site, comprising thin medium silty clay loam or silt loam topsoil over silty clay loam upper subsoil showing evidence of seasonal waterlogging (grey mottled colour) at shallow depth (above 40 cm). The lower subsoil is formed of dense slowly permeable silty clay or clay.
2.4 The thin nature of the topsoils suggests that the land has not been ploughed for arable use for a minimum of several decades.
2.5 An example profile is described below from observation 6 (Map 1). 0-19 cm Very dark greyish brown (10YR 3/2) medium silty clay loam with common distinct fine yellowish red (5YR 6/6) mottles; stoneless; moderately developed medium sub-angular blocky structure; friable; non-calcareous; clear smooth boundary to: 19-38 cm Brown (10YR 5/3) medium silty clay loam with common faint fine brownish yellow (10YR 6/8) mottles; stoneless; moderately developed coarse sub- angular blocky structure; friable; non-calcareous; gradual smooth boundary to: 38-56 cm Grey (10YR 6/1) heavy silty clay loam with common to many distinct fine reddish brown (5YR 5/4) mottles; stoneless; moderately developed coarse to very coarse sub-angular blocky structure; friable; non-calcareous; gradual smooth boundary to: 56-120 cm Pinkish grey (5YR 6/2) silty clay to clay with many fine prominent reddish brown (5YR 5/4) and reddish yellow (5YR 5/6) mottles; stoneless; weakly developed very coarse angular blocky to massive structure; very firm; non- calcareous. 2.6 These soils are imperfectly-draining (Soil Wetness Class III) and have a low to moderate capacity to absorb excess winter rainfall.
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3.0 Agricultural quality
3.1 To assist in assessing land quality, MAFF developed a method for classifying agricultural land by grade according to the extent to which physical or chemical characteristics impose long-term limitations on agricultural use for food production. The MAFF Agricultural Land Classification (ALC) system classifies land into five grades numbered 1 to 5, with grade 3 divided into two subgrades (3a and 3b). The system was devised and introduced in the 1960s and revised in 1988.
3.2 The agricultural climate is an important factor in assessing the agricultural quality of land and has been calculated using the Climatological Data for Agricultural Land Classification3. The relevant site data for an elevation of 25 m is given below.
• Average annual rainfall: 672 mm
• January-June accumulated temperature >0°C 1485 day° • Field capacity period 138 days (when the soils are fully replete with water) mid Nov-early Apr • Summer moisture deficits for: wheat: 117 mm potatoes: 113 mm
3.3 The survey described in the previous section was used in conjunction with the agro-climatic data above to classify the site using the revised guidelines for ALC issued in 1988 by MAFF4. There are no climatic limitations to land quality in this locality.
SURVEY RESULTS 3.4 The agricultural quality of the land is limited by wetness. Land of grade 3 has been identified.
Subgrade 3a 3.5 All of the land with agricultural potential is imperfectly-draining (Soil Wetness Class III) with medium-textured topsoils. The resulting wetness is likely to restrict machinery access for field operations in early spring constraining
3Climatological Data for Agricultural Land Classification. Meteorological Office, 1989 4Agricultural Land Classification for England and Wales: Guidelines and Criteria for Grading the Quality of Agricultural Land. MAFF, 1988.
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flexibility and the range of crops which can be grown regularly, although both autumn and spring sowings are usually possible.
Non Agricultural 3.6 This land includes buildings, associated hard standings, sealed tracks and areas of woodland.
Grade areas 3.7 The grades of land are shown on Map 2 and the areas occupied are shown below. Table 1. Areas occupied by the different land grades
Grade/subgrade Area (ha) % of the land
Subgrade 3a 2.29 73
Non Agricultural 0.85 27
Total 3.14 100
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4.0 Conclusions
4.1. The sustainability appraisal of the Chilterns and South Bucks Local Plan (January 2016) states that the site is part of an area of grade 1 agricultural land. This statement is based on very low resolution obsolete mapping which is not appropriate for the appraisal of individual sites.
4.2. Detailed assessment of the site has shown that the site has not been in agricultural use for considerable time (at least 17 years), and there is evidence to suggest it may never have been used as cropland under modern agriculture.
4.3. While some parts of the site retain their agricultural potential, previous activities and the growth of trees means a significant proportion of the site area could no longer be considered as having any agricultural potential.
4.4. The agricultural areas of the site are of subgrade 3a rather than grade 1 quality, due to wetness limitations. The land would require the installation of an intensive drainage system if it were to be useable as best and most versatile agricultural land. It is unlikely this would be economic given the small area of the site.
Land Research Associates Report 1272/1– Soils and agricultural quality of land east of Old Slade Lane
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APPENDIX
MAPS AND DETAILS OF OBSERVATIONS
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Classification: OFFICIAL PORep1502 (REDACTED) Land at Richings Park: ALC and soil resources survey – Details of observations at each sampling point
Obs Topsoil Upper subsoil Lower subsoil Slope Wetness Agricultural quality No Depth Texture Stones Depth Texture Mottling Depth Texture Mottling (°°°) Class Grade Main limitation >20 mm (cm) (cm) (cm) (%) 1 Non Agricultural – hard standings 2 Non Agricultural – hard standings 3 0-18 MZCL 0 18-35 MZCL xxx 35-100+ ZC xxx 0 IV/III 3b/3a W 4 0-18 MZCL 0 18-43 MZCL x 43-69 ZC xxx 0 III 3a W 69-100+ C xxx 5 Non Agricultural –caravans and mobile buildings etc. 6 0-19 MZCL 0 19-38 MZCL xx 38-56 MZCL xxx 0 III 3a W 56-120 ZC xxx 7 0-20 MZCL 0 20-45 MZCL xxx 45-90+ ZC xxx 0 III 3a W 8 0-15 MZCL 0 15-47 MZCL xx 47-100+ ZC xxx 0 III 3a W 9 Non Agricultural –woodland 10 0-23 ZL 0 23-54 MZCL xxx 54-88 HZCL xxx 0 III 3a W 88-110+ ZC xxx 11 0-12 MZCL 0 12-23 MZCL xxx 23-44 HZCL xxx 0 III 3a W 44-90+ C xxx 12 0-19 MZCL 0 19-27 MZCL xx 27-47 HZCL xxx 0 III 3a W 47-80+ C xxx
Key to table Mottle intensity: Texture: Limitations: o unmottled C - clay W - wetness/workability x few to common rusty root mottles (topsoils) ZC - silty clay D - droughtiness or a few ochreous mottles (subsoils) SC - sandy clay De - depth xx common to many ochreous mottles and/or dull structure faces CL - clay loam (H-heavy, M-medium) St – stoniness xxx common to many greyish or pale mottles (gleyed horizon) ZCL - silty clay loam (H-heavy, M-medium) Sl – slope xxxx dominantly grey, often with some ochreous mottles (gleyed horizon) SCL - sandy clay loam F - flooding SZL - sandy silt loam (F-fine, M-medium,C-coarse) T – topography/microrelief SL - sandy loam (F-fine, M-medium, C-coarse) LS - loamy sand (F-fine, M-medium, C-coarse) Texture suffixes & prefixes: S - sand (F-fine, M-medium, C-coarse) ca – calcareous: x-extremely, v-very, sl-slightly n-none P - peat (H-humified, SF-semi-fibrous, F-fibrous) (ca) marginally calcareous LP - loamy peat; PL - peaty loam mn - ferrimanganiferous concentrations a depth underlined (e.g. 50) indicates the top of a slowly permeable layer R - bedrock gn – greenish, yb – yellowish brown, rb – reddish brown (a wavy underline indicates the top of a layer borderline to slowly permeable) r – reddish; (v)st – (very) stony; sdst– sandstonelst - limestone dist - disturbed soil layer; mdst - mudstone
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Technical Note
Introduction
Site Location
1.1 This Technical Note has been prepared to review the sustainable transport options in the proximity of the site off Richings Way, Iver.
1.2 Figures 1 and 2 show the location of the site and the local highway network. The site currently comprises one dwellings and agricultural land with access via Richings Way, if the site was to be further developed a secondary access will be provided further east on Richings Way, potentially at the junction with Thorney Lane South. The site is bounded by agricultural land to the east and residential properties to the north (off Wellesley Avenue), south (The Poynings) and west (Old Slade Lane).
Local Highway Network
1.3 It is likely that a site access will be located on Richings Way opposite Wellesley Avenue, this could take the form of a cross roads or mini-roundabout. A decision on the type of access will be made following discussions with the Local Highway Authority (LHA).
1.4 Richings Way is approximately 6.0m wide and is subject to a 30mph speed limit and has a number of traffic calming measures in place, including ‘build outs’ reducing the road width to single file.
1.5 There is potential for the wider site to be developed in which case a secondary site access potentially will be provided at the junction of Richings Way / Thorney Lane South, which currently takes the form of a 3 arm mini-roundabout.
Sustainable Transport Options
Walking
1.6 Walking is the most important mode of travel at the local level and offers the greatest potential to replace short car trips, particularly those under 2km. As outlined below, a large number of services and amenities are within 2km of the site and therefore within a reasonable walking catchment area. Table 1 below details suggested acceptable walking distances.
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Walking Distance (m)
Town Centre Commuting Elsewhere Desirable 200 500 400 Acceptable 400 1000 800 Preferred Maximum 800 2000 1200
Table 2: Suggested Acceptable Walking Distances
1.7 There is a footway provided on the northern side of Richings Way either side of Wellesley Avenue, this footway is approximately 2.0m wide and is in good condition.
1.8 There is also a footway provided on the southern side of Richings Way west of Wellesley Avenue, however this is only 1.0m wide but is in a fair condition.
1.9 There are footways on Wellesley Avenue approximately 1.5m wide and in average condition for a residential street. Wellesley Avenue provides the most direct route to Iver Railway Station and local facilities, this is discussed later in this document.
1.10 If the extended site was to be developed, the secondary site access would provide direct link to the railway station via Somerset Way. Somerset Way has footways on both sides of the carriageways and are in good condition. The footway on the west of the carriageway is between 1.5m and 2.0m wide and the footway on the east of the carriageway is between 1.0m and 1.5m wide.
1.11 There is a public right of way to the south of the site linking Old Slade Lane to the Richings Way at the junction with Thorney Lane South.
Cycling
1.12 Cycling has the potential to act as a substitute for shorter car journeys up to a distance of around 5km in urban or rural areas, or form part of a longer journey when combined with public transport.
1.13 A 5km distance covers the all of suburban areas of Iver including surrounding residential suburbs, retail and employment areas. This distance also reaches the Uxbridge, Heathrow Airport and eastern areas of Slough.
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1.14 There is a designated cycle route to the south of the site, which can be accessed via Old Slade Lane. This route links Thorney Park Golf Course to National Cycle Route 61 which connects Slough with Uxbridge. A figure showing cycling routes within the
Bus Services
1.15 The nearest bus stop is located close to Iver Railway Station approximately 600m from the site.
1.1 Route 583 stop adjacent to Iver Railway Station. Table 2 sets out a summary of the bus services running near the site. Monday - Friday Number Route Operator Saturday Sunday Daytime Evening Slough – Wexham Park Hospital – Four a Four a Four a No 583 Redline Richings Park - day day day service Uxbridge Table 2: Bus services Adjacent to Iver Railway Station
Rail Services
1.16 Iver Railway Station is located approximately 650m to the north of the site, which based on the recommended walking distances shown in Table 1 is deemed to be acceptable and only just out the desirable range.
1.17 Iver Railway Station is currently operated by Great Western Railway and provides direct services to Reading (up 4 an hour) and London Paddington (up to 4 an hour).
1.18 A location close to a rail station can be a selling point for development, and will have the potential to reduce the number of car trips generated. However, to realise this potential the station needs to be attractive, both in terms of level of service, passenger facilities and the access.
1.19 Iver station will benefit from a number of improvements in preparation for Elizabeth line services, including a new information system, security systems and CCTV.
1.20 Transport for London will install lifts at the station before the first Elizabeth line services begin in 2019.
1.21 In addition to the station works overhead electric wires will be installed on the line in preparation for new, electric trains and extensive track and signaling work will improve reliability and increase capacity. Thorney Lane bridge near the station has also been replaced.
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1.22 From December 2019, up to four Elizabeth line trains an hour in each direction will serve Iver station, allowing passengers to travel right through central London without having to change trains. Table 2 shows the key journey times from Iver.
To Current Journey Time Crossrail Journey Time
Bond Street 48 minutes 26 minutes Liverpool Street 1 hour 33 minutes Canary Wharf 1 hour 8 minutes 40 minutes Reading 31 minutes 27 minutes Table 2: Crossrail key journey times
1.23 The table above shows that journey times to a number of key locations will be significantly reduced following the opening of the Elizabeth Line from Iver. This will further increase the attractiveness of the railway station for commuters.
Proximity to Local Services and Amenities
1.24 A review of local facilities has been undertaken. Walking distances, based on the distance from the site, are set out in Table 3 and Figure 3 for a range of facilities.
Facility Distance Education Richings Park Pre-School 0.25 km Health Saleys Chemist 0.7 km Employment & Leisure Iver Post Office 0.6 km Richings Sports Park 0.3 km Iver South SDW 1.5 km The Ridgeway Trading Estate 1.9 km Fairbriar House 1.5 km Iver Water Treatment 1.4 km Thorney Park Golf Course 1.2 km Lakeside Estate 1.9 km
Table 3: Local Facilities
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1.25 It can be seen from Table 3 above that there are a number of local facilities within easy walking distance of the site, reducing the reliance on the private car.
Summary
1.26 The site is deemed to be in a good location to promote sustainable travel, with the railway station within easy walking distance and offering an extremely good level of service. This service will be even more attractive following the completion of Crossrail.
1.27 It can be seen by reviewing the CIHT recommended walking distances that the railway station is within the acceptable walking distance again showing the site to be very sustainable in transport terms.
1.28 There are good pedestrian routes between the site and local amenities reducing the reliance on the private car. The pedestrian routes to the railway station are direct with the footways in a good condition and deemed to be safe due to the street lighting and all routes being overlooked by nearby dwellings.
Author: Nick Smith Date: 2nd December 2016
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APPENDIX A: Figures
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Site Location
© Crown copyright, all rights reserved. 2016. Licence number 100002189.
client title scale N. T. S. drawn by LP checked by NS Land and Partners date December 2016 cad file SLP Iver.dwg project Site Location Plan Mayer Brown Limited drawing number rev. Zellig 313 The Custard Factory Birmingham B9 4AU Richings Way, Iver Telephone 0121 224 7630 [email protected] www.mayerbrown.co.uk X/LPIver.1-1 Page 43 of 45 Classification: OFFICIAL PORep1502 (REDACTED)
KEY - AMENITIES EDUCATION 1 Richings Park Pre-School 6 HEALTHCARE 2 Saleys Chemist Pharmacy EMPLOYMENT OPPORTUNITIES-LEISURE 3 Iver Post Office 4 Richings Sports Park 5 Iver South SDW 8 6 The Ridgeway Trading Estate 7 Fairbriar House 8 Iver Water Treatment 9 Thorney Park Golf Course 7 10 Lakeside Estate
Train Station Bus Stop
2 3 9
4
1
400m
1600m
5
10
© Crown copyright, all rights reserved. 2016. Licence number 100002189.
client title scale N. T. S. drawn by LP checked by NS Land and Partners date cad file Accessibility and Sustainability December 2016 SLP - Iver.dwg project
Mayer Brown Limited drawing number rev. Zellig 313 The Custard Factory Birmingham B9 4AU Richings Way, Iver Telephone 0121 224 7630 [email protected] www.mayerbrown.co.uk X/LPIver.1-3 Page 44 of 45 Classification: OFFICIAL PORep1502 (REDACTED)
© Crown copyright, all rights reserved. 2016. Licence number 100002189.
client title scale N. T. S. drawn by LP checked by NS Land and Partners date December 2016 cad file SLP - Iver.dwg project Location Plan Mayer Brown Limited drawing number rev. Zellig 313 The Custard Factory Birmingham B9 4AU Richings Way, Iver Telephone 0121 224 7630 [email protected] www.mayerbrown.co.uk X/LPIver.1-2 Page 45 of 45