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Chiltern and South Bucks Local Plan – Green Belt Preferred Options Consultation

1. Introduction SUEZ Recycling and Recovery UK Ltd (SUEZ) are the landowners of the Pickeridge Closed Landfill Site, Pickeridge Farm, Stoke Common Road, Fulmer, Buckinghamshire, SL3 6HA (site location plan attached at Appendix 1). The site is currently dissected by the M40. The land to the south of the M40 is part of the former landfill which closed and was restored in 2001, with its five year aftercare period ending in 2006. The land to the north of the M40 was never landfilled and has been retained in SUEZ’s ownership. The area of the north of the M40 is a long rectangular strip of land that is located between the M40 and the settlement of Gerrards Cross. The land is currently located within the Green Belt. It is understood that South Bucks and Chiltern District Councils are currently consulting on their Green Belt Preferred Options Consultation to remove a number of areas of land from the Green Belt. SUEZ have also been made aware that the land at the Pickeridge has been considered in the Issues and Options Consultation for the Green Belt in March 2016 (site reference 69) and was assessed against the five purposes of the Green Belt as outlined in Paragraph 80 of the NPPF and against the Methodology developed by Arup for the Council in March 2016. It should be noted that at this stage SUEZ have not been directly consulted on this consultation or any of the previous consultations, which is not in line with Regulation 18 of the Town and Country Planning (Local Planning) (England) Regulations which states that when preparing a Local Plan a Local Planning Authority must notify each of the bodies or persons specified in paragraph (2) of the subject of a local plan which the local planning authority propose to prepare, and invite each of them to make representations to the local planning authority about what a local plan with that subject ought to contain. The persons specified in paragraph 2 include such residents or other persons carrying on business in the local planning authority’s area from which the local planning authority consider it appropriate to invite representations. Given that SUEZ are the Freehold owners of the Pickerage Closed Landfill and part of our ownership has been considered in detail for potential Green Belt release, we are disappointed that we have not had the opportunity to make the appropriate representations on previous consultations regarding the Green Belt. 2. Planning Policy The National Planning Policy Framework was adopted in March 2012 and sets the Government’s stance on the Green Belt.

Paragraph 79 states the Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.

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Paragraph 80 of the NPPF outlines the five purposes of the Green Belt, which are as follows:

 to check the unrestricted sprawl of large built-up areas;

 to prevent neighbouring towns merging into one another;

 to assist in safeguarding the countryside from encroachment;

 to preserve the setting and special character of historic towns; and

 to assist in urban regeneration, by encouraging the recycling of derelict and other urban land. It is against these five tests that land should be assessed against when considering removing land from the Green Belt.

Paragraph 84 goes on to state when drawing up or 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 channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the outer Green Belt boundary.

The above statement is also further enhanced in paragraph 85 which states that when defining Green Belt boundaries Local Authorities should

 satisfy themselves that Green Belt boundaries will not need to be altered at the end of the development plan period; and

 define boundaries clearly, using physical features that are readily recognisable and likely to be permanent At a local level the planning policies for the South Bucks area are contained within the adopted Local Plan (1999) and the adopted Core Strategy (2011). Neither of the aforementioned documents contain any relevant policies on Green Belt release and are more focused on safeguarding the Green Belt from development.

It is acknowledged that South Bucks and Chiltern District Councils are currently in the process of updating their Local Plan and this consultation forms part of the Local Plan revision.

3. Green Belt Assessment Methodology In order to undertake the Green Belt Assessment it is understood that a methodology was developed by the Council and their consultants to review potential sites for release. This was first published in 2015 and revised in March 2016.

It is understood that any potential alterations to the Green Belt must be based on a new permanent and defensible boundary; thus, permanent man-made and natural features were selected as the initial basis of criteria for the identification of the ‘General Areas’.

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 Motorways;  A and B Roads;  Railway lines;  River Chess;  River Colne;  River Misbourne;  River Thames; and  River Wye. Given the nature of Buckinghamshire it is understood that it was necessary to further define the General Areas based on the following criteria.

 Unclassified public roads and private roads;  Smaller water features, including streams, canals and other watercourses;  Prominent physical features (e.g. ridgelines);  Existing development with strongly established, regular or consistent boundaries;  Protected woodland or hedgerows. It is understood that then each area was assessed against the five purposes of the Green belt as outlined in Paragraph 80 of the NPPF.

The purpose assessment criteria is set out below:

 To check the unrestricted sprawl of large built up areas – (a) Land parcel is at the edge of one or more distinct large built-up areas, (b) Prevents the outward sprawl of a large built-up area into open land, and serves as a barrier at the edge of a large built-up area in the absence of another durable boundary.

 To prevent neighbouring towns from merging - prevents development that would result in merging of or significant erosion of gap between neighbouring settlements, including ribbon development along transport corridors that link settlements.

 Assist in safeguarding the countryside from encroachment - protects the openness of the countryside and is least covered by development.

 To preserve the setting and special character of historic towns - protects land which provides immediate and wider context for a historic settlement, including views and vistas between the settlement and the surrounding countryside. Purpose five was excluded from the Assessment.

SUEZ agree that the methodology for purposes 1, 2 and 4 are consistent with the aims and objectives of the NPPF. However, we have concerns over the consistency of its application across sites.

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SUEZ wish to make the comments that the methodology for the 3rd purpose assessment should be amended, as it is our opinion that it relies too heavily on how much of the site is currently developed. This form of assessment does not accurately reflect on how effective (or not) the site is from safeguarding the countryside form encroachment. The assessment should be a judgement based on how much countryside the site actually contains rather than how developed the site is. Countryside is land/scenery which is rural in character, i.e. a relatively open natural, semi-natural or farmed landscape. The sites could then be scored on the following criteria

 If land parcel contains countryside and no urbanising development, and is open, - 5

 If land parcel contains countryside interspersed with development and is open – 4

 If land parcel contains countryside and limited urbanising development, and is relatively open – 3

 If land parcel contains small elements countryside or contains urbanising development compromising openness - 1

 If land parcel does not contain countryside or contains urbanising development compromising openness - 0 It is understood that each criteria was then scored out of 5 based on the methodology devised by Arup in March 2016 as set out below.

The site within SUEZ’s ownership forms part of General Area 69 (Stage 1) or 2.20 (Stage 2). The site was scored in the assessments (March and October 2016) against the five purposes of the Green Belt as outlined in table 1.1 below:

Table 1: Stage 1 Council Assessment

Purpose Criteria Assessment Score

(1) To check the a) Land parcel is at the The land parcel is at the edge of the PASS unrestricted edge of one or more Gerrard’s Cross large built-up area. sprawl of large distinct large built-up built-up areas areas (b) Prevents the outward The land parcel is connected with 3+ sprawl of a large built up the large built-up area of Gerrard’s area into open land, and Cross, preventing its outward sprawl serves as a barrier at the into open land. The boundary edge of a large built up between the land parcel and the area in the absence of Gerrard’s Cross built-up area is another durable weak consisting of detached homes boundary. with large gardens bounded by woodland. Although those

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properties on Howards Wood Drive are regular, there are breaks in this built form and properties within the land parcel on (and leading from) Howards Thicket and Fulmer Drive are more dispersed and irregular. While the M40 Motorway forms a durable boundary along the south of the land parcel, the parcel is an important boundary to sprawl owing to the weak boundary with the settlement of Gerrards Cross. Purpose 1: Total Score 3+/5

(2) To prevent Prevents development The land parcel forms part of the 3 neighbouring that would result in wider gap between the non- Green towns from merging of or significant Belt settlements of Gerrards Cross merging erosion of gap between and Stoke Poges and Farnham neighbouring Common. While the scale of the gap settlements, including is important to restricting the ribbon development merging of Gerrards Cross with the along transport corridors Green Belt settlement of Fulmer, that link settlements. this land parcel is less important to the gap overall than Green Belt areas to the south as the land parcel is contained to the south by the M40 Motorway. Purpose 2: Total Score 3/5

3) Assist in Protects the openness of Less than 5% of the land parcel is 4 safeguarding the the countryside and is covered by built form. Countryside from least covered by encroachment development. The land use is mostly characterised by woodland with some open fields in the east of the land parcel; some of which are used for pasture adjacent to Fulmer Road, and contribute to the largely rural character of the land parcel overall. The woodland is denser in the north of the land parcel where trees are more mature.

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There is sporadic built form in the west and east of the parcel including large detached properties dispersed amongst the woodland in the west of the parcel and a pylon, electricity substation and farm building in the east of the land parcel, north of the M40.

The topography of the land parcel is predominantly flat in the east, sloping up to the west, with open long distance views to the south interrupted by the M40 in some places. The topography and presence of woodland contributes to a more enclosed feel to the land parcel in the west. Despite being of a small scale and the close influences of infrastructure and built-form, the land parcel possesses a strong unspoilt rural character.

Purpose 3: Total Score 4/5

(4) To Protects land which The land parcel does not abut an 0 preserved the provides immediate and identified historic settlement core setting and wider context for historic and does not meet this Purpose. special settlement, including views character of and vistas between the historic towns settlement and the surrounding countryside. Purpose 4 : Total Score 0/5

It is understood that based on the above scoring, the site was dropped part way through the Stage 2 Assessment as the site did not meet the purposes of the Green Belt. SUEZ do not agree with the above assessment, undertaken by the Council and their consultants and as result we have undertaken our own assessment based on the methodology set out in the March 2016 document as outlined in Table 1.2 below.

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Table 1.2 – SUEZ Assessment

Purpose Criteria SUEZ Comments and SUEZ Assessment Score

(1) To check the a) Land parcel is at the SUEZ agree with the assessment PASS unrestricted edge of one or more undertaken by the Council that the sprawl of large distinct large built-up land parcel is at the edge of the built-up areas areas Gerrards Cross large built-up area. (b) Prevents the outward SUEZ agree that the land parcel is 3 sprawl of a large built up connected with the large built-up area into open land, and area of Gerrards Cross, preventing serves as a barrier at the its outward sprawl into open land. edge of a large built up However SUEZ are of the opinion area in the absence of that the site is predominantly another durable bordered by prominent, permanent boundary. and consistent boundary features. The M40 acts as the southern boundary which is a permanent feature on the landscape. To the north the site is bordered by a regular settlement pattern along Howards Thicket. The eastern and western boundaries of Windsor Road and Fulmer road also represent permanent and defensible boundaries. Given this and especially given the northern and southern boundaries it can be considered that the area of land is predominantly bordered by prominent, permanent and consistent boundary features.

In line with the March 2016 methodology we believe the site should be scored a 3 which is: Land parcel is connected to one or more large built-up area(s), though the large built-up area(s) is/are predominantly bordered by

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prominent, permanent and consistent boundary features.

Purpose 1: Total Score 3/5

(2) To prevent Prevents development SUEZ disagree with the 1 neighbouring that would result in assessment undertaken by the towns from merging of or significant Council and their consultants. The merging erosion of gap between site does not provide an important neighbouring gap to prevent the merging of settlements, including Gerrards Cross with Fulmer and ribbon development Stokes Poges. The development of along transport corridors the M40 acts as a defensible that link settlements. boundary which prevents the merging of Gerrards Cross with the aforementioned settlements. The land to the south of the M40 is a former landfill site and is unlikely to be developed in the near future due to the contamination associated with the site.

Given the above we consider that the site forms a ‘less essential gap’ between non- Green Belt settlements, which is of sufficient scale and character that development is unlikely to cause merging between settlements or affect gaps between Green Belt and non- Green Belt settlements and therefore the site should be re scored as a 1 in line with the March 2016 methodology, which states: A ‘less essential gap’ between non- Green Belt settlements, which is of sufficient scale and character that development is unlikely to cause

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merging between settlements or affect gaps between Green Belt and non- Green Belt settlements

Purpose 2: Total Score 1/5

3) Assist in Protects the openness of SUEZ do not agree with the 1 safeguarding the the countryside and is Councils Methodology or Countryside from least covered by Assessment of Purpose 3. encroachment development. Based on SUEZ’s methodology for Purpose 3.

The site is bounded by the M40 to the south and built development to the north. Therefore it does not assist in safeguarding the Countryside from encroachment.

It is accepted that the site has very little in terms of built development but does not contain any countryside either. The site also has defensible boundaries that exist round the site. Given this the site has an enclosed and urban character, which compromises openness.

Taking the above in account, we believe the site should be scored a 1.

Purpose 3: Total Score 1/5

(4) To Protects land which SUEZ agree with the assessment 0 preserved the provides immediate and that the land parcel does not abut setting and wider context for historic an identified historic settlement special settlement, including views character of and vistas between the

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historic towns settlement and the core and does not meet this surrounding countryside. Purpose.

Purpose 4 : Total Score 0/5

In addition to the above the Stage 2 assessment states that Very Special Circumstances (VSC) do not exist to remove the site from the Green Belt. However SUEZ are of the opinion that VSC’s do exist based on the following reasons as outlined in the March 2016 methodology.

 Is there a good fit with the spatial strategy – yes, the site would act as a built area extension(s) to the principal settlement of Gerrards Cross and provides a more efficient and effective use of land.

 Would development in the area satisfy sustainable development criteria – yes the release of this land would contribute to building a strong, responsive and competitive economy, by ensuring that sufficient land of the right type is available in the right places and at the right time to support growth and innovation. The site would also supporting strong, vibrant and healthy communities, by providing the supply of housing required to meet the needs of present and future generation.

 Looking at the RGA/RSA in question to what extent would there be conflict with purposes and integrity of the Green Belt as set out in the NPPF – As outlined in Table 1.2 above the site does not conflict with the purposes of the Green Belt.

 Looking at the strategic context of the wider area, to what extent is there conflict with the wider strategic function of the Green Belt in the form of cumulative impacts: would the release from the Green Belt affect the scoring in surrounding parcels and/or the scoring affected by judgements about exception circumstances in other parcels – No, the land is self-contained within defensible boundaries and its development would not impact upon any of the other sites put forward in the assessment. In addition it is considered that the site would meet the definition of sustainable development as it would be within walking distance of bus stops and services including schools, retailing and education, which would comply with Core Policy 7 of the adopted Core Strategy.

The removal of the site from the Green Belt would open up an opportunity to deliver development on an area of land that doesn’t not meet the purposes of the Green belt and assist in delivering the required housing numbers for the Local Authority Area.

4. Green Belt Preferred Options Consultation Based on the Stage 1 and Stage 2 assessments the Council are currently consulting on their Green Belt Preferred Options.

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SUEZ do not dispute any if the sites that have been put forward for removal from the Green Belt, however we have concerns over the consistency of scoring especially with regards to Purpose 3. SUEZ would request that changes are made to the methodology to the Purpose 3 assessment to ensure the each site is scored in a consistent manner.

SUEZ requests that based on our scoring the site at the Pickeridge added to the Preferred Options consultation as the site clearly does not meet the five purposes of the Green Belt based on the following:

 to check the unrestricted sprawl of large built-up areas – the site is bounded on its southern side by the M40 motorway which provides a defensible boundary and prevents the unrestricted sprawl of Gerrards Cross. To the north the site is bounded by Gerrards Cross itself. The wider sites eastern and western boundaries are bounded by main arterial routes in and out of Gerrards Cross which also provide defensible boundaries. Taking this in account it is considered that unrestricted sprawl could not occur if this site was removed from the Green Belt;

 to prevent neighbouring towns merging into one another – the removal of this site would not result in the merging of neighbouring towns for the reasons outlined above;

 to assist in safeguarding the countryside from encroachment – As outlined above the site does not contain any elements of the Countryside and is bounded on all side by defensible boundaries and therefore the countryside would not be encroached by the removal of this site from the Green Belt.

 to preserve the setting and special character of historic towns – Gerrards Cross is not considered to be a town of historic value and there this criteria is not considered to be relevant. 5. Summary

Taking all of the account into the above, we would request that the site attached as appendix 1 (General Area 69 (Stage 1) or 2.20 (stage 2)). to this document is reassessed based on the information provided and put forward as a site to be realised from the Green Belt as its designation currently serves no purpose.

The release of the site from the Green Belt would bring forward a site that meets the definition of sustainable development and one that is located in one of the key settlements for the Local Authority Area. The site is well located in terms of its location in relation to public transport, education, retail and employment. The delivery of the site will also assist the Council in meeting their required housing numbers.

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Appendix 1

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Chiltern and South Bucks Local Plan Green Belt Preferred Options Consultation Response Form

This is your chance to provide your views on the 15 Preferred Green Belt Options listed in the Consultation Document. Please do not limit your comments to these 15 options, this consultation also provides the opportunity for you to comment on the evidence base documents, other Local Plan matters, and to suggest other options.

This form has two parts:

PART A - respondent (your) details, only your name will be published (at this stage you may wish to remain anonymous); and

PART B - for comments, which may be made publically available following the close of the consultation. If needed continue your comments on separate sheets.

Please note: responses received as part of this consultation cannot be treated as confidential. All comments made may be made public and included in Council documents displayed on the Councils’ websites. However no personal details, other than the respondent’s name (if provided), and job title or organisation (if applicable) will be made public. Responses submitted to Chiltern District Council or South Bucks District Council will be processed and shared between the two Councils. Chiltern District Council and South Bucks District Council are the Data Controllers for the purposes of the Data Protection Act 1998.

This form is also accompanied by an Equality Monitoring Form. Individual data collected from this Monitoring Form will remain confidential with only summary results being published.

Please return your completed forms to one of the addresses/emails below:

The Planning Policy Team [email protected] Chiltern District Council or King George V House King George V Road [email protected] Amersham Bucks PLEASE NOTE: YOU ONLY NEED TO EMAIL YOUR HP6 5 AW RESPONSE TO ONE OF THE ABOVE EMAIL ADDRESSES

All Consultation Responses must be received by 5 pm on 12th December 2016*.

* The Consultation deadline may be subject to extension – please check the websites (below) for more details.

If you would like to discuss any matter relating to this consultation please contact a member of the Planning Policy Team during normal office hours on (01494) 586 678 or via the email addresses provided above.

The Consultation document and supporting evidence base are available on the Councils’ websites: www.chiltern.gov.uk/planning/localplan2014-2036 and www.southbucks.gov.uk/planning/localplan2014-2036

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Are you:

An Individual An Organisation Other (please specify)

Personal Details* Agent’s Details (if applicable)

**Title Mr

**First Name Niall

**Last Name Kelly

Job Title Assistant Planning Manager (if on behalf of an organisation)

Organisation SUEZ Recycling and Recovery UK (if applicable)

**Address

Telephone Number

**Email Address

*if an agent is appointed, you may wish to complete only the title and name boxes and, if applicable, the organisation box but please complete the full contact details for the agent.

**Name and either email or address required if you wish to be added to the consultation database (see below).

Consultation Database (Mailing List) The Councils have a Consultation Database (mailing list) used to keep individuals and organisations informed about Planning Policy Documents across both Council areas. Documents include: the Local Plan, Supplementary Planning Documents and Neighbourhood Plans, (please note some plans may not be applicable to your area).

Chiltern District Council and South Bucks District Council are the Data Controllers for the purposes of the Data Protection Act 1998. Individuals and organisations on the Planning Policy Consultation Database will only be contacted by the Councils in relation to the preparation and production of planning policy documents. The Councils will not publish the names of those individuals on the database but may publish names of statutory bodies and organisations at certain stages of the Local Plan process. Please indicate if you want to be added to the joint consultation database (tick box below). Please note: you do not need to tick this box if you received a letter or email notification from the Councils prior to the start of the consultation, as you are already registered.

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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 document

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