Classification: OFFICIAL PORep2695 (REDACTED) PART A – YOUR DETAILS

Are you:

An Individual An Organisation Other (please specify)

Personal Details* Agent’s Details (if applicable)

**Title Mr Miss

**First Name Neil Katie

**Last Name Beards Christou

Job Title Senior Planner and Urban Designer (if on behalf of an organisation)

Organisation Tarmac David Lock Associates (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 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.

Page 1 of 27 Classification: OFFICIAL PORep2695 (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 representation and supporting plans.

Page 2 of 27 Classification: OFFICIAL PORep2695 (REDACTED)

CHILTERN AND SOUTH BUCKS LOCAL PLAN GREEN BELT PREFERRED OPTIONS CONSULTATION: Tarmac Consultation Response

1.1 This representation is made by David Lock Associates (DLA) on behalf of Tarmac in relation to the Chiltern and South Bucks Local Plan Green Belt Preferred Options Consultation document. Tarmac owns land at All Souls Farm Quarry, which is identified in the Green Belt Assessment Part 2. A Location Plan is attached as DLA 01.

Adjoining Landowner Support

1.2 Local adjoining landowners have also lent their support to this representation, including the following: • Lidstone Family Trust • United Charity • Ravinda Singh Takhar • Mr and Mrs H. Barnard • Makhan Singh Jabble, Daljeet Kaur Jabble, Rashpal Jabble and Manmeet Jabble • Old House Court Management Ltd.

1.3 A land ownership plan is attached as DLA 02.

Site Factors

1.4 The site at All Souls Farm Quarry is located entirely within the administrative area of South Bucks District Council and adjoins the north-eastern boundary of Borough and the built-up area of Slough. Tarmac will lead promotion of the whole site for development during all stages of the Joint Local Plan process.

1.5 The site currently takes access from Park Lane and is also bounded by the A412 Uxbridge Road and Church Lane. It is located between the built-up neighbourhoods of Wexham and George Green. It is contiguous with the built-up area of Slough and has the potential to provide a logical and sustainable urban extension and/or new business location on the north-eastern edge of Slough. The Tarmac land ownership extends to some 44 hectares. The wider potential development area extends to 65 hectares in total.

Page 3 of 27 Classification: OFFICIAL PORep2695 (REDACTED)

1.6 Tarmac has completed a Feasibility Study of the development potential of All Souls Farm Quarry. Sand and gravel extraction at the site has now ceased and final restoration backfilling under licence, with inert material, is currently being completed alongside mineral recycling operations. This operation will provide a sound development platform which can accommodate any conventional development types and formats.

1.7 The site is available for immediate development and the former sand and gravel extraction operations provide no constraint on development. Technical transportation studies confirm that there are suitable access options. The simple fact that Tarmac own most of the site confers significant advantages because it simplifies the planning, design and development process. Future development of the All Souls Farm Quarry site could be delivered as part of the potential Northern Expansion of Slough, as proposed by (SBC), or independently of any wider development proposal. An independent development can readily be configured to ensure that it does not prejudice a simultaneous or subsequent development of a wider area.

1.8 This submission responds directly to the Green Belt Preferred Options Consultation document and the supporting Green Belt Assessment Part Two. Tarmac wish to put forward the site at All Souls Farm Quarry as a suitable and available alternative Green Belt Preferred Option.

Green Belt Assessment Part Two (2016)

1.9 Tarmac supports the approach of Chiltern and South Bucks District Councils to undertake a Green Belt Review as part of the preparation of their Joint Local Plan. It is agreed that the required exceptional circumstances exist that require Green Belt boundary revisions to accommodate new development.

Page 4 of 27 Classification: OFFICIAL PORep2695 (REDACTED)

1.10 The National Planning Policy Framework (NPPF) (para. 83) sets out that

Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan. At that time, authorities should consider the Green Belt boundaries having regard to their intended permanence in the long term, so that they should be capable of enduring beyond the plan period.

1.11 The exceptional circumstances in this case relate to the proven level of housing need in the Districts of Chiltern and South Bucks and Slough and the lack of suitable and available alternative sites to accommodate that need, as confirmed in the Green Belt Development Options Appraisal (2016) (para. 1.1) and by SBC in its Issues and Options consultation document due for public consultation in January 2017.

1.12 Tarmac considers that there are clear inconsistencies in the Joint Green Belt Assessment, which need to be addressed. Our concerns in relation to the methodology for site selection in the Green Belt are threefold:

i) The Green Belt Preferred Options appear prejudged – the Green Belt Preferred Options have been published in advance of identifying a preferred Spatial Option for the Joint Local Plan that properly takes account of the OAHN housing requirements of Chiltern and South Bucks and the Duty to Co-operate with neighbouring authorities;

ii) Site assessment against the purposes of the Green Belt – the assessment of the site at All Souls Farm Quarry is considered within both Stage 1 and 2 assessments where, confusingly, it is referred to under different area names. In our view, the site at All Souls Farm Quarry is considered to perform weakly when assessed against the purposes of the Green Belt as set out in national planning policy (NPPF) and should be taken forward as an alternative preferred option; and

iii) The Duty to Co-operate with neighbouring authorities - Lack of consideration of cross boundary strategic development needs and appropriate options to meet identified needs, particularly for Slough.

1.13 We have set out our detailed response to these inconsistencies below.

Page 5 of 27 Classification: OFFICIAL PORep2695 (REDACTED)

i) The Green Belt Preferred Options appear prejudged

1.14 The Issues and Options consultation document (2016) contained a total of 12 possible options, including Option D to extend the principle settlements outside of the plan area, including Slough. The Issues and Options document sets out that all the Options would be tested during the next stage of the plan process. As also identified by SBC1, to-date no Spatial Options have been properly tested to analyse whether they are the most sustainable forms of development or could best accommodate the OAHN housing requirements. It is not clear when the Councils intend to identify their preferred Spatial Option for the Joint Local Plan or why this has not taken place in advance of the publication of the Green Belt Preferred Options. This is contrary to the National Planning Policy Framework (NPPF) which states, “when defining [Green Belt] boundaries, local planning authorities should ensure consistency with the Local Plan strategy for meeting identified requirements for sustainable development” (para. 85). The assumption is made that the draft Local Plan, when published in Spring 2017, will seek to reconcile and clarify some of these issues.

1.15 In our view, it appears that the Green Belt Preferred Options have been prejudged in advance of the Council’s identification of the amount and location of land required to be released from the Green Belt based on the objectively assessed housing need (OAHN). Chiltern and South Bucks have asked that Aylesbury Vale District Council (AVDC) accommodate some 5,800 dwellings of unmet need out of a total OAHN of 14,700. Whilst it is acknowledged that the Councils are effectively playing ‘catch-up’ having now agreed to prepare a Joint Local Plan, it is important that the correct planning processes and procedures are followed to achieve sustainable development in both Districts.

1 Slough Borough Council, Planning Committee, 7 December 2016: Response to South Bucks & Chiltern Green Belt Preferred Options Consultation

Page 6 of 27 Classification: OFFICIAL PORep2695 (REDACTED)

ii) Site assessment against the purposes of the Green Belt

1.16 Sites considered within the Chiltern and South Bucks’ Green Belt Assessment are tested against the first four of the five purposes of the Green Belt in accordance with national planning policy (NPPF, para. 80):

1. To check the unrestricted sprawl of large built-up areas; 2. To prevent neighbouring towns merging into one another; 3. To assist in safeguarding the countryside from encroachment; 4. To preserve the setting and special character of historic towns; and 5. To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

1.17 The fifth purpose of the Green Belt relates to assisting in urban regeneration and is excluded from the Assessment as there are no planned urban regeneration schemes which would be inhibited by Green Belt designations. This could be construed as a convenient and parochial view because in the wider area economic and social regeneration is a priority of SBC.

1.18 The Green Belt Assessment Part Two refers to the All Souls Farm Quarry site under varying area names and references. There are evident inconsistencies in the approach to assessment with the site having reached Stage 2 of the assessment in certain instances, but only Stage 1 when referred to under alternative area names. The site is referred to under the following names:

• All Souls Farm Quarry, Wexham [Site 4.3182] • Slough BC – Area South of Stoke Poges, George and Middle Green [Site 4.3383] • George Green – Area to West of Wexham Park Hospital [Site 2.294]

1.19 These alternative site references are indicated on grid reference map 54 of Appendix 3 and grid reference map 54 of Appendix 6 of the Green Belt Assessment Part Two.

2 Appendix 5: Volume 7 of the Green Belt Assessment Part Two, October 2016 3 Ibid. 4 Appendix 5: Volume 2 of the Green Belt Assessment Part Two, October 2016

Page 7 of 27 Classification: OFFICIAL PORep2695 (REDACTED)

1.20 The Assessment identifies sites 4.318 and 4.338 as areas of land where it is not possible to identify a potential NPPF compliant Green Belt boundary at Stage 1 (not considered further). Whereas, when considered under site reference 2.29, the site passed the Stage 1 assessment and concluded that the area passed the Part Two Green Belt purpose assessment although the site was then not considered further. It is not evident from the confused methodology why this site has not been identified as a Green Belt Preferred Option.

1.21 In our view, the All Souls Farm Quarry site is incorrectly excluded following the Green Belt Assessment in the emerging Joint Local Plan. Our reasons for why we consider that the site should be identified as a Preferred Option are set out below.

1.22 In relation to the first Green Belt purpose, the site adjoins the north-eastern boundary of Slough Borough and the built-up area of Slough. If new boundaries are based on naturally occurring or manmade features such as roads, they will present a more robust and defensible strategy. It is a requirement of the NPPF (para. 85) for local planning authorities to “define [Green Belt] boundaries clearly, using physical features that are readily recognisable and likely to be permanent”. The A412 Uxbridge Road and Wexham Park Lane would provide strong, logical and defensible boundaries to the remaining boundaries of the site to the north, east and south-east. This would check the unrestricted sprawl of the built-up area of Slough. The A412 Uxbridge Road provides a strong physical feature which would establish a more permanent Green Belt boundary to that of Church Lane which provides the current Green Belt boundary if the site is being considered independently.

1.23 We therefore strongly disagree with the Green Belt Assessment for area 4.3185 where it states that “it is not possible to define a boundary around the site which is permanent and defensible”. This contradicts the assessment for area 2.296 wherein it states “it is possible to identify a boundary that is permanent and defensible in accordance with NPPF requirements. The option is well defined by encircling infrastructure – Church Lane to the west and south west, the A412 to the east and south east and Wexham Park Lane to the north. These features provide clear defensible and durable boundaries”.

5 Appendix 5: Volume 7 of the Green Belt Assessment Part Two, October 2016 6 Appendix 5: Volume 2 of the Green Belt Assessment Part Two, October 2016

Page 8 of 27 Classification: OFFICIAL PORep2695 (REDACTED)

1.24 Where development is planned positively through a Local Plan and benefits from a well-designed scheme with robust and considered master planning, unrestricted sprawl would not constitute the resultant built form. Sustainable urban extensions, such as that which could be developed at All Souls Farm Quarry would be eminently sustainable and physically connected to the surrounding area. As supported by the NPPF, “the supply of new homes can sometimes be best achieved through planning for larger scale development, such as new settlements or extensions to existing villages and towns that follow the principles of Garden Cities” (para. 52). SBC are actively promoting the Northern Expansion of Slough, including the All Souls Farm Quarry site, as a new ‘Garden Suburb’. This proposal would accord with the NPPF and Tarmac’s vision for the site.

1.25 The second Green Belt purpose seeks to prevent the coalescence of neighbouring towns. The site would provide a sustainable urban extension on the north-eastern edge of Slough and would not result in coalescence with any other town due its location. The hamlet of George Green currently extends westwards along the route of the A412 to join the edge of Slough’s built-up area. George Green is therefore not entirely separate from the built-up area of Slough. Development of the All Souls Farm Quarry site would complete an existing built-up edge to Slough and would create an interface with George Green, albeit physically separated by the A412 Uxbridge Road.

1.26 The strong and defensible boundaries which the A412 Uxbridge Road and Wexham Park Lane provide to the site would help in addressing the third Green Belt purpose of seeking to safeguard the countryside from encroachment. We strongly support the assessment for area 2.297 where it identifies that the site is “under greater influence from Slough built area than from the countryside beyond. This is partly due to the fact that it directly abuts the Slough urban area to the west but also because there is a concentration of existing residential development in the option’s north west and further dispersed development around the option’s southern perimeter. Additionally, a large portion of the northern and central part of the area is in use as a gravel and mineral extraction site which further detracts from a rural character. The remaining areas are in agricultural use but the character is considered to be semi-urban”.

7 Ibid.

Page 9 of 27 Classification: OFFICIAL PORep2695 (REDACTED)

1.27 The fourth Green Belt purpose is not relevant to the assessment of the All Souls Farm Quarry site as it is not directly neighbouring a historic town, as identified in the assessment of area 2.298.

1.28 The Green Belt for land at All Souls Farm Quarry performs weakly when assessed against the Green Belt purposes and the Green Belt boundary should be amended to enable the removal of the whole of the site. Redefined Green Belt boundaries around the built-up area of Slough to include the extent of Tarmac’s land ownership at All Souls Farm Quarry would provide the District authorities with a strong defensible extension to the development pattern of Slough. We also believe that this design response would be in keeping with national guidance provided by the NPPF which recommends using physical features that are readily recognisable, likely to be permanent and endure beyond the plan-period (paragraph 85).

iii) The Duty to Co-operate with neighbouring authorities

1.29 It is imperative that the local authorities in the area adopt a progressive approach towards the “Duty to Co-operate” and put forward pragmatic solutions to the location of new housing areas. This is a requirement of paragraph 157 of the NPPF where it sets out that “Local Plans should…be based on co-operation with neighbouring authorities”. Slough has a clear and proven functional, economic and spatial inter-relationship with the southern part of the Chiltern and South Bucks plan area. The economic performance of Slough continues to accelerate as its connectivity improves and its locational advantages become more accepted. This is clearly evidenced by the increase in office development around the station. The functional relationship between South Bucks will similarly strengthen.

1.30 The proposed expansion of Heathrow, with a new rail link to Slough (Western Rail Link to Heathrow ‘WRLtH’), will make international travel even easier. When it opens in 2019 the Elizabeth Line (Crossrail) will provide direct train services into Central London and beyond. This strong inter-relationship was clearly recognised by the inclusion of South Bucks District within the Berkshire Strategic Housing Market Assessment area. The decision to prepare a Joint Local Plan with Chiltern District has produced an anomalous situation whereby South is now also assessed as part of the Buckinghamshire Housing Market Area where its functional relationships to areas

8 Appendix 5: Volume 2 of the Green Belt Assessment Part Two, October 2016

Page 10 of 27 Classification: OFFICIAL PORep2695 (REDACTED)

further north in the County are weaker. It is imperative that the Green Belt review is informed by the need to accommodate development needs arising from the Berkshire Strategic Housing Market Area (SHMA) and it cannot be considered “sound” if it does not take proper account of those needs.

1.31 As part of its Review of the Local Plan SBC has now approved its Issues and Options Consultation document for consultation early in 2017. To meet this need, the total OAHN for Slough over the period 2016 – 2036 is over 20,000 dwellings. It includes a Slough Northern Expansion (Option J1) for some 5,000 dwellings that is within the current Green Belt on the edge of Slough and within SBDC. All Souls Farm Quarry is located at the centre of the Area of Search. This area is shown on the attached plan DLA 03.

1.32 Slough is almost entirely built-up and the Borough is unable to accommodate a significant proportion of its emerging housing requirements within its boundaries. It is, in effect, fully developed with very limited remaining areas remaining for future development. SBC has noted that the emerging Joint Local Plan has not properly considered a Northern Expansion of Slough despite specific requests to do so. In failing to do so, the Councils do not consider cross boundary strategic development needs or identify appropriate options to meet these needs, particularly in relation to the neighbouring authority of Slough.

1.33 SBC’s view is clear that a Northern Expansion is a logical and sustainable way of meeting the housing needs of either authority or as a joint contribution to overall housing needs. Tarmac are willing to discuss with both SBDC and SBC how development of All Souls Farm Quarry can meet the needs of both or individual authorities.

1.34 The effective and lawful operation of the Duty to Co-operate is vital if the housing and other development needs of South Bucks, Chiltern and Slough are to be properly met. By failing to take proper account of these strategically important issues the Green Belt review is fatally flawed.

Page 11 of 27 Classification: OFFICIAL PORep2695 (REDACTED)

Illustrative Concept Plan

1.35 An illustrative Concept Plan has been prepared to demonstrate both the deliverability and capacity of the site for residential-led development. This is attached as DLA04. The Concept Master Plan shows one way in which the site features might be interpreted, as a framework for future development to be brought forward. Points of achievable and deliverable access into the site have been identified, as confirmed by technical transportation studies. The illustrative Concept Plan includes land within Tarmac’s ownership, and land held by adjoining landowners who have given their support in principle for the promotion of development of George Green.

Conclusions

1.36 We consider that the Green Belt Preferred Options have been prejudged in advance of identifying a preferred Spatial Option for the Joint Local Plan that properly takes account of the OAHN housing requirements of Chiltern and South Bucks and the Duty to Co-operate with neighbouring authorities.

1.37 The site at All Souls Farm Quarry provides a robust alternative Green Belt Preferred Option which is a logical and sustainable development location that can meet the OAHN requirements of South Bucks and/or Slough as part of their respective Local Plans, either as a standalone site or as part of a larger ‘Garden Suburb’ concept.

1.38 The analysis of the Green Belt Assessment in relation to the All Souls Farm Quarry site is largely favourable. However, the conclusions are not consistent with the analysis. We consider that there is no sound basis for the site to be excluded following the Green Belt Assessment. We therefore request that the site at All Souls Farm quarry is identified as a Green Belt Preferred Option for future residential-led development and is taken forward as a Preferred Options in the Joint Local Plan. A plan has been prepared to show our suggested revised Green Belt boundary. This is attached as DLA05.

Page 12 of 27 Classification: OFFICIAL PORep2695Key: (REDACTED)

DLA 0 1 Tarmac Ownership

Slough Wider Potential Development Area

South Bucks District

Co Const Bdy Boro Const & UA Bdy Local Authority District Boundary

Keepers Cottage

45.1m

Und

WEXHAM PARK LANE

44.9m

RH

30 Church Lane 36.7m

Und

VALLEY END

1

2

Culzean

Con Calore

Tioh

Walnut

Cottages

Wexham Park Lane

3 4

Woodlands

Waldeck

Stn 6

MH BOREHOLE-B 1015

5 MH

MH

FB

3

PEG-B peg

14 12

11

10

10a

MH

Lane End 21

Kingstone House

Puckspool 9

Greencorner

5

28

GRANGEWOOD

28b 28a

28c

28f

28e

St Mary's

Jorric

The White House

SP

Fourwinds

73

Appletreewick

83 N

54 Und

SP

Def 0m 200m

SP

Def

El FF A412 Uxbridge Road Sub Sta Track Sinks Drain

Drain NOTE SP This drawing is for information purposes only and not for use in construction. LIDSTONE COURT St Mary's Church

Drain Do NOT scale from this drawing. Wexham Court Collects Primary School All dimensions are to be checked on site and any discrepancies should be immediately reported to the originator of the drawing. All information is copyright protected and may not be used or reproduced without prior permission.

Balancing Pond

The

Und Cottage 30.6m Hall

SP

10 to 16 FB

Und

4 to 9

Drain

Old House Court

1 to 3

Church Lane Drain Drain Reproduced by permission of Ordnance Survey on behalf of HMSO. © Crown copyright and database right 2014 All rights reserved. Drain Ordnance Survey Licence number 100022533 Title Slough Quarry

TCB LB Land Ownership and Wider FB

1 19 Potential Development Area UXBRIDGE ROAD POST OFFICE LANE 3 5 Beaumont 4 Court Scale Date 28-06-16 1:2500@A1 - 1:5000@A3

Drawn Designed Approved Drawing Number ADW ---DAK LAF043 - 001 A

Slough

DAVID LOCK ASSOCIATES LIMITED 50 NORTH THIRTEENTH STREET, CENTRAL MILTON KEYNES, MK9 3BP South Bucks District TEL: 01908Page 666276 FAX 13 : 01908 of 605747 27 EMAIL: [email protected] www.davidlock.com Classification: OFFICIAL ILLUSTRATIVE CONCEPT PLAN PORep2695 (REDACTED) DLA 04

Co Const Bdy

Boro Const & UA Bdy

Keepers Cottage Narrow section of Wexham Park Road restricted to

45.1m KEY Und footpath and cycle link beyond proposed Primary

44.9m route and form emergency access route Existing routes

30

36.7m Primary/secondary routes Und Wexham Park Road

VALLEY END

1

2

Culzean

Con Calore

Tioh

Walnut Key access points Cottages

3 4

Footpath/cycle links Woodlands

Waldeck

BOREHOLE-B 1015

5 Retained woodland MH MH

FB

3

PEG-B

14 Water bodies 12 11

10

10a

MH

Lane End 21

Watercourse Kingstone House

Puckspool 9 Residential development Greencorner

5

28

GRANGEWOOD

28b 28a Primary school site 28c

28f

28e

Local centre St Mary's

Jorric

The White House

SP

Fourwinds

73 Green space

Appletreewick

83 A412 Uxbridge Road

54 Und

SP

Def

SP

Def

El FF Sub Sta

SP

St Mary's Church

Wexham Court Collects Primary School

Balancing Pond

The

Und Cottage 30.6m Hall

SP

10 to 16 FB

Und

4 to 9

Old House Court

1 to 3

Drain Church Lane Drain

TCB LB George Green FB

1 19 UXBRIDGE ROAD POST OFFICE LANE 3 5 Beaumont 4 Court

MARCH 2016 N LAF043/015 1:5000@A3 0m 200m

Based on the Ordnance Survey’s 1:5,000 map of 2008 with the permission of The Controller of Her Majesty’s Stationery Offi ce © Crown Copyright David Lock Associates, 50 North Thirteenth Street, Central Milton Keynes, MK9 3BP Licence number 100022533

ALL SOULS FARM QUARRY SLOUGH Page 14 of 27 Classification: OFFICIAL PORep2695 (REDACTED) DLA 0 2

Page 15 of 27 Classification: OFFICIAL PORep2695 (REDACTED) Draft Vn 09/11/2016 SBC ISSUES AND OPTIONS CONSULTATION DOCUMENT D L A 03

Figure 16: Option J1

Page 100 Page 16 of 27 Classification: OFFICIAL PORep2695Key: (REDACTED)

DLA 05 Revised Green Belt Land

Slough Local Authority District Boundary

South Bucks District

Co Const Bdy

Boro Const & UA Bdy

Keepers Cottage

45.1m

Und

WEXHAM PARK LANE

44.9m

RH

30 Church Lane 36.7m

Und

VALLEY END

1

2

Culzean

Con Calore

Tioh

Walnut

Cottages

Wexham Park Lane

3 4

Woodlands

Waldeck

Stn 6

MH BOREHOLE-B 1015

5 MH

MH

FB

3

PEG-B peg

14 12

11

10

10a

MH

Lane End 21

Kingstone House

Puckspool 9

Greencorner

5

28

GRANGEWOOD

28b 28a

28c

28f

28e

St Mary's

Jorric

The White House

SP

Fourwinds

73

Appletreewick

83 N

54 Und

SP

Def 0m 200m

SP

Def

El FF A412 Uxbridge Road Sub Sta Track Sinks Drain

Drain NOTE SP This drawing is for information purposes only and not for use in construction. LIDSTONE COURT St Mary's Church

Drain Do NOT scale from this drawing. Wexham Court Collects Primary School All dimensions are to be checked on site and any discrepancies should be immediately reported to the originator of the drawing. All information is copyright protected and may not be used or reproduced without prior permission.

Balancing Pond

The

Und Cottage 30.6m Hall

SP

10 to 16 FB

Und

4 to 9

Drain

Old House Court

1 to 3

Church Lane Drain Drain Reproduced by permission of Ordnance Survey on behalf of HMSO. © Crown copyright and database right 2014 All rights reserved. Drain Ordnance Survey Licence number 100022533 Title All Souls Farm Quarry

TCB LB Revised Green Belt Boundary FB

1 19 UXBRIDGE ROAD POST OFFICE LANE 3 5 Beaumont 4 Court Scale Date 12-12-16 1:2500@A1 - 1:5000@A3

Drawn Designed Approved Drawing Number ADW ---DAK LAF043 - 019 --

Slough

DAVID LOCK ASSOCIATES LIMITED 50 NORTH THIRTEENTH STREET, CENTRAL MILTON KEYNES, MK9 3BP South Bucks District TEL: 01908Page 666276 FAX 17 : 01908 of 605747 27 EMAIL: [email protected] www.davidlock.com Classification: OFFICIAL PORep2695 (REDACTED)

CHILTERN AND SOUTH BUCKS LOCAL PLAN GREEN BELT PREFERRED OPTIONS CONSULTATION: Tarmac Consultation Response

1.1 This representation is made by David Lock Associates (DLA) on behalf of Tarmac in relation to the Chiltern and South Bucks Local Plan Green Belt Preferred Options Consultation document. Tarmac owns land at All Souls Farm Quarry, which is identified in the Green Belt Assessment Part 2. A Location Plan is attached as DLA 01.

Adjoining Landowner Support

1.2 Local adjoining landowners have also lent their support to this representation, including the following: • Lidstone Family Trust • Stoke Poges United Charity • Ravinda Singh Takhar • Mr and Mrs H. Barnard • Makhan Singh Jabble, Daljeet Kaur Jabble, Rashpal Jabble and Manmeet Jabble • Old House Court Management Ltd.

1.3 A land ownership plan is attached as DLA 02.

Site Factors

1.4 The site at All Souls Farm Quarry is located entirely within the administrative area of South Bucks District Council and adjoins the north-eastern boundary of Slough Borough and the built-up area of Slough. Tarmac will lead promotion of the whole site for development during all stages of the Joint Local Plan process.

1.5 The site currently takes access from Wexham Park Lane and is also bounded by the A412 Uxbridge Road and Church Lane. It is located between the built-up neighbourhoods of Wexham and George Green. It is contiguous with the built-up area of Slough and has the potential to provide a logical and sustainable urban extension and/or new business location on the north-eastern edge of Slough. The Tarmac land ownership extends to some 44 hectares. The wider potential development area extends to 65 hectares in total.

Page 18 of 27 Classification: OFFICIAL PORep2695 (REDACTED)

1.6 Tarmac has completed a Feasibility Study of the development potential of All Souls Farm Quarry. Sand and gravel extraction at the site has now ceased and final restoration backfilling under licence, with inert material, is currently being completed alongside mineral recycling operations. This operation will provide a sound development platform which can accommodate any conventional development types and formats.

1.7 The site is available for immediate development and the former sand and gravel extraction operations provide no constraint on development. Technical transportation studies confirm that there are suitable access options. The simple fact that Tarmac own most of the site confers significant advantages because it simplifies the planning, design and development process. Future development of the All Souls Farm Quarry site could be delivered as part of the potential Northern Expansion of Slough, as proposed by Slough Borough Council (SBC), or independently of any wider development proposal. An independent development can readily be configured to ensure that it does not prejudice a simultaneous or subsequent development of a wider area.

1.8 This submission responds directly to the Green Belt Preferred Options Consultation document and the supporting Green Belt Assessment Part Two. Tarmac wish to put forward the site at All Souls Farm Quarry as a suitable and available alternative Green Belt Preferred Option.

Green Belt Assessment Part Two (2016)

1.9 Tarmac supports the approach of Chiltern and South Bucks District Councils to undertake a Green Belt Review as part of the preparation of their Joint Local Plan. It is agreed that the required exceptional circumstances exist that require Green Belt boundary revisions to accommodate new development.

Page 19 of 27 Classification: OFFICIAL PORep2695 (REDACTED)

1.10 The National Planning Policy Framework (NPPF) (para. 83) sets out that

Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan. At that time, authorities should consider the Green Belt boundaries having regard to their intended permanence in the long term, so that they should be capable of enduring beyond the plan period.

1.11 The exceptional circumstances in this case relate to the proven level of housing need in the Districts of Chiltern and South Bucks and Slough and the lack of suitable and available alternative sites to accommodate that need, as confirmed in the Green Belt Development Options Appraisal (2016) (para. 1.1) and by SBC in its Issues and Options consultation document due for public consultation in January 2017.

1.12 Tarmac considers that there are clear inconsistencies in the Joint Green Belt Assessment, which need to be addressed. Our concerns in relation to the methodology for site selection in the Green Belt are threefold:

i) The Green Belt Preferred Options appear prejudged – the Green Belt Preferred Options have been published in advance of identifying a preferred Spatial Option for the Joint Local Plan that properly takes account of the OAHN housing requirements of Chiltern and South Bucks and the Duty to Co-operate with neighbouring authorities;

ii) Site assessment against the purposes of the Green Belt – the assessment of the site at All Souls Farm Quarry is considered within both Stage 1 and 2 assessments where, confusingly, it is referred to under different area names. In our view, the site at All Souls Farm Quarry is considered to perform weakly when assessed against the purposes of the Green Belt as set out in national planning policy (NPPF) and should be taken forward as an alternative preferred option; and

iii) The Duty to Co-operate with neighbouring authorities - Lack of consideration of cross boundary strategic development needs and appropriate options to meet identified needs, particularly for Slough.

1.13 We have set out our detailed response to these inconsistencies below.

Page 20 of 27 Classification: OFFICIAL PORep2695 (REDACTED)

i) The Green Belt Preferred Options appear prejudged

1.14 The Issues and Options consultation document (2016) contained a total of 12 possible options, including Option D to extend the principle settlements outside of the plan area, including Slough. The Issues and Options document sets out that all the Options would be tested during the next stage of the plan process. As also identified by SBC1, to-date no Spatial Options have been properly tested to analyse whether they are the most sustainable forms of development or could best accommodate the OAHN housing requirements. It is not clear when the Councils intend to identify their preferred Spatial Option for the Joint Local Plan or why this has not taken place in advance of the publication of the Green Belt Preferred Options. This is contrary to the National Planning Policy Framework (NPPF) which states, “when defining [Green Belt] boundaries, local planning authorities should ensure consistency with the Local Plan strategy for meeting identified requirements for sustainable development” (para. 85). The assumption is made that the draft Local Plan, when published in Spring 2017, will seek to reconcile and clarify some of these issues.

1.15 In our view, it appears that the Green Belt Preferred Options have been prejudged in advance of the Council’s identification of the amount and location of land required to be released from the Green Belt based on the objectively assessed housing need (OAHN). Chiltern and South Bucks have asked that Aylesbury Vale District Council (AVDC) accommodate some 5,800 dwellings of unmet need out of a total OAHN of 14,700. Whilst it is acknowledged that the Councils are effectively playing ‘catch-up’ having now agreed to prepare a Joint Local Plan, it is important that the correct planning processes and procedures are followed to achieve sustainable development in both Districts.

1 Slough Borough Council, Planning Committee, 7 December 2016: Response to South Bucks & Chiltern Green Belt Preferred Options Consultation

Page 21 of 27 Classification: OFFICIAL PORep2695 (REDACTED)

ii) Site assessment against the purposes of the Green Belt

1.16 Sites considered within the Chiltern and South Bucks’ Green Belt Assessment are tested against the first four of the five purposes of the Green Belt in accordance with national planning policy (NPPF, para. 80):

1. To check the unrestricted sprawl of large built-up areas; 2. To prevent neighbouring towns merging into one another; 3. To assist in safeguarding the countryside from encroachment; 4. To preserve the setting and special character of historic towns; and 5. To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

1.17 The fifth purpose of the Green Belt relates to assisting in urban regeneration and is excluded from the Assessment as there are no planned urban regeneration schemes which would be inhibited by Green Belt designations. This could be construed as a convenient and parochial view because in the wider area economic and social regeneration is a priority of SBC.

1.18 The Green Belt Assessment Part Two refers to the All Souls Farm Quarry site under varying area names and references. There are evident inconsistencies in the approach to assessment with the site having reached Stage 2 of the assessment in certain instances, but only Stage 1 when referred to under alternative area names. The site is referred to under the following names:

• All Souls Farm Quarry, Wexham [Site 4.3182] • Slough BC – Area South of Stoke Poges, George and Middle Green [Site 4.3383] • George Green – Area to West of Wexham Park Hospital [Site 2.294]

1.19 These alternative site references are indicated on grid reference map 54 of Appendix 3 and grid reference map 54 of Appendix 6 of the Green Belt Assessment Part Two.

2 Appendix 5: Volume 7 of the Green Belt Assessment Part Two, October 2016 3 Ibid. 4 Appendix 5: Volume 2 of the Green Belt Assessment Part Two, October 2016

Page 22 of 27 Classification: OFFICIAL PORep2695 (REDACTED)

1.20 The Assessment identifies sites 4.318 and 4.338 as areas of land where it is not possible to identify a potential NPPF compliant Green Belt boundary at Stage 1 (not considered further). Whereas, when considered under site reference 2.29, the site passed the Stage 1 assessment and concluded that the area passed the Part Two Green Belt purpose assessment although the site was then not considered further. It is not evident from the confused methodology why this site has not been identified as a Green Belt Preferred Option.

1.21 In our view, the All Souls Farm Quarry site is incorrectly excluded following the Green Belt Assessment in the emerging Joint Local Plan. Our reasons for why we consider that the site should be identified as a Preferred Option are set out below.

1.22 In relation to the first Green Belt purpose, the site adjoins the north-eastern boundary of Slough Borough and the built-up area of Slough. If new boundaries are based on naturally occurring or manmade features such as roads, they will present a more robust and defensible strategy. It is a requirement of the NPPF (para. 85) for local planning authorities to “define [Green Belt] boundaries clearly, using physical features that are readily recognisable and likely to be permanent”. The A412 Uxbridge Road and Wexham Park Lane would provide strong, logical and defensible boundaries to the remaining boundaries of the site to the north, east and south-east. This would check the unrestricted sprawl of the built-up area of Slough. The A412 Uxbridge Road provides a strong physical feature which would establish a more permanent Green Belt boundary to that of Church Lane which provides the current Green Belt boundary if the site is being considered independently.

1.23 We therefore strongly disagree with the Green Belt Assessment for area 4.3185 where it states that “it is not possible to define a boundary around the site which is permanent and defensible”. This contradicts the assessment for area 2.296 wherein it states “it is possible to identify a boundary that is permanent and defensible in accordance with NPPF requirements. The option is well defined by encircling infrastructure – Church Lane to the west and south west, the A412 to the east and south east and Wexham Park Lane to the north. These features provide clear defensible and durable boundaries”.

5 Appendix 5: Volume 7 of the Green Belt Assessment Part Two, October 2016 6 Appendix 5: Volume 2 of the Green Belt Assessment Part Two, October 2016

Page 23 of 27 Classification: OFFICIAL PORep2695 (REDACTED)

1.24 Where development is planned positively through a Local Plan and benefits from a well-designed scheme with robust and considered master planning, unrestricted sprawl would not constitute the resultant built form. Sustainable urban extensions, such as that which could be developed at All Souls Farm Quarry would be eminently sustainable and physically connected to the surrounding area. As supported by the NPPF, “the supply of new homes can sometimes be best achieved through planning for larger scale development, such as new settlements or extensions to existing villages and towns that follow the principles of Garden Cities” (para. 52). SBC are actively promoting the Northern Expansion of Slough, including the All Souls Farm Quarry site, as a new ‘Garden Suburb’. This proposal would accord with the NPPF and Tarmac’s vision for the site.

1.25 The second Green Belt purpose seeks to prevent the coalescence of neighbouring towns. The site would provide a sustainable urban extension on the north-eastern edge of Slough and would not result in coalescence with any other town due its location. The hamlet of George Green currently extends westwards along the route of the A412 to join the edge of Slough’s built-up area. George Green is therefore not entirely separate from the built-up area of Slough. Development of the All Souls Farm Quarry site would complete an existing built-up edge to Slough and would create an interface with George Green, albeit physically separated by the A412 Uxbridge Road.

1.26 The strong and defensible boundaries which the A412 Uxbridge Road and Wexham Park Lane provide to the site would help in addressing the third Green Belt purpose of seeking to safeguard the countryside from encroachment. We strongly support the assessment for area 2.297 where it identifies that the site is “under greater influence from Slough built area than from the countryside beyond. This is partly due to the fact that it directly abuts the Slough urban area to the west but also because there is a concentration of existing residential development in the option’s north west and further dispersed development around the option’s southern perimeter. Additionally, a large portion of the northern and central part of the area is in use as a gravel and mineral extraction site which further detracts from a rural character. The remaining areas are in agricultural use but the character is considered to be semi-urban”.

7 Ibid.

Page 24 of 27 Classification: OFFICIAL PORep2695 (REDACTED)

1.27 The fourth Green Belt purpose is not relevant to the assessment of the All Souls Farm Quarry site as it is not directly neighbouring a historic town, as identified in the assessment of area 2.298.

1.28 The Green Belt for land at All Souls Farm Quarry performs weakly when assessed against the Green Belt purposes and the Green Belt boundary should be amended to enable the removal of the whole of the site. Redefined Green Belt boundaries around the built-up area of Slough to include the extent of Tarmac’s land ownership at All Souls Farm Quarry would provide the District authorities with a strong defensible extension to the development pattern of Slough. We also believe that this design response would be in keeping with national guidance provided by the NPPF which recommends using physical features that are readily recognisable, likely to be permanent and endure beyond the plan-period (paragraph 85).

iii) The Duty to Co-operate with neighbouring authorities

1.29 It is imperative that the local authorities in the area adopt a progressive approach towards the “Duty to Co-operate” and put forward pragmatic solutions to the location of new housing areas. This is a requirement of paragraph 157 of the NPPF where it sets out that “Local Plans should…be based on co-operation with neighbouring authorities”. Slough has a clear and proven functional, economic and spatial inter-relationship with the southern part of the Chiltern and South Bucks plan area. The economic performance of Slough continues to accelerate as its connectivity improves and its locational advantages become more accepted. This is clearly evidenced by the increase in office development around the station. The functional relationship between South Bucks will similarly strengthen.

1.30 The proposed expansion of Heathrow, with a new rail link to Slough (Western Rail Link to Heathrow ‘WRLtH’), will make international travel even easier. When it opens in 2019 the Elizabeth Line (Crossrail) will provide direct train services into Central London and beyond. This strong inter-relationship was clearly recognised by the inclusion of South Bucks District within the Berkshire Strategic Housing Market Assessment area. The decision to prepare a Joint Local Plan with Chiltern District has produced an anomalous situation whereby South Buckinghamshire is now also assessed as part of the Buckinghamshire Housing Market Area where its functional relationships to areas

8 Appendix 5: Volume 2 of the Green Belt Assessment Part Two, October 2016

Page 25 of 27 Classification: OFFICIAL PORep2695 (REDACTED)

further north in the County are weaker. It is imperative that the Green Belt review is informed by the need to accommodate development needs arising from the Berkshire Strategic Housing Market Area (SHMA) and it cannot be considered “sound” if it does not take proper account of those needs.

1.31 As part of its Review of the Local Plan SBC has now approved its Issues and Options Consultation document for consultation early in 2017. To meet this need, the total OAHN for Slough over the period 2016 – 2036 is over 20,000 dwellings. It includes a Slough Northern Expansion (Option J1) for some 5,000 dwellings that is within the current Green Belt on the edge of Slough and within SBDC. All Souls Farm Quarry is located at the centre of the Area of Search. This area is shown on the attached plan DLA 03.

1.32 Slough is almost entirely built-up and the Borough is unable to accommodate a significant proportion of its emerging housing requirements within its boundaries. It is, in effect, fully developed with very limited remaining areas remaining for future development. SBC has noted that the emerging Joint Local Plan has not properly considered a Northern Expansion of Slough despite specific requests to do so. In failing to do so, the Councils do not consider cross boundary strategic development needs or identify appropriate options to meet these needs, particularly in relation to the neighbouring authority of Slough.

1.33 SBC’s view is clear that a Northern Expansion is a logical and sustainable way of meeting the housing needs of either authority or as a joint contribution to overall housing needs. Tarmac are willing to discuss with both SBDC and SBC how development of All Souls Farm Quarry can meet the needs of both or individual authorities.

1.34 The effective and lawful operation of the Duty to Co-operate is vital if the housing and other development needs of South Bucks, Chiltern and Slough are to be properly met. By failing to take proper account of these strategically important issues the Green Belt review is fatally flawed.

Page 26 of 27 Classification: OFFICIAL PORep2695 (REDACTED)

Illustrative Concept Plan

1.35 An illustrative Concept Plan has been prepared to demonstrate both the deliverability and capacity of the site for residential-led development. This is attached as DLA04. The Concept Master Plan shows one way in which the site features might be interpreted, as a framework for future development to be brought forward. Points of achievable and deliverable access into the site have been identified, as confirmed by technical transportation studies. The illustrative Concept Plan includes land within Tarmac’s ownership, and land held by adjoining landowners who have given their support in principle for the promotion of development of George Green.

Conclusions

1.36 We consider that the Green Belt Preferred Options have been prejudged in advance of identifying a preferred Spatial Option for the Joint Local Plan that properly takes account of the OAHN housing requirements of Chiltern and South Bucks and the Duty to Co-operate with neighbouring authorities.

1.37 The site at All Souls Farm Quarry provides a robust alternative Green Belt Preferred Option which is a logical and sustainable development location that can meet the OAHN requirements of South Bucks and/or Slough as part of their respective Local Plans, either as a standalone site or as part of a larger ‘Garden Suburb’ concept.

1.38 The analysis of the Green Belt Assessment in relation to the All Souls Farm Quarry site is largely favourable. However, the conclusions are not consistent with the analysis. We consider that there is no sound basis for the site to be excluded following the Green Belt Assessment. We therefore request that the site at All Souls Farm quarry is identified as a Green Belt Preferred Option for future residential-led development and is taken forward as a Preferred Options in the Joint Local Plan. A plan has been prepared to show our suggested revised Green Belt boundary. This is attached as DLA05.

Page 27 of 27