Classification: OFFICIAL PORep2068 (REDACTED)

Representation to Emerging Chiltern & South Bucks Local Plan

Land North of Botley Road, Botley, Bucks HP5 1XN

GRE Group November 2016 Submission to: Emerging Chiltern and South Local Plan

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CONTENTS

1.0 Chiltern & South Bucks Local Plan (2014-2036) – Representation to 3 the Green Belt Preferred Options Consultation

2.0 Introduction of the Site 3

3.0 Planning Policy Context of the Site 5

4.0 Identification of Development Needs & Potential Land Supply 7 Development Needs & Market Areas Land Availability for Future Development

5.0 Spatial Strategy Options for Chiltern & South Bucks District Councils 9 The Councils’ Strategic Approach Spatial Strategy & Assessment of Options

6.0 Evidence Base 12 Residential Development Needs and Opportunity in Botley Housing & Economic Land Availability Assessment

7.0 BAE/Infill Development Options & Green Belt Assessment in Botley 15

8.0 Conclusions 17

Appendices 19-24

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1.0 Chiltern & South Bucks Local Plan (2014-2036) – Representation to the Green Belt Preferred Options Consultation 1.1 The GRE Group have compiled this document in order represent it to the Green Belt Preferred Options Consultation for the emerging Chiltern and South Bucks District Council’s Local Plan. There have been no previous representations made for this site, and therefore it will be assessed in accordance with the (Regulation 18) Issues and Options Consultation, and the Green Belt Preferred Options Consultation. Between 19th January and 14th March 2016, Chiltern and South Bucks District Councils carried out an Initial (Regulation 18) Consultation Incorporating Issues and Options. Various comments were received and taken into consideration by both Councils, and as a result, this has assisted in the compilation of this subsequent Green Belt Preferred Options Consultation.

1.2 The land in question will be introduced in the following section, which will include a brief overview of its location, surroundings and development potential. After this, principal points of this representation are discussed, including an introduction to the current planning policy context in Chiltern and South Bucks and comments on the Development Needs and Opportunities, and the Spatial Strategy Options set out in the consultation document.

1.3 In light of the overall discussion the conclusion is therefore drawn that the land in question is suitable for allocation for residential development and should form part of an infilling of Green Belt land, as part of an extension of Botley.

2.0 Introduction of the Site

A satellite image to show the approximate area of the site in question – boundary outlined in red.

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2.1 This site is approximately 17.3 hectares (42.8 acres) and is located north of Botley Road within the hamlet: Botley, and currently comprises agricultural land, with a few rows of houses off Botley Road on the southern border of the site. A border of trees and vegetation separates the site with other surrounding fields. The site does not fall within, and is not near any Flood Risk Zones associated with the River Chess, as established by the Environment Agency.

2.2 The site is situated directly adjacent to a bus stop, which serves bus routes 71 and 73, allowing easy access to , Old and New , Bois, Chesham, , , Coleshill, Penn Street and Winchmore Hill. Within Botley, there is the Hen and Chicken pub and Botley Stores. With the site’s proximity to Chesham train station (approximately 1.8km away), it enables the opportunity for easy access into central London, and the north-western suburbs via London Underground’s Metropolitan Line. The site is also approximately 1km away from Chesham Grammar School, Ley Hill School, Chesham and Ley Hill Golf Club and the two pubs in Ley Hill: The Crown and The Swan. Chesham town centre is approximately 1.8km away.

2.3 Botley is divided between Chesham and Latimer Parishes, and merges into the neighbouring village of Ley Hill.

A satellite image to show the available land – edged blue, compared to the representation site – edged red

2.4 As can be seen from the above image, a vast majority of the site in question is already available. Additional sections of land to the north and west of the site are available, and can also be put forward for consideration by the Council.

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3.0 Planning Policy Context of the Site

3.1 Council and South Bucks District Councils have been preparing a Joint Local Plan for the plan period 2014-2036 (since November 2015) due to pressure from the Government to speed up the process of delivering new Local Plans. Between 19th January 2016 and 14th March 2016, both Councils undertook their Initial (Regulation 18) Consultation Incorporating Issues and Options for the Local Plan. Further to this, the Councils are undertaking their Green Belt Preferred Options Consultation, which ends on 12th December 2016.

3.2 Although there is no formal Call for Sites process for the emerging Local Plan, any nominations for land may be put forward in writing in order to be assessed amongst those that were submitted for the Call for Sites for the separate Councils, before the decision was made to create a Joint Local Plan.

3.3 This report will use the evidence base that has been supporting Chiltern District Council with their process of compiling their new Local Plan:

. Buckinghamshire Housing and Economic Development Needs Assessment (HEDNA) Report of Findings (October 2016). . Draft Housing and Economic Land Availability Assessment (January 2016) (HELAA). . Buckinghamshire Green Belt Assessment Part 1: Methodology and Assessment of Land Parcels. . Chiltern and South Bucks Settlement Infrastructure Capacity Study: Report of Settlement Findings – Baseline Assessment (January 2016). . Sustainability Appraisal of the Chiltern and South Bucks Local Plan Initial Consultation (Regulation 18) Incorporating Issues and Options: Reasonable Alternatives Report (January – March 2016). . Chiltern and South Bucks Green Belt Preferred Options Consultation Document (October – December 2016). . Chiltern and South Bucks Green Belt Assessment Part 2: Draft Report

3.4 As a result of this level of evidence, as shown in the Issues and Options and Regulation 18 stages, this document is able to consider what the perceived key issues are within Chiltern and South Bucks Districts. The Councils will need to address these issues, whilst also adjusting the strategies accordingly to account for pressures from national planning policy and the Duty to Co-operate

3.5 The Visions and Objectives on the emerging policy and its ‘Broad Findings’ from the Regulation 18 consultations of the separate Local Plans included:

Chiltern: 1. General support of Core Strategy objectives. 2. Requested additional measures for protection of Green Belt and AONB. 3. ‘Improved design, enhancement of local character’. 4. HS2 (impact and opposition).

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South Bucks: 1. General support of Core Strategy objectives. 2. ‘Differing views for and against ‘maintaining the Green Belt’’.` 3. ‘Improved design reflecting local identity’. 4. Inclusion of SuDS and improved river corridors.

3.6 With the Regulation 18 Incorporating Issues and Options Consultation Document, suggestions for Built Area Extensions (BAEs) into the Green Belt were put forward. These were subject to further assessment, within the Preferred Options Document. Whilst assessing the BAE suggestions, it is vital to assess their value as part of the Green Belt, and also its value in terms of heritage and historical features, landscape features, and most importantly, its impact on Chiltern’s Area of Outstanding Natural Beauty. The NPPF puts forward that AONBs should be given the highest amount of protection (for its scenic landscape value and the conservation of wildlife and cultural heritage).

3.7 Although potential BAEs have been put forward by the Issues and Options document and the later Preferred Options document, it is still important to assess other options, such as the release of smaller areas of the Green Belt, like the site in which this report relates. It is later demonstrated in this report that the site in question puts forward a more beneficial alternative than the BAE option for Chesham.

3.8 More recently, Chiltern and South Bucks’ Green Belt Preferred Options document outlines that the key issues that the Councils need to address are:  The level of development that should be planned for, taking account of overall development opportunities, policy and environmental constraints, deliverability and the scope to secure sustainable development within the Local Plan area and wider sub-regional context  A review of the Green Belt and whether land could in principle be removed from the Green Belt to help contribute to meeting development needs, namely whether exceptional circumstances exist for a Green Belt change and whether or not a change will significantly harm the purposes of including land in the Green Belt  A Green Belt Development Options Appraisal taking into account the Green Belt Assessment to-date, other on-going technical work such as Sustainability Appraisal, infrastructure needs, impact on the Chilterns Area of Outstanding Natural Beauty and other information such as relevant consultation responses at Issues and Options and additional information provided by those promoting site options  Infrastructure requirements necessary to support the level of planned development

Notwithstanding the fact that the updated HEDNA (September 2016) reduced the housing need very slightly from 15,100 to 14,700 dwellings, Chiltern and South Bucks District Councils cannot deliver a substantial proportion of this (5,800 dwellings –which is almost 40% of the total assessed need). This figure already encapsulates how the Councils are not preparing their Local Plan in order to deliver the Objectively Assessed Need. This is fundamentally against the requirements of the NPPF, and therefore would not be deemed as sound by the Planning Inspectorate.

3.9 In relation to the above, South Bucks and Chiltern District Councils are attempting to direct some of the unmet need to Aylesbury Vale District. Yet, Aylesbury Vale District Council is currently unable to demonstrate sufficient suitable sites in order to deliver their own housing need within their Draft 6

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Local Plan. In addition to this, Aylesbury Vale District Council have stated that they are ‘robustly challenging’ the figures which have been put forward that outline the quantity of unmet housing need which is being directed at them – this portrays the lack of consensus between the Local Authorities in relation to this.

3.10 Further to the BAE options as set out in the Issues and Options document, the more recent consultation document puts forward a refined set of preferred options for land to be removed from the Green Belt. An analysis of the North East Chesham preferred option will be discussed in more detail in Section 7 of this report.

4.0 Identification of Development Needs & Potential Land Supply

4.1 Development Needs & Market Areas Before discussing the potential land availability for housing throughout Chiltern and South Bucks, it is apparent that the development needs should be established. The Consultation Document identifies that the new Local Plan needs to ensure that at least the full Objectively Assessed Housing Need is targeted and delivered.

4.2 Within its conclusions, the ‘best fit’ approach is described as a means by which housing and economic market areas are defined for plan-making purposes. For the emerging Local Plan, Buckinghamshire Housing Market Area has been seen to be the ‘best fit’, with part of South Bucks District falling within Berkshire Housing and Economic Market Area.

4.3 From this, it can be understood that respective assessments of other authorities within Berkshire and Buckinghamshire may overlap with Chiltern and South Bucks Districts. This, in turn, may impact these Housing Market Areas and the complex relationships within them. The Duty to Cooperate is therefore a very beneficial means for Councils to evaluate the relationships of these markets, and adjust their strategy accordingly.

4.4 Having said this, there are also some weaknesses present. Conclusion c) accurately relays that there is a very strong relationship between Chiltern/South Bucks and London. Yet, it later states that “ [...] given that London has a different plan-making arrangement and its housing and economic market area is defined as Greater London the strongest market relationships outside of London need to be considered.”

4.5 The fact that London has a different plan-making arrangement should not necessarily mean that its relationship with neighbouring authorities should be given less attention or underplayed in any way. It should therefore be apparent that when moving forward with the Local Plan, the consultation document should pay full consideration to the pressure which is created by London’s housing market, and its impact on the volume of housing in which Chiltern and South Bucks will need to deliver until 2036.

4.6 In light of the above discussion, the growth options that are taken forward in the consultation document must take into consideration the most appropriate ways in which to fulfil these sorts of Development Needs. Subsequent sections of this document discuss these options in greater detail but it is at this point asserted that due to the strong market relationships between London and

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Chiltern in particular, that certain settlements in the areas covered by the emerging policy will be more suitable to accommodate growth in response to this pressure than others. Such settlements include Chesham and its surrounding settlements, with its key transport links to London being, amongst other reasons, crucial in this relationship.

4.7 Alongside this, the general need to release Green Belt land to meet Development Needs is described in section 5 of this document. As such it follows that in addition to maximising development in the existing built area of these particular settlements, this area will require expansion into the Green Belt. The site in question, as part of the wider built area extension and the infilling of pockets of Green Belt land, in accordance with accompanying justification, should form part of this.

4.8 Land Availability for Future Development In addition to assessing the development need of the Local Authorities, it is evident that establishing available, suitable and achievable land in order to cater for the needs is vital. Within the ‘Development Opportunities’ section of the Consultation document, it identifies that the Housing and Economic Land Availability Assessment will be updated at least annually in order to get an understanding of supply opportunities and to “test whether they can be delivered within the plan period”.

4.9 Despite this assurance, Section 3 proceeds to explain that the current draft HELAA does not include open space within the built-up areas, or any development options within the Green Belt, that is not previously developed land. With regard to Green Belt land, a ‘Stage 1 Rejection’ was made to any land within this designation due to the fact that the Councils were undertaking a Green Belt Assessment themselves. The outcome of the Green Belt Assessment will provide the basis for the subsequent HELAA. This approach is understood, however it seems that discounting open space and Green Belt sites from the document is unhelpful. This is because the HELAA should provide a full and proper assessment of the available sites. It is later established that release of land from the Green Belt is an inevitability for the Council in order to ensure that there is a sufficient land supply to cater for the increasing demand.

4.10 The above is reinforced by the fact that within the Consultation document, Spatial Strategy Options present the likelihood that Built Area Extension(s) into Green Belt land is necessary in order to meet the Development Needs. Although this broad concept is accepted by both Councils, more thorough assessments need to take place in order to examine individual sites. With the current approach, the draft HELAA does not do this, therefore it is asserted that with the further development of the Joint Local Plan, carrying out this analysis of all sites at every possible stage is necessary.

4.11 In particular, the proposed Botley land to which this document relates was subject to a ‘Stage 1 Rejection’ due its Green Belt status. However, when compared with Chesham’s BAE option in the Issues and Options document, and the smaller BAE option which was put forward in the Green Belt Preferred Options document, the suitability of bringing this site forward towards the release from the Green Belt is clearly demonstrated. This would suggest that, given appropriate analysis, there are sufficient suitable sites to fulfil Chiltern and South Bucks’ Development Needs, and the land in question forms part of these. The HELAA needs to engage sooner with sites such as the one in question – as if it had, the positives associated with the site in question would have been determined. The subsequent section will analyse the strategic options, as set out in the consultation document, and put forward suggestions as to the most effective options. 8

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4.12 More recently, it has been established that there is an unmet housing need of 40% of the total Objectively Assessed Need / 5,800 dwellings for Chiltern and South Bucks Districts. This issue is further exacerbated by the dependence of Aylesbury Vale District Council (in the Duty to Cooperate) to take on the displacement of housing, as is required by the Objectively Assessed Need. As can be seen in the most recent version of the emerging Vale of Aylesbury Local Plan (July 2016 Draft), there is an acknowledgement of their lack of ability to deliver the housing requirement for adjacent Local Planning Authorities – including Chiltern and South Bucks. As a result of this, it is asserted that Chiltern and South Bucks must take on a new approach with their spatial strategy, and consider more Green Belt areas for release, for use as residential development.

5.0 Spatial Strategy Options for Chiltern & South Bucks District Councils

5.1 The Councils’ Strategic Approach As previously mentioned, the Issues and Options Consultation Document states that there “will be a significant gap for unmet development needs in the plan area unless further site options can be identified or new development opportunities can be provided within the Green Belt” (paragraph 3.7). This point is reinforced within the Green Belt Preferred Options Consultation document.

5.2 The previous Consultation document addresses the primary visions (mentioned in paragraph 3.5 of this document) and draws upon these. In addition to this, it is stated that the new Joint Local Plan will “reflect the emerging joint local plan evidence base” (paragraph 4.4 of the Issues and Options Consultation document). Although it is important to take into account the conclusions of the previous separate Local Plans, it is considered to be vital to utilise the findings of the Joint Local Plan. As it has been previously discussed, the primary focus for the emerging Local Plan is the fulfilment of an accurately established Development Needs and the continuing updating of the evidence base.

5.3 It is therefore apparent that in order to achieve the main objective of Development Need delivery, the removal of land from Green Belt designation, such as the site in which this document relates, will be necessary. The Council also appreciates this notion in its acceptance that “there are exceptional circumstances to review the Green Belt”. The Options, as put forward by the Councils in the Issues and Options Consultation document, will be assessed in more detail in the following section.

5.4 Spatial Strategy and Assessment of Options As highlighted above this assessment of the spatial options is set against the site at Botley to which this document relates, and comments are made within this context. Due to some of the Options having a similar approach towards delivering Development Needs, they will be assessed together. Certain options (including Option K) will also not be assessed in this representation, as they are not seen to be relevant to the site in question.

5.5 Options A & B These options will be assessed as a group, due to its similarity in its approach to increasing development opportunities within existing built-up areas. Option A seeks to make more efficient and effective use of land within existing built-up areas, and Option B puts forward need to review the purpose and function of existing areas of special control. It is evident that striving for an efficient and effective use of land within existing built-up areas should be a necessity for both Councils. This is due to increasing the sustainability of future development as much as possible. Additionally, the relocation of open spaces is believed to offer more benefits than simply the creation of more

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development opportunities in built-up areas. The replaced open spaces are compatible with the Green Belt, and therefore means that a heightened level of protection of Green Belt function can be achieved over the potential alternative of more built development in the Green Belt. In carrying out this option, it is seen that the protection of the AONB from development will occur – although it is still asserted that the release of Green Belt land is still required.

5.6 The reviewing of Residential Areas of Special (Chiltern) / Exceptional (South Bucks) Character, as set of by Option B, is also encouraged. Within the Chilterns, these locations are referred to as ‘Areas of Little Change’ and have been given policy weight with CS21. This outlines that the special character should be retained and preserved throughout both the Chilterns and South Bucks. However, it is perceived that additional restrictions are being made on these areas, when these areas could be used in order to cater for additional development. In addition to this, it seems that Chiltern District Council’s CS20 of the Core Strategy seeks to encourage development that respects the design of neighbouring environment, thus incorporating a similar approach to that of CS21 (but without adding further restrictions).

5.7 In relation to the above, it is believed that a review of such areas is necessary, and as a result it is emphasised that both Options A and B must be pursued in order to allow greater urban efficiencies and create more development opportunities in the existing built-up areas of Chiltern and South Bucks.

5.8 Options C, D & E Options C, D and E propose built area extension(s) to the principal settlements within and on the edge of Chiltern and South Bucks, and also to a wider range of smaller settlements. It has been previously established that both South Bucks and Chiltern District Councils acknowledge the existence of exceptional circumstances in which warrants a Green Belt review. Furthermore, it will also be necessary for a wider policy-based exploration of the approach to take place (as recommended through Options C, D and E. As a result, it is viewed that all of these options should be carried out in order for the Councils to demonstrate that there will be a delivery of the required Development Need for the plan period.

5.9 Although it is believed that all of the above options need to be explored further, different settlements are able to accommodate different levels of growth. This is also recognised in the Chiltern and South Bucks Infrastructure Capacity Study. Growth should therefore be directed in the most sustainable locations – the two principle towns (Chesham and Amersham) and their surrounding settlements. The site in question is located very close to Chesham, and as such, should be viewed preferably in terms of its sustainability.

5.10 Options F & G Options F and G propose, respectively, a review of settlements within the Green Belt with a view to remove those which are larger and more sustainable, and a review of the inner Green Belt boundaries. Both of these options propose smaller scale changes to the Green Belt boundaries to better reflect the relationship between built-up areas and the open Green Belt, in order to create development opportunities where appropriate. It is due to this that they are assessed together. A smaller scale review of Green Belt boundaries in the manner proposed to bring certain built-up areas out of the Green Belt will allow for significant improvements in effective and efficient use of land in such locations. Settlements such as Botley would be included in this review. The opportunities

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created by these options would be invaluable for delivering sustainably located future development. As a result, both of these options should be reviewed by both Councils, and the site in question should put forward a valuable location for future development. As part of these options, it will be seen that there is substantial development potential within these smaller pockets of Green Belt land, which would enable the pressures on local services to be spread across different settlements within the two Districts.

5.11 Option H On the same merits as the above, it is affirmed that Option H, which includes a review of the scope for allowing limited infilling within villages and generally built up frontages within the Green Belt, needs to occur for the emerging Local Plan. Villages still represent existing built-up areas which do and will have opportunities for certain scenarios of infill that represent sustainable development, increasing the efficiency of land use even in smaller existing built-up areas. It is for this reason that infill sites should be considered by both Councils.

5.12 Option I Option I refers to the extension(s) of other settlements such as the larger villages. This puts forward a similar approach to that of Options C, D and E. It is on the same merits as for those Options that this Option should also be explored further where the settlements in question are capable of accommodating such growth in a sustainable manner. The site in question provides a good example of how an extension to the existing built-up area of a village could be a beneficial means of providing additional land for future development.

5.13 As a result of the preceding discussion throughout this section it is considered that all options require further exploration. The options put forward by the Councils essentially put forward approaches that increase delivery within existing built-up areas and approaches which allow for the release of Green Belt land throughout different settlements. The discussions have shown that both of these mechanisms need to explored in full, in order to meet the Development Needs of Chiltern and South Bucks. Consequently, Option L needs to be pursued.

5.14 It should also be noted that in establishing the distribution of development throughout the two Districts, the Development Needs in the more constrained area of the Chilterns should not be displaced to South Bucks. The allocation for future development needs to take account of the location of different levels of Development Needs and land supply. This should be centred in and around Chiltern’s well-connected principal settlements, such as Chesham. The following section will expand further on this notion, using Chiltern’s evidence base.

5.15 The Built Area Extension Option for Chesham, as set out in Appendix 2 of the Chiltern and South Bucks’ Regulation 18 – Incorporating Issues and Options Document, is shown in full in Appendix B of this document. This option identifies an area east of Chesham’s primary built-up area, as one in which could be an extension to the existing built area of the town. It should be noted that although it would be in a sustainable location, it would enable the merging of Chesham, Botley, and . This is particularly notable, since Botley has already merged into Ley Hill. This Built Area Extension option could therefore mean that three settlements: Chesham, Botley and Ley Hill would be coalesced. This conflicts with one of the main purposes of the Green Belt, as set out in the NPPF.

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5.16 Green Belt Preferred Options The work which has been set out in the Green Belt Preferred Options document is not fully complete, but has been published in order to allow for public consultation. As is explained throughout this document, it is considered that further work should be undertaken in order to expand the options for Green Belt release. It is considered that the release of a higher quantity of smaller areas of Green Belt land (such as the one in which this report relates) would be less detrimental to the character of the Districts than the release of fewer larger areas of Green Belt land. This is due to the demand for services being spread across the Districts, as opposed to a higher strain on services in one, or just a few, particular settlements.

5.17 Further to the Issues and Options Consultation, within the Green Belt Preferred Options, Preferred Option 1 to the North East of Chesham puts forward a site of 57.26 ha (with an estimated developable area of 26.1 ha) (as shown in Appendix D). This proposed BAE also causes the coalescence of Chesham, Orchard Leigh and Lye Green. The merging of these settlements would detrimentally impact the rural character of Orchard Leigh and Lye Green, and would again conflict the key purposes of the Green Belt – resulting in the sprawl of a large built-up area and the encroachment on to countryside.

5.18 When assessing the site in question compared with the Preferred Option North East of Chesham, it can be seen that the release of Green Belt land from Botley would not result in the sprawl of a large built up area, and would have a limited impact on the encroachment of the countryside. The site in question is also located relatively sustainably, and would not cause the merging or coalescence of settlements. The release of the land in question from the Green Belt would form a natural growth of Botley, and provide much needed housing.

5.19 Although it is appreciated that the site in question has not formed any previous representations, it is considered that Chiltern and South Bucks’ emerging Local Plan must consider more suitable sites which could be released from the Green Belt. There are many available and more suitable sites for Green Belt release which have not been considered, and this further represents the unsound nature of the preparation of the joint Local Plan. As previously mentioned, the way in which the emerging Local Plan has been prepared is currently not consistent with the aims of the NPPF – especially with regard to the provision of the Objectively Assessed Need throughout the Districts. As such, a further investigation in to the Green Belt release options needs to occur, including a sincere consideration of the site in question.

6.0 Evidence Base

6.1 It has already been set out that it is vital to consider development options in settlements on the edges of primary built-up areas in order to deliver the required levels of development. As a result, it is crucial to clearly establish how and why the settlement and site in question needs to play a part in this delivery. As in the previous section, it is reiterated that the following analysis is put forward in relation to the proposals to which this document relates, and therefore only the most relevant aspects of the evidence base are given full consideration.

6.2.0 RESIDENTIAL DEVELOPMENT NEEDS AND OPPORTUNITY IN BOTLEY (BUCKS HEDNA ASSESSMENT UPDATE OCTOBER 2016 & CHILTERN AND SOUTH BUCKS SETTLEMENT INFRASTRUCTURE CAPACITY STUDY)

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6.2.1 As already set out, a comparative assessment of the Development Needs in Chiltern and South Bucks (as described in the Buckinghamshire Housing and Economic Development Needs Assessment 2015 Report of Findings Consultation Draft, Jan 2016) against potential development land supply (as described in January 2016’s Draft Housing and Economic Land Availability Assessment) determines that Green Belt release to create new Development Opportunities is a requirement.

6.2.2 Specifically, it is asserted that a review of settlements within the Green Belt is necessary in order to explore development potential and allow for small-scale releases which would meet the test of exceptional circumstance to undertake a change, not undermine a purpose of the Green Belt and be capable of defining a new durable and defensible boundary. This is particularly key in settlements that are sustainably located. Spatial Strategy Options F and G address these.

6.2.3 Further to this understanding, more evidence is available which demonstrates the significant development needs that are being faced. This reinforces the obligation of releasing land from the Green Belt.

6.2.4 The updated HEDNA (from October 2016) relays that the total dwelling requirement between the period of 2013 – 2033 is 14,700 new dwellings and 10 net hectares of employment land (industrial warehousing and offices) arising in Chiltern and South Bucks districts. Although this figure has been reduced slightly since the previous HEDNA document draft, the Councils still accept that they are not able to meet this demand. The unmet need is a substantial figure of 5,800 dwellings, which is just below 40% of the total requirement. As a result of this, there is more pressure on the Green Belt Preferred Options Consultation in order to help contribute towards this unmet need.

6.2.5 The previous paragraph can be understood in conjunction with the data set on the following page – taken from the ‘HMAs and FEMAs in Buckinghamshire – The Impact of the Joint Plan for Chiltern and South Bucks’ document (January 2016). The below chart shows that there are substantial commuting flows to London from the Chilterns and South Bucks, which is indicative of the market pressures that Chiltern and South Bucks face as a result of its proximity to London. Whilst this does relate to South Bucks as well as Chiltern, it is emphasised that the major public transport linkages (London Underground Metropolitan line) between London and three of Chiltern’s principal settlements (Chesham, Amersham and Little Chalfont) are indicative of Chiltern’s primacy in this regard.

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6.2.6 The NPPF, in its core planning principles, asserts the importance of guiding development to sustainable locations: “Actively manage patterns of growth to make the fullest possible use of public transport, walking and cycling, and focus significant development in locations which are or can be made sustainable”. (Paragraph 17).

The site in question is located approximately 1.8km from Chesham train station, which is one of the primary public transport links within the District. The site’s relative sustainability is a big consideration in the justification of making it available for future development.

6.2.7 In this regard, the Chiltern and South Bucks Settlement Infrastructure Capacity Study makes it more evident that the presence of such infrastructure must guide development towards the key settlements within the Chilterns. The document highlights the development opportunities presented by the stations (“Rail and underground lines and stations”) as well as the fact that the Metropolitan line holds some capacity for growth due to existing investment on signalling and new trains. It is upon this, in addition to the discussion in previous sections of this document, that the case for significant sustainable growth in Chesham and its neighbouring settlements is set, and the sustainability of the site in question is further evident.

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6.3.0 HOUSING & ECONOMIC LAND AVAILABILITY ASSESSMENT (HELAA) – JANUARY 2016 DRAFT

6.3.1 Owing that there is an established need to bring sites out of the Green Belt in order to deliver residential development in and around the key settlements, such as Botley, the following analysis of the January 2016 Draft HELAA demonstrates that sites within Botley were only rejected at the 1st stage due to its Green Belt status, and not for any other reason.

6.3.2 The sites within Botley (as seen in Appendix A of this document), were rejected at the 1st stage due to its Green Belt status. The Council’s justification for rejections made on this basis is as follows:

“The NPPF identifies these sites should only be developed in very special circumstances. A separate Green Belt Assessment is being carried out, to consider parcels of land against the purposes of the Green Belt. Any site currently within the Green Belt will be identified as being unsuitable at this stage. If the Green Belt Assessment identifies the site performs poorly in terms of the Green Belt functions, or options are taken forward after testing, they will then be subsequently assessed through the HELAA process for their development potential” (page 12).

6.3.3 At the present stage, the methodology for the Green Belt Assessment has been published and the site in question forms (as part of a wider Green Belt Parcel) part of this assessment process. However, it is acknowledged that the current draft form of the HELAA rejects Green Belt sites in accordance with the rationale set out above. Relevant findings from the Green Belt Assessment will now be discussed in more detail.

7.0 BAE/Infill Development Options & Green Belt Assessment in Botley

7.1 Policies GB4 and GB5 of Chiltern’s Local Plan (Saved Policies) (1997) identify particular localities in which limited infilling of development is acceptable. Botley is included within these areas. This already shows that there is some leniency towards allowing some development within the settlement.

7.2 Green Belt Assessment Part 1 ARUP carried out a Green Belt Assessment as part of the evidence base for Chiltern District and South Bucks District Councils. The site in question forms a section of Green Belt Land Parcel 15, (and partially takes up part of Parcel 16b) as part of this document. A summary of the assessment of Land Parcel as a whole is set out in Appendix C. Even though part of the site is within Parcel 16b, the site in question relates mostly with Parcel 15, and so the subsequent assessment will focus on this. It is also important to assess options in relation to the five purposes of the Green Belt:  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 (NPPF, paragraph 80)

7.3 As previously mentioned, in the Issues and Options document, a BAE option for Chesham was suggested by the Council for further testing (as shown in Appendix B). This area of land falls within Parcels 13a and 16b in ARUP’s Green Belt Assessment. When assessing these parcels against the

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purposes of the Green Belt, Parcel 16b was seen to have a fairly significant role in preventing sprawl of Chesham and the merging of the town with Bovingdon and Botley and protecting the openness of the countryside. Land parcel 13a also plays an important role in preventing the outward sprawl into open land, including Lycrome Wood. This area of woodland also provides a durable boundary at the edge of the large built-up town of Chesham. As a result of these findings, although it is appreciated that the suggested BAE is only indicative at this stage, it can be established that it meets many of the purposes of the Green Belt thus is not appropriate for development. This is especially true when compared to the site in question, as this puts forward a more favourable option that does not allow the coalescence of 3 settlements.

7.4 It was established that Land Parcel 15 as a whole did not meet all of the Green Belt purposes, as set out by the NPPF. The area fails to restrict sprawl of large built up areas. It received an average score when assessing it against the area’s ability to prevent towns from merging – it was specifically noted that the Botley and Ley Hill section of Green Belt Parcel was less important for preventing the coalescence of settlements. The overall land parcel also scored 3/5 when assessed against its ability to safeguard the countryside from encroachment. Finally, when analysed against whether the land preserves the setting and special character of historic towns, the land parcel failed to meet this purpose.

7.5 As a result of the above findings, it was found that this area did not meet many of the purposes of the Green Belt and therefore was recommended that the Council should consider this land parcel further, with a specific focus on the ‘Botley area’ in order to review the area for release from the Green Belt. It was also noted that the area was not particularly ‘open’, with no long views throughout land parcel due to areas of woodland and high hedgerows and trees bordering the road. Any development on the site in question would therefore not be to the detriment of the openness of the Green Belt in this area, and should therefore be seen very favourably, compared with many other areas within the Green Belt.

7.6 In addition to this, the development of the site in question would essentially extend the existing residential row of dwellings within Botley, and would create a new Green Belt boundary that would connect well with the surrounding barriers. This site, once developed to residential, would not impact the street scene from Botley Road, due to the way in which it would be set back from the road, and the existence of the high hedgerow and trees along Botley Road’s boundary. There would be minimal detrimental impacts on the amenities of local residents, as there are relatively few neighbouring dwellings. As it has been previously demonstrated that the development potential described would not cause undue harm to the Green Belt function of the site or the wider parcel 15, and that the land is preferable for the infilling of land for residential development.

7.7 Draft Green Belt Assessment Part 2 The Green Belt Assessment Part 2 forms part of the evidence base, and puts forward a more detailed assessment of the identified areas which were established in Part 1. In addition to this, it includes an assessment of proposals made to the Call for Sites in the Regulation 18 Consultation. This part of the Green Belt Assessment also seeks to establish whether there are exceptional circumstances that would justify the alteration of the Green Belt boundary.

7.8 Within this document, there is an assessment of ‘Area north east of Chesham (Lye Green Road Area)’/Reference no. 1.01 (map of area is shown in Appendix D). It is stated that the boundary is 16

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permanent and defensible in accordance with the requirements of the NPPF. It also stated that “there would be limited conflict with Green Belt purposes”, and that the new boundary would prevent sprawl and joining of Chesham and Botley or Berkhamsted. However, there has been no consideration to the merging of Chesham with Lye Green and Orchard Lee, which are both hamlets north-east of Chesham. In the event of this area being released from the Green Belt, the setting and special character of these hamlets would be severely harmed, and this would further encourage the sprawl of a large built-up area. As a result of this, this option would conflict with some of the key Green Belt purposes, as set out by the NPPF.

7.9 The settlement of Botley (Reference No. 1.02 – shown in Appendix E) was also considered within the Green Belt Assessment Part 2 document. However, due to a supposed lack of permanent features which would make up the boundary of the area, there was no further assessment on the purpose of the Green Belt in this area, and no exceptional circumstances assessment. This could have been rectified by altering the northern boundary of the area so that it was in line with the hedges within the fields to the north of this proposed area, which would have only slightly increased the overall area. This approach is seen to be inappropriate and negative, as the ‘lack of permanent features’ does not reduce the suitability of the wider site for Green Belt release. This negative approach is especially obstructive when Chiltern and South Bucks District Councils are unable to demonstrate a five-year housing land supply, and have an unmet need of 5,800 dwellings within their Plan period. It is recommended that in addition to the consideration of the site in question, the area which is outlined in 1.01 is examined accordingly, and can provide an extension to this.

7.10 As a result of the above discussion, it is demonstrated that the site in question should be assessed with the settlement of Botley (site reference 1.01), in order for a more comprehensive analysis to occur. The site in question, in addition to the settlement of Botley, do not currently play a vital role as part of the Green Belt, and a sizable proportion of the considerable level of unmet need can be met within this area.

8.0 Conclusions

8.1 Throughout this document, the need to deliver Green Belt sites with the infilling of settlements has been demonstrated. Botley’s proximity to Chesham and its services makes it an ideal location, and presents a very sustainable means of providing the much needed housing within the District. As it has been previously discussed, the area of Green Belt in which the site lies (and its wider land parcel – number 15) plays a negligible role as part of the functional Green Belt. The site itself relates well to the existing settlement, and when developed in the manner proposed, has the ability to form a strong and permanent Green Buffer to both prevent the coalescence of Chesham and Botley, and assist in safeguarding the countryside from encroachment. The site in question is not part of an AONB, and is not as risk of flooding.

8.2 The Built Area Extension option for Chesham (in the Issues and Options Document) does not present a suitable site for the removal of the Green Belt, especially as it would enable the merging of Chesham, Botley and Ley Hill. This would be inappropriate, especially since Botley is already contiguous with the neighbouring village of Ley Hill. Further to this, the refined Preferred Option of a BAE to the North East of Chesham would also enable the merging of Chesham with two hamlets: Lye

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Green and Orchard Leigh. The unique character of these hamlets would be detrimentally impacted by the sprawl of the large built-up area of Chesham. The site in question provides a much more preferable solution to the provision of housing within the District, as it does not enable the merging of settlements, and it will not have a substantial impact on the rural character of the area.

8.3 The land in question has been shown to be suitable, available and achievable. The boundaries are permanent and defensible, as they are bounded by Botley Road and well-established hedges. It is on this basis, therefore, that the land is submitted for consideration in relation to the consultation document; and it is on this basis that its suitability to contribute towards the infilling of Green Belt land is asserted in the strongest terms.

8.4 Within this report, the issues associated with Chiltern and South Bucks’ failings in relation to the Duty to Cooperate have been discussed. It has also been discussed that the Councils’ approach is currently flawed in relation to their formation of the Local Plan. As a result, the 40% unmet housing need, and the lack of attempt to deliver appropriate sites for residential development, indicates that it is not in accordance with the aims of the NPPF. Consequently, it is advised that there is a reassessment of the Preferred Options, and the site in question should be considered for further analysis.

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Appendix A – HELAA Sites Rejected within Botley

Site 14: Land to the Rear of the Swan, Ley Hill, Blackwell Hall Lane – Stage 1 Rejected due to its Green Belt status (and not previously developed land) Site 15: Land north of Cherry Tree Farm, Ley Hill – Stage 1 Rejected due to its Green Belt status (and not previously developed land) Site 26: Land to the south of Kiln Lane, Ley Hill – Stage 1 Rejected due to its Green Belt status (and not previously developed land)

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Appendix B – Regulation 18 Issues and Options Green Belt Strategic Option in Chesham

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Appendix C – Land Parcel 15 Green Belt Assessment

Approximate site boundary, edged red

General Area Land Parcel 15 Area (ha) 313.2 Purpose Criteria Assessment Score (1) To check the (a) Land parcel is at the The land parcel is not at the edge of a distinct large FAIL unrestricted edge of one or more built-up area sprawl of large distinct large built-up built-up areas areas. (b) Prevents the (Same as above) 0 outward sprawl of a large built-up area into open land, and serves as a barrier at the edge of a

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large built-up area in the absence of another durable boundary. Purpose 1: Total Score 0/5 (2) To prevent Prevents development The land parcel forms part of a wider gap between the 3 neighbouring that would result in non- Green Belt settlements of Chesham to the west towns from merging of or significant and Bovingdon to the east. The south of the parcel merging erosion of gap between around Botley and Ley Hill is less important for neighbouring preventing the coalescence of settlements, given the settlements, including level of existing development, though the overall scale ribbon development and openness of the gap is important to restricting along transport their merging (as well as protecting the gaps to the corridors that link Green Belt settlements of Botley and Ley Hill). settlements. In addition, it should also be noted that, at the local level, the parcel plays a role in protecting the gap between Chesham, Lye Green and Orchard Leigh, identified as Rows of Dwellings in the Chiltern Local Plan, restricting them from coalescing. Purpose 2: Total Score 3/5 (3) Assist in Protects the openness of Less than 5% of the land parcel is covered by built 3 safeguarding the countryside and is form, which consists of ribbon development along the countryside least covered by Jasons Hill and more concentrated development i the south of the parcel around Botley. from development. encroachment The interior of the parcel has a rural character, especially the east end, consisting of farm land for arable and pasture land. The topography is generally flat however there are no long views due to the areas of woodland that interrupt and the high hedgerows and trees that borders most of the roads on the perimeter, and Jasons Hill that intersect north to south through the parcel. The centre and the west parcel has more development, with a large collection of houses in Botley as well as the church, school, and playing fields, and with the addition of ribbon development along Jasons Hill. These urbanising influences give the parcel a largely rural character.

Purpose 3: Total Score 3/5 (4) To preserve Protects land which The land parcel does not abut an identified historic 0 the setting and provides immediate ad settlement core and does not meet this Purpose. special wider context for character of historic settlements, historic towns including views and vistas between the settlement and the surrounding countryside. Purpose 4: Total Score 0/5

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Appendix D – Preferred Option 1: North East of Chesham

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Appendix E – Reference No. 1.02 Botley – Green Belt Assessment Part Two Draft Report (October 2016)

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