Transport  Economy  Environment Buckinghamshire County Council County Hall, Walton Street Rob Smith Aylesbury, Buckinghamshire HP20 1UA Director Growth, Strategy & Highway

Spatial Planning strat [email protected] Wycombe District Council Queen Victoria Road High Wycombe HP11 1BB

Telephone 01296 385000 www.buckscc.gov.uk

Submitted by email to: Date: 19 July 2019 [email protected]

Dear Mr Callaghan,

Princes Risborough Expansion – Supplementary Planning Document (SPD) Consultation

Thank you for consulting Buckinghamshire County Council (BCC). BCC welcomes the opportunity to comment on the Princes Risborough Expansion Supplementary Planning Document consultation. BCC appreciates previous engagement with Wycombe District Council on the development of this SPD. We hope these comments help to further develop the SPD and looks forward to continuing to work with you on this.

Please find our main comments set out below, more detailed comments on the plan can be found in appendix 1.

Transport

General principles/ strategic comments:

• There should be safe and attractive access to the station(s) from the expansion area for active modes of travel, these routes should proceed all the way to the train station rather than stop at the edge of the expansion area. This includes access to Princes Risborough and Monks Risborough station; this will assist in avoiding additional car trips to stations through the provision of viable, attractive alternatives. • There should be access to the existing town centre by active modes to reduce segregation of the development area and the exiting town centre and other services (such as existing schools). • The expansion area should be accessible and inclusive to all. • The Phoenix Cycling Trail joins at Princes Risborough and links to Thame. Consideration should be given for linkages to existing cycling provision and Rights of Way network.

• There should be considerations for cyclists as well as provision of a pedestrian link through the green corridor open space along Crowbrook stream. • The Healthy Streets principle focuses on indicators for a healthy street environment. Consideration of the indicators to create Healthy Streets should be given. The 10 indicators of Healthy Streets include: o Easy to cross o Shade and shelter o Places to stop and cross o Not too noisy o People choose to walk, cycle and use public transport o People feel safe o Things to see and do o People feel relaxed o Clean air o Pedestrians from all walks of life • We are supportive of the new road to provide relief for the A4010 through Princes Risborough Town Centre. • Consideration should be given to the design and size of the roundabout (Longwick Road/ new road roundabout) to be in keeping with the nature of the development. The design of the roundabout should take into account crossings for pedestrians. • There needs to be a suitable route for a bus service that combines a reasonably direct route with access from residential areas with 250m – 400m. Road widths should also accommodate buses passing each other. • The option of a flexible Demand Responsive bus service should be considered as well as a fixed route. • Suitable bus stop infrastructure should be included e.g. bus stops, shelters, Real Time Information displays) • We are supportive of early delivery of pedestrian underpass to help set habits towards sustainable modes and provide mitigation for the expansion area.

Ecology

The consultation documents highlight that there are two non-statutory sites designated for nature conservation interest within the area (Longwick bog LWS & Kingsmead meadow and ponds BNS). Additionally the area is 5km of the Chiltern Beechwoods Special Area of Conservation (SAC). Development on or adjacent to non-statutory sites should be avoided, and an Appropriate Assessment may be required to determine whether the proposals could impact the SAC.

In addition, the impact of the proposals on existing Priority Habitats (NERC Act, 2006) should be assessed and opportunities for incorporating these into the design for the expansion area should be sought.

Established and potentially important hedgerows exist within the expansion area, which may contain mature/veteran trees. Retaining trees is recommended to reduce impacts on

biodiversity throughout the expansion area, and the impact on veteran trees will need to be properly assessed as these are considered an “irreplaceable habitat”.

It is recommended that a desk study is carried out to understand the distribution of legally protected and notable species in the expansion and buffer areas. Records can be obtained from BMERC (Buckinghamshire and Milton Keynes Environmental Record Centre). It is known, for example, that great crested newts, bats, otter, reptiles and badger exist within the expansion area. Protected and notable species are material considerations in planning applications and should be fully assessed and mitigated for, as part of any development application.

In relation to the planning of floodlights around the sports hub and elsewhere, it is important to ensure that the lights are directed to the ground and away from surrounding vegetation. This will ensure lights are only illuminating the areas necessary, and will reduce the impact on bats and other light-sensitive wildlife. Please refer to the current guidance on bats and artificial lighting1.

Potential severance for wildlife could become an issue, however with the proposed habitat corridor along the Crowbrook Stream, which connects the two non-statutory sites and Alscot conservation area; there is the potential to create an excellent network for biodiversity. Opportunities for “biodiversity net gain” are likely to be found in this area. Please note that additional habitat corridors may be required depending on results of detailed ecological surveys.

We hope that the Buckinghamshire and MK Natural Environment Partnership have been consulted as they will be able to provide more specific engagement on green infrastructure (covered in Section 3).

Archaeology

We would have liked to have seen a Heritage and/or Archaeology paragraph that acknowledges the requirement for archaeological assessment and evaluation/mitigation as set out in the NPPF Section 16 Conserving and Enhancing the Historic Environment and through the Wycombe Local Plan Policies CP11 and DM31.

Education

We acknowledge that much of what has been written has been agreed regarding education with our education services however, please see below our additional comments in relation to the policies affecting education provision.

• We would be supportive of a school in the south to ensure that most parts of the town are within a distance of 1km from their nearest school. • Thank you again for the opportunity to comment on the Princes Risborough Supplementary Planning Document consultation. If you have any further queries, please contact the BCC Strategic Planning team via the following email address: strat [email protected]

1 This is available at https://cdn.bats.org.uk/pdf/Resources/ilp-guidance-note-8-bats-and-artificial- lighting-compressed.pdf?mtime=20181113114229

Yours Sincerely

Rob Smith Director of Growth, Strategy & Highways Transport Economy Environment

Appendix 1

Section 2

Text Topic Area Comment Reference 2.1.3 Flooding Paragraph 4 of the Main Issues table should mention surface water flooding. Paragraph 5 should mention surface water flood risk as a constraint. 2.3.3 Transport Further consideration could be given to cycle parking which is required to help encourage cycling as a first choice for short trips. Please see BCC’s adopted Countywide Parking Guidance for cycle parking guidance. 2.5.2 Transport The flat topography identified also provides significant opportunities for walking which should be recognised.

Section 3

Text Topic Area Comment Reference Transport Safe and secure cycle parking is an important component to encourage cycling. Therefore consideration should also be given to delivering cycle parking within the local centre and 3.5.2 at both primary schools. Please see BCC’s adopted Countywide Parking Guidance for further details on cycle parking. Transport Whilst supportive of proposals for shared parking and drop off facilities, the document does not highlight the importance of this location for enabling sustainable modes of transport 3.5.3 to school. BCC are seeking to promote sustainable travel among school pupils and have our Getting to School Strategy. Transport The figure does not include reference to pedestrian and Fig 26b cycle movements to the primary schools. These are key sites that could be accessed via sustainable transport. Education We suggest replacing the word ‘including’ to ‘that could include green infrastructure features such as’ – For instance the local authority sustainability strategy that we are working 3.7.1 on as part of the Accelerated Change programme seeks to avoid green roofs on schools as they are a burden and costly both to install and maintain. 3.7.2 Flooding We would like to see balancing ponds changed to strategic basins 3.7.3 Flooding The additional measures identified could be more ambitious as there is no mention of SuDS within communal areas. This could include promoting of active rainwater harvesting and green roofs in these areas along with other multi-

functional SuDS. Transport A broader consideration should be made to ensure that plot sizes/shapes are suitable to allow cycles to be moved between the designated storage areas and the highway network without the need to move a motor vehicle to allow this. 3.8.1

Driveways and garages may need to be wider than the minimum standards to facilitate the encouragement of sustainable modes of transport.

Transport We are supportive of the need to provide a new road, following the proposed alignment. It is understood that detailed design on alignment is still to be undertaken.

There is limited detail in the SPD associated with the new junction between the B4009 to the new link road.

The SPD highlights:

Local Plan policy PR8 2. f) requires development to provide measures to deter through traffic on unsuitable routes including through Askett, Mill Lane, Crowbrook Road, and 3.8.2 Bridge Street/Church Lane, and achieve a safer environment for all road users. The specific measures are not detailed at this point although the indicative relief road design included a closure of the section of Mill Lane between Lower Icknield Way and the intersection with the new relief road. The Council is commissioning further work to consider the options to address these issues and to inform consideration of any planning applications in this area.

Engagement with BCC will be required in relation to the measures put forward to address these issues.

Transport Whilst supportive of electric vehicle charging point measures the wording of 3.8.4 is unclear. It is not explicit whether there is a requirement to include passive wiring at all residential developments. This section could be made clearer.

3.8.4 Where electric vehicle charging provision is being made there should be additional space allowed to enable the charging cable to be connected and cables to be used without leading to a hazardous environment for residents or road users.

Section 4

Text Topic Area Comment

Reference 4.2.7 Ecology In addition to our comments below we would like to see the Sub following additional points Paragraph • Green and brown roofs should be incorporated into 3 (Green the designs where possible Infrastructu • Landscaping proposals should include species rich re) hedgerows rather than walls and fences, and that species should be native and of local provenance. Using plant species that benefit pollinators is preferred. • Brown roofs are as good for wildlife as green roofs, and require less maintenance. • Sensitive lighting strategies must be designed into development proposals in areas prioritised for/or sensitive for wildlife in line with current guidance https://cdn.bats.org.uk/pdf/Resources/ilp-guidance- note-8-bats-and-artificial-lighting- compressed.pdf?mtime=20181113114229. This is particularly relevant for Section 4.4.2 (Green Lanes). GI1 Ecology There should be an emphasis on creating green space that is functional for both wildlife and people. GI2 Ecology Should remove the word “residential development” as this should apply to everything, not just housing GI4 Ecology Should include the word “hedgerows”

GI5 Ecology Should include hedgerows as well as trees

GI6 Ecology Landscaping should benefit wildlife Transport BCC has recently begun investigating use of the ‘Healthy Streets Approach’. This highlights that it would be good practice to ensure there is adequate shade and shelter throughout the entire local centre to make the area 4.2.8 accessible for all residents. We suggest that this approach and the associated principles are applied more broadly throughout the whole development. This will help to ensure it is accessible to all and that residents choose to walk and cycle. Transport Design principles for the northern school do not include any reference to sustainable transport. As previously commented BCC are promoting sustainable travel to schools through LTP4 Policy 11 and the Getting to School Strategy. We 4.2.10 believe encouraging sustainable transport should also be promoted through the design principles for both schools. It is understood that Alscot Green Lane will provide access to both the Local Centre and Primary School – will this provide problems at school drop off and pick up times? Transport We suggest that there may be opportunities to better integrate Longwick into the pedestrian and cycle network. Residents in Longwick will be within walking and cycling Fig 45 distance of the new local centre and other amenities. Therefore it is important to consider broader connectivity and chances for integration.

Transport We are supportive of the provision of foot and cycleways to connect with Princes Risborough station. However we note that on Figure 45 provision of the segregated route will cease prior to the station. The remainder of this journey should be 4.3.7 on suitable infrastructure for pedestrians and cyclists. This means ensuring the current route is safe, suitable and well-lit or identifying upgrades to achieve this. Similar considerations should also be made for access to Monks Risborough station. Transport We believe there is the risk that the western/north western part of the development could be severed by the relief road. 4.3.7 Therefore consideration needs to be given to the roads design, ensuring there are suitable and safe pedestrian road crossings. Transport We welcome reference to the provision of disabled parking spaces at SOS2. The provision of disabled parking should 4.4.1 also be included as a design principle at other key sites such as the local centre and medical centre. General Flooding This section is very specific in mentioning swales but no other comment: types of SuDS, we suggest that swales be used as an example as opposed to mentioned only this component

Section 5

Text Topic Area Comment Reference Transport Whilst the plan considers the need for additional secondary education there is no consideration given to the transport 5.2.2.3 impacts of this. We believe the plan needs to include an evaluation of this and ensure that there is suitable provision in place. Transport Parking considerations should also take into account 5.2.2.8 provision for disabled parking spaces and sustainable travel e.g. electric vehicle charging points.

Section Appendix 4

Text Topic Area Comment Reference Education Revised DfE guidance now recommends that costs are based on the average cost to build new schools (as published by DfE) – which would increase the cost of each primary school to £8,884,437 (total cost of £17,768,874). This figure would increase to £19,545,762 if we assume an additional 10% for sustainability design features