Classification: OFFICIAL PORep1510 (REDACTED) Page 1 of 104 Classification: OFFICIAL PORep1510 (REDACTED) Representations raised on behalf of The Trustees of Market Reading Field in response to the Chiltern and South Bucks Local Plan Green Belt Preferred Options Consultation December 2016 © TIM NORTH & ASSOCIATES LIMITED COPYRIGHT 2016 No part of this publication may be reproduced by any means without the permission of Tim North & Associates Ltd Page 2 of 104 Classification: OFFICIAL PORep1510 (REDACTED) PREAMBLE These representations have been prepared on behalf of The Trustees of Market Reading Field, the owners of a parcel of land situated off Eagle Close, Quill Hall Lane, Amersham, Buckinghamshire HP6 6LL, in response to the Chiltern and South Bucks Local Plan Green Belt Preferred Options Consultation October – December 2016. This response is required to be read in conjunction with earlier representations made on behalf of the same owners to the Chiltern and South Bucks Local Plan Initial Consultation Incorporating Issues and Options under Regulation 18 of the Town & Country Planning (Local Planning) (England) Regulations 2012. The earlier representations comprised a stand-alone document directed at planning considerations, alongside a separate Transport Sustainability and Access Feasibility Study prepared by PFA Consulting Plc; both documents proposing a mixed use or composite development on Market Reading Field. The earlier representations set out the landowners aspirations to create a small sustainable urban extension (hereinafter referred to as a SUE) to the main settlement of Amersham, catering for around 60 dwellings; a large area of public open space; 625 sq.m (6727 sq.ft) of Class B1(a)/(b) business units; along with a doctor’s surgery accommodating five practitioners. These subsequent representations comprise two separate parts. The first section is directed at those fundamental concerns surrounding the approach taken in arriving at the 15 preferred sites or options for removal from the Metropolitan Green Belt. These concerns do not relate to the underlying methodology chosen, which has resulted in the 15 preferred sites or options being identified for release from the Metropolitan Green Belt. The issue is whether the two Councils by pursuing an approach in identifying sites or options for removal from the Metropolitan Green Belt, independently from a comprehensive assessment of the extent to which their full objectively assessed housing needs (hereinafter referred to as FOAN) can be met in their respective administrative areas, has resulted in a restricted selection of reasonable alternatives in meeting both Councils’ FOAN. Page 3 of 104 Classification: OFFICIAL PORep1510 (REDACTED) Implicit in this approach is whether, consciously or not, the extent of unmet housing needs required to be accommodated in the adjoining Authority is greater than would otherwise be the case, had a more robust exercise been undertaken into satisfying both Councils’ FOAN in their respective administrative areas. The approach taken by the two Authorities is best illustrated by the Foreword to the Green Belt Options Consultation document in which it is said:- “A key part of the Local Plan will be to explore options for meeting development needs in the Green Belt that cannot be met within built areas, on previously developed land, nor can be met in areas outside of Chiltern and South Bucks. This work is not yet complete but has progressed sufficiently for Preferred Options to be identified and tested through public consultation. “ There is a clear implication in this statement, that the approach is to concentrate firstly on built up areas, then previously developed land, then areas outside of Chiltern and South Bucks District Council, before lastly considering releases of land from the Metropolitan Green Belt in Chiltern and South Bucks DCs’ administrative areas. The strategy is flawed in that it places reliance on meeting unmet needs in an adjoining authority’s area, before contemplating the release of land to better meet Chiltern and South Bucks District Councils’ FOAN. It is contended the last two stages should be reversed. This is particularly important seen in the context of a key issue to emerge from a summary of consultation responses identified by the Council’s consultants Golder Associates to the Vale of Aylesbury Consultation Draft Plan, in which overwhelming support was recorded from residents and other parties located in Aylesbury Vale District Council’s administrative area, for that Authority when contemplating providing for potentially 12,000 new homes to meet the unmet needs in South Buckinghamshire and High Wycombe, “to robustly challenge this allocation through the commissioning of an independent investigation into other areas’ allocation figures.” The second section of these representations considers the manner in which the site known as Market Reading Field, given Reference No. 4.085 was assessed in accordance with the selected methodology, following the submission of representations on behalf of the Trustees of Market Reading Field to the Chiltern & South Bucks Local Plan Initial Consultation Incorporating Issues & Options. A number of inconsistencies emerge from your Councils’ assessment of my client’s site. Page 4 of 104 Classification: OFFICIAL PORep1510 (REDACTED) The detailed representations raised on behalf of the Trustees of Market Reading Field went beyond an assessment of those parameters comprising the “The Buckinghamshire Green Belt Assessment Report: Methodology and Assessment of General Areas” prepared by Ove Arup & Partners, to incorporate a pre- and post-mitigation assessment matrix as part of a Sustainability Appraisal. In this way, the earlier representations raised on behalf of the Trustees of Market Reading Field went beyond issues surrounding Part 1 of the Buckinghamshire Green Belt Assessment, to include matters the subject of what is termed Part 2 of the same Green Belt Assessment where it relates to land in Chiltern and South Bucks District Councils’ administrative areas. This point aside, it is my client’s view that no proper consideration was given to the contents of the submitted representations, including the ability of the same land to meet unmet local needs. In particular, no attention was paid to assessing Market Reading Field as part of a recommended “sub-area” to General Area 22b. This is in spite of the Issues and Options document prepared under Regulation 18 of the Town & Country Planning (Local Planning) (England) Regulations 2012, showing the same land along with Quill Hall Farm, as one of four larger potential extension options to Amersham. Furthermore, at time when there is an absence of any firm commitment by the adjoining Authority to meet all of the unmet housing needs derived from Chiltern and South Bucks District Councils, no consideration was given to Market Reading Field as a potential “safeguarded (white) land” site. Page 5 of 104 Classification: OFFICIAL PORep1510 (REDACTED) IMPORTANT ISSUES ARISING FROM THE APPROACH IN IDENTIFYING THE 15 PREFERRED SITES OR OPTIONS One of the spatial strategies set out in the Issues and Options Consultation Document was Option C, suggesting built up extensions to a number of principal settlements in the two Councils’ administrative areas; Amersham being one of those settlements. A total of four built up area extension options were promoted in the case of Amersham, one of which comprised land known as Market Reading Field and Quill Hall Farm. The evidence base at the time of publication of the Issues and Options Consultation document included the “Buckinghamshire Green Belt Assessment Part 1A: Methodology” prepared by Ove Arup & Partners and dated 11th August 2015. The detailed assessment of individual “General Areas” of the Metropolitan Green Belt against the purposes of a Green Belt, together with the respective pro-forma assessment were not available to third parties at the time the consultation process on the Issues and Options document commenced. A separate document entitled “The Buckinghamshire Green Belt Assessment Report: Methodology and Assessment of General Areas” was published by Ove Arup & Partners on 7th March 2016. This document consolidated the individual Green Belt assessments undertaken by the same consultants on behalf of Aylesbury Vale DC, Wycombe DC and Chiltern and South Bucks DCs. It covers the entire Green Belt in Buckinghamshire, being one comprehensive document reproducing the information set out in “The Buckinghamshire Green Belt Assessment Part 1A: Methodology” where it relates to South Bucks and Chiltern DCs’ administrative areas. The only differences between the two Buckinghamshire Green Belt Assessments where they concern the methodological approach in assessing potential releases of land from the Green Belt, concern three areas. Firstly, several non-Green Belt and Green Belt settlements omitted from earlier maps were added. Secondly, non-Green Belt settlements have now been set out in their entirely in a table. Thirdly, a minor alteration has been made to Footnote 21 where it concerns “Purpose 3: To assist in safeguarding the countryside from encroachment”. In respect of the last issue, Footnote 21 in “The Buckinghamshire Green Belt Assessment Part 1A: Methodology” stated: Page 6 of 104 Classification: OFFICIAL PORep1510 (REDACTED) “For example, General Areas with a relatively low level of built form (i.e. between 20-30%) and a largely rural character would score 3; however a General Area with a relatively