Chesham Town Council Response to Chiltern District Council’s Draft Core Strategy Consultation. CTC welcomes the objectives of the Core Strategy. In particular it supports the fact the vision expressed in the Chiltern Sustainable Community Strategy has been adopted as the vision for the Core strategy. (P 16) CTC does not totally agree with some of the detail in the Core Strategy however and wishes to raise the following points: 1. SHLAA and Sustainable Villages 1.1 We note that the SHLAA carried out by CDC only looked at urban areas and did not seek to identify housing sites in village locations. The chart ‘proposed distribution of housing development in Chesham’ ( 7.11 and on) shows that a significant amount of development has occurred from 2006 – 2010 in Chalfont St Giles, Great Missenden, Prestwood and Heath End, Penn & Knotty Green, Chesham Bois, Seer Green and other villages. Indeed, in ‘other villages’ the whole allocated complement of 60 houses has already been delivered. Seer Green and Missenden are both served by mainline stations, and public transport to Missenden/Prestwood is comparable to that serving Chalfont St Giles. 1.2 The Core Strategy attaches considerable importance to sustainability for villages, but ignores the fact that building more dwellings there would contribute to this. No evidence is presented as to what makes individual villages remain sustainable communities. For instance we note in particular the number of planning applications for change of use of local pubs from public houses to private residences (The Bull at Bellingdon, the Pheasant at Ballinger) and that one of the grounds argued in support of this is that there is insufficient local clientele who can walk to these pubs. Recommendation 1a We recommend that CDC should carry out evidence based work to identify potential sites within the Chiltern villages and that this would enable them to identify more sites there, thus taking the pressure off the urban areas. These areas should include Ashley Green, Bellingdon, Chartridge, Ley Hill and the Lee 2. Housing Allocation for Chesham 2.1 We welcome the fact that the Core Strategy identifies that Chesham has two constraints which are unique within Chiltern, the Air Quality Management Area and the Congestion Management Zone. (Para 7.9) The Core Strategy highlights that its disadvantages include these constraints (p25...There may be difficult transport issues with additional traffic generation ....particularly Chesham’). We welcome the reduction in the allocation of houses in Chesham from 750 – 650, but can find no evidence in the document that, in view of these particular constraints, the town can accommodate an additional 600 houses. We have asked the District Council to supply the evidence which leads them to conclude that these properties can be accommodated within Chesham without a further deterioration in Air Quality, and more congestion along the A413, especially at peak hours. We note that there are already 379 houses already built or permitted within Chesham which contribute to the housing requirement, and consider that this is sufficient. 2.2 In any event we think that it is particularly unwise to identify a site for 57 houses on the Amersham & Wycombe college site. This development would generate significant additional traffic movements through the centre of Chesham, both to school and to work, and would worsen the air quality and congestion along the A413. We also do not accept that the need for educational provision on this site has reduced to such an extent as to make the school site redundant. Recommendation 2a Consequently we recommend that no new houses be allocated to Chesham beyond the number already permitted or built and that Policy CS12 (p41) to be deleted. 2.3 We note that although Hospital Hill is one of the two identified major sites in Chesham, there is no specific policy dealing with this site alone. We suggest that a specific policy should be drafted. We agree that the site at Hospital Hill is suitable for housing and for a care home use, but we are concerned about the impact on the nearby road system. We are also concerned that any development on this site needs reasonable parking provision. Also, because of the restraints on the site, any development at very high density will be extremely prominent on the hillside, dominating the view from Amersham Hill. The wooded backcloth behind the town that is so much part of Chesham would be prejudiced. Recommendation 2b We recommend that a specific policy is written for the development on the Hospital Hill site. We recommend that a condition of any development on the Hospital Hill site is a S106 agreement addressing much needed highway improvements to Waterside (CS11 p40), that reasonable parking provision is made as part of any development, and that the design of any such development reflects the importance of this prominent position. 2.5 CTC is concerned that the policy on ‘Areas of Little Change’ has never been applied to Chesham. (CS25) We understand that consultants appointed by CDC will now consider the whole of the Chiltern Area. Recommendation 2c We recommend that included in this policy are, properties on the south side of Chartridge Lane (overlooking Pednor), properties on the right hand side of Hivings Hill (numbers 79‐149), properties on both sides of Manor Way, and numbers 40 ‐96 Bois Moor Road. 2.6 Affordable housing is an issue of considerable concern to the district as a whole. We note the requirement for 35% affordable housing, but point out that very little affordable housing has been delivered in the houses built from 2006‐2010. In Chesham there is a particular requirement for accessible housing for old people. Recommendation 2d We recommend that the percentage of affordable Housing in Chiltern needs to be considerably increased from 2010–2026 in order to meet the target. (Policy CS 26) 2.7 We are also concerned that policies CS 26 and CS 28 are too vague. We are aware anecdotally that developers have defeated previous attempts to enforce affordable housing targets by land‐banking land and only releasing sites which are too small to meet the affordable housing thresholds. Recommendation 2e We therefore recommend that CS 26 be amended to add ‘’The council will refuse permission where this affordable housing requirement is not met and an application site is part of an identifiable larger area capable of more comprehensive development.’ Recommendation 2f We recommend that the wording of CS28 be amended to read ‘The council will only permit the following mix in respect of the affordable element of housing schemes ....’ 2.7. Comments on proposed sites elsewhere in the District CTC supports the identification of major sites in Chalfont St Peter and Chalfont St Giles, not only as we consider these proposed developments to be appropriate but also because we think that only on large sites will there be the possibility of section 106 agreements to deliver the required additional infrastructure. 3. Employment 3.1. We support policy CS 31 with modifications. We have asked the District Council for, but have not been supplied with, the survey carried out in November 2009. We note however that para 18.7 recognizes that there is particular concern in Chesham over buildings and sites which have been vacant for an unreasonably long time. We also comment that, again because of the peculiar nature of Chesham which has developed along the line of the river valley, these sites tend to be in the town centre and on the flat. We think there is scope in Chesham for some employment land to be released for housing use on sites which afford easy walking access to the town centre Recommendation 3a We recommend that policy CS31 be amended to allow the limited release of employment sites in Chesham for housing, where these sites afford easy walking access to the town centre, if necessary on the basis that sites are ‘swapped’ with sites which would otherwise be allocated for housing use on the outskirts of the town. Recommendation 3b We would also recommend that in any event, the alternative uses permitted under this policy should include hotel use and a tourist information centre. We support policy CS31. 4. The Environment We support policies CS35, CS36 and CS37, but are concerned that they fail to acknowledge firstly that the river is already over abstracted (see The Colne Catchment Abstraction Management Strategy December 2007) and secondly that there is already regular discharge of sewage into the river Chess as a result of lack of capacity in the sewerage infrastructure. These concerns support our recommendation above that no further housing should be permitted in Chesham within the plan period. We recommend that policy CS35 should be amended as follows;‐ Recommendation 4a Delete the fourth bullet point entirely, and replace with ‘development proposals should respect and enhance in particular the unique nature of the chalk stream habitat in the River Chess’. .