Classification: OFFICIAL PORep2119 (REDACTED) Mayfield House 256 Banbury Road Oxford Mr G Winwright OX2 7DE Planning Policy Team T: 01865 511444 South Bucks District Council F: 01865 404433 Capswood Oxford Road Your ref: Denham Our ref: LP/csw/1078787 UB9 4LH 12th December 2016 Dear Mr Winwright CHILTERN AND SOUTH BUCKS LOCAL PLAN GREEN BELT PREFERRED OPTIONS CONSULTATION – LAND AT MIDDLEGREEN ROAD, WEXHAM, SLOUGH 1.0 Introduction 1.1 Carter Jonas has been instructed by Taylor Wimpey, who have an option agreement on the land at Middlegreen Road, to prepare representations to the Chiltern and South Bucks Local Plan Green Belt Preferred Options consultation. 1.2 Land at Middlegreen Road (the ‘Site’) lies in South Bucks District and immediately adjoins the administrative area of Slough Borough Council. 1.3 This consultation response should be read in conjunction with the nomination which was made to the Call for Sites consultation in February 2016, and the representations which were made to the Local Plan Issues and Options consultation in March 2016, on behalf of the landowner (Mr R Offer). 1.4 This representation provides a response to the: • Green Belt Preferred Options Consultation Document; and • Draft Green Belt Assessment Part Two. 1.5 The Green Belt Development Options Appraisal, which is also published as part of the evidence base for the consultation, assesses the sites which were recommended for further consideration in the Green Belt Part One Assessment. This document does not refer to Land at Middlegreen Road. 1.6 Other comments are made specifically in support of the promotion of Land at Middlegreen Road. 2.0 Site Description 2.1 The Site covers an area of approximately 8.5 hectares and comprises predominantly young woodland, with some more open areas which are used for cattle grazing. In the north east corner of the Site is an area which is currently used for commercial purposes, renovating Page 1 of 11 Classification: OFFICIAL PORep2119 (REDACTED) and restoring telecommunications equipment. Vehicular access to the commercial area and wider Site is from Middlegreen Road. The topography of the Site is largely level. 2.2 The main west coast railway line and the Grand Union Canal are both to the south of the Site. The boundary of the Site to the west is formed by Rochfords Gardens, a 1980’s housing development. To the north of the Site is land owned by Slough Nurseries, which comprises a plant nursery, accommodated in extensive greenhouses and ancillary buildings. The boundary to the east is formed by Middlegreen Road and Nursery Lane, and to the south by Lavender Farm, which is accessed from Nursery Lane. 2.3 To the north of Slough Nurseries lies a 25ha active sand and gravel quarry, which was granted planning permission in 2014, and is accessed from the A412 Uxbridge Road. Once the mineral extraction has been completed, the site will be restored to agriculture and nature conservation uses. 2.4 A plan showing the Site is attached at Appendix 1 to this letter. 3.0 Issues and Options Consultation 3.1 The response submitted to the Issues and Options consultation, in relation to the Land at Middlegreen, stated: • Support for the intention of Chiltern and South Bucks District Councils to meet their full, objectively assessed need for housing; • Under the Duty to Cooperate, South Bucks and Chiltern Districts should not dismiss the potential need to accommodate unmet housing needs from adjoining areas, in particular Slough Borough; • The HELAA is a central part of the Joint Local Plan evidence base, and will assist in determining the amount of development that needs to be accommodated on land currently in the Green Belt; • The HELAA and related policy decisions should take full account of longstanding community concerns over the impact of urban intensification on townscape character. A balance needs to be struck between making more efficient use of urban land and the extent of land released from the Green Belt for development; • Support for the inclusion of Land at Middlegreen Road in the built area extension option identified at page 36 of the Issues and Options document; • There are exceptional circumstances to warrant a review of the Green Belt; and • The need for a hierarchical approach to identifying sites and meeting development needs; firstly sites in urban areas, then built area extensions adjacent to the principal settlements within and adjacent to the Plan area (particularly Slough). 3.2 In summary, if released from the Green Belt, Land at Middlegreen Road could make an important contribution to meeting housing need in the District (where they arise), and / or contribute to meeting the unmet housing need from Slough Borough. 2 Page 2 of 11 Classification: OFFICIAL PORep2119 (REDACTED) 4.0 Green Belt Preferred Options Consultation Development Needs in Chiltern and South Bucks District 4.1 To inform further work on the Joint Local Plan, Chiltern and South Bucks District Councils have undertaken a joint further review of their Housing and Economic Development Needs Assessment (HEDNA, September 2016), which also covers Aylesbury Vale and Wycombe District Council areas. The updated HEDNA identifies a need for 14,700 new homes in Chiltern and South Bucks Districts over the plan period (2014-2036). 4.2 Paragraph 1.2 of the Green Belt Preferred Options document states that the Councils believe that this housing figure cannot be met in full, despite opportunities that are likely to be found through a Green Belt review and increasing densities for development opportunities. The Councils have therefore been in discussion with Aylesbury Vale District Council, to explore the potential for some of Chiltern and South Bucks needs to be met outside the Plan area. An in-principle agreement has been reached for unmet needs to be provided in the emerging Vale of Aylesbury Local Plan, subject to further evidence to justify the amount of development and the Vale of Aylesbury Local Plan being able to identify sufficient capacity. 4.3 Based on the work Chiltern and South Bucks District Councils have undertaken to date, the Councils estimate an unmet need of some 5,800 units. 4.4 However, the Green Belt Preferred Options document notes that the Green Belt Assessment Part Two is only a draft document, and will not be completed until the outcome of this consultation and other work is known. The opportunity for the Councils to identify further sites for development therefore clearly still remains, and therefore even an initial estimate of the quantum of unmet housing need to be accommodated in Aylesbury Vale seems premature at this time. 4.5 The “Update” section of paragraph 1b) of the Green Belt Preferred Options consultation document states that: ‘Chiltern and South Bucks District Councils’ position remains that our needs as a first priority should be met through sustainable development opportunities within Chiltern and South Bucks but that full needs will not be able to be met, despite opportunities that are likely to be found through a Green Belt review and increasing densities for development opportunities.’ 4.6 The Councils do not seem to be open to the possibility that their unmet housing need could be reduced, or even removed altogether, if sufficient land is released from the Green Belt within Chiltern and South Bucks Districts. 4.7 The HEDNA calculation of housing need recommends that in Aylesbury Vale, the housing target should be increased by 10% above the projected household growth rates to take account of market signals and lack of affordability. In Chiltern and South Bucks Districts, a 20% increase is recommended. The intention to ‘export’ some of the Chiltern and South Bucks housing need to Aylesbury Vale will perpetuate, and indeed exacerbate, the issue of poor affordability in South Bucks and Chiltern Districts. 3 Page 3 of 11 Classification: OFFICIAL PORep2119 (REDACTED) 4.8 The Duty to Cooperate requires neighbouring local authorities and local authorities in a single housing market area to work together, to jointly meet their housing need. Slough Borough Council has a significant housing target of 970 homes per annum, and its options for where these homes can be delivered are significantly constrained by flood plain in the south of the Borough, and a tightly drawn Borough boundary. 4.9 Slough Borough Council has requested through representations to the Chiltern and South Bucks Issues and Options consultation (March 2016) that Green Belt land is released in South Bucks, to enable the development of an urban expansion to Slough in the form of a ‘Garden Suburb’. However, none of the Preferred Options sites in the current consultation are particularly close to Slough, and indeed, there is nothing in the Green Belt Preferred Options consultation document that indicates that Chiltern and South Bucks Councils are seeking at this time to factor in accommodating any unmet needs arising from Slough Borough. 4.10 As Officers will be aware, under the Duty to Cooperate, Chiltern and South Bucks Councils will need to demonstrate to a Planning Inspector that they have effectively cooperated with their neighbouring authorities, including Slough. There is an opportunity here for the Draft Green Belt Part Two assessment to be amended to respond to the housing need arising in Slough, by identifying further sites adjacent to Slough for release from the Green Belt. 4.11 Land at Middlegreen Road lies immediately north east of the boundary with Slough, and is well placed to contribute to assist in meeting Slough’s housing need. If the site were released from the Green Belt, it would provide a sustainable location for development, which relates well to existing residential development, and to facilities and services in the town (and nearby local centres). 4.12 As well as needing to take account of their own housing need and the housing need of neighbouring authorities, Chiltern and South Bucks Councils should also be making provision to ensure that they have the flexibility to accommodate the additional development pressures arising from planned expansion of Heathrow, and indeed, to assist in addressing any unmet needs arising from the London Plan Review.