Classification: OFFICIAL PORep2759 (REDACTED) Chiltern and South Bucks Local Plan – Green Belt Preferred Options Consultation 1. Introduction SUEZ Recycling and Recovery UK Ltd (SUEZ) are the landowners of the Pickeridge Closed Landfill Site, Pickeridge Farm, Stoke Common Road, Fulmer, Buckinghamshire, SL3 6HA (site location plan attached at Appendix 1). The site is currently dissected by the M40. The land to the south of the M40 is part of the former landfill which closed and was restored in 2001, with its five year aftercare period ending in 2006. The land to the north of the M40 was never landfilled and has been retained in SUEZ’s ownership. The area of the north of the M40 is a long rectangular strip of land that is located between the M40 and the settlement of Gerrards Cross. The land is currently located within the Green Belt. It is understood that South Bucks and Chiltern District Councils are currently consulting on their Green Belt Preferred Options Consultation to remove a number of areas of land from the Green Belt. SUEZ have also been made aware that the land at the Pickeridge has been considered in the Issues and Options Consultation for the Green Belt in March 2016 (site reference 69) and was assessed against the five purposes of the Green Belt as outlined in Paragraph 80 of the NPPF and against the Methodology developed by Arup for the Council in March 2016. It should be noted that at this stage SUEZ have not been directly consulted on this consultation or any of the previous consultations, which is not in line with Regulation 18 of the Town and Country Planning (Local Planning) (England) Regulations which states that when preparing a Local Plan a Local Planning Authority must notify each of the bodies or persons specified in paragraph (2) of the subject of a local plan which the local planning authority propose to prepare, and invite each of them to make representations to the local planning authority about what a local plan with that subject ought to contain. The persons specified in paragraph 2 include such residents or other persons carrying on business in the local planning authority’s area from which the local planning authority consider it appropriate to invite representations. Given that SUEZ are the Freehold owners of the Pickerage Closed Landfill and part of our ownership has been considered in detail for potential Green Belt release, we are disappointed that we have not had the opportunity to make the appropriate representations on previous consultations regarding the Green Belt. 2. Planning Policy The National Planning Policy Framework was adopted in March 2012 and sets the Government’s stance on the Green Belt. Paragraph 79 states the Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence. 12/12/2016 [1 of 12] Page 1 of 16 Classification: OFFICIAL PORep2759 (REDACTED) Paragraph 80 of the NPPF outlines the five purposes of the Green Belt, which are as follows: 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. It is against these five tests that land should be assessed against when considering removing land from the Green Belt. Paragraph 84 goes on to state when drawing up or reviewing Green Belt boundaries local planning authorities should take account of the need to promote sustainable patterns of development. They should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the outer Green Belt boundary. The above statement is also further enhanced in paragraph 85 which states that when defining Green Belt boundaries Local Authorities should satisfy themselves that Green Belt boundaries will not need to be altered at the end of the development plan period; and define boundaries clearly, using physical features that are readily recognisable and likely to be permanent At a local level the planning policies for the South Bucks area are contained within the adopted Local Plan (1999) and the adopted Core Strategy (2011). Neither of the aforementioned documents contain any relevant policies on Green Belt release and are more focused on safeguarding the Green Belt from development. It is acknowledged that South Bucks and Chiltern District Councils are currently in the process of updating their Local Plan and this consultation forms part of the Local Plan revision. 3. Green Belt Assessment Methodology In order to undertake the Green Belt Assessment it is understood that a methodology was developed by the Council and their consultants to review potential sites for release. This was first published in 2015 and revised in March 2016. It is understood that any potential alterations to the Green Belt must be based on a new permanent and defensible boundary; thus, permanent man-made and natural features were selected as the initial basis of criteria for the identification of the ‘General Areas’. 12/12/2016 [2 of 12] Page 2 of 16 Classification: OFFICIAL PORep2759 (REDACTED) Motorways; A and B Roads; Railway lines; River Chess; River Colne; River Misbourne; River Thames; and River Wye. Given the nature of Buckinghamshire it is understood that it was necessary to further define the General Areas based on the following criteria. Unclassified public roads and private roads; Smaller water features, including streams, canals and other watercourses; Prominent physical features (e.g. ridgelines); Existing development with strongly established, regular or consistent boundaries; Protected woodland or hedgerows. It is understood that then each area was assessed against the five purposes of the Green belt as outlined in Paragraph 80 of the NPPF. The purpose assessment criteria is set out below: To check the unrestricted sprawl of large built up areas – (a) Land parcel is at the edge of one or more distinct large built-up areas, (b) Prevents the outward sprawl of a large built-up area into open land, and serves as a barrier at the edge of a large built-up area in the absence of another durable boundary. To prevent neighbouring towns from merging - prevents development that would result in merging of or significant erosion of gap between neighbouring settlements, including ribbon development along transport corridors that link settlements. Assist in safeguarding the countryside from encroachment - protects the openness of the countryside and is least covered by development. To preserve the setting and special character of historic towns - protects land which provides immediate and wider context for a historic settlement, including views and vistas between the settlement and the surrounding countryside. Purpose five was excluded from the Assessment. SUEZ agree that the methodology for purposes 1, 2 and 4 are consistent with the aims and objectives of the NPPF. However, we have concerns over the consistency of its application across sites. 12/12/2016 [3 of 12] Page 3 of 16 Classification: OFFICIAL PORep2759 (REDACTED) SUEZ wish to make the comments that the methodology for the 3rd purpose assessment should be amended, as it is our opinion that it relies too heavily on how much of the site is currently developed. This form of assessment does not accurately reflect on how effective (or not) the site is from safeguarding the countryside form encroachment. The assessment should be a judgement based on how much countryside the site actually contains rather than how developed the site is. Countryside is land/scenery which is rural in character, i.e. a relatively open natural, semi-natural or farmed landscape. The sites could then be scored on the following criteria If land parcel contains countryside and no urbanising development, and is open, - 5 If land parcel contains countryside interspersed with development and is open – 4 If land parcel contains countryside and limited urbanising development, and is relatively open – 3 If land parcel contains small elements countryside or contains urbanising development compromising openness - 1 If land parcel does not contain countryside or contains urbanising development compromising openness - 0 It is understood that each criteria was then scored out of 5 based on the methodology devised by Arup in March 2016 as set out below. The site within SUEZ’s ownership forms part of General Area 69 (Stage 1) or 2.20 (Stage 2). The site was scored in the assessments (March and October 2016) against the five purposes of the Green Belt as outlined in table 1.1 below: Table 1: Stage 1 Council Assessment Purpose Criteria Assessment Score (1) To check the a) Land parcel is at the The land parcel is at the edge of the PASS unrestricted edge of one or more Gerrard’s Cross large built-up area. sprawl of large distinct large built-up built-up areas areas (b) Prevents the outward The land parcel is connected with 3+ sprawl of a large built up the large built-up area of Gerrard’s area into open land, and Cross, preventing its outward sprawl serves as a barrier at the into open land. The boundary edge of a large built up between the land parcel and the area in the absence of Gerrard’s Cross built-up area is another durable weak consisting of detached homes boundary. with large gardens bounded by woodland. Although those 12/12/2016 [4 of 12] Page 4 of 16 Classification: OFFICIAL PORep2759 (REDACTED) properties on Howards Wood Drive are regular, there are breaks in this built form and properties within the land parcel on (and leading from) Howards Thicket and Fulmer Drive are more dispersed and irregular.