Classification: OFFICIAL PORep2695 (REDACTED) PART A – YOUR DETAILS Are you: An Individual An Organisation Other (please specify) Personal Details* Agent’s Details (if applicable) **Title Mr Miss **First Name Neil Katie **Last Name Beards Christou Job Title Senior Planner and Urban Designer (if on behalf of an organisation) Organisation Tarmac David Lock Associates (if applicable) **Address Telephone Number **Email Address *if an agent is appointed, you may wish to complete only the title and name boxes and, if applicable, the organisation box but please complete the full contact details for the agent. **Name and either email or address required if you wish to be added to the consultation database (see below). Consultation Database (Mailing List) The Councils have a Consultation Database (mailing list) used to keep individuals and organisations informed about Planning Policy Documents across both Council areas. Documents include: the Local Plan, Supplementary Planning Documents and Neighbourhood Plans, (please note some plans may not be applicable to your area). Chiltern District Council and South Bucks District Council are the Data Controllers for the purposes of the Data Protection Act 1998. Individuals and organisations on the Planning Policy Consultation Database will only be contacted by the Councils in relation to the preparation and production of planning policy documents. The Councils will not publish the names of those individuals on the database but may publish names of statutory bodies and organisations at certain stages of the Local Plan process. Please indicate if you want to be added to the joint consultation database (tick box below). Please note: you do not need to tick this box if you received a letter or email notification from the Councils prior to the start of the consultation, as you are already registered. Page 1 of 27 Classification: OFFICIAL PORep2695 (REDACTED) PART B – RESPONSE Green Belt Options – Please Provide your Comments The Councils have concluded that land within the Green Belt will need to be released in order to contribute to meeting development needs to 2036. This is despite maximising opportunities on ‘brownfield land’ or sites within the built areas and on previously developed land in the Green Belt. The Councils have identified 15 preferred options for development in the Green Belt after taking account of views expressed in a consultation earlier this year and testing a full range of options. All of these preferred options if suitable for development will be needed to contribute to our development needs. They are ‘preferred’ options at this stage as work is on-going to test their suitability. Further testing following this consultation will establish what infrastructure (e.g. highway improvements, schools, medical facilities etc.) will be needed to support the options moving forward taking into account current pressures and circumstances. We are consulting on these 15 preferred options to: a) Seek views to help determine their suitability for development; b) Help understand views on what type of development should be sought if suitable and what type of requirements (other than infrastructure) should be secured as part of development; c) Enable comments on the draft technical work supporting the selection of the preferred options; and d) Provide the opportunity for alternative options to be put forward. Evidence and background documents are available here: www.chiltern.gov.uk/planning/localplan2014- 2036/evidence and www.southbucks.gov.uk/planning/localplan2014-2036/evidence. When commenting please clearly indicate which preferred option(s) you are commenting on. Please do not provide any personal information you do not want to be made publically available as these comments may be published at a later date. Please see attached representation and supporting plans. Page 2 of 27 Classification: OFFICIAL PORep2695 (REDACTED) CHILTERN AND SOUTH BUCKS LOCAL PLAN GREEN BELT PREFERRED OPTIONS CONSULTATION: Tarmac Consultation Response 1.1 This representation is made by David Lock Associates (DLA) on behalf of Tarmac in relation to the Chiltern and South Bucks Local Plan Green Belt Preferred Options Consultation document. Tarmac owns land at All Souls Farm Quarry, which is identified in the Green Belt Assessment Part 2. A Location Plan is attached as DLA 01. Adjoining Landowner Support 1.2 Local adjoining landowners have also lent their support to this representation, including the following: • Lidstone Family Trust • Stoke Poges United Charity • Ravinda Singh Takhar • Mr and Mrs H. Barnard • Makhan Singh Jabble, Daljeet Kaur Jabble, Rashpal Jabble and Manmeet Jabble • Old House Court Management Ltd. 1.3 A land ownership plan is attached as DLA 02. Site Factors 1.4 The site at All Souls Farm Quarry is located entirely within the administrative area of South Bucks District Council and adjoins the north-eastern boundary of Slough Borough and the built-up area of Slough. Tarmac will lead promotion of the whole site for development during all stages of the Joint Local Plan process. 1.5 The site currently takes access from Wexham Park Lane and is also bounded by the A412 Uxbridge Road and Church Lane. It is located between the built-up neighbourhoods of Wexham and George Green. It is contiguous with the built-up area of Slough and has the potential to provide a logical and sustainable urban extension and/or new business location on the north-eastern edge of Slough. The Tarmac land ownership extends to some 44 hectares. The wider potential development area extends to 65 hectares in total. Page 3 of 27 Classification: OFFICIAL PORep2695 (REDACTED) 1.6 Tarmac has completed a Feasibility Study of the development potential of All Souls Farm Quarry. Sand and gravel extraction at the site has now ceased and final restoration backfilling under licence, with inert material, is currently being completed alongside mineral recycling operations. This operation will provide a sound development platform which can accommodate any conventional development types and formats. 1.7 The site is available for immediate development and the former sand and gravel extraction operations provide no constraint on development. Technical transportation studies confirm that there are suitable access options. The simple fact that Tarmac own most of the site confers significant advantages because it simplifies the planning, design and development process. Future development of the All Souls Farm Quarry site could be delivered as part of the potential Northern Expansion of Slough, as proposed by Slough Borough Council (SBC), or independently of any wider development proposal. An independent development can readily be configured to ensure that it does not prejudice a simultaneous or subsequent development of a wider area. 1.8 This submission responds directly to the Green Belt Preferred Options Consultation document and the supporting Green Belt Assessment Part Two. Tarmac wish to put forward the site at All Souls Farm Quarry as a suitable and available alternative Green Belt Preferred Option. Green Belt Assessment Part Two (2016) 1.9 Tarmac supports the approach of Chiltern and South Bucks District Councils to undertake a Green Belt Review as part of the preparation of their Joint Local Plan. It is agreed that the required exceptional circumstances exist that require Green Belt boundary revisions to accommodate new development. Page 4 of 27 Classification: OFFICIAL PORep2695 (REDACTED) 1.10 The National Planning Policy Framework (NPPF) (para. 83) sets out that Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan. At that time, authorities should consider the Green Belt boundaries having regard to their intended permanence in the long term, so that they should be capable of enduring beyond the plan period. 1.11 The exceptional circumstances in this case relate to the proven level of housing need in the Districts of Chiltern and South Bucks and Slough and the lack of suitable and available alternative sites to accommodate that need, as confirmed in the Green Belt Development Options Appraisal (2016) (para. 1.1) and by SBC in its Issues and Options consultation document due for public consultation in January 2017. 1.12 Tarmac considers that there are clear inconsistencies in the Joint Green Belt Assessment, which need to be addressed. Our concerns in relation to the methodology for site selection in the Green Belt are threefold: i) The Green Belt Preferred Options appear prejudged – the Green Belt Preferred Options have been published in advance of identifying a preferred Spatial Option for the Joint Local Plan that properly takes account of the OAHN housing requirements of Chiltern and South Bucks and the Duty to Co-operate with neighbouring authorities; ii) Site assessment against the purposes of the Green Belt – the assessment of the site at All Souls Farm Quarry is considered within both Stage 1 and 2 assessments where, confusingly, it is referred to under different area names. In our view, the site at All Souls Farm Quarry is considered to perform weakly when assessed against the purposes of the Green Belt as set out in national planning policy (NPPF) and should be taken forward as an alternative preferred option; and iii) The Duty to Co-operate with neighbouring authorities - Lack of consideration of cross boundary strategic development needs and appropriate options to meet identified needs, particularly for Slough. 1.13 We have set out our detailed response to these inconsistencies below. Page 5 of 27 Classification: OFFICIAL PORep2695 (REDACTED) i) The Green Belt Preferred Options appear prejudged 1.14 The Issues and Options consultation document (2016) contained a total of 12 possible options, including Option D to extend the principle settlements outside of the plan area, including Slough. The Issues and Options document sets out that all the Options would be tested during the next stage of the plan process. As also identified by SBC1, to-date no Spatial Options have been properly tested to analyse whether they are the most sustainable forms of development or could best accommodate the OAHN housing requirements.