Beaconsfield Society response to Green Belt consultation

The Beaconsfield Society Response to Green Belt Preferred Options Consultation December 2016
Option 9: Beaconsfield

(a) and (b) : Suitability

Having studied the SBDC Evidence Base for release of Green Belt east of Beaconsfield, Preferred Option 9, we The Beaconsfield Society as an accredited Stakeholder in this process conclude that no proven case has been made for release of Green Belt in this location for an assured and sustainable provision of any level of housing need within the Council’s areas. Therefore Preferred Option 9 is unsuitable for development beyond the existing developed area of Wilton Park (approx.22ha).

Option 9 is not suitable for release from Green Belt and development because:

• No defined housing need that can viably and sustainably be met in these particular areas of land has been proven. See Appendix 1.

• No employment need has been proven that can only be provided by commercial activity on these areas of land. See Appendix 2.

• The release of this Green Belt land would not be sustainable. See Appendix 3.

• The sustainable prerequisite infrastructure and facilities needs have not been defined let alone shown to be financially viable and deliverable. See Appendix 4.

• The SBDC Green Belt assessment and Evidence Base have failed to demonstrate (as required) that this Green Belt land does not serve all the 5 declared purposes of the Green Belt. See Appendix 5.

• The HEDNA categorically does NOT specify 1700 homes in Preferred Option Area 9.

(c) Evidence Base

• The SBDC Stage 2 Consultation and its justification for release of Green Belt is unsound because it is based on incomplete, inadequate and improper disclosure of “evidence”; that “evidence” is seriously and fundamentally flawed and lacking in fact. The “evidence” is instead based on assumptions and uncertainty. See following Appendices.

(d) Alternative Options

• Preferred Option 9 is unsuitable for release from Green Belt and development. Release from Green Belt and development should be limited to the existing developed area of Wilton Park only (approx.22ha) and which should remain extremely well screened so as to protect: the Historic Core of Beaconsfield Old Town; the oldest Conservation Area in the district; Listed Buildings in the vicinity and their amenity; the prevailing rural scene; and nearby Area of Natural Beauty.
• Local knowledge confirms that any extra commercial or industrial activity would only be viably located in adjacent towns already equipped with appropriate infrastructure and workforce (e.g. Wycombe, Loudwater, Chesham), not in a green field.

Therefore, in conclusion, no exceptional circumstances (as required by the NPPF) have been evidenced to justify the release of this Green Belt land; need alone is not sufficient and is not proven in any event. This Green Belt land continues to serve the 5 declared purposes of the Green Belt. In consequence, this Green Belt land should remain as protected Green Belt land and is unsuitable for development.

What follows are the 5 Appendices for the submission.

Appendix 1

The Hedna is fundamentally flawed as its methodology is based on migration trends, assumptions and uncertainty across the district; it does not establish exceptional circumstances required for release of this Green Belt in Beaconsfield. This land is, therefore, unsuitable for release and development.

Housing need in Beaconsfield, as expressed below, has not been defined in the Hedna nor elsewhere in the SBDC Evidence Base and is not backed up by a substantive need assessment. Without this, housing need in Beaconsfield has, therefore, not been proven.

Housing need alone cannot be an exceptional circumstance to justify release of Green Belt.

The Hedna does not ask nor answer the pertinent questions surrounding housing need in Beaconsfield. The following has not been defined or demonstrated:

1. The demographic and numbers of people unable to purchase or rent on the open market and needing housing in Beaconsfield rather than elsewhere. Define and enumerate this demographic by: age; occupation; employment status; level of need; income; housing or other benefits being received; age of children; number of children; number of adults; number of OAPs; number of persons with special needs and what type of special needs; specify where these persons are currently living; specify where these persons will work, how they will travel to work and what jobs they are expected to do; specify how many key workers work in Beaconsfield and correlate the number with occupation and place of work.
2. The type of housing needed for those specified in point 1 above. Define this housing by: size of unit; number of bedrooms; type of unit (flat, studio, terraced house, semi/detached house, bungalow, warden assisted unit etc.); number of council dwellings required (and what type, what tenure and at what rent); number of social rented units (what type, what level of rent); number of housing association units (what type, what level of rent, how many part-owned units); affordable housing (what type, size, cost, what scheme, what discount off market rate); how many of each type of unit would be available for purchase over the longer term and at what discount; number, size and type of starter homes (and what purchase schemes/what discounts would apply); specify whether these units would be re-sellable at full market price and on what terms; number of private units (type, size, how many bedrooms, cost); type and number of parking facilities associated with each unit.
3. The cost of the land required for the construction of the dwellings specified in point 2 above.
4. The construction cost of the dwellings specified in point 2 above including materials and labour.
5. The prospective sale prices and rental of the dwellings mentioned at point 2 above.
6. How the persons defined in point 1 above would be able to afford the housing defined in point 2 above.

If it is shown that affordable housing in the true sense and as defined above is not viable or pertinent to the Beaconsfield Green Belt Option 9, housing need cannot be satisfied here.

The present consultation should not and must not trigger release as no viability has been shown or even assessed and Option 9 Beaconsfield East must be withdrawn from further consideration.

Appendix 2

The HEDNA is fundamentally flawed in its methodology allocating 5ha of employment space to this Green Belt land in Beaconsfield. It has not established the exceptional circumstances required. This land is unsuitable for Green Belt release and development. The need for employment land is not defined; there is no substantive need assessment. Without this, employment land need in Beaconsfield has not been proven.

The HEDNA does not ask nor answer the pertinent questions surrounding employment land need in Beaconsfield. The following has not been defined and demonstrated and, without such, no case has been proven for release of this Green Belt land:

1. Type of employment use to be created; use class; number of employees in each unit and at each pay grade.
2. Location and number of units.
3. Floor area and type of each unit (e.g. office unit, office block, freehold, leasehold, retail unit, business park, warehouse, light industrial unit).
4. The demographic to work in each unit.
5. Where the demographic defined at point 4 above would live and where do they live now?
6. How many parking spaces to be allocated to each unit defined at point 3 above.
7. How the demographic described at point 4 would travel to and from work.
8. How many extra journeys would be generated daily to account for the journeys made by the demographic at point 4.
9. What impact would the journeys described in point 8 have on local infrastructure and traffic congestion.
10. What impact would the employment use specified at point 1 have on the existing business users of the town? How would the business impact the existing traders in the town? Negative impact?
11. The cost of the land required for the construction of the units specified at point 3 above.
12. The construction cost of the units specified above at point 3 above.
13. The prospective sale prices and rental of the units mentioned at point 3 above.
14. Compare the cost in points 11, 12 and 13 with similar units in nearby Loudwater and High Wycombe.
15. How the requirement for 5ha of employment land in Beaconsfield has been calculated.
16. How this can be justified in light of entire high rise office buildings in High Wycombe and also Maidenhead currently being converted to residential use.
17. Why Beaconsfield allocated a full 50% of the entire 10ha employment need of the whole district when by the Hedna’s own admission Beaconsfield is not an important commercial property location.
18. Employment space will not assimilate with the Conservation Area, Beaconsfield Historic Core, the nearby Area of Outstanding Natural beauty, ancient woodland, hedgerows, ponds, agricultural and habitats. Impact entirely negative.
19. What proportion of Beaconsfield residents out-commute?
20. What employment the current residents of Beaconsfield are engaged in and where.
21. What salaries the current residents of Beaconsfield enjoy.
22. Why this is needed in Beaconsfield and not elsewhere.

It has not been shown that employment space is viable or pertinent to the Beaconsfield Green Belt or Conservation Area; employment space cannot be satisfied here; this land is not suitable for employment space. Exceptional circumstances have not been proven for release of this Green Belt land in Beaconsfield.

It must also be shown that this employment space cannot be located elsewhere in the locality – but just along the A40 an entire high rise office block is being converted to residential dwellings and there is vacant brown field land nearby in Loudwater. Therefore, there is no need for this type of development here. The present consultation should not and must not trigger release as no viability has been shown or even assessed; no need has been demonstrated and Option 9 Beaconsfield East must be withdrawn from further consideration.

Appendix 3

Release of this Green Belt would not be sustainable because:

• There are 3 listed buildings on the site and 2 on the edge.
• The Beaconsfield Old Town Conservation area is partially located in the south west of the Green Belt.
• Development would harm the setting of the Beaconsfield Historic Core located to the south west.
• 4,000 additional residents would impact the nearby Burnham Beeches.
• Development would be highly visible from the nearby Area of Outstanding Natural Beauty and harm its outlook.
• Additional pollution from numerous vehicle movements associated with 4,000 extra residents would add to the pollution created at the nearby junction 2 of the M40.
• Development would encroach on the “mosaic of woodland and farmland” residents currently enjoy as there are no parks to speak of in Beaconsfield.
• Ancient woodland would be destroyed or have its amenity ruined.
• Ponds and hedgerows would be destroyed or have their amenity ruined.
• The SBDC consultants state “loss of ancient woodland represents a permanent loss which cannot be mitigated or recreated.”
• Allotments would be destroyed.
• The cricket club is located on the Green Belt and is a highly important local facility in a town where there is a lack of recreational facilities.
• The football pitches at Wilton Park in Green Belt are a highly important local facility in a town where there is a lack of recreational facilities.
• Development would result in loss of habitats, the species which inhabit them and loss of habitat connectivity.
• The site contains important agricultural land
• The site contains land within the Buckinghamshire Mineral Safeguarding Area and development would negate important mineral resources.
• Public footpaths cross the site and are an important local resource because there are no public parks to speak of.
• Inflated housing targets would result in preventable loss of the countryside according to The Campaign for the Protection of Rural England.
• Green space, trees and vegetation are vital for the health and well-being of residents in this polluted area and required to off-set carbon dioxide emissions and also emissions from the nearby landfill site.

Appendix 4

The Chiltern and South Bucks Settlement Infrastructure Capacity Study assessed Beaconsfield “for accommodating the potential for new growth.” Para.1, “it is important to look at potential critical infrastructure issues at the early stages of plan preparation and evidence gathering because this could have a fundamental impact on whether the policies and proposals in the new Local Plan are realistic, deliverable and can be implemented…” The Study focussed on 6 categories of infrastructure: education, health, transport, utilities, flood defences and social care. TWO THIRDS of these categories have been labelled red: “insufficient information currently available.” So, Option 9 is not suitable and not shown to be realistic and deliverable.

Beaconsfield receives a “red” (“insufficient information”) category for:

• Primary education – “very limited scope” – Para.44 confirms that “Bucks CC has very little capital funding available to provide additional school places and there is no guarantee that this funding will be available in future years.”
• Secondary education – “very limited scope” – Para. 49 states that Bucks CC have stated in the Study that 700 homes would generate an additional form of entry of primary pupils and 1200 homes would generate an additional secondary school, form of entry.
• Acute health (hospital) – “to be confirmed”
• Primary Health (GP) – “very limited scope”
• Transport – main roads – any possible improvements would only be “directly related to the development”
• Transport – motorways – “implications to be tested”
• Utilities – waste water – “need Ofwat approval” and “potential cost to consumers via water bills” –trunk sewer “close to capacity” – Gerrards Cross Waste Water Treatment Works requires site wide upgrades.
• Social care – “data difficult to disaggregate in relation to the current information” and “provision could be by private or public sector for some types of accommodation.” The Study highlights the need for further evidence into the issue of affordable care beds and this is a key concern in relation to accommodation for the elderly.

Beaconsfield received an “amber” designation (“capacity dependent on planned measures and improvements” – but no details given) for:

• Transport – rail: “implications to be tested”
• Utilities – drinking water – suggested measures include: “demand management, water efficiency measures and transfer of supply from outside catchment”
• Utilities – electricity and gas: “a site specific matter”
• Household waste collection and recycling

Para.38 confirms that one of the most severely affected roads is the A355 between Amersham and Beaconsfield and the A355 south of Beaconsfield. The proposed relief road would be hopelessly swamped by the proposed population growth.

Para.45 confirms “the scope for accommodating future potential growth in population or housing…seems very limited.” Put simply “more engagement is needed.”

Para.58 states that Beaconsfield and Gerrards Cross are already “referred to by Chiltern Railways as being two of the busiest stations in the area with their carparks frequently at full capacity.”

The Study states that “there are several elements to this Study which will need to be the subject of further work.” This includes “commissioning work on viability.”

The Study concludes that it is not known how the required infrastructure would be funded and warns against what CIL could deliver.

The Responses from the Infrastructure Providers/Other Organisations to the Questionnaires submitted as part of the Study have revealed:

• High level assessment needed for M40 between jct.1 and 3 – already an accident blackspot.
• No accessibility to bus services has been considered in distinguishing which settlements to include in the Study and Beaconsfield bus services are very poor and incapable of supporting an extra 4,000 residents.
• No account has been taken of sufficiency of walking and cycling infrastructure. The A355 which would separate the Option land from the rest of the town is a highly dangerous road for cyclists and pedestrians – impossible to cross safely at peak times.
• There is a need for AFFORDABLE care bed provision for the elderly.
• Historic England state “ in considering potential growth locations need to consider the positive contribution made by the historic environment and ensure that harmful pressures are avoided…” Irrevocable harm would be caused to the character and setting of the historic core of Beaconsfield Old Town.

In conclusion, the infrastructure and facilities need is not shown to be viable and deliverable for release of this Green Belt land and the resultant growth in population of the town. Therefore, Option 9 is not suitable and should not be taken further.

Appendix 5

The SBDC Green Belt Assessment states:
• The NPPF confirms Government attaches “great importance to Green Belts.”
• The NPPF confirms “the fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open.”
• The five purposes of Green Belt still apply.

Given that your Assessment has tested the land in Option 9 and confirms that all parcels of Green Belt in Beaconsfield continue to perform all 5 purposes of Green Belt (with the only exception being the currently developed Wilton Park area), the Option 9 land remains of great importance and must be kept permanently open. Option 9 is not, therefore, suitable for release (with the exception of the Wilton Park developed area).

The SBDC Green Belt Assessment refers to the National Planning Practice Guidance which reiterates the importance of Green Belt. It states that “need” alone is not enough to override constraints on Green Belt land. Housing need has been stated as the key driver for the Study but housing need alone cannot constitute exceptional circumstances for release of Green Belt – para. 2.6 of your Assessment refers and see Calverton PC v. Nottingham CC & Others. Exceptional circumstances cannot solely be framed around providing more houses.

Need should not be met if “any adverse impacts of doing so would significantly and demonstrably outweigh the benefits” and the NPPF “makes clear that, once established, Green Belt boundaries should only be altered in exceptional circumstances.” No exceptional circumstances have been proven because:
• need alone is not sufficient to release Green Belt; and
• need has not been proven (see prior Appendices); and
• Option 9 continues to perform the 5 purposes of Green Belt; and
• the harm outweighs any benefit (which at best is described as “moderate.”)

Therefore, this Option 9 is not suitable for release or development (with the exception of the Wilton Park land currently developed).

The Option does not meet sustainability objectives. The following sustainability factors also significantly restrain the ability of the Council to meet its (unproven) need:
• Cultural heritage – severe harm would be caused to the Conservation Area of the historic core of Beaconsfield Old Town. The Core Strategy and current local plan emphasise the importance of the Green Belt setting of the historic core.
• Landscape –destruction of the countryside would ensue in a town for which the countryside is an important recreational amenity as there are no parks to speak of
• Biodiversity and geodiversity –mineral deposits would be sterilised, habitats destroyed
• Climate change would be accelerated
• Natural resources – important agricultural land would be lost forever and minerals negated
• Pollution – this Green Belt is desperately needed to mitigate against the polluting effects of the nearby M40, landfill site and traffic hotspots
• Transport and accessibility – all transport modes would be swamped by an extra 4,000 people
• Housing – viability of deliverability of affordable housing on this land not proven
• Health – bigger population in general and bigger population of elderly will swamp existing medical facilities

Our more specific comments on SBDC Assessment Part 2 of the 6 parcels of land in this Option are set out here:

Reference numbers 1.13 and 1.13A (the A355 land):

• There is no defensible boundary with Beaconsfield Golf Club because it is only a thin line of trees.
• The new relief road should not be considered as a justification for releasing surrounding land. The proposed relief road should NOT be a factor. Much Green Belt land across the country is bisected by roads – for example, the A40 and M40. The relief road is not an urbanising factor.
• This area is readily visible from the Conservation Area of Beaconsfield Old Town and its historic core. Causes irremediable and permanent harm to the character and setting of this old market town.
• Fragmentation is not a valid reason to release Green Belt.
• The parcel DOES contribute significantly to the gap between Beaconsfield and Seer Green.
• The Assessment states: “The land has a mainly rural, open character.” That should be protected.
• Your argument is circular: “if the area of land to the south is removed, Area 1.13A would not score strongly against one or more green belt purposes.” Put another way: release one parcel and use this release to justify release of neighbouring parcel and so on. This is SIMPLY WRONG. Cumulative impact would be unacceptable. This presumptive argument is flawed and should be struck out.
• This proposal is NOT sustainable – See Appendix 3.
• No transport benefits – the relief road would be swamped by over 4,000 extra residents, the town would grow by one third with unsupportable stress on its facilities.
• The Assessments states that the development would only have “MODERATE benefits” on housing – so NO exceptional circumstances.
• No positive benefits shown. Harm outweighs any benefit.

Reference numbers 1.14 A and B (Wilton Park plus cricket club etc)

• The Cricket ground is highly important to the town in a town where recreational facilities are severely limited.
• 1.14B should not be released. Your Green Belt assessment states that this land provides “no major benefits to housing” and therefore no exceptional circumstances can apply for its release.
• Football pitches are important local facilities in a town where recreational facilities are severely limited and should be retained.
• We would accept release of the currently developed part of 1.14A (Wilton Park) only (NOT 1.14B), but NO FURTHER RELEASE OF GREEN BELT IN BEACONSFIELD. Should the Wilton Park land be released, it should be for housing only; and only if need is proven in accordance with Appendix 1; and on the strict proviso that screening is retained and enhanced so as to screen all development from view; and so as not to adversely impact remaining green belt which MUST be protected.

Reference number 1.15 (land between jct.2 and Pyebush roundabout)

• This land has been proven by your assessment to continue to perform the functions of the Green Belt.
• It is a green finger into Beaconsfield, part of the green lungs of the town.
• It performs the highly important function of mitigating against pollution from the motorway – an area of air pollution monitoring.
• It is not joined to parcel 1.14 so this is irrelevant.
• It is highly strategic green belt between existing housing and the motorway and acts as an important buffer from deleterious traffic flow.
• It has significant tree cover – it gives the town its significant semi-rural feel and is important for health.
• It would only provide “moderate benefit” if released, therefore, no exceptional circumstances exist for its release.
• It has no current access –it would require very significant infrastructure to create one.
• If released, it would add to stress on Burnham Beeches.
• Floods.

In summary, no exceptional circumstances have been proven and the parcels of Green Belt continue to perform the 5 Green Belt purposes. Therefore Option 9 is not suitable for release beyond the currently developed Wilton Park area and should be removed from consideration and must not be taken further.