PART B Please copy and use a separate sheet for each representation. Pegasus Group

PART B Please copy and use a separate sheet for each representation Name or Organisation: Pegasus Group 1. To which part of the Plan does this representation relate? Paragraph number: 5.4.17 5.4.25 Policy / site reference or name: BE2 Hollands Farm Map number / name: Figure 39 Hollands Farm - Illustrative Layout 2. Do you consider the Plan so far as the part of the Plan with which this representation is concerned is: 2.(1) Legally Compliant Yes No 2.(2) Sound* Yes No 2.(3) Complies with the Duty to co-operate Yes No * The considerations in relation to the Plan being sound are explained in the National Planning Policy Framework in paragraph 182 and are set out in Appendix A of this form. If you have entered No to 2.(2) please continue to Q3. In all other circumstances, please go to Q4. 3. Do you consider the Plan so far as the part of the Plan with which this representation is concerned is unsound because it is: (1) Not positively prepared (2) Not justified (3) Not effective (4) Not consistent with national policy

4. Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate. Please be as precise as possible. If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the duty to co-operate, please also use this box to set out your comments. REPRESENTATION SEEKING MODIFICATION OF POLICY BE2 (AND ASSOCIATED PARAGRAPHS OF THE REGULATION 19 WYCOMBE DISTRICT LOCAL PLAN) Introduction and summary Pegasus on behalf of Keep Bourne End Green ( KBEG ) submit that the allocation of site BE2: Hollands Farm ( Hollands Farm ) should be removed from the Regulation 19 submission version Wycombe District Local Plan ( the WDLP ) for the following principal reasons: The important role that Hollands Farm plays as Green Belt, both in terms of the fundamental aim of Green Belt policy (preventing urban sprawl by keeping land permanently open) and the essential characteristics of Green Belt (openness and permanence) (NPPF paragraph 79) and with regard to the five Green Belt purposes (NPPF paragraph 80). All as further explained by the Martin Leay Review of Green Belt Considerations and the Pegasus Green Belt Assessment of Hollands Farm, Bourne End and Surrounding Area (appended). Hollands Farm is an extensive tract of attractive farmland that is valuable in landscape terms in its own right. All as further explained by the Martin Leay Landscape and Visual Impact Assessment and the Pegasus Landscape Character Assessment of Hollands Farm, Bourne End and Surrounding Area (appended). Development of Hollands Farm for the quantum of development proposed will almost inevitably conflict with paragraph 1(b) of Policy BE2, which requires no adverse impact on the setting of Hedsor Road and Riversdale Bourne End and Wooburn Conservation Area, as well as causing harm to a wider range of designated heritage assets. All as further explained by the Pegasus Land at Hollands Farm, Bourne End, Buckinghamshire: Hedsor and Riversdale Conservation Area Setting Assessment and the Pegasus Land at Hollands Farm, Bourne End, Buckinghamshire, Built Heritage Note (appended). Hollands Farm is unsuitable for development for the quantum of development proposed given the lack of necessary local infrastructure, as explained elsewhere by representations made by Pegasus on behalf of KBEG in relation to Policy CP3 of the WDLP, the impact on the local transport network, as also set out elsewhere by the representations made by KBEG in relation to Policy CP4 of the WDLP, and by the representation made by Pegasus on behalf of KBEG in relation to the sustainability appraisal that underpins the WDLP ( the WDLP SA ), as explained by the Motion Transport Feasibility Appraisal and the Motion Flood Risk Analysis (appended), and also due to a lack of employment opportunities given no further employment land is proposed by Policy BE2. The deliverability of the site is not at all certain owing to concerns regarding highway infrastructure, as explained by the Motion Transport Feasibility Appraisal (appended), and also education infrastructure and land ownership matters and viability as a whole. Wycombe District Council has failed to demonstrate consideration of reasonable alternatives to Green Belt release around Bourne End and Wooburn in the sustainability appraisal that supports the WDLP ( the WDLP SA ), likewise has failed to identify the likely significant effects on the environment. These matters, which go to legal non-compliance as well as soundness, are addressed in the representation made by Pegasus on behalf of KBEG in relation to the WDLP SA. That Wycombe District Council has come to propose the release from Green Belt and allocation for housing of Hollands Farm is at least in part due to the Council s failure to gather and present adequate site specific evidence to support that conclusion. That failure is addressed first, before the other points listed above are considered in greater detail. The EiP Inspector is warmly and sincerely urged to visit Hollands Farm in order to understand its true character and its Green Belt role and the nature of the surrounding area, including designated heritage assets, all of which unfortunately the Council s evidence base has either missed altogether or misunderstood. Note that this representation is made without prejudice to KBEG s broader points made regarding the

need (or otherwise) for the release of any Green Belt in Wycombe District for housing, as set out in other representations made by KBEG. KBEG has made separate representations seeking modification of the settlement hierarchy proposed by WDLP Policy CP3, of WDLP Green Belt Policy CP8, in relation to the Sustainability Appraisal that underpins the WDLP ( the WDLP SA ) and its failure to consider reasonable alternatives to the distribution of some 800 homes to Bourne End and Wooburn and, crucially, the linked issue of Green Belt release at Bourne End, and also to the overall spatial strategy proposed by WDLP Policy CP2. Some of those representations are made by Pegasus planning consultancy on behalf of KBEG, some are made by KBEG direct. This representation is underpinned by the following evidence base, which reports are appended to the representations made by Pegasus on behalf of KBEG (the reports are also referred to in full in the representation prepared by Pegasus concerning the WDLP SA): - Martin Leay Review of Green Belt Considerations; - Pegasus Green Belt Assessment of Hollands Farm, Bourne End and Surrounding Area; - Martin Leay Landscape and Visual Impact Assessment; - Pegasus Landscape Character Assessment of Hollands Farm, Bourne End and Surrounding Area; - Pegasus Land at Hollands Farm, Bourne End, Buckinghamshire: Hedsor and Riversdale Conservation Area Setting Assessment; - Pegasus Land at Hollands Farm, Bourne End, Buckinghamshire, Built Heritage Note; - Motion Transport Feasibility Appraisal - Motion Flood Risk Analysis - Pegasus Sustainability Appraisal 1.0 Inadequacy of evidence base 1.1 Paragraphs 158, 165,169 and 170 of the NPPF state, so far as relevant, that: 158. Each local planning authority should ensure that the Local Plan is based on adequate, upto-date and relevant evidence about the economic, social and environmental characteristics and prospects of the area. Local planning authorities should ensure that their assessment of and strategies for housing, employment and other uses are integrated, and that they take full account of relevant market and economic signals. 165. Planning policies and decisions should be based on up-to-date information about the natural environment and other characteristics of the area including drawing, for example, from River Basin Management Plans 169. Local planning authorities should have up-to-date evidence about the historic environment in their area and use it to assess the significance of heritage assets and the contribution they make to their environment. 170. Where appropriate, landscape character assessments should also be prepared, integrated with assessment of historic landscape character, and for areas where there are major expansion options assessments of landscape sensitivity. 1.2 The need for proportionate evidence is a key part of the test of soundness (second bullet of NPPF paragraph 182). 1.3 It is considered that in the case of Policy BE2: Hollands Farm an inadequate site specific evidence base exists for plan making purposes with regard to: Landscape Character and Visual Impact Assessment. Consideration of the role the site plays within the Green Belt. The Historic Environment and Heritage Assets. Landscape Character and Visual Impact Assessment 1.4 As the Martin Leay Landscape and Visual Impact Assessment ( the MLA LVIA ) commissioned by KBEG with regard to the Hollands Farm site (appended) explains, there is no evidence that

Wycombe District Council or any would be developer have carried out a site specific landscape character and/or visual impact assessment worth the name prior to the decision to release Hollands Farm from Green Belt and allocate it for housing, a highly unsatisfactory situation that could well result in a flawed allocation on land that is not suitable (see paragraphs 1.5-1.6 of the MLA LVIA) The landscape assessment, which includes a landscape appraisal, at pages 10-11 of Appendix GB1 to the Wycombe District Council Green Belt Part Two Assessment (September 2017), being a repeat of material contained in Appendix 4 to the June 2016 draft Green Belt Part 2 Site Assessment, does not come close to a proper site specific landscape character assessment, or a visual impact assessment. 1.5 Hollands Farm sits within the Chilterns National Landscape Character Area and the published landscape character information that exists is at a county and district level, in the form of the 2011 Buckinghamshire County Landscape Classification and the Wycombe District Landscape Character Assessment prepared by Land Use Consultants, understandably at a broad-brush scale. 1.6 As the MLA LVIA explains, the Wycombe District Landscape Character Assessment mistakenly shows Hollands Farm within the settlement area, whereas the land is clearly not part of the settlement and its landscape character is defined by its open farmland, hedges and woodland (MLA LVIA paragraph 2.10 and elsewhere). The error is perhaps unsurprising given the Wycombe District Landscape Character Assessment was only mapped at a scale of 1:25,000 (see MLA LVIA paragraph 2.14). 1.7 As the MLA LVIA explains, rather than 1:25,000 scale, at the least 1:5,000 scale would be required for a site specific study to support the release and allocation of Hollands Farm (MLA LVIA paragraph 2.18). 1.8 The Pegasus Landscape Character Assessment report prepared by Andrew Cook ( the Pegasus LCA ) notes the same error in the Wycombe District Landscape Character Assessment. 1.9 Equally, Policy BE2, including the illustrative layout at Figure 39 of the WDLP, provides insufficient development-related information to describe, let alone fully assess, the nature or scale of development. 1.10 In the circumstances, it has been necessary for KBEG to commission Martin Leay to carry out a landscape study and a landscape and visual impact assessment ( LVIA ) for Hollands Farm, so far as LVIA is possible given the WDLP Figure 39 illustrative layout is little more than a schematic development diagram, and for KBEG to commission Pegasus to prepare a local landscape character assessment ( the Pegasus LCA ), to compliment the site-specific MLA LVIA. 1.11 Work equivalent to the MLA LVIA and the Pegasus LCA is what Wycombe District Council should have carried out, in landscape and visual impact terms, before deciding to release and allocate Hollands Farm. 1.12 The actual landscape and visual qualities of Hollands Farm and the surrounding area, either missed altogether or misunderstood by the Wycombe District Council evidence base, are explored below. 1.13 However, the WDLP is unsound as regards Policy BE2 for lack of landscape character and visual impact assessment evidence. Consideration of the role Hollands Farm plays in the Green Belt. 1.14 The general Green Belt policy in the WDLP is Policy CP8, in respect of which KBEG has made a separate representation in relation to broader, non site-specific, issues, but the evidence base that Wycombe District Council has used to inform CP8, and in particular Green Belt release, is also highly relevant here, to Policy BE2. 1.15 The Council s evidence base for Green Belt release comprises several parts: a Part 1 report Methodology and Assessment of General Areas, prepared by Arup covering all of Buckinghamshire and dated 7 March 2016; and a Part 2 report, being the final Wycombe District Council Green Belt Part Two Assessment dated September 2017 ( the Final Part 2 Report ). The Part 2 Report was a further iteration of the Wycombe District Council Draft Green Belt Part 2 Site Assessment dated June 2016 ( the June 2016 Report ). It is the June 2016 Report that Martin Leay s work principally focuses on, as he was instructed prior to the publication of the Final Part 2 Report, but there are no differences between them that are material to Martin Leay s work.

1.16 As is apparent from Appendix RG1 to the Final Part 2 Report, the Council s site visit to Hollands Farm was carried out on 10 March 2016 (see page 10 of RG1). It also appears that Hollands Farm was one of multiple sites assessed on that single day. It appears, in fact, that some 19 sites were assessed on that single day within the areas of Bourne End, Marlow, Hughenden Valley and Lane End, together totalling some 142.68ha (the full list is, by site reference: Part of GA50a, SBE0027+2BE0028, SBE0045, SBE0048, SBE0054, SHW0633, SLE0020, SLW0025, SMA0085, SMA0086, SMA0087, SMA0105, SMB0010, SRD0159, SWC0069, SWC0070, SWC0080 and SWC0081). But however many sites were assessed on 10 March 2016, it is abundantly clear that the assessment work the Council relies upon was inadequate and allowed for only superficial consideration of Hollands Farm. 1.17 The result of the inadequate assessment work is that the Council has mischaracterised Hollands Farm, which mischaracterisation has led to a flawed analysis of its performance as Green Belt. 1.18 In the circumstances, it has been necessary for KBEG to commission Martin Leay to carry out a Review of Green Belt Considerations ( the MLA Green Belt Report ) and for Pegasus to assess Hollands Farm by reference to the definitions of the five Green Belt purposes set out at NPPF paragraph 80 ( the Pegasus Green Belt Assessment ). 1.19 The actual performance of Hollands Farm as Green Belt, as found by Martin Leay and Pegasus, is explored below. 1.20 However, the WDLP is unsound as regards Policy BE2 for lack of adequate evidence to inform the performance of Hollands Farm as Green Belt. Historic Environment and Heritage Assets 1.21 The WDLP is not accompanied by an adequate up to date Heritage and Historic Environment evidence base, at least so far as Policy BE2 is concerned, and no bespoke heritage evidence base exists to support the allocation of Policy BE2: Hollands Farm, contrary to NPPF paragraphs 169 and 170. 1.22 The published evidence base for Heritage that supports the Regulation 19 Wycombe Local Plan consultation comprises the following: -Buckinghamshire and Milton Keynes Historic Landscape Characterisation (2006). - H High Wycombe - Buckinghamshire Historic Town Assessment Report (2011). - P Princes Risborough - Buckinghamshire Historic Town Assessment Report (2009). - M Marlow - Buckinghamshire Historic Town Assessment Report (2011). - B Buckinghamshire Historic Environment Record website. 1.23 Unfortunately, the heritage evidence base for Policy BE2 is singularly lacking despite clear advice from Historic England. 1.24 In their response to the Regulation 18 consultation, dated 5 August 2016, Historic England stated that: '. The new Local Plan therefore clearly and very largely fails to meet the requirements of the NPPF for the plan to contain a positive strategy for the conservation and enjoyment of, and a clear strategy for enhancing, the historic environment. This is a major failing of the Plan and one that we consider renders the Plan unsound'. 1.25 Moreover, with regard to site allocations the Historic England response stated; '...As regards site allocations, Historic England expects the selection of sites to be allocated for housing (or any development) to be based on, inter alia, full and proper consideration of the potential impacts of development on the historic environment; in particular on heritage assets and their setting, and the need to conserve and enhance those assets. This will require the use of a comprehensive historic environment evidence base as explained earlier in this letter, including specific studies to understand the significance of assets that maybe affected.' (emphasis added) 1.26 No site specific heritage study has been published by Wycombe District Council as evidence to

support the allocation of BE2: Hollands Farm, or to consider the potential impacts of the development of the site on the historic environment. While reference is made to the Hedsor Road Riversdale Conservation Area in the text of Policy BE2 no mention is made in the Policy of other heritage assets that lie around the periphery of the site, including listed buildings. 1.27 Specific evidence that would relate to the allocation of Hollands Farm by Policy BE2 would include the Draft Hedsor Road Riversdale Conservation Area Appraisal that has recently been subject to public consultation between 1 September 2017 and 16 October 2017 ( the Draft Conservation Area Appraisal ). However, the Draft Conservation Area Appraisal would not itself be sufficient heritage evidence for the purposes of plan making, nor does it provide sufficient geographical coverage to address the whole allocation under Policy BE2. 1.28 To remedy these deficiencies, KBEG commissioned Pegasus to assess the historic environment around Hollands Farm and the impact on that surrounding historic environment of the proposed allocation under Policy BE2. The findings of that work are explored below. 1.29 However, the WDLP is unsound as regards Policy BE2 by reason of the lack of evidence to take account of the impacts of development on the historic environment, contrary to both the advice of Historic England in their consultation response to the Draft Plan and to paragraphs 169 and 170 of the NPPF. 2.0 Importance of the role Hollands Farm plays as Green Belt. 2.1 It is clear national policy that Green Belt boundaries may only be changed in exceptional circumstances. Case law confirms that exceptional of itself includes necessity (Solihull MBC v Gallagher Homes [2014] EWCA Civ 1610; [2015] JPL) but mere suitability for housing development is not enough and the purposes of the Green Belt must come into play, per Jay J in Calverton PC v Nottingham Council & ors [2015] EWHC 1078 (Admin) at para.42). 2.2 The WDLP s approach to Green Belt release is pithily explained at WDLP page xvi, namely that some sites that Wycombe District Council consider perform weakly on Green Belt purposes are proposed to be released. 2.3 In fact, as the Green Belt Part 1 Assessment by Arup and Wycombe District Council s own (final) Green Belt Part Two Assessment Report explain (see paragraph 2.5(i) of the Final Part 2 Report), performing weakly/relatively weakly against the Green Belt purposes was made a crucial touchstone for release. If anything, the Council s approach was set out most clearly in the Draft Part 2 Report, at page 3: Sites will be considered capable of removal from the Green Belt when they perform weakly against all of the Green Belt purposes and the resultant boundaries and arrangement of Green Belt land would be acceptable. 2.4 The WDLP suggests, by implication, that these test has been met for Hollands Farm (see WDLP paragraph 5.4.18). That is an error, which error flows from a flawed evidence base. 2.5 The Wycombe District Council approach to Hollands Farm is untenable for two principal reasons: (1) It mischaracterises Hollands Farm (2) Its conclusions regarding the site s performance against Green Belt purposes are unsupported (which is likely to flow from the mischaracterisation). 2.6 As regards the Council s mischaracterisation of Hollands Farm, this is addressed by both the MLA Green Belt Report and the Pegasus Green Belt Assessment. 2.7 As the MLA Green Belt Report explains, the Council s evidence has mischaracterised Hollands Farm from the Part 1 report onwards. The Part 1 report (conveniently summarised within the main body of the June 2016 Report) characterised Hollands Farm as: i) Effectively enclosed within the settlement footprint of Bourne End/Wooburn ii) (Having) little linkage to the wider countryside iii) More semi-urban in character than rural iv) Almost completely enveloped by built form as a result of extensive ribbon development of Hedsor Road, which although washed over in the Green Belt, has an urban character and is functionally linked to Bourne End/Wooburn. 2.8 The Part 1 report also suggested that While the sub-area is largely open, the influence of built form reduces its sense of rurality. The acknowledgement of openness does, of course, go to one of the two essential characteristics of Green Belt.

2.9 That mischaracterisation in the Part 1 work was then carried through into the Council s Part 2 work, by way of the following (within Appendix 4 of the June 2016 Report and Appendix RG1 of the Final Part 2 Report): - - - Site is fully enveloped by development on all sides (Part 2 assessment, Section 1B, p.39 of Appendix 4 to the June 2016 Report). Although the site seems to be used as arable fields development surrounding the site weakens the connection to the wider countryside (Part 2 assessment, Section 1A(ii), p.39 of Appendix 4 to the June 2016 Report). giving the site a semi-urban character overall (Part 2 assessment, Section 1A(ii), p.39 of Appendix 4 to the June 2016 Report). 2.10 Contrary to those characterisations, and as the Inspector will see when they visit Hollands Farm, as they are warmly and sincerely urged to do: i) Whereas on plan form the Hollands Farm land may appear as surrounded by the Bourne End, Wooburn and Hawks Hill developed areas, on the ground there is absolutely no sense of the Hollands Farm land being enclosed by the nearby settlement areas. ii) The Hollands Farm site itself is part of the wider countryside and certainly possesses strong rights of way linkages to the contiguous countryside to the south. iii) The overriding character of the Hollands Farm site is very rural and highly attractive countryside rather than being accurately described as more semi-urban. iv) It is inaccurate and misleading to describe the Hollands Farm site as almost completely enveloped by built form. 2.11 The Council s mischaracterisation of Hollands Farm then feeds into its assessment of Hollands Farm against the five Green Belt purposes. 2.12 The Council s approach has been to assert that Hollands Farm is not performing the first, second and fourth of the five Green Belt purposes at all, to any extent, to discount the fifth Green Belt purpose altogether, and to conclude that Hollands Farm only scores positively against the third of the five Green Belt purposes Assist in safeguarding the countryside from encroachment, as regards which it is given a score of 2 in the Part 2 Assessment (see June 2016 Report Appendix 4, page 39, and Final Part 2 Report, Appendix GB1, page 9). 2.13 In addition to the flaws in the Council s approach due to an inadequate evidence base that mischaracterises Hollands Farm, the Council s approach is also flawed as a matter of principle as regards its approach to interpretation of the Green Belt purposes. That is because the effect of the Council s approach is to ignore the contribution Hollands Farm is making as Green Belt on the basis of an overly blunt and narrowly legalistic approach to interpretation of the five purposes that ignores the underlying Green Belt concerns that drive them. As the Pegasus Green Belt Assessment explains, whilst the Part 1 work by Arup sought to define the five Green Belt purposes in the context of Wycombe District, the Council s Part 2 work did not. However, the Council s Part 2 work is apparently based on the same overly narrow approach to interpretation of the five purposes. 2.14 In relation to Green Belt purpose 1 (to check the unrestricted sprawl of large built up areas), the Council s Part 2 work concludes that Hollands Farm is not at the edge of a large built-up area and therefore the site is scored fail against this purpose (see Final Part 2 Report, Appendix GB1, page 9). 2.15 However, as the Pegasus Green Belt Assessment explains (at paragraph 2.8), Purpose 1 is concerned with checking the unrestricted sprawl of large built up areas (and) urban sprawl is the creeping advancement of development beyond a clear physical boundary of a settlement so that Where the Green Belt is adjacent to a clear physical boundary the adjacent landscape form a role in safeguarding against unrestricted sprawl. Whilst Bourne End and Wooburn is not a large built up area, Hollands Farm is undeniably working hard to prevent unrestricted sprawl of the Cores (End) residential area further eastward and further southward (paragraph 2.12), working hard to ensure that there is no unrestricted sprawl of the business area further eastward towards the wooded settlement environment of Hawk s Hill and Harvest Hill (paragraph 2.14) and also working hard to prevent other unrestricted sprawl of Hawk s Hill and Harvest Hill area extending further westward towards Bourne End (paragraph 2.15). All of this gives pedestrians using the public rights of way across Hollands Farm a sense of passing

through open countryside (and) a clear sense that the Green Belt is framed to the west by the significant employment area of Bourne End and the residential area associated with Cores End to the north in stark contrast to the residential area to the east associate with Hawk s Hill and Harvest Hill (paragraph 2.16). 2.16 In relation to Green Belt purpose 2 (to prevent neighbouring towns merging into one another), again the Council s Part 2 work scores Hollands Farm 0 on the basis that it does not provide a gap between settlements and makes no discernible contribution to separation. On the contrary, as the Pegasus Green Belt Assessment explains, Hollands Farm is a narrow corridor of land located between Bourne End to the west and Hawk s Hill/Harvest Hill to the east (paragraph 3.6), all of which can be appreciated by the public (paragraphs 3.7-3.11) and the Green Belt here is significant in terms of fulfilling its purpose in preventing the neighbouring settled areas merging into one another (paragraph 3.12). 2.17 In relation to Green Belt purpose 3 (to assist in safeguarding the countryside from encroachment), the only purpose against which the Council have afforded Hollands Farm a positive score, albeit a score of only 2, as the Pegasus Green Belt Assessment observes, from the Arup Part 1 work onwards the Council has approached Hollands Farm on the basis that it is more semi-urban and with a reduced sense of rurality, yet Hollands Farm is significantly free of built form, the northern fields being farmed with no agricultural structures, barns associated with them (and) completely free of built form, similarly the fields to the north of the Hedsor Road are free of built form, the only cluster of buildings being agricultural structures located in the south-west close to and adjacent to the Bourne End Industrial Estate (paragraph 4.10). Hollands Farm cannot, therefore, be considered semi-urban, contrary to the Arup Part 1 work, and there is no erosion of the sense of openness associated with this Green Belt area and as such the sense of openness is perceived to be fully intact (paragraph 4.11). Hollands Farm significantly assists in safeguarding the countryside from encroachment (paragraph 4.12). 2.18 In relation to Green Belt purpose 4 (to preserve the setting and special character of historic towns), again the Council s Part 2 work scores Hollands Farm 0 on the basis that it does not abut an identified historic settlement core, but as the Pegasus Green Belt Assessment observes, this is contradicted by the draft Hedsor and Riversdale Road Conservation Area Appraisal (September 2017), which makes clear the importance of the rural and open nature of the Hollands Farm Green Belt to the north of Hedsor Road as part of the setting of the historic settlement (paragraphs 5.2-5.5). Quite clearly, Hollands Farm as Green Belt is playing a significant role in protecting and maintaining the setting and perception of this heritage asset (paragraph 5.15). 2.19 In relation to Green Belt purpose 5 (to assist in urban regeneration, by encouraging the recycling of other urban land), the Council excluded that purpose from the assessment. However, as the Pegasus Green Belt Assessment notes, that was incorrect. Some Green Belt parcels may assist more in helping to ensure the regeneration of urban brownfield sites that others. As regards Hollands Farm, given it is a narrow swathe of Green Belt it by its very presence assists in redirecting development pressures to other parts of the locality and in particular the wider settlement of Bourne End, so encouraging the recycling of derelict and other urban land within the urban fabric of the settlement (paragraph 6.4). 2.20 As per the summary of the Pegasus Green Belt Assessment: The Pegasus assessment of the site point to the important site specific role that the site plays in terms of the five purposes of the Green Belt and raise site specific matters that the WDC Part 2 report has failed to identify. It is apparent from the analysis of the five purposes of Green Belt that having looked at the Green Belt on the ground and having understood its physical and visual relationship with the adjacent settled landscape that this particular parcel of Green Belt (sic), particularly to the north of Hedsor Road, is significantly fulfilling the five purposes of Green Belt. Not only is it fulfilling the purposes, it is having a strong role in maintaining the identity and setting of these settled areas by being in place and by fulfilling all five purposes that Green Belt designation seeks to address. 2.21 As put in admirably short form by the conclusions of the MLA Green Belt Report, paragraph 4.2: i) TO CHECK THE UNRESTRICTED SPRAWL OF LARGE BUILT-UP AREAS The residential development of Hollands Farm would fail to check the southern/eastern spread of Bourne End. ii) TO PREVENT NEIGHBOURING TOWNS MERGING INTO ONE ANOTHER At present the Hollands Farm land provides a very green and rural character separation

between Bourne End and the Hawks Hill area. Housing development would bring to an end this separation, as well as resulting in the loss of significant open countryside. iii) TO ASSIST IN SAFEGUARDING THE COUNTRYSIDE FROM ENCROACHMENT As well as attractive views over Hollands Farm, the right of way which runs roughly north to south and across the western side appears very well used and from which footpath extensive open and countryside views are enjoyed both across the site and beyond. From the footpath, views to the west and south are not effected to any significant degree by the built form of the Hawks Hill settlement and which is extremely well screened by mature vegetation. The high quality countryside character of the Hollands Farm land is an important amenity asset for all local settlements and the users of the rights of way network. iv) TO PRESERVE THE SETTING AND SPECIAL CHARACTER OF HISTORIC TOWNS Consideration of the fourth Green Belt Purpose will need to include the heritage context of the Local Conservation Area at the southern end of Hollands Farm and for which the special character would be under threat from large scale modern development to the north. A narrow tree belt planted between the Conservation Area housing and development to the north would not be an effective or appropriate means of preserving the setting of this part of the Conservation Area. 2.22 As noted above, Wycombe District Council s approach makes weak/relatively weak performance against the Green Belt purposes an essential criteria before a site is to be considered for release. Applying Wycombe District Council s own criteria, Hollands Farm should never have advanced past the Part 1 assessment, given its strong performance against the Green Belt purposes and as Green Belt. In any event, Hollands Farm fails the national policy test of exceptional circumstances for Green Belt release. 2.23 Police BE2 should be removed from the WDLP in light of the important role Hollands Farm plays as Green Belt. 3.0 Hollands Farm is an extensive tract of attractive farmland that is valuable in landscape terms in its own right. 3.1 The shortcomings in the Council s evidence base as regards landscape character assessment and landscape and visual impact assessment have been noted above. They are set out in more detail in the MLA LVIA and the Pegasus LCA. Given the Council s mischaracterisations are essential to the Council s decision to release Hollands Farm from Green Belt and allocate it for housing, they are fundamental to Policy BE2 (and its lack of soundness). 3.2 The sustainability appraisal (SA) undertaken for the site to support the WDLP points to the impact of developing the site on the local landscape (despite the lack of formal site-specific landscape evidence as identified above) and by the Martin Leay report) the Technical SA states at paragraph 5.21 that: A small proportion of sites SBE0028+SBE0027 (Hollands Farm North) is also adjacent to the area identified by the Council as attractive landscape. Development at these sites has the potential for negative effects on the landscape and character in the east and south east of the settlement. 3.3 The Council not having produced the necessary evidence base to allow this to be adequately considered, the MLA LVIA and the Pegasus LCA represent the best evidence. 3.4 As the MLA LVIA explains, within the Summary and Conclusions section, the Hollands Farm site and its landscape setting comprise attractive farmed countryside and with significant views of the Hollands Farm land both from on-site and off-site, showing its attractive rural character which is all the more significant given that the land separates the settlement areas of Bourne End and Hawks Hill and Harvest Hill and which tract of land provides highly attractive views from the public right of way across Hollands Farm. Hollands Farm also contributes to the setting of the adjoining Conservation Area (explained further below along with the setting of various other designated heritage assets). The residential development proposals shown by Figure 39 to Policy BE2 would completely change the character of the countryside setting to both the south-eastern site of Bourne End and the western side of Hawks Hill. 3.5 As the Pegasus LCA explains, within its summary and conclusions: in the vicinity of Hollands Farm there are 6 discreet landscape character areas. The eastern edge of Bourne End settlement is defined by a residential area and an industrial estate which are both low-lying in vale. In contrast further east is the low density residential area of

Hawk s Hill and Harvest Hill situated in a heavily wooded undulating locally high ground. The houses that flank Hedsor Road form a further discreet residential enclave. The open land which separates these settled areas forms agricultural landscape which is important in separating these areas and assisting in identifying their unique identity. This important agricultural landscape has to date been omitted from previous published landscape character assessment, a fundamental flaw and omission which has the potential to misguide planning decision making. This character assessment makes it clear that there is a significant swath of landscape that does not form part of the urban environment of Bourne End but remains free of built form and undeveloped as open countryside. 3.6 The significance of the impact of development at Hollands Farm on the presently heavily wooded Hawk s Hill and Harvest Hill area, which the site presently separates from the eastern edge of the Bourne End settlement with attractive agricultural land, cannot be underestimated. But it has been missed by the Council s evidence base. 3.7 Policy BE2 should be removed from the WDLP in light of the landscape value of Hollands Farm in its own right. 4.0 Development of Hollands Farm for the quantum of development proposed will almost inevitably conflict with paragraph 1(b) of Policy BE2, which requires no adverse impact on the setting of Hedsor Road and Riversdale Bourne End and Wooburn Conservation Area, as well as causing harm to a wider range of designated heritage assets. 4.1 The Hollands Farm site is surrounded by a number of designated heritage assets, including the Hedsor Road and Riversdale Bourne End and Wooburn Conservation Area ( the Conservation Area ) singled out by paragraph 1(b) of Policy BE2, as well as many listed buildings. 4.2 The inadequacies in the Council s evidence base so far as heritage and the historic environment is concerned have been identified above. 4.3 To address those deficiencies, Pegasus have produced two reports, the Land at Hollands Farm, Bourne End, Buckinghamshire: Hedsor and Riversdale Conservation Area Setting Assessment ( the Pegasus CA Setting Assessment ) and the Pegasus Land at Hollands Farm, Bourne End, Buckinghamshire, Built Heritage Note ( the Pegasus Built Heritage Note ). 4.4 Tellingly, as regards Policy BE2, paragraph 1(b), the Conservation Area extends along Hedsor Road, immediately to the south of the Hollands Farm site, within an area identified by the Council s draft Character Appraisal for the Conservation Area as Upper Bourne End (one of three character areas within the Conservation Area identified by the Council s draft Character Appraisal). In relation to the Upper Bourne End character area, the Council s draft Character Appraisal states at p.4, when summarising the Special Interest of the Conservation Area, that: Upper Bourne End (Area A) largely conserves its rural setting as it comprises a ribbon of development along the eastern part of (Upper) Hedsor Road, a finger of built environment. This form of ribbon development was a characteristic that can be found all over the country where the margins of fields were developed, often by cottages to rent, to boost agricultural incomes while not losing significant productive areas of a farmer s fields. As a consequence the fields come right up to the rear boundaries of the road-frontage houses rear gardens. 4.5 As the Pegasus CA Setting Assessment notes, the Conservation Area principally derives its significance from the architectural and historic interest of its associated historic buildings, but the immediately adjacent agricultural land contributes to the significance of the Conservation Area through illustrating its historic rural context and at Upper Bourne End the adjacent agricultural land emphasises the linear development of this part of the settlement. Views to and from agricultural land, and the relationship between the settlement and this agricultural land, contributes to the significance of the Conservation Area, and at Upper Bourne End these include views to and from agricultural land to the south but also looking towards the settlement from agricultural land to the north (ie Hollands Farm) which bounds the northern edge of this part of the Conservation Area and provides a rural setting. These views towards Upper Bourne End character area, from within the Hollands Farm site, are identified as 'Significant' views in the draft Conservation Area Appraisal and contribute to the significance of the Conservation Area. 4.6 It is inevitable that development of the Hollands Farm site would alter agricultural land to the north of the Upper Bourne End Character Area to built form, resulting in the loss of the rural setting to the north of the settlement. Although the proposals in Figure 39 are indicative only, the amount of development proposed, 467 homes plus a primary school, would clearly require built form across the majority of the allocation site. The illustrative layout shown by Figure 39

suggests built form running immediately north of the existing buildings along Hedsor Road. This would interrupt Significant Views looking south-east from the public footpath crossing the site, even if the development area were subsequently set back to some extent, and would reduce the intelligibility of the historic linear development of Upper Bourne End, which would result in harm to the Conservation Area. As the Pegasus CA Setting Assessment observes, the amount of development proposed, 467 homes plus a primary school, means it is difficult to see how the allocation could be developed without any harm to the significance of the Conservation Area. 4.7 The conclusions of both the Pegasus CA Setting Assessment and the Pegasus Built Heritage Note are clear. 4.8 As the Pegasus CA Setting Assessment concludes: Development of the allocation site for 467 residential units and a primary school would result in harm to the Hedsor and Riversdale Conservation Area, a designated heritage asset. The allocation is therefore contrary to draft Policy BE2 of the Local Plan which states that "Development of the site is required to Not have an adverse impact on the setting of Hedsor Road and Riversdale Conservation Area". In terms of the NPPF, the harm from the site allocation would be less than substantial and under the NPPF paragraph 134 less than substantial harm to the significance of a designated heritage asset should be weighed against the public benefits of the proposal. 4.9 As regards the other designated heritage assets around Hollands Farm, comprising listed buildings, the Pegasus Built Heritage Note concludes: Development of the site would result in harm to one designated heritage asset of the highest significance, the Grade II* Listed Cores End Cottage and Cores End House. Development would also result in harm to designated heritage assets of less than the highest significance comprising the Hedsor and Riversdale Conservation Area, the Grade II Listed The Thatched Cottage, Long Woodcocks Waggoners Cottage, Heavenslea, Core End United Reformed Church, the Church of St Nicholas and the Grade II Registered Park and Garden Hesor (sic) House. 4.10 The Council s failure to adequately evidence the allocation of Hollands Farm in terms of the historic environment is laid bare by the sheer number of designated heritage assets that would suffer harm to their significance through harm to their setting and, most tellingly, by the fact that the Hedsor Road and Riversdale Conservation Area would itself almost inevitably suffer harm to its significance through harm to its setting by reason of the scale of development proposed, whatever the layout. 4.11 Policy BE2 should be removed from the WDLP in light of the harm to designated heritage assets and the historic environment as a whole. 5.0 Hollands Farm is unsuitable for development for the quantum of development proposed given the lack of necessary local infrastructure, the impact on the local transport network, and also due to a lack of employment opportunities given no further employment land is proposed by Policy BE2. 5.1 This item divides into three (1) a lack of local infrastructure (2) transport impacts and (3) lack of employment opportunities. 5.2 As to (1) lack of local infrastructure, Hollands Farm is unsuitable for development for the quantum of development proposed given the lack of necessary local infrastructure at Bourne End and the surrounding settlements (which area the WDLP refers to, artificially, as the settlement of Bourne End and Wooburn ). The detail of this is explained elsewhere in the representation made by Pegasus on behalf of KBEG in relation to Policy CP3 of the WDLP. That representation is adopted and should be taken as repeated here, but is not set out again in order to avoid duplication of paper. Briefly, though: Bourne End and Wooburn does not offer the services and facilities necessary to accommodate the quantum of residential development proposed (and as set out in the representation concerning Policy CP3, Bourne End and Wooburn should be a Tier 3 settlement, not a Tier 2 settlement). The lack of existing infrastructure at Bourne End to support the development includes lack of adequate primary school and medical facilities, which lead to a proposal that the Hollands Farm site deliver a primary school and, also, a medical centre. 5.3 As regards the lack of education infrastructure, paragraph 8.12 of the Local Plan Infrastructure

Delivery Plan states: The proposed housing allocations in Bourne End will generate the need for an additional 1FE primary school. This could be addressed on Land at Hollands Farm which could then meet the demand from the Slate Meadow site (BE1), and any other smaller allocations in Bourne End. Financial contributions from these sites will be required to fund the construction of the school. The exact location and delivery mechanism of the school will be subject to further assessment work in a development brief process. 5.4 However, the Slate Meadow site (Policy BE1 of the WDLP) is far more advanced than the Hollands Farm site and has recently been subject to a Draft Development Brief Consultation. The site is a reserve site in the present statutory development plan and it is likely that planning permission will be forthcoming for its development in the near future, and likely before a new primary school is built on the Hollands Farm site. 5.5 It has therefore been necessary for the local authority to be able to ensure that children emerging from the Slate Meadow site can be adequately accommodated within existing schools in Bourne End and Wooburn. It is understood that an additional half form of entry at Clayton s primary school is in the process of being negotiated to absorb the increased capacity from Slate Meadow. 5.6 The proposed quantum of development at Hollands Farm (467 homes) does not generate the need for a new one form entry primary school in its own right, however it is also clear that there would be no additional capacity in surrounding primary schools for children emerging from the site. Bourne End, quite clearly therefore, does not have the existing primary education infrastructure to accommodate the 800 new dwellings proposed in the WDLP, and yet neither does the delivery of approximately 467 dwellings at Hollands Farm require the delivery of a whole one form entry primary school (this goes to deliverability, addressed below). 5.7 As to (2) transport impacts, the impact on the local transport network from the (broadly) 800 homes distributed to Bourne End and Wooburn is addressed in the representation made by KBEG in relation to Policy CP4 of the WDLP, and also by the representation made by Pegasus on behalf of KBEG in relation to the sustainability appraisal that underpins the WDLP ( the WDLP SA ), and is all as explained by the Motion Transport Feasibility Appraisal (appended). 5.8 Briefly, though, even before the work done by Motion it was apparent from the Council s own evidence that the proposal will exacerbate an existing highway capacity issue at Cookham Bridge. 5.9 It is now clear from the work done by Motion that there is not only a lack of existing highway capacity to absorb the development proposed at Hollands Farm, with many junctions at or over capacity in the do-minimum (without Hollands Farm) scenario, but also other transport issues that present obstacles to delivery, because: (1) T The transport evidence base that Wycombe District Council has relied upon when developing the Local Plan is subject to a number of flaws that call into question the Council s ability to deliver the number of houses that it has identified to be required over the course of the next plan period. These include reliance on assessments that are based on historic data, and the failure to identify sufficient mitigation measures. So far as relevant to Policy BE2, these apparent limitations bring into question the deliverability of the Hollands Farm site. (2) T The Hollands Farm site access and its complimentary public transport strategy are subject to potential constraints that may preclude its delivery. These include access arrangements that would fall below visibility standards (an additional arm would need to be added to a roundabout to achieve the main access to Hollands Farm via Princes Road, yet visibility standards could not be achieved) and use of a narrow private route for a public bus service and also question marks over the proposed access arrangements in general, which involve roads that are presently in private ownership. Wycombe District Council must therefore provide further detailed evidence to ensure that the emerging access strategy for this site is deliverable, in the absence of which there can be no certainty that the level of development identified for Hollands Farm can be delivered (contrary to paragraph 173 of the NPPF). (3) T There are significant capacity constraints associated with the local highway network that need to be overcome in order for both Bourne End and Wooburn housing allocations, so the Hollands Farm site and also the Slate Meadow site, to accord with the requirements of the NPPF.

(4) T The current evidence base relied on by Wycombe District Council has not identified sufficient mitigation schemes to ensure that the local highway network operates effectively in the future, and it is clear that insufficient justification has been presented to support the inclusion of the Hollands Farm and Slate Meadow sites in the WDLP. Without these measures in place, the residual impact of the WDLP within Bourne End and Wooburn will be consistent with the severe threshold that is referred to in the NPPF as providing a justifiable highways reason to resist development. 5.10 As noted elsewhere, Motion also draw attention to the fact that the increased traffic from the development of the Slate Meadow site (BE1) is included in the Council s existing traffic levels, when Slate Meadow is merely an allocation in the WDLP and not developed. The inclusion of the traffic that would be generated if Slate Meadow was developed serves to artificially suppress the actual highway impacts of the proposed developments in the WDLP, including and in particular that of Hollands Farm, and therefore skews the evidence and results that the Council has presented for Regulation 19 consultation. 5.11 With regard to the proposed link road to be provided by Hollands Farm, in practice this would be a regular estate road, subject to national speed restrictions, that would pass through a residential area and past a proposed new primary school and exit onto Hedsor Road to the south, a rural lane. It is incorrect to think that it will provide a relief road for Bourne End, and it will serve to direct traffic towards Cookham Bridge which, as noted, is already a constrained crossing point over the River Thames. 5.12 Moreover, the southern access to/egress from the site, forming the southern end of the link road, is located in Flood Zone 3. 5.13 As to (3), lack of employment opportunities, while Bourne End and the surrounding settlements provide good existing employment opportunities, there is no proposal that they take additional employment development through the WDLP and therefore a large quantum of new housing is proposed at Hollands Farm (and Slate Meadow) without a corresponding growth in employment opportunities. This can only mean that those living in the new housing will be commuting out of the settlement. The sustainability of the new housing development is therefore questioned. 6.0 Deliverability Matters 6.1 Paragraph 47 of the NPPF requires local planning authorities to; identify a supply of specific, developable sites or broad locations for growth, for years 6-10 and, where possible, for years 11-15 6.2 Footnote 12 states; To be developable, sites should be in a suitable location for housing development and there should be a reasonable prospect that the site is available and could be viably developed at the point envisaged. 6.3 Pegasus on behalf of KBEG submit that the allocation of site BE2 Hollands Farm is not effective as there are considerable concerns over the deliverability of the site, which include some of the infrastructure matters, including highway infrastructure matters, discussed under item 5 above. The site is not evidenced as deliverable in years 1-5 of the plan period. There is no evidence that the necessary highway infrastructure is deliverable. The ownership of part of Jacksons Field and the unwillingness of the landowner to develop their site. The lack of viability evidence to substantiate a policy compliant development at the site. 6.4 These will be briefly addressed in turn. 6.5 As to timing, the Council s housing land supply evidence, which can be found at Appendix 2 Deliverable and Developable Housing Sites, of the Council s Housing and Economic Land Availability Assessment (September 2017) ( the HELAA ) states that sites SBE0028 (Hollands Farm) and SBE0027 (Jacksons Field) are developable in 6 to 10 years. 6.6 Necessarily, the site does not form part of the Council s five year housing land supply, presumably because there are significant issues that require resolution before planning permission could be obtained.