The New Wycombe District Local Plan. The future and why our district may never be that same again!
WERA has already commented substantively on the proposed development at Terriers and on the local plan published by Wycombe District Council (see at the bottom of this page).
WERA is also to give evidence at the public examination of the local plan on 4 September. Its draft statement is immediately below. Comments on the statement from residents would be very welcome. (lindaderrick@hotmail.com, 01494 718400)
Examination of WDC’s local plan
Matter 7: Development framework: High Wycombe 4 September 2018
1. I am the Chairman of Widmer End Residents’ Association (WERA). Widmer End is a village of some 2000 residents 3 miles to the NE of Wycombe.
2. WERA has commented on a number of aspects of the local plan including its letter of 21 November 2016 (resubmitted to the Examination) and I don’t propose to repeat these comments.
3. What WERA wants to do is expand on a theme which has run through all our comments. That theme is the need for social infrastructure, for example schools, community centres, playgrounds, playing fields, health centres, shops, which would contribute to a sense of community in the new developments. The provision of this social infrastructure for the new developments would also relieve pressure on existing communities like Widmer End.
4. I understand the purpose of the Examination is to consider the soundness of the local plan and that this consideration is to be based on the criteria set out in the National Planning Policy Framework (NPPF). These criteria are whether the plan is:
- Positively prepared
- Justified
- Effective
- Consistent with national policy
5. WERA’s contention is that the plan is not consistent with national policy and in particular will not enable the delivery of sustainable development in accordance with the policies in the National Planning Policy Framework (as revised July 2018)
6. Section 2 of the Framework, “Achieving sustainable development” says:
“7. The purpose of the planning system is to contribute to the achievement of sustainable development….
“8. Achieving sustainable development means that the planning system has three overarching objectives, which are interdependent and need to be pursued in mutually supportive ways (so that opportunities can be taken to secure net gains across each of the different objectives):
a) an economic objective…
b) a social objective – to support strong, vibrant and healthy communities, by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations; and by fostering a well-designed and safe built environment, with accessible services and open spaces that reflect current and future needs and support communities’ health, social and cultural well-being; and
c) an environmental objective…
7. WERA’s contention is that Wycombe’s local plan does not pursue the social objective; it does not support strong, vibrant and healthy communities by providing accessible local services.
8. Section 8 of the Framework, “Promoting healthy and safe communities”, says:
91. Planning policies and decisions should aim to achieve healthy, inclusive and safe places which:
a) promote social interaction, including opportunities for meetings between people who might not otherwise come into contact with each other – for example through mixed-use developments, strong neighbourhood centres, street layouts that allow for easy pedestrian and cycle connections within and between neighbourhoods, and active street frontages;
b) are safe and accessible, so that crime and disorder, and the fear of crime, do not undermine the quality of life or community cohesion – for example through the use of clear and legible pedestrian routes, and high quality public space, which encourage the active and continual use of public areas; and
c) enable and support healthy lifestyles, especially where this would address identified local health and well-being needs – for example through the provision of safe and accessible green infrastructure, sports facilities, local shops, access to healthier food, allotments and layouts that encourage walking and cycling.
92. To provide the social, recreational and cultural facilities and services the community needs, planning policies and decisions should:
a) plan positively for the provision and use of shared spaces, community facilities (such as local shops, meeting places, sports venues, open space, cultural buildings, public houses and places of worship) and other local services to enhance the sustainability of communities and residential environments;
b) take into account and support the delivery of local strategies to improve health, social and cultural well-being for all sections of the community;
c) guard against the unnecessary loss of valued facilities and services, particularly where this would reduce the community’s ability to meet its day-to-day needs;.. and
e) ensure an integrated approach to considering the location of housing, economic uses and community facilities and services.
94. It is important that a sufficient choice of school places is available to meet the needs of existing and new communities. Local planning authorities should take a proactive, positive and collaborative approach to meeting this requirement, and to development that will widen choice in education.”
9. WERA’s contention is that WDC’s local plan does not:
a) aim to achieve healthy, inclusive and safe places which promote social interaction as required by Paragraph 91 or
b) provide the social, recreational and cultural facilities and services the community needs as required by paragraph 92, or
c) provide a sufficient choice of school places to meet the needs of existing and new communities as required by Paragraph 94.
10. Indeed, we found it difficult to find any mention of communities in WDC’s local plan, much less find any discussion as to how the local plan achieves its social objective or complies with paragraphs 91, 92 and 94.
11. Para 2.19 of the local plan does identify five themes one of which is “Safe Communities”. This refers readers to a document called a “Sustainable Community Strategy. But this isn’t about how the local plan “promotes social interaction” or “provides the social, recreational and cultural facilities and services the community needs”.
12. The local plan also has eight strategic objectives but there is no mention of communities or people or any social objective. The objectives are:
- Cherish the Chilterns
- Strengthen the Sense of Place
- Foster economic growth
- Improve strategic connectivity
- Facilitate local infrastructure
- Deliver housing
- Champion town centres
- Mitigate Climate Change
13. Nothing about communities.
14. I want to illustrate what WERA means with three examples of developments. The first is Widmer End itself. Up until the 1970s, Widmer End consisted of houses and farms on three roads in a triangle. It had a pub, a village hall and a chapel. The village then more than doubled in size as about 400 houses were built in the middle of the triangle. With the development came shops, a church, a school, and a lot of small greens for the children to play on. The pub and chapel have since disappeared from Widmer End but we have gained a very large village green.
15. It’s not the best designed village – but we have local shops, meeting places, sports venues, and a place of worship. All in the village.
16. Most importantly we have a school. This means that children in the village go to school together. Most of them walk together. They play together. Their parents collect them from school and go to school events together. It makes a community.
17. My second example is a development built a couple of years ago at Kingshill Grange, about a mile from Widmer End. WERA took (and still takes) an interest in this development because it has made a significant impact on Widmer End, not least in increasing traffic through Widmer End. It has incidentally proved difficult if not impossible to use S 106 monies to effectively mitigate the impact.
18. 235 homes were built at Kingshill Grange. But this time, there was no school, no shops, and no community facilities except a playground. The playground is on the perimeter of the development adjacent to a busy road with no secure barrier to stop children running in the road. So there is no “strong neighbourhood centre” to promote social interaction.
19. In fact, far from promoting social interaction, the development has seen problems with crime and anti-social behaviour. The pressure to build more homes at the expense of providing local facilities, including adequate parking, has also caused serious parking and traffic problems in the vicinity.
20. Children from the Kingshill development go to 4 or 5 different primary schools, virtually all of them by car because there is no local school.
21. The children - and their parents - do not get to know each other. There is no natural way of getting together or meeting to chat.
22. The planning system did not perform its social objective in “promoting social interaction” at Kingshill Grange.
23. In 1973, planners looked at the community they were creating in Widmer End. They considered the people who would come to live in the development and the people who already lived in Widmer End and sought to promote social interaction and a sustainable community by providing local community facilities.
24. Forty years later when Kingshill Grange was built, the planners didn’t consider the people who would come to live there and how community facilities could be provided to help create a sustainable community. Instead a sort of tickbox approach was adopted. Are there any shops? Yes, there are some shops half a mile away in one direction and other shops a mile the other way. Are there school places? Yes, in 4 or 5 schools within 3 miles. Is there a meeting room? Yes, in the church a mile away.
25. The planners didn’t help create a community; they helped create a dormitory.
26. We see the same tick box approach running through the local plan. It means that a further development, this time at Terriers, is not being planned as a community; again it is to be a dormitory. This time about 500/600 homes could be built. But there are no planned community facilities. There may be some sporting facilities but these are intended to cater for a wide geographical area. This will not promote social interaction for people on the development and might actually create more traffic and congestion.
27. A new school is to be built at Gomm Valley – but that doesn’t promote social interaction or support the health, social and cultural well-being of the new development at Terriers. Children from Terriers will be dispersed to schools in the area and will have to get there by car.
28. In conclusion, the local plan fails to pursue the social objective required by the Framework and does not therefore comply with national policy.
29. The local plan fails to provide the social, recreational and cultural facilities and services the community needs. This includes failing to plan positively for the provision and use of shared spaces, community facilities (such as local shops, meeting places, sports venues, open space, cultural buildings, public houses and places of worship) and other local services. In failing to do this, the local plan fails to enhance the sustainability of communities and residential environments.
30. The local plan does not aim to achieve healthy, inclusive and safe places by promoting social interaction, including failing to provide “opportunities for meetings between people who might not otherwise come into contact with each other”.
31. The local plan does not provide sufficient choice of school places to meet the needs of existing and new communities; it does not provide local schools within walking distance of the children.
32. The local plan is therefore not sound.
33. Basically, the plan has forgotten the people and their communities.
The letter below, from WERA to Wycombe District Council, concerns the local plan.
(It was originally sent in November 2016, and resubmitted in 2018)
Dear Sirs,
New Wycombe District Local Plan: Draft Consultation Document
Whilst we are grateful for the opportunity to comment on this plan, we feel that your deadline of Monday 8 August is too close for us to collectively formulate a reasoned response to the plan as a whole. We will therefore deal almost exclusively with those sections that relate to proposed major developments on or near the boundaries of Widmer End ward of Hughenden Parish, and are therefore likely to have an impact on the quality of life in our area. These are Terriers Farm (Policy HW7), Glynswood (Policy HW10), and Tralee Farm and other land bordering Hazlemere and Holmer Green (Policy HW8).
We reluctantly accept the need for a substantial increase in housing in Wycombe District, but are alarmed by the scale of its projected encroachment on the Green Belt and particularly the Chilterns Area of Outstanding Natural Beauty. We believe that not all has been done to identify and earmark existing and potential brownfield sites. The District Council should insist that developers make full use of such sites before they can be allowed to build on our precious countryside.
We also question whether the proposal to build as many as 500 new homes per year for the next twenty years is really necessary, given the prospect of an economic downturn and a fall in immigration figures that are the likely consequences of Britain's decision to leave the European Union.
Very careful consideration should be given to any proposal to take land from the AONB. Such a proposal should be refused unless there are exceptionally good reasons for accepting it. Likewise, the original purpose of the Green Belt, namely to guard against large-scale merging of towns and villages to create a featureless metropolis, should be borne in mind. Repeated nibbling of the Green Belt by successive local plans will in time
reduce the belt to a token sliver of greenery between huge slabs of development.
Terriers Farm. We have already commented on your infrastructure proposals for this reserve site in our letter of 3 March 2016. We note with disappointment that the upper bound to the number of proposed homes has risen from 490 to 540. This should surely add to the need for a basis of social infrastructure, in other words a defined community centre incorporating social, educational, health and retail facilities. The need for such an
infrastructure is acknowledged in Policy CP7 (p. 43). However, apart from some open space and sports facilities, nothing appears to be planned to serve what will be equivalent to a new village in terms of population and area. For this site, and for others, no attempt has yet been made to provide the elements of infrastructure that will instil a sense of community in the new development.
Glynswood. Although relatively small, this development of about 50 new homes would scenically ruin the view from the footpath linking Four Ashes to the Hughenden valley, some of which passes through National Trust land. Policy DM31 (p. 165) states that any development within the AONB “will only be permitted in exceptional circumstances” and should “foster the economic and social wellbeing of the area”. In neither respect does the proposed development comply with this policy.
Tralee Farm. Development of this land will substantially reinforce the existing coalescence between Hazlemere and Holmer Green, especially if Chiltern District Council allows development of the land bordering the HW8 area. It will thicken the continuous ribbon of development to the north of High Wycombe stretching all the way from Walters Ash to Penn. As with Terriers Farm, there are no plans for any significant
degree of social infrastructure on this site.
Field Farm (Travellers' Site Reference GT015, p. 190). We would question the designation of this farm as a travellers' site, since we believe the proper process for such designation has not been followed. However, if it is indeed a travellers' site we have no objection to the proposal to convert the permission for one pitch from temporary to permanent. But we trust that this will not provide an excuse for enlarging the site to become a major settlement, as this would be entirely inappropriate for this area.
Further considerations. One reason why we are concerned with providing adequate social infrastructure in new developments is that doing so will relieve some of the pressure on existing communities. Road traffic, for example, is a big concern in our village. Education is another. As we stated in our letter of 3 March, referred to earlier, the provision of primary education on the Terriers Farm site would relieve pressure on Widmer End and other schools in the area to accept more pupils as well as providing a social focus for families living in the new development.
Finally, we hope that it will still be possible to engage in meaningful consultation on specific issues after the deadline of 8 August.
Yours sincerely,
Ian Guy,
Hon. Secretary, Widmer End Residents' Association
WERA is also to give evidence at the public examination of the local plan on 4 September. Its draft statement is immediately below. Comments on the statement from residents would be very welcome. (lindaderrick@hotmail.com, 01494 718400)
Examination of WDC’s local plan
Matter 7: Development framework: High Wycombe 4 September 2018
1. I am the Chairman of Widmer End Residents’ Association (WERA). Widmer End is a village of some 2000 residents 3 miles to the NE of Wycombe.
2. WERA has commented on a number of aspects of the local plan including its letter of 21 November 2016 (resubmitted to the Examination) and I don’t propose to repeat these comments.
3. What WERA wants to do is expand on a theme which has run through all our comments. That theme is the need for social infrastructure, for example schools, community centres, playgrounds, playing fields, health centres, shops, which would contribute to a sense of community in the new developments. The provision of this social infrastructure for the new developments would also relieve pressure on existing communities like Widmer End.
4. I understand the purpose of the Examination is to consider the soundness of the local plan and that this consideration is to be based on the criteria set out in the National Planning Policy Framework (NPPF). These criteria are whether the plan is:
- Positively prepared
- Justified
- Effective
- Consistent with national policy
5. WERA’s contention is that the plan is not consistent with national policy and in particular will not enable the delivery of sustainable development in accordance with the policies in the National Planning Policy Framework (as revised July 2018)
6. Section 2 of the Framework, “Achieving sustainable development” says:
“7. The purpose of the planning system is to contribute to the achievement of sustainable development….
“8. Achieving sustainable development means that the planning system has three overarching objectives, which are interdependent and need to be pursued in mutually supportive ways (so that opportunities can be taken to secure net gains across each of the different objectives):
a) an economic objective…
b) a social objective – to support strong, vibrant and healthy communities, by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations; and by fostering a well-designed and safe built environment, with accessible services and open spaces that reflect current and future needs and support communities’ health, social and cultural well-being; and
c) an environmental objective…
7. WERA’s contention is that Wycombe’s local plan does not pursue the social objective; it does not support strong, vibrant and healthy communities by providing accessible local services.
8. Section 8 of the Framework, “Promoting healthy and safe communities”, says:
91. Planning policies and decisions should aim to achieve healthy, inclusive and safe places which:
a) promote social interaction, including opportunities for meetings between people who might not otherwise come into contact with each other – for example through mixed-use developments, strong neighbourhood centres, street layouts that allow for easy pedestrian and cycle connections within and between neighbourhoods, and active street frontages;
b) are safe and accessible, so that crime and disorder, and the fear of crime, do not undermine the quality of life or community cohesion – for example through the use of clear and legible pedestrian routes, and high quality public space, which encourage the active and continual use of public areas; and
c) enable and support healthy lifestyles, especially where this would address identified local health and well-being needs – for example through the provision of safe and accessible green infrastructure, sports facilities, local shops, access to healthier food, allotments and layouts that encourage walking and cycling.
92. To provide the social, recreational and cultural facilities and services the community needs, planning policies and decisions should:
a) plan positively for the provision and use of shared spaces, community facilities (such as local shops, meeting places, sports venues, open space, cultural buildings, public houses and places of worship) and other local services to enhance the sustainability of communities and residential environments;
b) take into account and support the delivery of local strategies to improve health, social and cultural well-being for all sections of the community;
c) guard against the unnecessary loss of valued facilities and services, particularly where this would reduce the community’s ability to meet its day-to-day needs;.. and
e) ensure an integrated approach to considering the location of housing, economic uses and community facilities and services.
94. It is important that a sufficient choice of school places is available to meet the needs of existing and new communities. Local planning authorities should take a proactive, positive and collaborative approach to meeting this requirement, and to development that will widen choice in education.”
9. WERA’s contention is that WDC’s local plan does not:
a) aim to achieve healthy, inclusive and safe places which promote social interaction as required by Paragraph 91 or
b) provide the social, recreational and cultural facilities and services the community needs as required by paragraph 92, or
c) provide a sufficient choice of school places to meet the needs of existing and new communities as required by Paragraph 94.
10. Indeed, we found it difficult to find any mention of communities in WDC’s local plan, much less find any discussion as to how the local plan achieves its social objective or complies with paragraphs 91, 92 and 94.
11. Para 2.19 of the local plan does identify five themes one of which is “Safe Communities”. This refers readers to a document called a “Sustainable Community Strategy. But this isn’t about how the local plan “promotes social interaction” or “provides the social, recreational and cultural facilities and services the community needs”.
12. The local plan also has eight strategic objectives but there is no mention of communities or people or any social objective. The objectives are:
- Cherish the Chilterns
- Strengthen the Sense of Place
- Foster economic growth
- Improve strategic connectivity
- Facilitate local infrastructure
- Deliver housing
- Champion town centres
- Mitigate Climate Change
13. Nothing about communities.
14. I want to illustrate what WERA means with three examples of developments. The first is Widmer End itself. Up until the 1970s, Widmer End consisted of houses and farms on three roads in a triangle. It had a pub, a village hall and a chapel. The village then more than doubled in size as about 400 houses were built in the middle of the triangle. With the development came shops, a church, a school, and a lot of small greens for the children to play on. The pub and chapel have since disappeared from Widmer End but we have gained a very large village green.
15. It’s not the best designed village – but we have local shops, meeting places, sports venues, and a place of worship. All in the village.
16. Most importantly we have a school. This means that children in the village go to school together. Most of them walk together. They play together. Their parents collect them from school and go to school events together. It makes a community.
17. My second example is a development built a couple of years ago at Kingshill Grange, about a mile from Widmer End. WERA took (and still takes) an interest in this development because it has made a significant impact on Widmer End, not least in increasing traffic through Widmer End. It has incidentally proved difficult if not impossible to use S 106 monies to effectively mitigate the impact.
18. 235 homes were built at Kingshill Grange. But this time, there was no school, no shops, and no community facilities except a playground. The playground is on the perimeter of the development adjacent to a busy road with no secure barrier to stop children running in the road. So there is no “strong neighbourhood centre” to promote social interaction.
19. In fact, far from promoting social interaction, the development has seen problems with crime and anti-social behaviour. The pressure to build more homes at the expense of providing local facilities, including adequate parking, has also caused serious parking and traffic problems in the vicinity.
20. Children from the Kingshill development go to 4 or 5 different primary schools, virtually all of them by car because there is no local school.
21. The children - and their parents - do not get to know each other. There is no natural way of getting together or meeting to chat.
22. The planning system did not perform its social objective in “promoting social interaction” at Kingshill Grange.
23. In 1973, planners looked at the community they were creating in Widmer End. They considered the people who would come to live in the development and the people who already lived in Widmer End and sought to promote social interaction and a sustainable community by providing local community facilities.
24. Forty years later when Kingshill Grange was built, the planners didn’t consider the people who would come to live there and how community facilities could be provided to help create a sustainable community. Instead a sort of tickbox approach was adopted. Are there any shops? Yes, there are some shops half a mile away in one direction and other shops a mile the other way. Are there school places? Yes, in 4 or 5 schools within 3 miles. Is there a meeting room? Yes, in the church a mile away.
25. The planners didn’t help create a community; they helped create a dormitory.
26. We see the same tick box approach running through the local plan. It means that a further development, this time at Terriers, is not being planned as a community; again it is to be a dormitory. This time about 500/600 homes could be built. But there are no planned community facilities. There may be some sporting facilities but these are intended to cater for a wide geographical area. This will not promote social interaction for people on the development and might actually create more traffic and congestion.
27. A new school is to be built at Gomm Valley – but that doesn’t promote social interaction or support the health, social and cultural well-being of the new development at Terriers. Children from Terriers will be dispersed to schools in the area and will have to get there by car.
28. In conclusion, the local plan fails to pursue the social objective required by the Framework and does not therefore comply with national policy.
29. The local plan fails to provide the social, recreational and cultural facilities and services the community needs. This includes failing to plan positively for the provision and use of shared spaces, community facilities (such as local shops, meeting places, sports venues, open space, cultural buildings, public houses and places of worship) and other local services. In failing to do this, the local plan fails to enhance the sustainability of communities and residential environments.
30. The local plan does not aim to achieve healthy, inclusive and safe places by promoting social interaction, including failing to provide “opportunities for meetings between people who might not otherwise come into contact with each other”.
31. The local plan does not provide sufficient choice of school places to meet the needs of existing and new communities; it does not provide local schools within walking distance of the children.
32. The local plan is therefore not sound.
33. Basically, the plan has forgotten the people and their communities.
The letter below, from WERA to Wycombe District Council, concerns the local plan.
(It was originally sent in November 2016, and resubmitted in 2018)
Dear Sirs,
New Wycombe District Local Plan: Draft Consultation Document
Whilst we are grateful for the opportunity to comment on this plan, we feel that your deadline of Monday 8 August is too close for us to collectively formulate a reasoned response to the plan as a whole. We will therefore deal almost exclusively with those sections that relate to proposed major developments on or near the boundaries of Widmer End ward of Hughenden Parish, and are therefore likely to have an impact on the quality of life in our area. These are Terriers Farm (Policy HW7), Glynswood (Policy HW10), and Tralee Farm and other land bordering Hazlemere and Holmer Green (Policy HW8).
We reluctantly accept the need for a substantial increase in housing in Wycombe District, but are alarmed by the scale of its projected encroachment on the Green Belt and particularly the Chilterns Area of Outstanding Natural Beauty. We believe that not all has been done to identify and earmark existing and potential brownfield sites. The District Council should insist that developers make full use of such sites before they can be allowed to build on our precious countryside.
We also question whether the proposal to build as many as 500 new homes per year for the next twenty years is really necessary, given the prospect of an economic downturn and a fall in immigration figures that are the likely consequences of Britain's decision to leave the European Union.
Very careful consideration should be given to any proposal to take land from the AONB. Such a proposal should be refused unless there are exceptionally good reasons for accepting it. Likewise, the original purpose of the Green Belt, namely to guard against large-scale merging of towns and villages to create a featureless metropolis, should be borne in mind. Repeated nibbling of the Green Belt by successive local plans will in time
reduce the belt to a token sliver of greenery between huge slabs of development.
Terriers Farm. We have already commented on your infrastructure proposals for this reserve site in our letter of 3 March 2016. We note with disappointment that the upper bound to the number of proposed homes has risen from 490 to 540. This should surely add to the need for a basis of social infrastructure, in other words a defined community centre incorporating social, educational, health and retail facilities. The need for such an
infrastructure is acknowledged in Policy CP7 (p. 43). However, apart from some open space and sports facilities, nothing appears to be planned to serve what will be equivalent to a new village in terms of population and area. For this site, and for others, no attempt has yet been made to provide the elements of infrastructure that will instil a sense of community in the new development.
Glynswood. Although relatively small, this development of about 50 new homes would scenically ruin the view from the footpath linking Four Ashes to the Hughenden valley, some of which passes through National Trust land. Policy DM31 (p. 165) states that any development within the AONB “will only be permitted in exceptional circumstances” and should “foster the economic and social wellbeing of the area”. In neither respect does the proposed development comply with this policy.
Tralee Farm. Development of this land will substantially reinforce the existing coalescence between Hazlemere and Holmer Green, especially if Chiltern District Council allows development of the land bordering the HW8 area. It will thicken the continuous ribbon of development to the north of High Wycombe stretching all the way from Walters Ash to Penn. As with Terriers Farm, there are no plans for any significant
degree of social infrastructure on this site.
Field Farm (Travellers' Site Reference GT015, p. 190). We would question the designation of this farm as a travellers' site, since we believe the proper process for such designation has not been followed. However, if it is indeed a travellers' site we have no objection to the proposal to convert the permission for one pitch from temporary to permanent. But we trust that this will not provide an excuse for enlarging the site to become a major settlement, as this would be entirely inappropriate for this area.
Further considerations. One reason why we are concerned with providing adequate social infrastructure in new developments is that doing so will relieve some of the pressure on existing communities. Road traffic, for example, is a big concern in our village. Education is another. As we stated in our letter of 3 March, referred to earlier, the provision of primary education on the Terriers Farm site would relieve pressure on Widmer End and other schools in the area to accept more pupils as well as providing a social focus for families living in the new development.
Finally, we hope that it will still be possible to engage in meaningful consultation on specific issues after the deadline of 8 August.
Yours sincerely,
Ian Guy,
Hon. Secretary, Widmer End Residents' Association
