News

Chiltern District Council Planning Dept

Amersham

Attn Cllr N Rose, Ms C Castle

Dear Sirs,

Re: Draft Core Strategy

Chalfont St Peter Parish Council objects to the Chiltern Development Framework Draft Core Strategy for Chiltern District June 2009 Stakeholder Consultation Document(DCS). Objection is made on the following principles:

1. Planning Policy There appears to be a fundamental U-turn in Chiltern District Council planning policy that seems to breach its own standards. The site appears on the Proposals Map of the long established Chiltern District Local Plan as being within the built up area of Chalfont St Peter and is covered by CDC Policy R10. This policy states that development would not be permitted on any part of this site if it were to result in the loss as a whole or in part of any area of amenity open space or would be seriously detrimental to the established character of the amenity open space. This policy was observed as recently as 2008 when the Sisters of The Holy Cross applied for permission to erect a new convent near Grange Close. A smaller part of the Holy Cross site is not covered by Policy R10 and is, being former educational use, covered by Policy CSF2, i.e. loss of Community Services and Facilities. From rightly being a sensitive and highly protected site, the site now appears in a plan attached to CDC’s emerging Core Strategy as a ‘Strategic Housing Site’.

• Is this a mistake?

• What has happened in one year to turn CDC’s policy on its head?
• Is this a mistake by the Executive or Planners, poor communication with the Planning Dept, or an attempt to conceal existing policies within the new LDF system? 

This Council would currently oppose any application for such a change of use.  Local schools are currently over crowded (see “Education” below) and a recent CDC report showed Chalfont St Peter to be short of recreational facilities (see “Open Spaces” below).”

The Parish Council should also like to draw your attention to the leaflet which was posted through the doors of some Chalfont St Peter residents. Many thought it was from the CDC, trying to point out that the development of Holy Cross has CDC approval. The Parish Council has received protests from many residents, angry with CDC’s apparent support.

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  • Was CDC party to this publication and subsequent exhibition in Chalfont Library?

or

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  • Has CDC objected to it on the basis that it misrepresents CDC approval and policies?

1. Consultation requirements not met: 

  2.1 Methodology – suspect and not engaging:

CDC’s consultation on the DCS (The Four Options, August 2008) involved contacting key stakeholders including estate agents, developers, utility providers and parish councils directly.  Residents in the CDC area were given an opportunity to have their say only through an insert in the quarterly CDC magazine and through an announcement on their web site.  This passive methodology is known to be highly unlikely to involve residents and the facts bear this out: only 80 people in Chalfont St Peter (out of 12,000) responded.  Fewer still responded from each of the other parishes, even Amersham (31) and Chesham (29).  The residents of Chalfont St Peter do not feel they have been consulted.

2.2 Results – findings ignored:

Despite the suspect and non-engaging methodology, key findings are ignored. Out of the four options considered, CDC decided to adopt Option 3: the targeted expansion of Amersham, Chesham and CSP, despite the fact that:

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  • The responding residents from Amersham, Chesham and CSP voted for Option 2 (targeted expansion of Amersham & Chesham), and

• On the basis of populations represented, the parish & town councils voted 47% for option 4, 33% for option 2, and only 16% for option 3.

2.3 Consultation Requirements - not fulfilled:

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  • We would specifically like to know what alternatives were considered to imposing 400+ dwellings on Holy Cross and cutting down trees, demolishing a school, removing amenity space and why this option was chosen without apparent support from the selection process?
  • The Cabinet Office Code of Consultation Practice says councils should have a designated Consultation Co-ordinator to monitor the effectiveness of their consultation process.  CDC says they were not aware of this and says it has no such person. Why does CDC not comply?
  • The CAA (Comprehensive Area Assessment division of the Audit Commission) requires local councils to be able to demonstrate that they understand and take account of the needs and wishes of the local community. Why does CDC not demonstrate this?

1. Education It has been widely discussed and recognised that the CSP C of E International School (‘Middle School’) is above full capacity and that BCC has indicated that the Core Strategy developments will increase the number of children that require education in the village. However, the DCS methodology is based on the numbers falling

BCC has stated:–  “The Secretary of State takes the view that there is a deficit in school places in Chiltern District and as such, some form of contribution is required.  ”Therefore, until an agreed policy (in the form of an adopted SPD similar to the arrangement we have with Wycombe District Council) for all future planning applications in Chiltern and South Bucks over 4 dwellings, BCC would not support the grant of planning permission.  In response to recent requests from local members, we would like the county council's position on school places to go on record as a material consideration for all future planning applications.” 

It is also Government Policy that successful schools should be developed. However, it has been stated by CDC that the possibility of moving the C of E International School to the Holy Cross site with a land swap for its current site is ‘too difficult’ and will not be pursued. It has been stated elsewhere by CDC that this is nothing to do with CDC but is a BCC responsibility to pursue. At the request of the residents of Chalfont St Peter, BCC and CDC have been invited to discuss the opportunities with each other and CSP Parish Council. It would be obdurate of them to continue to decline to do so.

1. Holy Cross – Site Biodiversity and EIA According to Government’s Strategy for Sustainable Construction progress report Sept 2009, a biodiversity survey of the site will be required as the value of the construction will exceed the threshold defined in this document. Would you please confirm when this requirement will be complied with? CDC appears to have waived the need for an EIA. The Parish Council seeks a reversal of this decision and also request details of the meeting that this decision was made so that the public record can be seen.

Additionally, the effect on the environment of the additional foul outflow on the already inadequate Thames Water main sewer seems to have been glossed over by CDC. The Parish Council considers this to be an unacceptable stance by CDC, particularly considering the frequency with which the foul sewers back up in Cordons Close and the Lower Road.

1. Dwelling Density.   The proposed dwelling densities are completely inappropriate and out of keeping with the existing village context.

      Current dwelling densities:

      Area size: 1,610 hectares in the entire parish; dwellings: 4,665 

      Density: Just under 3 dwellings per hectare (DPH) for the entire parish

      The ‘Built up’ area (includes open spaces and Holy Cross), is 30% = 483 hectares. 

Even if all 4,665 dwellings are in ‘built up’ part of the parish, in the village, then the current density for Chalfont St Peter, including all common services, open spaces and amenities, is under 10 dwellings per hectare

DCS Proposal: 720+ new dwellings in the village, including c.400 at Holy Cross. This increases dwellings by over 15%, mainly on two sites. Holy Cross is 8 hectares, so 400 dwellings there would = 50 dwellings per hectare and in the centre of the village – more if you take off the new convent building.

Holy Cross Developers Proposals (October 2009): Site size: 8 hectares. ‘About’ 300 dwellings, plus 80 resident care home, plus ‘community use’ building.  Taking, say, two hectares for the new convent and nun’s housing, the ‘community use building, and the care home, and car parking for both, that leaves 6 hectares and a dwelling density of 50 dwellings per hectare.

The Chalfont St Peter Village Design Statement is currently being produced and it is clear from its results so far that the VDS will show that the Draft Core Strategy is out of keeping with the village context and at odds with the wishes of the residents. 

Sources:

   Chiltern District Council ‘Planning’, ‘Population Statistics’: www.chiltern.gov.uk/downloads/Factsheet_CH_ST_PETER.pdf

   Buckinghamshire County Council www.bucksonline.gov.uk/bucksmaps

   Office for National Statistics: www.statistics.gov.uk/hub/population/index.html

1. Holy Cross – Highways. Any development on the Holy Cross site would increase traffic levels and pollution as the access points from the site exit on to already congested locations. In the recent G Eve proposal there was parking for 600+ cars, the movement of which would dramatically affect the congestion and pollution in the village. If a pedestrian access was added half way up Market Place as proposed by the recent G Eve plan, it would greatly exacerbate the problems which already exist on this busy section of the village.

1. Holy Cross – Open Space. According to the Chiltern District Council Open Space, Sport and Recreation Facilities Audit and Needs Assessment Final Report June 2005, the open spaces in the village fall short of the required standard. “Taking account of the location of the larger sites, the nature of provision west of Gravel Hill Road and the need for further open space, provision of public open space in Chalfont St. Peter does not meet the quantitative standard”. From this we conclude that the Draft Core Strategy should support the preservation of Open Space on the Holy Cross site

It should be born in mind that the DCS is only in draft form, has not been out to public consultation and should not in any way be considered to be established or intended CDC policy.  Would you please confirm that its contents will not be applied to any  planning applications until such time as it receives full CDC and Government approval?

Yours faithfully

Chalfont St Peter Parish Council

Cc: CSP Parish Cllrs, Cllr J Wertheim,  G Peters, N Rose, D Meacock, CSP Parish Council website, Bucks Advertiser