Wilton Park Outline Planning Application

Society's full response to:

Planning Ref: 17/01763/OUT – Wilton Park redevelopment

No affordable housing (or payment in lieu) together with over-development (exceeding the existing footprint and floor area) results in this application breaching: the Wilton Park SPD; the Affordable Housing SPD; Core Strategy; Local Plan; and the NPPF. Further, it is NOT sustainable development and should be refused.

We wish to object to this application because:

  • It breaches the Core Strategy in multiple respects specified below.

  • It breaches the Wilton Park SPD in multiple respects specified below. The scheme follows neither the letter nor the spirit of the Wilton Park SPD.

  • It breaches the Local Plan in multiple respects specified below.

  • Breaches the Affordable Housing SPD as no affordable housing is being provided or payment in lieu and the Viability Study has not been made available to the public for scrutiny. Nothing is commercially sensitive in such a Study and developers commonly do provide them for public scrutiny e.g. the developers at 40 Penn Road, 48 Penn Road, 72 Penn Road, 153 Amersham Road, 22 Grove Road; there are numerous examples and this should be no exception.

  • It breaches the NPPF in multiple respects, as specified below.

  • The average price for a home in the town now exceeds £1 million. With no affordable housing element included in this scheme, this does nothing to help the housing crisis – in fact it will exacerbate it by building more homes priced out of the reach of most people, certainly key workers, on green belt land.

  • Wilton Park SPD “is the result of collaborative work by SBDC, BCC and Inland Homes plc” and as such Inland Homes have been well aware of the requirements of the SPD for years and should not now deviate from those principles agreed in collaboration with SBDC and BCC, in particular in relation to affordable housing, size of footprint and floor area of the development all of which are breached by this scheme.

  • The Wilton Park SPD was informed by a 6 week public consultation and the principles of the development set out in that SPD (informed by that public consultation) must be enforced.

  • Inland Homes bought the site in 2014 and have had years to bring forward a sustainable, financially viable scheme but the scheme produced is emphatically not sustainable.

  • Core Strategy 14 requires necessary infrastructure to be put into place, including the new vehicular access which will serve as the entrance to the estate from Pyebush roundabout (Minerva Way always having been considered inadequate for the proposed number of homes). Inland Homes has for years known both of this requirement for accessing the homes and the obligation to provide affordable housing; therefore, the requirement for an access road should not be used as an excuse for not providing affordable housing or a commuted sum in lieu.

  • Not only did Inland Homes collaborate with SBDC on the Wilton Park SPD but Inland Homes also “carried out stakeholder engagement, informal public consultation and commissioned technical studies from specialist consultants. The District Council provided planning policy advice throughout.” Given Inland Homes’ stated involvement with SBDC and also specialist consultants, technical studies and public consultation in collaborating on the Wilton Park SPD, Inland Homes should not now renege on the principles agreed in the SPD. Otherwise, what was the point of the Wilton Park SPD? Inland Homes should not be permitted to cherry pick the sections of the Wilton Park SPD which they like (e.g. potential for provision of 350 homes) but simply disregard the rest.

  • The Core Strategy identified number of homes at Wilton Park to be in the region of between 250 and 350 and the developer is developing the maximum number but still not including any affordable housing.

  • According to the Wilton Park SPD, it is a core principle of the NPPF that planning should be plan-led, empowering local people to shape their surroundings. Having consulted the public to inform the Wilton Park SPD, the principles contained in the SPD should be up-held but this application breaches those principles and the NPPF.

  • It has become common for developers to refer to 4 floor dwellings (comprising basement, ground, upper floor and roof accommodation) as 2.5 storey buildings. The developer has not given the floor areas (and actual number of levels) of all of the proposed buildings (and their total floor area) and heights in metres to enable a full comparison with the existing floor area and heights as required by the SPD and Green Belt local plan policies. This application should not be decided until this information is made public. This is highly pertinent to the affordable housing calculation and extent of breach of the Wilton Park SPD.

  • The existing footprint is 26,878 sq.m. The proposed footprint is stated to be bigger, in breach of the Wilton Park SPD, Local Plan and Core Policies.

  • The existing floor space is 45,152 sq.m. The proposed floor space has not been given but as the footprint is bigger and as the development contains more numerous and larger multi-level buildings, the existing floor area is also exceeded. This breaches the Wilton Park SPD, Local Plan (GB1, GB2, EP3, H9) and Core Policies.

  • The existing general amenity area is 276,639 sq.m which are large areas of landscaping and sports pitches. The proposed comparative has not but must be given and should not include de minimis patches of landscaping.

  • Existing roads and hardstanding are 52,197 sq.m. The proposed comparison has not been given but must be given in accordance with the Wilton Park SPD and green belt polices in the Local Plan and NPPF.

  • Currently there are 86 2 storey houses (2 level) on site. 40 of these are 2 and 3 bed houses. 46 are 3 and 4 bed houses and these have been demolished to build the access road. The proposal has more numerous, taller, bigger buildings with more levels and larger footprint and floor space in breach of the Wilton Park SPD and Local Plan.

  • Crossings for pedestrians are needed to access Minerva Way from existing A355 which is almost impossible at busy times and always dangerous; and also to access the new relief road/access road from the A40. Several crossing points will be needed on the south section of the relief road. Details of these have not been provided but must be given prior to this application being decided.

  • Capacity of Beaconsfield station car park will not be able to cope with the influx of new inhabitants and their car parking and transport needs.

  • Wilton Park is too far from the station to be a sustainable location. It is too far to walk.

  • Access to Seer Green Railway Station cannot apparently be provided on foot and this will create unacceptable stress on the use of Beaconsfield Railway Station and on the car park and use of Seer Green Station also – both would be accessed by car by the majority of rail commuters.

  • As shown by the Inland Homes’ Transport Assessment, bus services are inadequate and too infrequent to make Wilton Park a sustainable location.

  • Beaconsfield is a town with: a very high incidence of car ownership and use; and an average property price exceeding £1 million making it extremely unlikely that the inhabitants of Wilton Park will take the (infrequent and inadequate) bus services.

  • There are no designated cycle paths connecting Wilton Park with the railway station and the town’s schools.

  • The view from Chilterns AONB (less than 1km away) would be impaired by this scheme which covers a greater footprint than existing.

  • Added stress on Burnham Beeches due to an increase in population of c. 875 people.

  • Added stress on Black Pond and other local beauty spots due to increase in number of inhabitants (c.875 i.e. 350 homes multiplied by an average of 2.5 inhabitants per dwelling).

  • The only element notably visible from outside Wilton Park currently is the abandoned tower block. The new scheme will include multiple multi-storey buildings (up to 5 levels).

  • A Woodland Tree Preservation Order applies in the south and south-west of the site and there are 3 substantial woodlands lying to the east and north which are managed by the Forestry Commission. More detailed information is needed to explain how the public will be able to gain access to these woodlands and surrounding countryside across ALL of Wilton Park (i.e. this should not be limited to one “greenway” nor be limited by private access only or gated communities).

  • Full public access should be given to all open spaces, Wilton Park footpaths, connections to rights of way footpaths, adjacent parkland and countryside and woodlands.

  • Walk Wood and Wheatsheaf Wood have been dedicated by the Forestry Commission as “open access land” under s.16 Countryside and Rights of Way Act 2000 and public access should be constructed to these areas. In particular, public access to Walk Wood to the north and the ASNW to the south-east should be available from and across all Wilton Park roads and footpaths in general. In particular, it is not clear how access will be given to the public in order to access Walk Wood.

  • The inclusion of gated communities within the scheme would breach the Wilton Park SPD.

  • Land on the south side separating Wilton Park from the A40 requires more screening to ensure the screening of the higher buildings of this scheme.

  • More tree protection orders are needed in particular to protect the Category A mature trees (51 trees and 5 groups of trees in this category). All category A and B trees must be retained.

  • The designated Ancient Semi-Natural Woodland MUST be protected and is threatened by this scheme.

  • The 3 areas of ASNW immediately beyond Wilton Park’s northern, south-eastern and southern boundaries are threatened by this scheme and must be protected.

  • The NPPF requires protection of the Green Belt and the intrinsic character and beauty of the countryside but this application threatens both.

  • The Communities Secretary, Sajid Javid, insists there is no need to build on green belt.

  • The complete redevelopment of previously developed sites in the green belt (of which Wilton Park is one) is only allowed by the NPPF if new development would not have a greater impact on the openness of the Green Belt and the purpose of including land in it than the existing development. It would have a greater impact on the green belt due to floor space and footprint increases and increase in height of more numerous buildings; it breaches the NPPF.

  • The tower block has a comparatively small footprint, far exceeded by the numerous multi-level buildings proposed.

  • This does not improve social well-being because it does not deliver affordable housing or payment in lieu, as required by the NPPF; it does not fulfil the social role of sustainability and is, therefore, unsustainable.

  • The planning obligation for affordable housing is not being fulfilled and this scheme is unacceptable without it.

  • The requirement for affordable housing is necessary to make the scheme acceptable; it is directly related to the development and is fairly and reasonably related in scale and kind to the development as required by the NPPF.

  • Core Strategy also envisages more than 100 new affordable homes (40%) and these must be provided as per the Core Strategy, Wilton Park SPD, Affordable Housing SPD and NPPF.

  • Core Policy 14 also states the redevelopment proposals should “result in no greater impact on the openness of the Green Belt.” It impacts heavily on the openness of the green belt due to heights of more numerous multi-level buildings, floor space and foot print exceeding the existing.

  • Core Policy 14 requires that “open space areas are integrated with the surrounding areas and existing countryside access.” It is not clear that the public will have access to all roads and footpaths on Wilton Park and how access to the open space areas will be gained from these beyond the main cycle route.

  • Core Policy 14 also requires the provision of high quality walking, cycling and public transport routes.” A link with Seer Green Station is required, as a minimum by a frequent bus service, together with safe crossing points on the existing A355 and from the A40 to the new access road off Pyebush roundabout and details of these should be provided before this application is decided.

  • Core Policy 3 is breached as it requires 40% of all dwellings to be affordable. No viability statement has been made public to show how the scheme is not financially viable to provide it.

  • The public are angry that affordable housing has not been provided on this scheme as it is stated in Core Policy and the Wilton Park SPD that it WILL be provided.

  • Inland Homes should devise a scheme that supports provision of affordable housing.

  • The Wilton Park SPD states “the Council’s preference is for a higher proportion of affordable housing units with 2 or more bedrooms, as these provide greater flexibility in matching needs with provision.” This scheme breaches this principle.

  • No provision has been included for accommodation for older people, including nursing accommodation and extra care units, as required by Core Policy 2.

  • The scheme is too big. The NPPF states that the redevelopment of the site “should not have a greater impact on the openness of the Green Belt…than the existing development.” The Wilton Park SPD states that “openness” “is commonly taken to be the absence of built development” yet the scheme increases the amount of built development. Core Strategy states that development “should not occupy a larger area of floor space than existing buildings” but it breaches this requirement too.

  • Core Strategy also requires “the height, massing and distribution of the proposed development should have no greater impact than the existing development on the openness of the Green Belt” but this is breached by the size, height, footprint and floor area of the scheme.

  • This scheme fails the “tests” regarding size of floor space and openness of the Green Belt.

  • Core Policy 7 is breached as there are no improved links with Seer Green railway station.

  • Core Policy 6 is breached because it is not clear at all how social infrastructure such as education and health facilities will be supported – how many school places for each year group will be provided? Where? When? Further, it is not at all clear how Green Infrastructure will be provided such as open ACCESS for all to the adjacent woodlands, open countryside and rights of way. Access appears limited, especially for the elderly and disabled who would require vehicular transport and parking.

  • Regarding the “Greenways” (corridors through the site that connect the town to open space in Wilton Park and links to surrounding countryside) – it is unclear to what extent Wilton Park is a private estate.

  • Policy TR7 has been breached because it has not been clearly shown how the parking requirements have been met for: each dwelling of each different type; the retail space; the offices (1 space per 25 sq.m plus lorry parking); café; community hub; park; football pitches; pavilion and nursery. It has not been shown how many people are anticipated to use the pitches, changing rooms, park, nursery, pavilion, retail and offices; how many disabled spaces will be provided; how many employees will work on site; and how many parking spaces will be required as a result. This information should be provided before this application is decided.

  • Core Policy 5 requires “adequate open space and recreation facilities in terms of quantity, quality and accessibility.” What is the size of GENUINE open space to be provided (ie not just small landscaped areas)? More specific information is needed.

  • Core Policy 8 requires that all new development must “make a positive contribution to the character of the surrounding area.” As such, the principles of the Wilton Park SPD must be adhered to, to protect the character of the town and the openness of its green belt which is the special setting of the Beaconsfield Old Town Conservation Area.

  • Local Plan Policy EP3 states “development will only be permitted where its scale, layout, siting, height, design, external materials and use are compatible with the character and amenities of the site itself and adjoining development and the locality in general.” Scale and height are incompatible with existing and the locality.

  • Policy H9 requires that development must “not adversely affect the character or amenities of nearby properties or the locality in general.” The plot coverage, heights and density of this scheme will affect the character of the area; and the scale of the development will adversely impact the amenities (schooling, healthcare, traffic, public transport, roads) in the area.

  • The SBDC Residential Design Guide SPD is also breached as there is no affordable housing; and the development is not well connected to the surroundings as greater and safer accessibility is needed both with the town, Seer Green Station and the adjacent open countryside and woodland. Further, it is not clear definition if any areas are to be private (possibly even gated) and which areas are to be public. This information must be provided before this application is decided.

  • How will it be ensured that the public will have open access to all roads, footpaths, the park, football pitches, the community hub, changing rooms, pavilion, open areas in perpetuity? This must be shown before this application is decided.

  • A frequent bus service is required to service Wilton Park, Old Town and New Town on a loop. 82% of those responding to this issue in the consultation stated that a new bus connection was important. Without this, the scheme is not sustainable.

  • The scheme will add to the dreadful parking problems, especially those in the Old Town.

  • Any benefits (a small park and eventually a small gallery space and changing rooms) do not outweigh the huge burden of this development on the town. The relief road will be swamped as soon as built. There are already football pitches and a nursery on the existing site.

  • 80% of those responding to the consultation stated that buildings should be a maximum of 2 to3 floors with no greater footprint than currently exists (as specified in the Wilton Park SPD). This has been breached and the consultation result ignored.

  • Sports pitches should be open to all residents not just football clubs.

  • The tennis courts are stated to be private and should be open to public use.

  • Should the existing 46 houses be demolished and replaced instead of being refurbished, this would be in breach of policy and should be resisted.

  • No further release of green belt could be tolerated and no greater massing. The largely open character of the site must remain.

  • It is too far and too dangerous, due to traffic, to walk into Beaconsfield from the site. It is not sustainable.

  • Access should be provided to the fishing pond and other ponds for the public to enjoy.

  • Stone planter from the original mansion and the original kitchen garden wall must be protected.

  • How will foul water be dealt with? Existing treatment works and sewerage lack capacity. Nearby areas in Beaconsfield Old Town have experienced foul water flooding.

  • Badgers, bats, birds, newts, lizards and reptiles are threatened by this scheme.

  • Provision of open space is confusing – which areas are PUBLIC open space?

  • The scheme generally exceeds heights of most buildings on Wilton Park at present.

  • Spread of the development far exceeds the current spread.

  • In the round, the impact on the Green Belt is too great and greater than existing.

  • The clusters of landscaping are small and of no great benefit to protect the openness of the green belt and should be enlarged.

  • The scale and siting of the new development is not sympathetic to the character of the site.

  • It is town cramming.

  • No mitigation on traffic impact before relief road is completed.

  • The Wilton Park SPD states that in assessing viability “the Council will give limited weight to the price paid for the site. This is because the developer should have been mindful of the Council’s affordable housing requirements when entering into a contract to purchase the site.” Inland Homes should also have been mindful of all of the requirements of the SPD when drawing up this scheme.

  • According to the Wilton Park SPD, two thirds of the affordable units should be socially rented with the remainder as intermediate affordable homes. This has not been provided in this scheme.

  • According to the Wilton Park SPD, affordable housing should provide modest, high quality units and be integrated within the wider residential development, avoiding large clusters. This has not been done.

  • “It is expected that a significant proportion of affordable housing will be provided on-site at Wilton Park.” (Para.6.19 Wilton Park SPD) This has not been done.

  • A minimum of 100 parking spaces are needed at the community hub (para 6.29 WP SPD). The proposed 75 spaces are inadequate and do not conform with the SPD.

  • When will the Pavilion building be available to the public? For the duration of the development the Planning Statement states it will be used as a “site sales office.” This is unacceptable.

  • At least 17 hectares of ACCESSIBLE open space (excluding landscaped areas are to be provided but it is not at all clear if this has been complied with. Further details are needed.

  • “The SPD makes it clear that the development layout should not create a separate gated community -  SPD page 83. Will there be any gated communities? If so, this breaches the SPD.

  • There will not be enough Boys’ grammar school places due to distance admission policy.

  • Landscape and publicly accessible open space should be at least 17 ha – more details are needed.

  • A much improved green buffer zone is needed along the northern and southern boundaries of the site

  • Larger houses should be limited to 2 levels only, as envisaged by the SPD.

  • This application in addition to the following planning applications yet to be decided/implemented cumulatively adds up to too much development for our town to cope with in terms of health, education, and traffic infrastructure with or without the relief road: 6 flats at 40 Penn Road, 5 flats at 48 Penn Road, 6 flats at 96 Gregories Road, 12 flats at 2 Knottocks Drive, 9 flats at 1 Holtspur Top Lane, 5 flats at 1 Disraeli Park, 8 flats at 72 Penn Road, 8 flats at 153 Amersham Road, 5 flats at 70 Ledborough Lane, 8 flats at 66/68 Penn Road, 9 houses next to Wyvale, and so it goes on. These, in addition to the 350 dwellings at Wilton Park, the 95 units at Sunrise, Bury Lodge, and multiple other blocks of flats already built in recent years is drowning our town. The cumulative effect is adverse to the character and amenity of the town.

  • According to the Developer’s Planning Statement, the footprint of the development will be 27,933 sq.m – larger than the existing and in breach of the Wilton Park SPD – and even bigger if you include garages and carports. The comparative figures need to be much clearer and include garaging and carports. The figures also need to be far clearer on amount of public open space (excluding small landscaping areas).

  • The publicly accessible open space is insufficient and does not provide the size of area set out in the SPD (small landscaped areas, buffer zones do not count according to the SPD).

  • The scheme does not “meet the needs of the present without compromising the ability of future generations to meet their own needs” because no affordable housing is being provided.

  • There will be one 4 storey (5 levels) building and other new buildings will be between 1 and 3 storeys (4 levels) in height but it is not clear how many levels this does in fact include. Does it include additional roof accommodation or basement accommodation? What are the comparative floor areas? More information is needed.

  • The highest density area is over 35 dph which is not in keeping with the character of the area and breaches multiple local plan policies on density such as EP3 and H9 and CP8.

  • In breach of the Affordable Housing SPD, no viability study has been provided, nor the viability study produced by the District Valuer. The public are angry that this information has not been produced for public scrutiny. There is no one way to produce a viability study or value the land (existing use value, “existing use plus”, market value etc) and many interpretations are possible. That produced by the developer and that produced by the District Valuer should be open to public scrutiny.

  • Will free on street parking be available as it is elsewhere in the town? More parking information is required and more parking should be provided to avoid further stressing the lack of car park spaces in the Old Town.

  • The occupants of a development of 350 dwellings could bring c.700 cars onto the site. Visitors to the park, football pitches, users of the offices, Pavilion and community hub could bring in excess of 300 cars. Then there will be deliveries, employees and workers, meaning that there would be a massive number of traffic movements per day with which the town simply cannot cope and which will pollute our air further.

  • The massive increase in traffic movement on the site will negatively impact the green belt and setting of the Old Town.

  • Light pollution.

  • The traffic movement study commissioned by Inland Homes lacks data as it does not include the boys’ grammar schools or any private schools in its calculations. Therefore, it is unreliable.

  • This scheme will damage the quality of life of the townspeople by: overdevelopment; increase in traffic; adverse impacts on air quality, pollution, health and education services.

  • This scheme does not widen the opportunities for home ownership because no affordable housing is included.

  • GB1 and GB2 of the Local Plan are breached.

  • Heights of existing buildings are given in Table 5 but heights of new buildings are not and must be given to enable an accurate comparison.

  • The affordable housing contribution should have been calculated by now. The INCREASE IN FLOORSPACE must be disclosed both from an affordable housing perspective and to assess full impact on openness of the greenbelt.

  • The Daily Express reported this a few years ago: “The Ministry of Defence’s language school in Beaconsfield, Buckinghamshire, was a victim of budget cuts last September.”

The vacant building credit does not apply where buildings have been abandoned. The tower and other buildings were abandoned by the MOD when their School of Languages closed due to changes in defence policy. The vacant building credit should not be applied in any affordable housing calculation.

  • The vast majority of current buildings are only 1 or 2 storeys. The tower has a relatively small footprint and has been abandoned in any event. Therefore full affordable housing provision should be made.

  • The developer has always known of the cost of the access road; the fact that it will be from Pyebush and not Minerva Way; and the fact that the ex MOD homes lying in the path of the access road would be demolished in order to construct it; and the developer is building the full complement of 350 homes. Therefore, full affordable housing provision should be made and the vacant building credit denied.

  • The Viability Statement must be disclosed to the public for scrutiny – failing to do so is not in the public interest; and breaches public policy and the Affordable Housing SPD.

  • Disabled access and parking must be enabled to access the open spaces and woodland to north, south and east.

Please reject this application

AJW For The Beaconsfield Society


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