Letter 23 Nov 07 objecting to residential development

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RE: Planning Application No. 07/07553/OUT. Alfred Davis Memorial Sports Ground (Marlow Football Club), OakTree Road, Marlow.

Outline application for residential development of 94 (12x1 bed flats, 49x2 bed flats, 17 x3 bed
& 16x 4 x bed houses including access to Oak Tree Road following demolition of existing structures.

Below is a copy of the letter sent by The Marlow Society:

Mr. Chris Steuart,
Planning and Major Projects Directorate,
Wycombe District Council,
Queen Victoria Road,
High Wycombe, Bucks.,
HP11 1BB.

23 November 2007

Dear Mr. Steuart,

Planning ApplicationNo. 07/07553/OUT. Alfred Davis Memorial Sports Ground (Marlow Football Club), OakTree Road, Marlow.

Outline application for residential development of 94 (12x1 bed flats, 49x2 bed flats, 17 x3 bed
& 16x 4 x bed houses including access to Oak Tree Road following demolition of existing structures.

The Marlow Society wishes to lodge its strong objection to the above application for the erection of 94 dwellings on the Marlow football ground in Oak Tree Road which it considers to be in contravention of Local Plan policies G3 (General Design Policy) and L3 (Green Space).

Policy G3.
Explanatory paragraphs 2.14 and 2.15 state that ‘new development will need to be carefully assimilated into existing townscapes and landscapes by sensitive design, and by respecting , and where possible enhancing, the established character of the area (2.14) and ‘in all types of development, the layout should respect and incorporate any existing features or green spaces worthy of retention on site or in the vicinity. In particular, views into and out of the site will be important. (2.15).
The proposed development contravenes all of these provisions.

Policy G3 (1) (c) states that proposals will need to demonstrate visibly that they are ‘compatible with the immediate surroundings of the site and appropriate to its wider context by reference to street patterns and land levels, plot sizes, means of enclosure, proportion, scale, bulk, form and massing’
The Proposed development contravenes at least seven of these eight requirements, particularly in respect of the proposed density, height, bulk and massing.

Policy L3
Explanatory paragraph 10.15 states that ‘ Green Space’ is an essential component of the built environment in both rural and urban settlements and its protection is a vital factor in achieving sustainable land use and development’. Paragraph 10.17 states that ‘Proposals that would result in the loss or fragmentation or reduction in size of green spaces will be firmly rejected’.
This site is located in a residential area where green spaces provide very necessary amenity within the surrounding dense urban area. The site is zoned in the Proposals Map of the Adopted Local Plan to 2011 as ‘Green Space’ and any development should comply with Policy L3 of the Adopted Plan. This states that, ‘Planning permission will not be given for proposals involving the loss or fragmentation or reduction in size of green spaces within the built up areas.’
Additionally, both the emerging Local Development Framework and the District Open Space Study of 2005 identify East Marlow as an area of Green Space deprivation and consequently any further loss of green space is totally unacceptable.

Attempting to justify development in this green space, the applicant appears to claim special circumstances exist to bring this development within the provisions of Policy L3 (2), in that the elimination of this prescribed green space is justified by the provision of 94 dwellings on this site and the development of sporting facilities within the town’s Green Belt, albeit these facilities (which could easily be accommodated within the existing Oaktree Road site) comprise structures resulting in inappropriate development in terms of Green Belt policies.

If any special circumstances could be established in relation to this proposal, then the developer is obliged to retain a substantial element of green space and the overall character and quality of space maintained, or make alternative provision of equivalent quality and quantity within a reasonable distance. (Policy L3.2 ). No such provision is evident or possible with this proposal and it is the considered view of this Society that a remote football facility in the town’s Green Belt does not fulfil this requirement to the benefit of the adjacent built up area as safeguarded by Policy L3.2. The proposal is therefore a gross over development of this site leaving no provision for the retention of green space as required by policy L3(2).

It is this Society’s view that any permission which takes account of inappropriate development within the Green Belt surrounding Marlow or regards this as ‘enabling development’, notably, in this case, to satisfy commercial objectives, would establish a dangerous precedent for other unsuitable developments within the Green Belt. Connecting two application sites and making the development of each to be conditional on planning permission being given for the other is considered to be an unacceptable manipulation of the planning system which should not be tolerated. Planning permission on any site should be considered independently on the merits of the site specific land use and adopted planning policies. In this case the applicant appears to regard the provision of housing on this green space as enabling a ‘ planning gain, in the provision of a football complex within the town’s green belt, ignoring the well established principle that any planning gain should benefit directly the site being developed.

Much emphasis is given by this applicant to the District’s requirement for housing and we totally reject the suggestion that this also should be regarded as ‘special circumstances’ for the over development of this site with the erection of 94 dwellings on a green space site of 1.6 hectares. Potential housing development in Marlow has clearly increased, for example:-

1) The owners of the Portland’s site in the town centre now propose 83 dwelling on this site, an increase of 33% over the 50 homes prescribed in the Local Plan..
2) 24 dwellings are now in the course of construction on the Quoitings site, which clearly exceeds the number envisaged by the Planning Inspector’s report on the current Adopted Local Plan.
3) Outline planning permission has now been given for 50 houses on the playing field of Great Marlow School.
4) 20 dwellings are now under construction on the site of 109-117, Little Marlow Road
5) Policy M4 of the Adopted Plan includes for the provision of housing on the
Riley Road site which is likely to provide a significant additional number of dwellings within the town centre.
6) Quite apart from these specific potential developments, a significant number ‘windfall’ proposals are likely to come to fruition.

Moreover, we note that the Council’s submission, under matter 7 - Marlow, to the current public examination of its Local Development Plan Core Strategy states the following:

“The Housing Land Background Paper Update shows how there is a baseline housing potential in Marlow for almost 300 dwellings for the period 2006 – 17. It also shows that there is a potential for over 500 homes in the town for the period 2006-26. All these sites are within the town and would not involve incursions into the Green Belt”.

The Council has confirmed to this Society that development of the Marlow Football Club site for housing has not been taken into account in the Update document because – “We have not factored that in as the proposal is contrary to our policies on both the current club and the Green Belt”.

This Society believes that this large potential increase in the urban capacity of Marlow for housing development, as envisaged by the Council, will in itself raise some very challenging sustainability issues for our historic riverside town. These would be significantly compounded by approval of nearly 100 dwellings and the consequential damaging loss of precious urban and fringe greenspace as proposed by the applicants and their partners.

The above estimates take no account of similar current housing development opportunities elsewhere in the District. The Society takes note that in the Council’s consultation documentation and seminars, considerable emphasis has been given to the Council’s views that there is sufficient land capacity within the District’s urban areas that it may not even be necessary to retain currently safeguarded potential housing sites. We are therefore confident that the Council will not permit the over development of its adopted Green Spaces. The Society accepts the desirability to provide housing units including affordable housing but submits that this proposal involving, as it does, the over development of its green spaces is not an acceptable means for this provision and considers, therefore, that there are no strategic, pressing or special circumstances that justify the development of housing on this Green Space site.

Building ninety four dwellings in this location will bring unsustainable pressure on the C of E Primary School in Wethered Road within whose catchment area this site lies. The Society estimates that this development might well require some three or four additional intake classes at this school and there is no consideration given to this or any other soft infrastructure which this development would require.

The Society’s view is that local public opinion was fully and openly tested in 2004 when the Local District Plan was adopted and approved at Public Inquiry and departure from its policies would bring into question and compromise any future consultation process. This Society regards the determination of this proposal as a vital test of the integrity of the Adopted Local Plan and the Marlow Society expects the Council to uphold its policies and refuse this application unconditionally.

Yours sincerely,

RF Waters,
Chairman.Mr. Chris Steuart,
Planning and Major Projects Directorate,
Wycombe District Council,
Queen Victoria Road,
High Wycombe, Bucks.,
HP11 1BB.

23 November 2007

Dear Mr. Steuart,

Planning ApplicationNo. 07/07553/OUT. Alfred Davis Memorial Sports Ground (Marlow Football Club), OakTree Road, Marlow.

Outline application for residential development of 94 (12x1 bed flats, 49x2 bed flats, 17 x3 bed
& 16x 4 x bed houses including access to Oak Tree Road following demolition of existing structures.

The Marlow Society wishes to lodge its strong objection to the above application for the erection of 94 dwellings on the Marlow football ground in Oak Tree Road which it considers to be in contravention of Local Plan policies G3 (General Design Policy) and L3 (Green Space).

Policy G3.
Explanatory paragraphs 2.14 and 2.15 state that ‘new development will need to be carefully assimilated into existing townscapes and landscapes by sensitive design, and by respecting , and where possible enhancing, the established character of the area (2.14) and ‘in all types of development, the layout should respect and incorporate any existing features or green spaces worthy of retention on site or in the vicinity. In particular, views into and out of the site will be important. (2.15).
The proposed development contravenes all of these provisions.

Policy G3 (1) (c) states that proposals will need to demonstrate visibly that they are ‘compatible with the immediate surroundings of the site and appropriate to its wider context by reference to street patterns and land levels, plot sizes, means of enclosure, proportion, scale, bulk, form and massing’
The Proposed development contravenes at least seven of these eight requirements, particularly in respect of the proposed density, height, bulk and massing.

Policy L3
Explanatory paragraph 10.15 states that ‘ Green Space’ is an essential component of the built environment in both rural and urban settlements and its protection is a vital factor in achieving sustainable land use and development’. Paragraph 10.17 states that ‘Proposals that would result in the loss or fragmentation or reduction in size of green spaces will be firmly rejected’.
This site is located in a residential area where green spaces provide very necessary amenity within the surrounding dense urban area. The site is zoned in the Proposals Map of the Adopted Local Plan to 2011 as ‘Green Space’ and any development should comply with Policy L3 of the Adopted Plan. This states that, ‘Planning permission will not be given for proposals involving the loss or fragmentation or reduction in size of green spaces within the built up areas.’
Additionally, both the emerging Local Development Framework and the District Open Space Study of 2005 identify East Marlow as an area of Green Space deprivation and consequently any further loss of green space is totally unacceptable.

Attempting to justify development in this green space, the applicant appears to claim special circumstances exist to bring this development within the provisions of Policy L3 (2), in that the elimination of this prescribed green space is justified by the provision of 94 dwellings on this site and the development of sporting facilities within the town’s Green Belt, albeit these facilities (which could easily be accommodated within the existing Oaktree Road site) comprise structures resulting in inappropriate development in terms of Green Belt policies.

If any special circumstances could be established in relation to this proposal, then the developer is obliged to retain a substantial element of green space and the overall character and quality of space maintained, or make alternative provision of equivalent quality and quantity within a reasonable distance. (Policy L3.2 ). No such provision is evident or possible with this proposal and it is the considered view of this Society that a remote football facility in the town’s Green Belt does not fulfil this requirement to the benefit of the adjacent built up area as safeguarded by Policy L3.2. The proposal is therefore a gross over development of this site leaving no provision for the retention of green space as required by policy L3(2).

It is this Society’s view that any permission which takes account of inappropriate development within the Green Belt surrounding Marlow or regards this as ‘enabling development’, notably, in this case, to satisfy commercial objectives, would establish a dangerous precedent for other unsuitable developments within the Green Belt. Connecting two application sites and making the development of each to be conditional on planning permission being given for the other is considered to be an unacceptable manipulation of the planning system which should not be tolerated. Planning permission on any site should be considered independently on the merits of the site specific land use and adopted planning policies. In this case the applicant appears to regard the provision of housing on this green space as enabling a ‘ planning gain, in the provision of a football complex within the town’s green belt, ignoring the well established principle that any planning gain should benefit directly the site being developed.

Much emphasis is given by this applicant to the District’s requirement for housing and we totally reject the suggestion that this also should be regarded as ‘special circumstances’ for the over development of this site with the erection of 94 dwellings on a green space site of 1.6 hectares. Potential housing development in Marlow has clearly increased, for example:-

1) The owners of the Portland’s site in the town centre now propose 83 dwelling on this site, an increase of 33% over the 50 homes prescribed in the Local Plan..
2) 24 dwellings are now in the course of construction on the Quoitings site, which clearly exceeds the number envisaged by the Planning Inspector’s report on the current Adopted Local Plan.
3) Outline planning permission has now been given for 50 houses on the playing field of Great Marlow School.
4) 20 dwellings are now under construction on the site of 109-117, Little Marlow Road
5) Policy M4 of the Adopted Plan includes for the provision of housing on the
Riley Road site which is likely to provide a significant additional number of dwellings within the town centre.
6) Quite apart from these specific potential developments, a significant number ‘windfall’ proposals are likely to come to fruition.

Moreover, we note that the Council’s submission, under matter 7 - Marlow, to the current public examination of its Local Development Plan Core Strategy states the following:

“The Housing Land Background Paper Update shows how there is a baseline housing potential in Marlow for almost 300 dwellings for the period 2006 – 17. It also shows that there is a potential for over 500 homes in the town for the period 2006-26. All these sites are within the town and would not involve incursions into the Green Belt”.

The Council has confirmed to this Society that development of the Marlow Football Club site for housing has not been taken into account in the Update document because – “We have not factored that in as the proposal is contrary to our policies on both the current club and the Green Belt”.

This Society believes that this large potential increase in the urban capacity of Marlow for housing development, as envisaged by the Council, will in itself raise some very challenging sustainability issues for our historic riverside town. These would be significantly compounded by approval of nearly 100 dwellings and the consequential damaging loss of precious urban and fringe greenspace as proposed by the applicants and their partners.

The above estimates take no account of similar current housing development opportunities elsewhere in the District. The Society takes note that in the Council’s consultation documentation and seminars, considerable emphasis has been given to the Council’s views that there is sufficient land capacity within the District’s urban areas that it may not even be necessary to retain currently safeguarded potential housing sites. We are therefore confident that the Council will not permit the over development of its adopted Green Spaces. The Society accepts the desirability to provide housing units including affordable housing but submits that this proposal involving, as it does, the over development of its green spaces is not an acceptable means for this provision and considers, therefore, that there are no strategic, pressing or special circumstances that justify the development of housing on this Green Space site.

Building ninety four dwellings in this location will bring unsustainable pressure on the C of E Primary School in Wethered Road within whose catchment area this site lies. The Society estimates that this development might well require some three or four additional intake classes at this school and there is no consideration given to this or any other soft infrastructure which this development would require.

The Society’s view is that local public opinion was fully and openly tested in 2004 when the Local District Plan was adopted and approved at Public Inquiry and departure from its policies would bring into question and compromise any future consultation process. This Society regards the determination of this proposal as a vital test of the integrity of the Adopted Local Plan and the Marlow Society expects the Council to uphold its policies and refuse this application unconditionally.

Yours sincerely,

RF Waters,

Chairman.