PENN & TYLERS GREEN RESIDENTS SOCIETY AND ASHWELLS FORUM provided their comments on the amended design and access statement for Ashwells outline planning application.
Also attached is the detailed traffic analysis which will be used to argue against the need to widen Cock Lane. ( Traffic Assessment Part 11)
This is a disappointing, careless and error-strewn application which does not address our comments on the previous application made in February 2018. It still assumes that Cock Lane will be widened, to which we have repeatedly made strong and coherent objection. The northern sector clearly needs to be revised to take account of the width of the copse, which is wider than as shown on the plan, as well as of any consequence of the route of the pumped foul water main. Visitor car parking spaces are inadequate. Affordable housing arrangements require clarification. We therefore make strong objection to this application in its present state.
ROADS AND ACCESS
Site access. There is confusion over the access to the site. in the 5 Feb 2019 Bucks County Council (BCC) letter to Robert Harrison, Condition 3 says: ” Each respective access point (on the Ashwells estate and Cock Lane) shall provide both access to and egress from the development hereby permitted”. However, the later Transport Assessment (TA) Addendum, dated March 2019, states in para 3.1.1 that “a revised site layout plan has been prepared. This has retained the previously agreed and submitted access points, namely the main access/egress on to Cock lane at the south-west of the site, and the link through Ashwells at the northern boundary.” The previously agreed access as proposed in the December 2017 TA was that “the existing gated access from Ashwells will form egress only access for vehicular traffic”. Local residents would prefer this latter ruling to continue.
The names given to the street hierarchy on p.58 are not consistently used throughout the document, making it confusing to read. In particular, the text on pp. 58, 59, 60, & 61, describing the 4 street types, does not match the headings above the diagrammatic sections alongside. Throughout the Design and Access document, the explanations involving street hierarchy are confused by the multiple use of different terminologies for the same thing .
There are contradictory references to bus services (pp.38, 57), The original Travel Plan does not envisage any bus services through Ashwells.
Mention is made of traffic calming on site (p.58), but there is no detail provided on where this would be.
We object to the proposed lay-bys on the green edges to the track along the Sandpits boundary because they are likely to become a regular default parking space for immediately local residents and the promised green buffer will be lost..
COCK LANE WIDENING
Plan and text (p.9) show widening down to the Gomm Valley link road. A letter dated 5 Feb 2019 from County Highways to Robert Harrison of WDC states that “The section of Cock Lane between Tylers Green and High Wycombe is inadequate by reason of its width in order to safely and conveniently accommodate the additional vehicle movements generated by the proposed development.” They recommend refusal of the application unless all the narrow part of Cock Lane is widened “to a minimum width of 6.5m in order to future-proof the northern section for potential bus services”. We maintain strong objection to this proposal which has no justification from predicted traffic flows, as clearly demonstrated in our separate analysis (Part II) of the wider transport implications of this application.
The sustainability aspects of the proposals are contained in a 3-line statement on p.38, together with the section on Sustainable Drainage on p.55. There is no separate Sustainability Statement submitted with the application, and this is unacceptable for a development of this scale.
This disregard of sustainability issues is underlined by the inexplicable and conflicting references to features not present on the Ashwells site, i.e. “field ditches/drains that discharge into Semington Brook”; “final attenuation needed in NE part of the site”, “introduction of pumping station in NE corner of site”; “a grass mixture suitable for wetlands and traditional water meadows”.
The parking space numbers inexplicably appear to be based on Wiltshire standards, giving variously 224–228 allocated spaces and 43–26 unallocated spaces (263?–254 in total) which is higher than the BCC standards which would give 225 allocated and 22 unallocated spaces.
Parking space calculations includes garages which are very vulnerable to use as storage or domestic extension. Car ports would be less likely to be lost. 43 unallocated parking spaces would seem more appropriate for a site where there could be visitors using the wider benefits of the valley.
On p.26 it says that at a formal Pre-Application meeting on 17 October 2016, it was decided that parking courtyards were to be removed from backs of perimeter blocks, but on p.35 as part of design changes to the north east parcel, it is stated that this perimeter block should have allocated parking in the centre.
CHARACTER AND IDENTITY
On p.52 it is stated that “The development should avoid any ‘estate’ feel “. Unfortunately the images provided suggest otherwise. It is further stated that “architectural detailing should show clear reference to local vernacular styles, but poor copies will not be promoted”. The reference images and character sketches provided indicate that they either fail to follow the local vernacular (in its many variations), or are pastiche imitations, or both. They do not, as is claimed, “enhance the character of Tylers Green.”
It is intended that “landmark building will be located at key positions either side of the main access”. However, this is not reflected in the illustrative masterplan.
There are discrepancies in the selection of materials. A note on p.52 suggests the use of clay tiles for roofs, but p.54 states that roof finishes should be coloured concrete tiles which “reflect use on local agricultural buildings”. Also there is a suggestion on p.52 that local materials include ‘high quality stone’ as a construction material, which is incorrect.
It is stated that the retention of the chalk pit would provide a ‘symbolic heart’ to the development, designated as a ‘pocket park’ (p52). This may well be a worthy proposal , but it may not be topographically suitable for wider community activities (p.50).
The area shown on the plan for the Copse in these layouts needs to be significantly increased to equate to the actual reality of the trees. i.e several metres wider than in the layout plans (pp.40 & 41) and this will require amendment to the present layout of houses. It is essential that the Copse’s current boundaries (post and wire fence, etc) are defined by GPS and marked on the ground, so that developers do not encroach on them.
Thames Water has already noted the need to divert the existing foul sewer across the NE corner of the site (est. cost £250,000). This will require an agreed route with a build-over agreement if it runs near houses which may restriction where houses can be built. There is no indication here or later as to where this foul water main would run and. Access will be required to it along the edge of Ashwells estate (pp.12, 18).
Traffic route out of the northern sector (16 to 20 houses) will be an inefficient extended circular route away from the site exit, then back across the green lane and along one side of the chalk pit, about 7 times longer (400–500 yards longer) than a direct route past one side of the chalk pit (pp.39,40 & 41).
Species List – Hedgerows. Last year better screening for Carter Walk was promised, since in winter the trees provide little cover, so we suggest that evergreen shrubs are added to the list. e.g. Laurel and Ligustrum Ovaliforium [type of privet growing fast to 15 ft], (p. 53).
If, as stated, though it is not the case elsewhere in Tylers Green, bin Lorries will collect only from adopted roads, will secondary roads (gravel surface) be adopted? If not, households in the northern corner could face up to almost 400yds drag (over gravel surface) to get bins to a collection point! (p.62).
This northern sector will need to be redesigned to take into account both the correct width of the Copse and the as yet undecided route for the pumped foul water main. .
Building densities. As a comparison with the proposed 29 per hectare: Wheeler Ave + Carter Walk etc = 15/h; Ashwells =18/h; Sandpits = 5/h. The earlier proposal of 102 houses would produce a density of 27/h (p.22).
The Footpath to Carter Walk is an existing one, not as shown, a diverted one. There is no mention of the urgent need to upgrade this path, which leads to the Horse & Jockey pub, at both ends (p.43).
Lighting. Why is this question being raised when this is a street light free area (p.43).
Electricity substation is required to reduce the 11,000 volt in the High Voltage (HV)cable entering at Cock Lane and running across the site, down to the 250 volts needed for household consumption. No location is shown.
LV cable to the old phone mast has already been removed. The remaining cables are HV and should be buried (p.18).
Design Code – There are 3 references to a non-existent Design Code, stating that it will be produced in 2018 (pp.26, 38, 52).
AXA owned land – The document makes several references to AXA, which need updating to name the new owners, Aviva
Scaling bar and north point are not shown on masterplan, which is standard practice.
Areas of development shown in the Summary Schedule on p.42 do not add up correctly. If the roads area of 0.9 Ha is part of a total site area of 7.6 Ha, then either the net residential (3.8 Ha) or the POS (3.8 Ha) figure is wrong.
Location of affordable housing. Page 3 of Savills’ covering letter dated 12 March 2019, states that there will be a total of 177 housing units spread across Ashwells and the Bellfield Road site. It is stated that the total amount of affordable housing by bedspace will be 45% across the two sites, however there is no information provided on the split between the sites.
Stewardship of Green Spaces (p.52): The stewardship arrangements are undecided, but Chepping Wycombe Parish Council have asked to be consulted.
Miles Green, Chairman P&TG Residents Society and Ashwells Forum. 4 April 2019
Part II – TRANSPORT ASSESSMENT
Transport Assessment Addendum document, prepared as before by Odyssey, added to the WDC website as a 38 page support paper to the Application, comprises just 4 pages of text and 34 pages of drawings and letters exchanged with BCC.
The initial assessment of this was that there was no problem, based on:
Section 4.0 Summary & Conclusions:
- No change to original conclusions,
- Revised internal layout has not restricted vehicle access,
- Increased number of houses / dwellings (108 -> 109, on their numbers) -> no change to flows,
4.1:”Previous findings…….remain applicable and accurate.”
4.1.4: “On this basis the proposals are considered appropriate and will not cause a significant or material impact on the surrounding network”.
Major Concern buried in the letters attached: Digging in the letters attached to the report produced the letter dated 5 Feb 2019 from BCC to WDC that had not been made public before. This letter is referred to in the main Odyssey report in 2.1.5 (in the History section) stating
“BCC as part of their final response, confirmed on 5th February 2019 that whilst it is not within the gift of the Ashwells Applicant to complete localised widening along the entirety of the single-track section of Cock Lane, the Highway Authority understand that Wycombe District Council have aspirations for the Gomm Valley/ Ashwells Reserve Site as part of its Local Plan and that ultimately the intensification of Cock Lane must be balanced against the provision of housing.”
This BCC to WDC letter states that
“However, aforementioned widening improvements potentially secured from these proposals aside [widening Cock Lane down the side of the whole Ashwells site], the remainder of its length between the southern extent of the off-site works and a position around Nos.107 and 146 Cock Lane is of insufficient width and character to accommodate any further vehicular intensification as a result of further development”
And therefore that the Highways Authority recommends REFUSAL to the application due to Cock Lane being too narrow to accommodate the additional traffic. Extract below:
“Reason 1: The section of Cock Lane between Tylers Green and High Wycombe is inadequate by reasons of its width in order to safely and conveniently accommodate the additional vehicle movements generated by the proposed development. The development is contrary to Policy CS20 (Transport and Infrastructure) of the Wycombe Development Framework Core Strategy (adopted July 2008) and the Buckinghamshire County Council Highways Development Management Guidance document (adopted July 2018).”
TIA: (Traffic Impact Assessment):
There are no actual flow calculations in the Addendum document, just in the original Jan 2018 Transport Assessment report. However, the ‘spider’ diagrams show traffic flowing out of the site onto Cock Lane, peak AM flows as follows:
Note: The traffic generation rates used are industry standard, predicting 43 v/hr, but the directions then taken are based on linking to quite inappropriate census areas (linked to Micklefield and east Totteridge) rather than Penn & Tylers Green census area, but much worse is that they do not give consideration to the directional flows of the most relevant area = existing Ashwells estate itself, numbers they themselves provide in the ‘spider’ diagrams in Appendix A [despite this being pointed this out to them after the last version of this application. Why offer consultation, but then not listen?].
|Direction||1) Odyssey projected||2) Existing Ashwells||3) our extrapolation of 2)|
|North||35% -> 15 vehs / hour||89% -> 17 vehs / hour||89% -> 38 vehs / hour|
|South||65% -> 28 vehs / hour||11% -> 2 vehs / hour||11% -> 5 vehs / hour|
|Total||100% -> 43 vehs / hour||100% -> 19 vehs / hour||100% -> 43 vehs / hour|
Correcting the flow direction significantly reduces the flow onto Cock Lane south [ 28 v/hr -> 5 v/hr], and reduces any WDC / BCC argument that the development flows require widening of Cock Lane, but we need to both object to the BCC conclusions, and also to take the argument to the planners responsible at both WDC and BCC using the lower traffic numbers because it looks like it is WDC’s aspirations for the Gomm Valley/ Ashwells Reserve Site as part of its Local Plan that is driving the BCC response.
The good news is that the decision seems to be based on the two policies referred to by BCC, and having looked briefly at them one would conclude that these are very lightweight Guidance / Advisory documents which would not stand up against the major danger that widening and attracting in a flood of 700 extra vehicles / hour would pose for our village and in particular for the Middle School
Ashwells entry / exit roadways to both be two way:
BCC’s refusal to allow Ashwells road to be directionally limited are covered in the part 1 document.
The matter of Traffic Calming, despite having been widely debated and rejected last year by the Forum and Charles Brocklehurst, may still be in BCC’s thoughts as local views have not been acknowledged in any of the subsequent BCC / WDC correspondence.
The 5 Feb 2019 letter states:
You will be aware that residents of Penn and Tylers Green raised concerns that the development would result in vehicles movements occurring on the local network to the detriment of the safe and convenient use of the local highway network. As such a traffic calming scheme was proposed by the applicant and a Safety Audit requested for this scheme located on New Road and Church Road.
[This is despite it being pointed out to them that the concern raised was about construction traffic, and that any concerns about total vehicle movements would only be if Cock Lane was widened and 700 v/hr flooded the roads to and past the Middle School].
The 5 Feb 2019 letter continues:
In the case of a positive determination of this application, I recommend that the following obligations and conditions form part of any consent issued:
Condition 4: No other part of the development shall commence until the following off-site highway works:
Widening works to Cock Lane in order to provide a 6.5m width
A traffic calming scheme for New Road and Church Road
A drop-off area on Cock Lane serving Tylers Green Middle School
have been laid out and constructed in accordance with details to be first approved in writing by the Local Planning Authority in consultation with the Highway Authority.
Note the requirement that the three conditions be completed before any other part of the development can start.
There appears to be no recognition of the points we all made last year relating to the proven safety of Cock Lane etc. A copy of last year’s P&TGRS’s Transport Assessment is attached.
Summary, repeating what we said a year ago
In summary, BCC and WDC have not demonstrated that they have a viable method of reducing the doubling of traffic volume that their Cock Lane widening linked to a the GV scheme is forecast to attract past the Middle School, and so cannot achieve the aim of the Development Brief which is that there should be no significant increase in traffic using Cock Lane. This Ashwells application does in fact weaken their case which is based on three assertions that are not supported by factual data, namely:
- a) that Cock Lane needs to be widened for reasons of Highway safety
- b) that increased traffic from the developments provides the justification
- c) that traffic calming measures can prevent a significant increase in traffic.
In the light of this evidence, we urge WDC to ask BCC either to withdraw their insistence on the need for widening Cock Lane and connecting it to the top of the GV development. We are ready to provide any detail required to justify our arguments about traffic flow.
Gerry King 02 April 2019