Ref CH/2015/1063/FA : Land North Of High Street Old Amersham
The Amersham Society acknowledges the growing demand for the type of accommodation envisaged by this application in order to meet the needs and secure quality of life for people with a variety of disabilities. We understand that finding suitable sites for facilities of this nature is not easy. However, we believe that the site chosen is not suitable.
One of the objects of the Amersham Society is to promote standards of architecture, conservation, planning, design, maintenance and use of buildings and infrastructure compatible with the character and quality of life in and/or affecting the old town of Amersham.
Our primary reason for objecting to the proposed Paradigm project is because the development is on green belt land but there are other reasons for questioning the development which relate to flooding, disturbance of archaeology and distance from amenities.
Green Belt Land
One of the five purposes of green belt is to preserve the setting and special character of historic towns. In Old Amersham, we have an extraordinary example of a pre-twentieth century townscape which, when approached from the west (i.e. Aylesbury) is seen to be surrounded by fields, with minimal intrusion of twentieth century building intervening between countryside and town. The Amersham Society is determined to preserve that special character and we believe that it is therefore imperative that green belt is preserved intact and undeveloped on the western edge of the town.Any encroachment on the green belt on the western approach to the Old Town will inevitably result in pressure from developers to build on neighbouring fields. This will make your task of protecting the green belt extremely difficult and could set a precedent for future development at the west end of the town.
The Amersham Society accepts need for a specialist residential facility and has no objection to it being sited in Old Amersham provided that it does not constitute a visual intrusion next to the historic streets. The Society has already supported development on green belt at the eastern side of the Old Town next to the by-pass where there is already 20th century development nearby. This would seem to be a better site for the Paradigm development.
In view of the fact that some properties have not yet fully recovered from previous flooding of the Old Town in February 2014, the Society is concerned about a potential increase in flood risk that might arise from this development. Given the uncertain impact of HS2 and climate change and the sensitivity of the river and its banks, we are not convinced that all the flood risks that might arise have been adequately addressed in the planning application. These concerns are set out in Appendix 1.
The Society is concerned that the development may disturb some important archaeological evidence and is not satisfied that the desk-based assessment commissioned by Paradigm is sufficient. It would therefore seem irresponsible to allow development on the site. A review of the desk top assessment is included as Appendix 2.
Given that the residents will have special needs and will want convenient access to local facilities, it is acknowledged within the planning application, that these facilities should be within easy walking distance. The actual distances that we have measured between the proposed entrance and key facilities are significantly greater than those suggested in the planning application. Tesco supermarket which would probably be the most used shopping facility is 1317 metres from the Paradigm site. We are surprised that the application statement gives the impression that there is a butcher closer than the one in Tesco. We note that the Chartered Institute for Highways and Transportation document ‘Guidelines for Providing for Journeys on Foot’ (2006) which gives the acceptability of walking distances to local facilities as the:
- desirable walking distance is considered to be 0 – 400m,
- acceptable walking distance is 401- 800m and
- preferred maximum is 801-1,200m.
The newsagent in The Broadway is over 900m. In fact, there are very few services likely to be of use to the residents located circa 750 m from the site, except for pubs and cafes. (See Appendix 3)
In addition to our primary objection to the proposed development in the selected location our committee would strongly urge you to take into account our other detailed concerns as set out in this letter.
Appendix 1: Flood risk
The Amersham Society has expressed concern about the impact on the River Misbourne of the tunnelling for HS2. It is extremely unclear what effect the tunnelling will have on the water table and watercourse through the valley. The Paradigm proposals assume that HS2 will have no impact but there is a strong possibility that the volume of water in the river could swing radically from one extreme to the other. Climate change is another unknown factor affecting the volume of water in the river.
We note that the proposed buildings will be on land designated Flood Zone 1 (low probability of flooding) but we believe that building only 40 metres from the river on very slightly rising land has the potential to flood in weather conditions that seem to be occurring much more frequently. We would argue that there are several much more suitable sites for this development in the Old Town that are not subject to flooding.
The process of building the bridge across the river will inevitably disturb the riverbed and banks at this critical point before the river enters the town. It is likely to dislodge and stir up a great deal of silt which will be deposited further downstream and heighten the flood risk in the Old Town. We have seen nothing in the plans to describe careful steps that will be taken to preserve the bank and avoid disturbing the river bed. We also believe that soil excavated during building only 40 metres from the river will run-off into the river creating more silt and increasing the risk of flood to the Old Town.
We read in the planning proposal that attenuation basins will hold the run-off from the roof and release it into the river when it is able to take an increased flow. While the report is confident that the attenuation basins will cope with a 1 in a 100 year storm, we are not satisfied that these basins will be of sufficient capacity to hold all this run-off when there is the sort of prolonged rainfall event that resulted in the flooding of February 2014
In paragraph 5.5.5 it is stated that the long term maintenance of the drainage system will be the responsibility of ‘a management company’. While this management company will, no doubt, start with good intentions, we are concerned that the quality of this management may not be sustained as the drainage infrastructure ages and begins to deteriorate.
Appendix 2: Archaeological Assessment
In looking at the desk based archaeological report by Cgms commissioned by Paradigm, we believe it to be unsatisfactory and its conclusions unacceptable. First, the desk–based archaeological report is substandard for an area of historical interest and does not meet Buckinghamshire County Council’s ‘historic environment desk based assessment’ brief and its specific report requirements.
Secondly, the report states how ‘based on current evidence the site is considered to have a ‘moderate archaeological potential for the Roman, Saxon/Early medieval, Neolithic & Bronze age periods’. How can the term ‘moderate archaeological potential’ be used when the report itself states how there is “a probable Roman to Saxon site located immediately north-west of the study site”. The report goes on to add how these burials indicate a possible Roman villa and settlement around 300/350m away at Mantles Green. The north –west section of the proposed construction includes part of this cemetery and will cut into an ‘Archaeological Notification Area’ for a suspected Roman settlement. So how can this area be described to merely have ‘moderate archaeological potential’?
The report goes on to state how the construction in the proposed area for redevelopment is only ‘likely’ to have an impact on remaining archaeological deposits remaining on site.
However, the assessment goes on to say it will be the ‘cutting of foundations and services’ which will cause the damage. Therefore it is not likely that undiscovered archaeological remains will be irreversibly destroyed but a certainty.
Lastly, the report goes on to say how ‘it is considered that any remains present on the site are assessed to be no more than of local or regional significance’ despite just saying how there would only be ‘moderate archaeology potential’. This is not good enough reason to destroy 2,000 to 1,000 year old artefacts which constitute our local heritage. Chiltern District Council’s own Heritage Strategy (2014) states how ‘it considers it important to acknowledge the importance of heritage assets locally and, although not worthy of national protection, some local heritage assets may be important in defining the local character of the area. ‘Bucks County Council’s guidelines even state how a desk based report is ‘meant to suggest potential means to minimise or mitigate negative impacts’; the report does not address this.
Appendix 3: Distances to Facilities
The Access Map given in Appendix 2 of the Planning Statement appears to give ‘crow flies’ distances which give a misleading impression of distances to facilities. The Planning Statement (section 8) claims to quote Policy CS12 of the Chiltern District Core Strategy (CDCS) ‘Specialist Housing’ and emphasises that ‘Accessibility is therefore a vital component of assessing the suitability of sites for Specialist Housing’. It also quotes (section 8.2) from The Chartered Institute for Highways and Transportation document ‘Guidelines for Providing for Journeys on Foot’ (2006) which gives the acceptability of walking distances to local facilities as:
- the desirable walking distance is considered to be 0 – 400m,
- the acceptable walking distance is 401- 800m and
- the preferred maximum is 801-1,200m.
The Planning Statement then goes on to assert that the majority of services on Old Amersham High Street are located circa 750m from the Site. The shops comprise a range of retail outlets selling a variety of clothes. There is also a newsagent, hairdressers and butchers. A number of restaurants, pubs and a hotel are also located along the High Street, as is a museum. A large Tesco supermarket is located slightly further away from the Site (1km) but is still within a reasonable walking distance.
This is factually wrong in that there is no butcher’s shop in the High Street, and has not been for many years. This suggests that the authors carried out a drive-by assessment, rather than walking a ‘reasonable distance’ as they expect residents in the supported living accommodation to do.
It is also wrong in that there is no newsagent in the High Street. It is in The Broadway, a distance of over 900 m rather than the implied 740 m. In fact, there are very few services likely to be of use to the residents located circa 750 m from the site, except for pubs and cafes.
The Statement mentions that the site is 1.2 km from Amersham Hospital but the relevance of that is unclear, given that the hospital now has no A&E facilities and only a few clinics.
The Planning Statement (section 8.2) includes a table purporting to show the distance to key facilities:
Local Centre (including shops, restaurant and community facilities)
This is at best misleading. There are no shops likely to be useful on neither a daily/weekly basis nor any community facilities within 678 m. The only shop likely to be regularly useful is the Tesco supermarket which is over 1,300m away (not 1 km as claimed). This is described as ‘within a reasonable walking distance’ despite The Chartered Institute for Highways and Transportation document describing such distances as ‘the preferred maximum’. The Planning Statement is inaccurate in the above table when it rates the Public Transport distance as ‘preferred’ when in fact it should be ‘the preferred maximum’. In fact, looking at the Chiltern District Core Strategy CS12, none of the required facilities fall within the ‘desirable’ distance and almost none fall within the ‘acceptable’ distance.