Policy SP BP2 - Chesham
Person ID 1214824 Full Name Mr John Munns ID 5371 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-12-12 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details
8741 Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has
8742 met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I consider the Local Plan to be NOT legally compliant because in reading through the contents, I see that believe this policy in on many counts, the proposals are at odds with the National Planning Policy Framework (NPPF) and consistent with the National government directives, with regard to Green Belt Policy, and to areas protected by Green Belt status. I set Planning Policy Framework out my reasons as follows; Feb 2019 please explain why 1/ The proposals indicate with much emphasis, the intention of removing Green Belt designation from thirteen areas, and also the intention of removing or modifying Green Belt status of villages and hamlets in Chiltern District and South Bucks. Firstly, I question the confliction of interests concerning carbon emissions. The Local Plan forecasts a 21% increase in emissions; yet recently the government confirmed its aim to achieve zero emissions by 2050. It should be clear to all that increased vehicle use and higher volumes of traffic are major perpetrators of emissions growth. With this in mind, it should also be recognised with responsible concern, that a direct consequence of building housing developments on Green Belt land and in rural villages, by the nature of their location (generally out of town/rural), will be a wholesale increase in traffic volume, with the reliance on residents' vehicles travelling into (and returning from) surrounding towns for their needs. Awareness of these facts should add weight to the necessity when planning, for home-building to be where possible, within the proximity of town centres to minimise use of vehicles / traffic congestion. This ultimately reduces growth of emissions and poor air quality. However, there is little evidence in the local plan that suggests much consideration is given to options such as higher-density development of existing brown field sites, and for centralising developments within (or close to) town centres where possible. Chesham Renaissance CIC ( a community-led, non-profit) organisation has produced such a plan; `The Chesham Master plan' for mainly affordable homes to be built within the town centre, which also aims to regenerate the town in the process. 2/ With reference to the revision of Green Belt boundaries;
8743 The NPPF and government directives specify that local authorities must be able to demonstrate `exceptional circumstances' and fully explain why they are justified in any proposal to remove Green Belt designation of an area, or modify a Green Belt boundary. Any such proposal should only be put forward after ALL other possible options have been considered and exhausted. In addition, the NPPF (Paragraph 11B) require Plan Makers to provide for objectively assessed needs for housing and other uses, unless the application of Framework policies (including Green Belt) provide a strong reason for restricting the overall scale, type or distribution of development in the plan area.. Therefore, it must be recognised that both Chiltern District and South Bucks are responsible for areas which are covered predominantly by areas of AONB and Green Belt protection¼which together, impose a necessary restriction on development. With this situation, the Local Plan is at odds with the NPPF/Government directives, which renders it not legally compliant in its proposals. 3/ It is acknowledged that The Community Infrastructure Levy (CIL) associated with the Local Plan, has an infrastructure funding gap of between £179 m and £231 m. Provision of effective infrastructure would be crucial for the scale of developments proposed in the Local Plan before any plans could even be considered as sustainable. Therefore, this shortfall of available funding is another reason that renders the Local Plan as not legally compliant and unsound in its concept. I refer to Spatial Policy SP SP1 and Policy SP BP2 (Lye Green, Chesham). In particular, I draw attention to proposals which aim to remove Green Belt designation from areas within the Local Plan.. REF: POLICY SP SP1: The Councils have stated that release of some Green Belt is necessary as part of an overall three part strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. In relation to the 3 part strategy, I explain why I consider the Local Plan is unsound; (1) I question whether the council have paid due attention to identifying / exploring the potential of brown field sites/areas; particularly those close to, or within town centres. (2) I question whether the council are only in liaison with Aylesbury authority, and not with other authorities across a wider area, to possibly deliver a more dispersed spread for the delivery of housing. (3) Developments of such magnitude as those proposed in the Local Plan would no doubt create detrimental results if provided in Green Belt sites. In particular, the locations are generally away from town centres and on the periphery ± which will generate increased traffic congestion from more vehicle use, and ultimately an increase in emissions and poor air quality. Such developments would necessitate provision of new highway infrastructure to accommodate them; However, this may be prohibitive in both practical and financial terms. Furthermore, some essential purposes that Green Belt designation serves, will be either lost or undermined in the process of development if plans were to proceed in these areas. These are; · To check the unrestricted sprawl of large built up areas · To assist in safeguarding the countryside from encroachment · To preserve the setting and special character of historic towns. With specific regard to Chesham; its local environment and topography, with its limited road infrastructure, does not lend itself to large development plans, due to the nature of its location, being surrounded largely by AONB, steep hills and narrow, winding roads which will not accommodate any necessary highways alterations to support the big increase in traffic that such large developments would create. As Chesham is in effect, a `basin', it is sensitive and susceptible to vehicle emissions being trapped in locations, such as the A416 Berkhamsted Road. This stretch already falls short of EU safe air levels, and thus, is a designated air quality management area, as a result. This is the main route through Chesham and it already bears the brunt of traffic regularly exceeding capacity level. Any major housing development will worsen this situation, especially if its location were to be on the edge of town as policy SP BP2 would be. Any such development is not sustainable, or justified, and would fall foul of Government NPPF policy and their carbon emission-reduction plans. REF: POLICY SP BP2: I contend that this is not a sustainable location for housing development; is not consistent with NPPF, and which further demonstrates that the Local Plan is unsound. For this, I give the following reasons; 1/ This Green Belt site at the NE edge of Chesham consists mainly of high quality farmland, which separates the hamlet of Lye Green from the main Chesham conurbation. The site is more than 2Km from Chesham Town centre and the train station and Broadway bus services. The site is at the top of steep hills which would deter many from walking between there and the town centre and its station. Any development of housing on the site would create the need for vehicle use and traffic movements in and out of the town centre, where the roads are already regularly used to capacity and incur high pollution levels through its main routes. The provision of an additional bus stop will not address these problems ± the bus service providers are prone to change and the services are often found to be unreliable.
8744 2/ Chesham is very limited in practical ways for accommodating any significant highways alterations to the two routes leading to this site, due to the constraints of space and the unique topography of the area and town. 3/ The land proposed for development has been used for many decades by local residents, ramblers, dog walkers and families for recreational use. It is also inhabited by wildlife and the area is an asset to the local community, as well as providing quality scene-scape that enhances the character of the local area and is in close proximity to AONB land. The land is proposed to become a designated `asset of Community value' which is the intention of the local residents/community and the campaign group `Brown not green' and I support this incentive too. 4/ I do not accept that there is any justification or sound case for `exceptional circumstances' to prevail, that could warrant the release of this land from Green Belt designation, or for it to be modified in such a way for development of housing as per policy SP BP2. Exceptional circumstances cannot be claimed on the basis of housing need in an area, as confirmed by the courts. With reference to NPPF paragraph 133, a primary aim of Green Belt designation, is to prevent urban sprawl and to preserve the openness of the area. ± the site in question performs this very well. Green Belt also serves the function to safeguard the countryside from encroachment, which is relevant protection to this area. I also draw attention to another essential function of Green Belt policy; which is `to assist in urban regeneration, by encouraging the recycling of derelict and other urban land¼ However, the proposal of SP BP2 would undermine this completely, were the plan to be implemented. I question the viability and the credibility of the selecting of Green Belt sites by the Local authority, and I question whether any genuine exceptional circumstances exist to warrant the removal of any of the sites from Green Belt designation within the plans. In summary, I conclude that the local Plan is unsound, unjustified and inconsistent with Government policy and that of its NPPF directives. Policy 3a - Please specify as I would suggest the following modifications; precisely and succinctly as A much greater emphasis should be applied to the prospect of developing brown field land/sites, possible how you would modify this policy to improve including consideration for some higher-density development within brown field sites. its alignment to this test of A review and appraisement of all opportunities identified should be given priority. soundness. Brown field development potential must take full precedence over any consideration to review Green Belt boundaries and any consideration to develop Green Belt land. Serious consideration should be given to exploring all the alternative options for building homes, other than considering using Green belt land. The focus should be on developing in areas close to, or in the centre of towns, and not on the periphery. One such option is the `Chesham Masterplan', by Chesham Renaissance CIC, which I feel should be given serious consideration. Redefining Green Belt boundaries should only come into consideration when exceptional circumstances exist, and are genuinely proven. This directive (paragraph 136 in latest NPPF) must be adhered to, and it should be heeded that courts have held that `local housing needs/targets' do not by themselves qualify as `exceptional circumstances'. Planning should fully demonstrate compliance with Government plans to reduce carbon emissions to a zero level by 2050. In respect of this, prevention of increased vehicle use and traffic movements/volume is essential for curtailing an increase in carbon emissions and the worsening of pollution and air quality. Therefore, there is great responsibility within the planning sector to take account of these aspects, and in particular, to avoid planning developments out of town or on the periphery where generation of vehicle use and traffic volume would result¼and this is where some of the Green Belt sites (considered for development) are located. In consideration of the aforementioned points, the proposal for removing villages from Green Belt designation, and the associated proposal for development and infilling of rural villages, as shown in policies SP PP1 and DM PP1, should be aborted, otherwise such developments will generate increased vehicle use and higher traffic volumes, as the new residents would need to travel to and from larger towns for their needs ± increasing congestion and emissions as a result. In addition to this, the character and heritage of Chiltern villages will be compromised as well as their charm and intrinsic value, by overdevelopment, and the removal of Green Belt status would set a precedent to encourage uncontrolled development. Policy-level file upload - 5493549 Please attach any supporting evidence
Person ID 1223780 Full Name Simon Goodes ID 5388 Order 236 Number 11.3
8745 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible.
8746 Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I believe the draft Local Plan is NOT legally compliant because it has not demonstrated sufficient regard to not believe this policy to be the National Policy and guidance issued by the Secretary of State. positively prepared please To accord with the government planning guidelines contained in the National Planning Policy Framework explain why (NPPF) and elsewhere, any revision to the Green Belt boundaries should only be undertaken after all other options have been exhausted. I contend that this local plan has not exhausted all other options. As a prime example, the commendable Chesham Masterplan by CIC Chesham Renaissance has not been integrated into the local plan. I do not consider housing need alone as `exceptional circumstances' to amend Green Belt boundaries. The local plan forecasts a 21% increase in carbon emissions in the plan period. As the Government aim is for net zero carbon emissions on developments this is clearly unsustainable. The NPPF requires development to be sustainable. There is insufficient infrastructure improvement in the local plan to make the development of 500 homes and 15 gypsy pitches a sustainable development. PP Mods - Please specify as The plan needs to be modified by including the wealth of brownfield sites and higher density housing in the precisely and succinctly as centre of Chesham which is demonstrated in the Chesham Masterplan by CIC Chesham Renaissance. This possible how you would would result in a more sustainable development of lower cost housing which is required for the local community modify this policy to improve rather than 3,4 and 5 bedroom homes which would attract people from outside the area, pushing up prices its alignment to this test of for local people. Developers will always push for the larger properties as the profit revenue is far greater that soundness. that of affordable housing which is in chronic short supply in the area. There is a huge, undeveloped brownfield site in Bovingdon , which, whilst very close to Chiltern District , although situated in Hertfordshire. Co-operation with other areas, not just Aylesbury, would be beneficial. I am a supporter of Brown not Green Chesham and I am content for them to speak on my behalf at ant hearing or public examination. Policy 1 - If you do not The local plan relating to the area North East of Chesham is unsound. The area has been listed as an Area believe this policy to be of Community Value due to the wide range of user activity on this Green Belt land. This open space with justified please explain why multiple footpaths, both registered and unregistered (but used by many generations of local people) is highly utilised, not just by Lye Green residents but a significant volume of Chesham residents.This usage has been extant for many decades. Our household has been forced to have a water meter installed by our water supply company, due to local pressure on water resources. Please note over abstraction of water from the River Chess and the consequential impact on incredibly rare chalk streams. Increasing the demand by 50 homes,15 gypsy pitches and retail development will only exacerbate the problem. The land NE of Chesham may only be 2 km from Chesham underground station but it is a steep hill. Observation of the passengers for morning rush hour trains shows that the vast majority are dropped off by motor vehicle or park in the station car park. It should be noted that the proposed local plan will utilise the
8747 station car park for retail outlets. It should also be noted that all seats on the morning rush hour trains are taken, with standing room only. Residents in the proposed new development will not walk to the station, they will drive. Chesham is already gridlocked in the rush hours. Berkhamsted Road in Chesham is already designated as an Air Quality Management Area. Further development in the vicinity will only exacerbate the problem. The land NE of Chesham is not sustainable for development. The Green Belt must be protected for future generations. Policy 2a - Please specify as I refer to the comments previously submitted but in summary would advocate that; precisely and succinctly as All other options are fully explored including increased density of development of brownfield land and the possible how you would policies emerging from Chesham Masterplan. modify this policy to improve its alignment to this test of Green Belt land should only be considered when all other options are exhausted and in any event the soundness. proposals for developing land NE of Chesham (policy SP BP 2) should be removed as it is an unsustainable location the development of which will cause harm to the wider town including loss of an asset that improves the well-being for the community. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5493588 Please attach any supporting evidence
Person ID 1223781 Full Name Frazer Lewis ID 5429 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you
8748 consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible.
8749 Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do To whom it may concern, not believe this policy to be I would like to register my strong objection to the Local Plan. positively prepared please explain why Chesham is already bursting at the seams and further building on the proposed scale is reckless in my opinion. The roads are struggling to cope with the number of vehicles currently using them. To add thousands more would be catastrophic. Not to mention there©s no provision for extra schools, Drs© surgeries etc to cope with the thousands more people due to inhabit these new homes. Finally, using green belt land to achieve the above is sacrilegious. This green land is too precious to lose. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not Chesham©s infrastructure and services are already struggling to cope with the enormous demands placed believe this policy to be upon them. justified please explain why Further development of housing without significant investment in infrastructure (roads, parking, medical and school facilities etc) will exacerbate these issues. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1223075 Full Name Jon Hildreth ID 5456 Order 236 Number 11.3
8750 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible.
8751 Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The proposals to release Green Belt land to meet housing targets are not justified from the evidence submitted not believe this policy to be by the Councils. positively prepared please The Councils have stated that release of some Green Belt is necessary as part of an overall three part explain why strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. I question the soundness of such a general policy and whether all the brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites. The development of such Green Belt sites involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient and unfunded. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham cannot accommodate any significant highways improvements anyway due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion, with further worsening air quality. It appears that the area©s needs have not been objectively assessed to an acceptable standard when compared with the assessments made by Chesham Society and Chesham Renaissance. Both of whom have put a lot more detail into their proposals and objections. PP Mods - Please specify as I refer to the comments previously submitted but in summary would advocate that increased density of precisely and succinctly as development of brownfield land and the policies emerging from Chesham Masterplan and the Chesham possible how you would Renaissance CIC should be explored further. modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as I refer to my comments previously submitted precisely and succinctly as possible how you would modify this policy to improve
8752 its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as I refer to my comments previously submitted precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I believe the draft Local Plan is NOT legally compliant because it has not demonstrated sufficient regard believe this policy in to the National Policy and guidance issued by the Secretary of State. consistent with the National Planning Policy Framework The National Planning Policy Framework (NPPF) together with other guidance issued by the Feb 2019 please explain why Government is also supported by recent ministerial statements that have made it clear that Local Authorities MUST demonstrate they have exhausted all options BEFORE considering revision of Green Belt boundaries. This Local Plan is seeking substantial modifications to Green Belt boundaries including the removal of Green Belt designation of 13 areas within the Districts as well as modifying the Green Belt status of many local villages. I contend this draft Local Plan has not demonstrated that all other options have been fully explored and as such this Plan is not justified, sound or in accordance with National Policy and accordingly is not legally compliant. Furthermore that Paragraph 11 b) of the NPPF (and the footnotes thereto) require Plan Makers to provide for objectively assessed needs for housing and other uses UNLESS the application of Framework policies (including Green Belt) provide a strong reason for restricting the overall scale, type or distribution of development in the plan area Chiltern District & South Bucks are significantly constrained by development policies such as Green Belt & Areas of Outstanding Natural Beauty (AONB). The Local Plan is therefore inconsistent with National Guidance and as such it is not legally compliant for the Local Authority to claim that housing needs justify a review of these same Green Belt boundaries. It is insufficient to claim that the combination of housing need and the presence of significant areas of development constraint policy collectively represent ?exceptional circumstances? (as required in the NPPF) to justify modification of Green Belt boundaries especially given the NPPF states that one of the key features of Green Belts are their permanence. The Government has also recently confirmed its aim for the UK to have net zero carbon emissions by 2050 and it is noted within the Sustainability Appraisal supporting this Draft Local Plan, that the Plan area is forecast to see carbon emission increase by 21% in the Plan Period. Accordingly, the Plan is inconsistent with Government Policy and therefore not legally compliant. There is also a significant infrastructure funding gap acknowledged within the Community Infrastructure Levy evidence that supports this Local Plan, of between ?179m & ?231m. Given this infrastructure is vital to ensure that development is sustainable (as also required by the NPPF) this further demonstrates the Plan is both unsound and not legally compliant. Policy 3a - Please specify as The Plan needs to be modified by; precisely and succinctly as Co-operating with other nearby authorities. Not just Aylesbury. It is simply unsatisfactory to assert this possible how you would modify this policy to improve cannot be done because they are different Functional Market Areas and that co-operation is not its alignment to this test of necessary therefore. soundness. A more detailed appraisal of brownfield land opportunities MUST be undertaken. Some brownfield opportunities have been ignored or missed. Closer scrutiny of alternative options for housing delivery should be explored (such as Chesham Masterplan by CIC Chesham Renaissance). Green Belt boundary reviews should only be considered AFTER all other reasonable alternatives have been exhausted. Policy-level file upload - Please attach any supporting evidence
Person ID 1218054 Full Name Cassandra Lewis ID 5462 Order 236
8753 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as
8754 precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I would like to register my strong objection to the Local Plan. not believe this policy to be Chesham is already bursting at the seams and further building on the proposed scale is reckless in my positively prepared please opinion. explain why The roads are struggling to cope with the number of vehicles currently using them. To add thousands more would be catastrophic. Not to mention there©s no provision for extra schools, Drs© surgeries etc to cope with the thousands more people due to inhabit these new homes. Finally, using green belt land to achieve the above is sacrilegious. This green land is too precious to lose. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve
8755 its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1223727 Full Name Mrs Victoria Mistry ID 5464 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible.
8756 Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
8757 Policy 1 - If you do not The proposals to release Green Belt land to meet housing targets (Generally, Spatial Policy SP SP1 & believe this policy to be specifically Policy SP BP2 at Lye Green NE of Chesham) are not justified from the evidence submitted by justified please explain why the Councils. The Councils have stated that release of some Green Belt is necessary as part of an overall three part strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. I question the soundness of such a general policy and whether all the brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites and in particular the Green Belt site NE of Chesham at Lye Green. The development of such Green Belt sites involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient and unfunded. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham cannot accommodate any significant highways improvements anyway due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion, with further worsening air quality. Air pollution is a particular concern in Chesham due to the already poor air quality along Bekhampstead Road where there is a designated Air Quality Management Area that already is recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will generate more traffic will make the air quality even worse and insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable nor justified nor is it in accordance with Govt policy. The Green Belt site NE of Chesham (SP BP 2) is not a sustainable location. It is over 2Km away from the train station and slightly further still from the town centre but anyone who cares to walk or cycle this distance also has to negotiate a steep hill too. Such an unsustainable location cannot be made sustainable merely by upgrading a couple of public footpaths within the site into bridleways to facilitate cycling. Neither does adding a bus stop address the geography or topography of the area especially if the promised enhanced bus service (which is already infrequent) either does not materialise or if it subsequently fails to be maintained after a few years. Further doubt is cast upon the ªsoundnessº of this Plan by virtue of there being conflicting policies within it. The Council seem to think that the Green Belt site NE of Chesham is sustainable and provides easy access to public transport including the tube station yet the same Plan promotes a considerable increase in retail development in the town (local draft plan policy SP EP3) , part of which would be built on the very car park that serves the Chesham tube station. This is inconsistent and unsound. For this Plan to sound it must also be effective. Unfortunately, further review of the proposal to remove land NE of Chesham at Lye Green from Green Belt designation is not effective as there are serious questions about the deliverability of this land. The main landowner is a farmer who has asserted publicly and in a letter to the editor of Your Chesham, that he is not prepared to release all of the land in his ownership for development. The land is also potentially an Asset Of Community Value and upon confirmation of this designation it would afford a community group the right to bid for the land. The community group (Brown Not Green) have stated their intention is to preserve the land given that many hundreds of local people have habitually used the fields at Lye Green as of right for various informal outdoor recreational purposes. These uses themselves may mean that many local individuals may have acquired easements over and across the land through prescription (20 years uninterrupted use) not least of whom would be the many private residences bordering the fields that have rear garden gates onto the fields at Lye Green. These easements and prescriptive rights may render the land very difficult to develop and make i undeliverable in planning terms. This land also provides an important habitat for wildlife that will be threatened by development of this land. It is perverse that the Local Authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Plan is unsound. The foregoing also points to flawed methodology of Green Belt site selection used by the Local Authority, which is neither effective, justified nor consistent with national policy and as such is unsound. Specifically, the selection of the land NE of Chesham at Lye Green (policy SP BP2) for removal from Green Belt designation is inconsistent with National Planning Policy Framework (NPPF). Paragraph 136 of the latest NPPF asserts that Green Belt boundaries should only be modified in ªexceptional circumstancesº. The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances. The Council engaged third party consultants to undertake the Part 1 Green Belt assessment and they identified numerous sites for ªfurther considerationº where exceptional circumstances ªmightº exist but expressly recommended further review of their assessment of each site against the 5 purposes of land being in Green Belt of all these sites. Unlike the neighbouring Local Authorities, the Part 2 Green Belt assessment was not undertaken by third party consultants but by the Local Authority itself who notably then did not undertake all the recommended reviews of each site including the land NE of Chesham at Lye Green (SP BP 2). Accordingly, this oversight in the Part 2 Green Belt assessment placed premature focus and fixation on releasing land at Lye Green NE of Chesham from Green Belt designation. The subsequent identification of the Chesham site for release is therefore unjustified. These comments apply equally to proposals effecting the villages in the Green Belt ± policies SP PP1 & DM PP1) The primary aim of Green Belt land (as recited in NPPF 133) is to prevent urban sprawl and to preserve the openness of the area. The Lye Green site (SP BP2) self-evidently performs this function well and has done so for decades.
8758 Another aim of Green Belt land stated in NPPF paragraph 134, is to prevent neighbouring towns and settlements from merging into one another.The Green Belt land NE of Chesham performs exceptionally well in maintaining a distinct separate between settlements of Chesham & Lye Green as well as helping to maintain separate identities of other nearby communities at Orchard Leigh, Botley, Whelpley Hill, Ashley Green. It is perverse and inconsistent with national guidance to allocate this land for removal from Green Belt in light of these facts especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if earmarked for development. A further aim of Green Belt designation stated in the NPPF at paragraph 134 (e) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. By allocating Green Belt land NE of Chesham for development, undermines this aim within Chesham. A community lead not for profit organisation called Chesham Renaissance CIC has been striving to create Chesham Masterplan that would not only provide many genuinely affordable homes in more sustainable locations nearer the town centre, but which would also regenerate some of the more deprived wards within Chesham. The Local Authority's proposals (policy SP EP3) are inconsistent with this local initiative and are therefore also inconsistent with national guidance and are consequently unsound. The Council have asserted that Government planning policy requires local councils to review Green Belt boundaries when considering how to accommodate the development needed in their areas. Just because the Council may be required to look, does not mean the Council should review Green Belt boundaries which as previously stated should only be modified in ªexceptional circumstancesº. National Planning Policy Framework (NPPF) as revised only last year, states in paragraph11 (b) I, directs ªplan makersº to create policies that are required in Local Plans for housing and other uses unless Framework policies (expressly including Green Belt) ªprovides a strong reason for restricting the overall scale type or distribution of development in the plan areaº Accordingly, I submit that given all of the above the land being proposed for release from Green Belt designation around Chesham is unjustified and contrary to national guidance. I am supportive of the Brown Not Green organisation's initiative to have the land listed as an Asset of Community Value and I feel they speak for me in respect of their objections to the draft Local Plan. Accordingly, I request that any representations made by them at any future examination in public regarding the soundness of this Local Plan be considered as an extension of my own comments herein. I feel the land NE of Chesham is an unsustainable location for development, that has been habitually used by the community for improved health & wellbeing for decades and the land performs well against Green Belt aims and objectives. Exceptional circumstances for reviewing Green Belt boundaries at this location, either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by Govt Policy and therefore the plan is unsound. Policy 2a - Please specify as I refer to the comments previously submitted but in summary would advocate that; precisely and succinctly as All other options are fully explored including increased density of development of brownfield land and the possible how you would policies emerging from Chesham Masterplan. modify this policy to improve its alignment to this test of Green Belt land should only be considered when all other options are exhausted and in any event the soundness. proposals for developing land NE of Chesham (policy SP BP 2) should be removed as it is an unsustainable location the development of which will cause harm to the wider town including loss of an asset that improves the well-being for the community. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I believe the draft Local Plan is NOT legally compliant because it has not demonstrated sufficient regard to believe this policy in the National Policy and guidance issued by the Secretary of State. consistent with the National The National Planning Policy Framework (NPPF) together with other guidance issued by the Government Planning Policy Framework is also supported by recent ministerial statements that have made it clear that Local Authorities MUST Feb 2019 please explain why demonstrate they have exhausted all options BEFORE considering revision of Green Belt boundaries. This Local Plan is seeking substantial modifications to Green Belt boundaries including the removal of Green Belt designation of 13 areas within the Districts as well as modifying the Green Belt status of many local villages. I contend this draft Local Plan has not demonstrated that all other options have been fully explored and as such this Plan is not justified, sound or in accordance with National Policy and accordingly is not legally compliant. Furthermore that Paragraph 11 b) of the NPPF (and the footnotes thereto) require Plan Makers to provide for objectively assessed needs for housing and other uses UNLESS the application of Framework policies (including Green Belt) provide a strong reason for restricting the overall scale, type or distribution of development in the plan area Chiltern District & South Bucks are significantly constrained by development policies such as Green Belt & Areas of Outstanding Natural Beauty (AONB). The Local Plan is therefore inconsistent with National Guidance and as such it is not legally compliant for the Local Authority to claim that housing needs justify a review of these same Green Belt boundaries. It is perverse to claim that the combination of housing need and the presence of significant areas of development constraint policy collectively represent ªexceptional circumstancesº (as required in the NPPF) to justify modification of Green Belt boundaries especially given the NPPF states that one of the key features of Green Belts are their permanence.
8759 The Government has also recently confirmed its aim for the UK to have net zero carbon emissions by 2050 and it is noted within the Sustainability Appraisal supporting this Draft Local Plan, that the Plan area is forecast to see carbon emission increase by 21% in the Plan Period. Accordingly, the Plan is inconsistent with Government Policy and therefore not legally compliant. There is also a significant infrastructure funding gap acknowledged within the Community Infrastructure Levy evidence that supports this Local Plan, of between £179m & £231m. Given this infrastructure is vital to ensure that development is sustainable (as also required by the NPPF) this further demonstrates the Plan is both unsound and not legally compliant. Policy 3a - Please specify as The Plan needs to be modified by; precisely and succinctly as Co-operating with other nearby authorities. Not just Aylesbury. It is simply unsatisfactory to assert this cannot possible how you would be done because they are different Functional Market Areas and that co-operation is not necessary therefore. modify this policy to improve its alignment to this test of Exploring such wider co-operation may result in further housing needs being taken elsewhere. soundness. A more detailed appraisal of brownfield land opportunities MUST be undertaken. Some brownfield opportunities have been ignored or missed. Closer scrutiny of alternative options for housing delivery should be explored (such as Chesham Masterplan by CIC Chesham Renaissance). Green Belt boundary reviews should only be considered AFTER all other reasonable alternatives have been exhausted. In the face of NPPF guidance and a more thorough appraisal of Green Belt sites being considered, it may then be necessary to conclude that it is not possible to identify poor performing Green Belt sites that can accommodate all the OAN for housing. Consequently it may be necessary to accept that a lower housing provision figure is appropriate. I am a supporter of Brown Not Green Chesham and I confirm I am content for them to speak for me at any hearing or public examination. Policy-level file upload - Please attach any supporting evidence
Person ID 1212969 Full Name Richborough Estates ID 5475 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Richborough Estates Partnership LLP Consultee Type - Please Agent/Developer select the type of consultee: Date Received - Date 2016-03-14 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID 1210983 Full Name Mr David Barnes Organisation Details Star Planning and Development Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally
8760 compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be
8761 as precise and succinct as possible Policy Level - PP - If you do Richborough Estates recognise that housing development would occur on the periphery of a settlement not believe this policy to be which is accessible and contains a range of facilities and services. However, the eastern part of the area is positively prepared please visually open to the wider landscape to the southeast and has a rural character typical of the local landscape, explain why with scattered linear development at Lye Green and along the B4505 to the south situated beyond the open fields and woodland that separate the land from the urban form and edge of Chesham. Development within the area would impact upon the open and rural character and lead to the merging of settlements and individual/small groups of dwellings along the roads. These are sensitivities identified by the Chiltern Landscape Character Assessment for the area. Existing woodland and tree belts, including a large wood to the northwest of the area, limit the potential for development and serve to separate the land from the built edge of Chesham. The extensive network of footpaths through the area also pose as a constraint due to recreational pressures and their retention within any development. Policy DM LP1 indicates that as a minimum of 70% of dwellings on the major sites would be 3-bedroom or more. It is unclear from the available information about what housing mix and density assumptions are being made to determine the assumed capacity of the allocation is achievable. Policy SP BP2 ± Chesham Conclusion 4. Accordingly, and taking into account factors such as overhead lines, in the absence of a master plan it is unclear whether the full 500 dwellings can be accommodated within this allocation. For the Local Plan to be positively prepared and effective, additional land needs to be released from the Green Belt to address this potential shortfall. PP Mods - Please specify as For the Local Plan to be positively prepared and effective, additional land needs to be released from the precisely and succinctly as Green Belt to address this potential shortfall, including omissions sites such as Raylands Farm, Gerrards possible how you would Cross. modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5500873 Please attach any supporting evidence
Person ID 1223752 Full Name Emma Child ID 5510 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details
8762 Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence
8763 Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not As a recent Chesham resident (we moved here from London 3 years ago) and mother of 2 children under believe this policy in 4, I am concerned that the proposal of 900 new houses on the greenbelt on the edge of Chesham. consistent with the National We live on the corner of Church Street and St Mary's Way so are no strangers the stresses and strains in Planning Policy Framework traffic that Chesham has to endure. It is a very busy road, often full to capacity and often congested. My Feb 2019 please explain why children attend nursery school at Ollie Owls on Berkhamsted Road and I am concerned about the quality of air in the area already. My husband uses the tube daily and this is also full to bursting at peak times and without any option of increased services from Chesham, my question is - are these plans really the best idea?
8764 To summarise I believe the Local Plan is in contravention of National Planning Policy Guidance Feb 2019, page 41, Section 138 as there is: - no additional housing planned for Amersham-on-the-Hill in the Local Plan - the housing that is planned in the Amersham area is for Green Belt in Old Amersham (which has far inferior public transport accessibility) - the additional housing for Chesham is outside the town centre on Green Belt land withterrible public transport accessibility Furthermore, in Amersham there is are ideal sites to develop housing, including the area between Chiltern Avenue and Sycamore Road, which includes East Building Supplies, the St. Michael's Church and Sorbon Estate's land holdings on Sycamore Corner. With careful medium term planning this large site could easily accommodate a net increase of 100dwellings, improve pedestrian connectivity between the new Leisure Centre and the High Street plus lend an opportunity towards creating a new town square and a new Church. Also, the Royal Mail sorting office on Hill Avenue is an underutilised site which could accommodate 20 apartments and some modern retail in the town centre. If these two, highly sustainable sites were redeveloped it would take some of the pressure off the house building target for Chesham. Rebalancing some residential development towards Amersham Town Centre, intensifying residential development within Chesham Town Centre would negate the `need' to release Green Belt land at Lye Green (or any other green belt land in Chesham & Amersham) and would be in concordance with National Planning Policy Guidance Feb 2019, page 41, Section 138. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham cannot accommodate any significant highways improvements due to the already limited verges and footway space beside the highway. I hope you reconsider these plans and create alternative options which are better balanced with the infrastructure of the towns. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1223751 Full Name Olly Moss ID 5509 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be
8765 as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public?
8766 Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I don't believe the proposals to release Green Belt land to meet housing targets are justified from the evidence believe this policy in submitted. I question the soundness of such a general policy and whether all the brownfield land opportunities consistent with the National with higher public transport accessibility have been identified (National Planning Policy Guidance Feb 2019, Planning Policy Framework page 41, Section 137 a & b) Feb 2019 please explain why I believe the Local Plan is in contravention of National Planning Policy Guidance Feb 2019, page 41, Section 138 as there is: - no additional housing planned for Amersham-on-the-Hill in the Local Plan - the housing that is planned in the Amersham area is for Green Belt in Old Amersham (which has far inferior public transport accessibility) - the additional housing for Chesham is outside the town centre on Green Belt land with terrible public transport accessibility Furthermore, in Amersham there is are ideal sites to develop housing, including the area between Chiltern Avenue and Sycamore Road, which includes East Building Supplies, the St. Michael's Church and Sorbon Estate's land holdings on Sycamore Corner. With careful medium term planning this large site could easily accommodate a net increase of 100 dwellings, improve pedestrian connectivity between the new Leisure Centre and the High Street plus lend an opportunity towards creating a new town square and a new Church. Also, the Royal Mail sorting office on Hill Avenue is an underutilised site which could accommodate 20 apartments and some modern retail in the town centre. If these two, highly sustainable sites were redeveloped it would take some of the pressure off the house building target for Chesham. Rebalancing some residential development towards Amersham Town Centre, intensifying residential development within Chesham Town Centre would negate the `need' to release Green Belt land at Lye Green (or any other green belt land in Chesham & Amersham) and would be in concordance with National Planning Policy Guidance Feb 2019, page 41, Section 138. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham cannot accommodate any significant highways improvements due to the already limited verges and footway space beside the highway. A frequent limitation to improving traffic flow, pedestrian or cycle improvements are that Highway Authority boundaries are not sufficient in area in order to accommodate additional traffic lanes/wider pavements/cycle lanes. The only way to widen the roundabouts and add traffic lanes is by reducing pavement width (not acceptable and will discourage sustainable modes of transport such as walking and cycling) or compulsory purchase order of front drives/housing (prohibitively expensive and time consuming). The increases in vehicular traffic which will directly be spurred by the proposed Local Plan may mean several of the roundabouts would require signalisation, increasing traffic queues exponentially and causing higher levels of NOx, CO2 and particulate pollution (PM10/PM2.5).
8767 Thus the Local Plan appears to contravene the following national, international and supranational policies/protocols of which the UK is a signatory: The Kyoto Protocol (1997) stemming from the 1992 United Nations Framework Convention on Climate Change (UNFCCC) - The Paris Agreement on Climate Change (2016) within the (UNFCCC), - The following EU air quality directives namely 2008/50/EC Directive on Ambient Air Quality and Cleaner Air for Europe & 2004/107/EC Directive on heavy metals and polycyclic aromatic hydrocarbons in ambient air. - The Climate Change Act 2008 (c 27) - Forthcoming UK legislation for a neutral carbon economy for 2050 as an amendment to the 2008 Climate Change Act. The edge of town locations outlined in the plan are diametrically opposed to Section 4.5.4 in the draft Local Plan. Please note the developments such as on the edge of Beaconsfield and around Lye Green would require a restriction of 1 car per dwelling in order to meet 4.5.4. I fail to see how this development would work for residents to access retail or employment markets and also recreational or educational facilities with such a parking restriction. Locating additional housing in town centres has many beneficial effects: 1. It is more environmentally sustainable (less car driving, less CO2, NOx and particulate emissions 2. It encourages people to walk around more and shop locally. This will benefit retail on the High Street (supports NPPF paragraph 23 ± vitality of town centres) 3. It will preserve traffic capacity on the crucial through road along St. Mary's Way 4. As per the Chesham Renaissance Masterplan it will enable the Council to reverse the historic negative impact of the demolition of Blucher Street by redeveloping Star Yard in a sympathetic manner and improving pedestrian links to Scottowes' Pond and Lowndes' Park. Another concern I have about the draft Local Plan is on Air Quality. Chesham has a fairly rare topography and exhibits `frost hollow' characteristics (Mayes 2013: Royal Meteorological Society, Box 1, page 61). This means that in high pressure anticyclonic conditions which frequently occur during winter months air from the top of the ridges (e.g Chartridge / Hilltop / Ashridge / White Hill / Nashleigh Hill) `sinks' into the valleys, trapping pollutants within radiation fog (p188, Goudie). These temperature inversions can cause rapidly worsening air quality, especially along transport corridors such as Berkhamsted Road, where many people live and there is a Primary School (Newtown Infant School), the Chesham Health Centre and two Nurseries. Berkhamsted Road is already designated as one of Chiltern and South Bucks three Air Quality Management Areas which already records air quality in excess of EU safe levels. Adding more homes outside town on the Green Belt will generate more traffic which in turn will make the air quality even worse. Insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable nor justified nor is it in accordance with Government policy or EU Directives 2008/50/EC & 2004/107/EC. As a final point I would like to register my concern about the Local Plan and the detrimental impact it will likely have upon rare chalk stream habitats in Chiltern District. There are only circa 200 chalk streams worldwide, with two of them in Chiltern; the River Chess and Misbourne. They are both frequently dried out due to over water abstraction (please see photo). I believe the additional houses planned for Chesham will negatively impact upon the Chess as more water will be abstracted for residential use, depriving the local aquifers of water to recharge the Chess (WWF 2014, The State of England's Chalk Streams). Two SSSIs associated with the River Chess will be negatively impacted ± Frogmore Meadows (Chiltern District/Three Rivers District Council/Dacorum Borough Council and Sarratt Bottom (Three Rivers District Council /Hertfordshire). I do not believe the draft Local Plan has appropriate mitigation for the increases in water abstraction and believe this should be included in full Environmental Impact Assessment (EIA) to accompany a revised Plan. This may require the building of new reservoirs with neighbouring Councils and mandating any new development in the town centre to incorporate rainwater and greywater recycling. The threshold for an EIA is a development in excess of 150 homes. The agglomerated impact of 5,200 extra houses in Chiltern and South Bucks would therefore require a robust EIA unless every single commercial development was 149 homes or less. Hence I believe the draft Local Plan is also in contravention the Wildlife and Countryside Act (1981) Section F226 F28H and European Union Directive (85/337/EEC) on Environmental Impact Assessments. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1223761 Full Name Jonida Gjoshi ID 5511 Order 236
8768 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as
8769 precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Having read the plan and seen arguments for and against, I would like to object to the current proposals on not believe this policy to be the grounds below: positively prepared please 1. Increased pollution on Berkhampstead Road where several nurseries and schools are located. explain why 2. Increased congestion on our limited tube services. 3. Use of greenbelt land when there's no proper use of brownfield land or land near the town centre which needs regeneration. 4. The impact the increased population will have in GP surgeries and schools. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve
8770 its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1223660 Full Name Clare Elstow ID 5529 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible.
8771 Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I am most surprised to hear of plans for significant additions to retail space (Enterprising Places) when the not believe this policy to be high street is already full of charity shops and nail bars, so a large new store would adversely impact the positively prepared please viability of the shops we already have. We do have a number of independent shops and cafes, and I would explain why not want to see any of them become unviable. (I have also seen a ref to redeveloping Darvell's ± our only independent excellent bakery. It would be much better to redevelop the eye-sore building that houses M & Co.) It also seems bizarre to propose siting a store on the station car-park! Surely a large store will need its own parking ± and the commuting car parking is already severely under-catered for: as mentioned above, that station car park is completely full by 08.30 on weekdays, and parking increasingly clogs nearby ± and further afield - streets.
8772 PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as consider the plan to be unsound, for the reasons set out in the response of the Chesham Society, which is precisely and succinctly as in turn based on the responses of possible how you would · Brown not Green (BnG) modify this policy to improve its alignment to this test of · Chesham Renaissance / CIC (CR) soundness. · The Chiltern Society (ChS) · The Chess Association (ChA) In summary, the plan is unsound because · The housing allocation has not been reduced to reflect the constraints of Green Belt and AONB. It will simply result in `urban sprawl' ± something the NPPF is keen to avoid. Plundering Green Belt land (protected spaces?!) is unacceptable: Lye Green is an asset of community value, and building all over it would destroy farmland, degrade the green belt, compromise biodiversity, and add hugely to the amount of traffic in town (no-one is going to walk two miles via a very steep hill with their shopping; a significant proportion of new house owners would be commuters ± and Chesham station car-park is already full every day from 08.30. (Many extra commuters flood in from the neighbouring towns and even county (eg Tring) to the town to take advantage of the TfL fares; my own road, Chartridge Lane, is now parked solid all the way from the roundabout and back up the hill for a quarter of a mile, as far as the school ± this has happened in the last 2 or 3 years.) I do not want to see green belt land being used as a `quick fix' solution ± please see Chesham Renaissance plans for much greater use of brownfield sites, and an imaginative vision for alternative approaches. Nor is there sufficient protection for the local Chalk Streams (natural spaces) as provided for in NPPF paragraph 11. [ ChS, ChA] I am particularly concerned about the chalk streams as they are such a rare habitat and over-abstraction by water companies has, yet again, meant a completely dry stream bed this year. There were no dead fish this time, because they were all killed by the catastrophic event in 2015 ± the ecosystem has still not recovered from that unforgivable destruction. Affinity is the only water company that does not have its own reservoir, and continues to plunder the aquifer ± which is totally unsustainable and has to stop. · New developments on Green Belt sites are proposed in unsustainable locations, to the detriment of traffic flow and air quality in the town. [BnG] See comments above. · The existing plans for use of Brownfield sites have been ignored, and no comparable plans put forward. [CR] ± why are local suggestions not being incorporated, especially as they largely are endorsed by Chesham Town Council. · Mitigation measures proposed for existing infrastructure problems (Water, Sewage, Traffic congestion, Air Quality¼) appear unconvincing, and unlikely to compensate for the proposed additional housing.[ChA, Chesham Society] Thames Water have already acknowledged that 20 new sewage treatment tanks would be necessary, partly to catch up on the existing under-provision (leading to raw sewage polluting the Ricer Chess) and partly to provide for the proposed level of additional housing ± but have not even begun to implement this essential infrastructure. The A 416 is a congestion Management Corridor ± but still a very problematic bottleneck for traffic passing through; and the air quality issues are already very problematic (obviously Chesham's geography, with the town centre in the Chess Valley, means fumes become even more concentrated ± cars for this many houses will just make things much worse. We're also already very short of commuter parking, so can't afford to lose any of the existing carparks ± see above. On the contrary, another `floor' needs adding to the station carpark and coal yard ± not more retail space. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why
8773 Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1223613 Full Name Emily Conboy ID 5532 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant
8774 legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Soundness not believe this policy to be I consider the plan to be unsound, for the reasons set out in the responses of the: positively prepared please explain why · Chesham Society, which is in turn based on the responses of · Brown not Green (BnG) · Chesham Renaissance / CIC (CR) · The Chiltern Society (ChS) · The Chess Association (ChA) In summary I consider the plan to be unsound for the same reasons detailed by Ms Elstow: · The housing allocation has not been reduced to reflect the constraints of Green Belt and AONB. It will simply result in `urban sprawl' ± something the NPPF is keen to avoid. · Plundering Green Belt land (protected spaces?!) is unacceptable: Lye Green is an asset of community value, and building all over it would destroy farmland, degrade the green belt, compromise biodiversity, and add hugely to the amount of traffic in town (no-one is going to walk two miles via a very steep hill with their shopping; a significant proportion of new house owners would be commuters ± and Chesham station car-park is already full every day from 08.30. (Many extra commuters flood in from the neighbouring towns and even county (eg Tring) to the town to take advantage of the TfL fares; my own road, Chartridge Lane, is now
8775 parked solid all the way from the roundabout and back up the hill for a quarter of a mile, as far as the school ± this has happened in the last 2 or 3 years.) · I do not want to see green belt land being used as a `quick fix' solution ± please see Chesham Renaissance plans for much greater use of brownfield sites, and an imaginative vision for alternative approaches. · Nor is there sufficient protection for the local Chalk Streams (natural spaces) as provided for in NPPF paragraph 11. [ ChS, ChA] I am particularly concerned about the chalk streams as they are such a rare habitat and over-abstraction by water companies has, yet again, meant a completely dry stream bed this year. There were no dead fish this time, because they were all killed by the catastrophic event in 2015 ± the ecosystem has still not recovered from that unforgivable destruction. Affinity is the only water company that does not have its own reservoir, and continues to plunder the aquifer ± which is totally unsustainable and has to stop. · New developments on Green Belt sites are proposed in unsustainable locations, to the detriment of traffic flow and air quality in the town. [BnG] See comments above. · The existing plans for use of Brownfield sites have been ignored, and no comparable plans put forward. [CR] ± why are local suggestions not being incorporated, especially as they largely are endorsed by Chesham Town Council. · Mitigation measures proposed for existing infrastructure problems (Water, Sewage, Traffic congestion, Air Quality ¼) appear unconvincing, and unlikely to compensate for the proposed additional housing.[ChA, Chesham Society] Thames Water have already acknowledged that 20 new sewage treatment tanks would be necessary, partly to catch up on the existing under-provision (leading to raw sewage polluting the Ricer Chess) and partly to provide for the proposed level of additional housing ± but have not even begun to implement this essential infrastructure. · The A 416 is a congestion Management Corridor ± but still a very problematic bottleneck for traffic passing through; and the air quality issues are already very problematic (obviously Chesham's geography, with the town centre in the Chess Valley, means fumes become even more concentrated ± cars for this many houses will just make things much worse. We're also already very short of commuter parking, so can't afford to lose any of the existing carparks ± see above. On the contrary, another `floor' needs adding to the station carpark and coal yard ± not more retail space. · I am most surprised to hear of plans for significant additions to retail space (Enterprising Places) when the high street is already full of charity shops and nail bars, so a large new store would adversely impact the viability of the shops we already have. We do have a number of independent shops and cafes, and I would not want to see any of them become unviable. (I have also seen a reference to redeveloping Darvell's ± our only independent excellent bakery. It would be much better to redevelop the eye-sore building that houses M&Co.) It also seems bizarre to propose siting a store on the station car-park! Surely a large store will need its own parking ± and the commuting car parking is already severely under-catered for: as mentioned above, that station car park is completely full by 08.30 on weekdays, and parking increasingly clogs streets nearby and further afield. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why
8776 Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5512651 Please attach any supporting evidence
8777 Person ID 1223679 Full Name David Digby ID 5541 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness?
8778 Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve
8779 its alignment to this test of soundness. Policy 3 - If you do not I believe the Draft Local Plan is not legally compliant as it does not comply with policy and guidelines. believe this policy in My main concern is over the removal of the Green Belt designation from the land NE of Chesham. The consistent with the National National Planning Policy Framework states that such designation should only be removed in ªexceptional Planning Policy Framework circumstancesº. The courts have repeatedly confirmed that housing need is not ªexceptionalº. Moreover, Feb 2019 please explain why housing need was foreseen and was one of the main drivers of the introduction of Green Belt land. The review of Green Belt land was wholly unsatisfactory, as it concluded that this area of land was of little value when measured against appropriate criteria. However this is clearly not the case, development on this site will increase urban sprawl with the effect of engulfing hamlets that are currently isolated, changing their historic character. The land was also considered of low recreational value, even though it is designated an Asset of Community Value. I also do not believe the development complies with sustainability guidelines. My main concern here is with regard to water, both the supply and removal of waste water. The development is in an area under serious water stress. The demand for water is already doing serious damage to nationally important chalk streams, such as the River Chess. Increasing demand when there is no additional supply is not sustainable. Similarly, the local Sewage Treatment Works is near capacity, with regular discharges of raw sewage when the site is overwhelmed. Even if these could be addresses there is insufficient funding available. I also have concerns about the effect of increased road use on air quality and the climate. Putting a large new development at the top of a very steep hill will encourage car use, rather than sustainable transport, such as walking or cycling. Chesham is also a poor choice for increased population as the service from its underground station is near capacity and there is limited scope for increasing the service, due to technical constraints, such as it being a single-line branch. It also has limited connections, for example to the mainline. As a consequence, many people drive from Chesham to other stations where they can catch Mainline trains. This increased car use will make the already poor air quality even worse. Policy 3a - Please specify as A thorough investigation of Brownfield Sites must be undertaken and this should feed into alternative proposals precisely and succinctly as such as the Chesham Masterplan. possible how you would If other options prove insufficient then a review of Greenbelt land should be thorough and independent. modify this policy to improve its alignment to this test of Since that is most likely to conclude that the Greenbelt designation should not be removed, the next step soundness. would be to accept that it is not possible to build more houses. Policy-level file upload - Please attach any supporting evidence
Person ID 1223624 Full Name Mr Mike Ridout ID 5552 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies
8780 and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary
8781 to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I am deeply concerned about many aspects of the draft Local Plan, which I have only been able to examine believe this policy in during the last few days, due to being out of the country for several weeks, and various pre-booked consistent with the National commitments. But I do wish to comment, although maybe in less detail than I would like to, as I am up against Planning Policy Framework the deadline in a few hours. Feb 2019 please explain why I think it is non-compliant, as it seems to me to be at odds with the National Policy & Guidance, issued by the Secretary of State. I would like to comment, in particular, on the proposals to remove 13 areas currently protected in the Green Belt, and release them for Development. Of special concern, is the site at Lye Green, Chesham SB BP2. It is bad enough that we are faced with potentially losing the entire loss of this Community Amenity land, which I have used for walking and recreational enjoyment of the open fields many times over the last 2 and a bit years, since my retirement, and by many many other local people for a range of recreational purposes and activities over decades who have established rights of access and use, and which I am pleased to note has recently been awarded the status of an Asset of Community Value, but to have it concreted over with housing and roads, with very little thought about some the practical impacts on the local environment, and residents of the northern part of Chesham in particular. The National Policy is clear that Green Belt land can only lose its status, under EXCEPTIONAL circumstances, and that CDC must demonstrate - including full evidence - that it has exhausted all alternative ideas, options, plans and sites, etc, before attempting to remove land from Green Belt protection. I do not believe that CDC has fully explored various other options, and therefore this plan is not only not justified, it is consequently not legally compliant either. Legal precedents have established that the redesignation of Green Belt land for housing need alone cannot be justified, and the latest NPPF says that there is a presumption in favour of sustainable development. Furthermore, paragraph 11b)i, directs planners to create housing policies in Local Plans unless Framework policies provide a strong reason for restricting the overall scale, type, or distribution of development in the plan area. Our local area already includes constraints due to the Green Belt and AONBs, and this also puts it at odds with national guidance and also renders it legally non-compliant. I am sure that you are aware of Footnote 6, which includes Green Belt as a Framework Policy of importance, but I do not believe that this draft plan pays any attention to this requirement. Policy 3a - Please specify as I believe that the Plan needs to be reviewed in light of the following: precisely and succinctly as · Cooperation and co-ordination with neighbouring local authorities. possible how you would modify this policy to improve · A joint approach to housing needs, may lead to the identification of alternative locations for housing.
8782 its alignment to this test of · Local initiatives such as the Brown Not Green proposals, and Chesham Masterplan should be thoroughly soundness. scrutinised and objectively evaluated, and if found not acceptable, comprehensive evidence should be published supporting such conclusions ± ªfull evidenceº - such as the methodology used for the evaluation, the data used, and comprehensive explanations as to why the evidence for these schemes leads to the conclusion that they are not acceptable. · This should occur BEFORE any application to de-register Green Belt land is made. Policy-level file upload - 5512660 Please attach any supporting evidence
Person ID 1214654 Full Name Mr Glyn Marsh ID 5605 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-12-12 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including
8783 references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do In respect of SP BP2©s location, the plan and supporting assessment consider only the measure of straight not believe this policy to be line distance to the centre of Chesham and its amenities including its rail (in fact London Underground) positively prepared please station. The site is c2km from the town and station but it is at a significantly higher elevation and the hill explain why gradient is steep. In practise this makes foot and bicycle travel between the site and town much more difficult and challenging in practise than the crude straight line distance would suggest- this would particularly be the case for small children, the elderly or people with restricted mobility. The almost inevitable result of building large numbers of new dwellings at the top of a steep gradient such as that on which SP BP2 is sited would be to substantially increase the level of car use for shopping, school and other journeys to and from town. The plan©s optimistic view that improving cycle routes between SP BP2 and Chesham will lower the likely traffic congestion and pollution impact appears to be based only on crude map distance and not on the most important facts of SP BP2©s actual topography. Similarly, the plan©s optimism about providing improved bus services is unconfirmed and unfunded, and would rely on the commercial considerations of current and future bus operators, so it cannot be considered a resolution to the site©s inherent access problems. The likely increase in car travel between site and town dictated by its steeply elevated situation would of course make Chesham©s traffic congestion and pollution problems worse. The Berkhamsted Road area of Chesham is already designated an Air Quality Management Area, and the pollution effects of this part of the plan will both intensify and spread this public health and environmental risk. The plan itself acknowledges
8784 that the likely increase in carbon emission it will create during the lifetime of the plan will be in the order of 21%, so collateral effects like harmful particulate emission can be expected also to increase substantially as a result. 2) Rail connectivity. This also seriously adversely affects the sustainability of SP BP2. One of the most important features of rail connectivity in Chesham is its inherent capacity restrictions. Chesham is situated at the end of a long single track spur of the Metropolitan underground line. Nearby settlements with rail links such as Amersham, Chalfont etc all benefit from a double track railway served by both London Underground and mainline rail companies. Chesham©s position at the far end of a spur means that unlike those places, It only has rail connectivity Southwards towards London, there is no Northwards connectivity at all. Also because of the single track format, there is an inherent limitation of two trains per hour to and from Chesham even during rush hour periods. By contrast, nearby settlements are served by up to six trains per hour in both directions. Services to and from Chesham in the rush hour are already amongst the most heavily used (because they are infrequent) on the Metropolitan Line. It is very likely that such a substantial increase in dwelling numbers for Chesham as proposed by the plan would put even greater pressure on inherently weak rail connectivity, and create further necessity for road travel. There is no indication at all in the plan or supporting assessment that this serious inherent weakness in Chesham©s transport infrastructure has even been recognised let alone been given consideration. It would be a very substantial undertaking to improve the carrying capacity of Chesham spur of the Metropolitan line. Even the provision of passing places on the current line to increase service frequency would require extensive track laying and signalling work, and complete double tracking would require rebuilding bridges etc and be an extremely costly business. There is no suggestion in the plan that London Underground has even been approached on this matter, and given Chesham©s position as effectively the furthest outpost of the entire Underground network, it is hard to imagine this receiving high priority for upgrades against the needs of London. Overall, I consider that the plan, in failing to take account of inherent weakness of rail connectivity in respect of SP BP2, does not demonstrate that it is sustainable. Given the factors outlined above, I contend that it positively fails the sustainability element of the soundness test. PP Mods - Please specify as I propose that the whole of the area SP BP2 be removed from the local plan entirely on the basis that the precisely and succinctly as plan©s soundness is compromised by the lack of sustainability of this site, as outlined above. possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe that the plan as it currently stands does not meet these tests. Firstly because it does not take into believe this policy to be account reasonable alternatives, such as the many Brown Field sites referenced above- it cannot be considered justified please explain why justified. It also cannot be considered justified because it there are failures in the evidence base, examples of which in respect of topography and transport infrastructure, are given below. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not Q1- Is the plan legally compliant? believe this policy in I contend that the plan is not legally compliant especially in respect of the requirement within the NPPF to consistent with the National utilise green belt land for development only where exceptional circumstances exist and where all potential Planning Policy Framework alternatives have been fully explored and discounted. In my view the plan does not demonstrate that either Feb 2019 please explain why of these obligations have been properly discharged, and therefore that the plan cannot be considered compliant with the relevant legal and policy frameworks such as the NPPF. In respect of alternatives to the plan©s proposal to remove Green Belt status from substantial areas of land, in the early iterations of this plan a large number of smaller brown field sites in the Chesham area and elsewhere were identified for further consideration. In many such cases these sites appeared suitable but the council had not at that point been able to establish ownership details to pursue them further as possibilities for positive inclusion in the plan. As the plan was iterated further, reference to almost all of these was simply omitted without any indication that the necessary steps had been taken to establish whether these sites could be used for development. The plan therefore does not demonstrate as required by the NPPF that all alternatives to developing Green Belt land have been exhausted. In respect of the argument of exceptional circumstances- this argument is clearly undermined by the points above- it is hard to see that exceptional circumstances exist where potential alternatives have not been demonstrably considered and rejected, with detailed reasoning provided. Also, the combination of unmet housing need and significant planning constraint in form of areas of Green Belt restriction cannot logically come together as exceptional circumstance justifying the reduction of that very Green Belt. To adopt that
8785 logic would be to reduce Green Belt status to that of a tradeable commodity and would tend to subvert its original significance in law. Also, I believe it is not consistent with national policy, because elements of it (specifically the plan for the area covered by SP BP2 at Lye Green NE of Chesham) are not sustainable. I would point to two particular weaknesses in terms of sustainability, neither of which appear to have been given appropriate consideration in the plan or in the sustainability assessment undertaken in support of the plan. These weaknesses are 1) the location of SP BP2, and 2) the underlying weakness of rail connectivity to and from Chesham, and in my view both render this element of the plan unsound. Policy 3a - Please specify as I contend that a full appraisal of Brown Field site availability and suitability must be carried out. Further, its precisely and succinctly as results should be published and made subject to proper scrutiny in respect of methodology and completeness possible how you would before any consideration is given to removing Green Belt status from land currently protected by it. That modify this policy to improve would go some way to demonstrating that all alternatives to releasing areas of Green Belt truly had been its alignment to this test of considered. All Brown Field sites must be considered and their potential in terms of number of dwellings soundness. must be used to against the total numerical requirement first. Policy-level file upload - Please attach any supporting evidence
Person ID 1223713 Full Name Sandie Mary Holland ID 5629 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible.
8786 Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I am opposed to this plan for many reasons but my primary cause for concern is that my daughter lives on not believe this policy to be White Hill, Chesham. She has a three month old baby. They live on the very busy, narrow section between positively prepared please Broadlands and Kirkle Road. At present her window cills, windows, front door and doorstep are covered in explain why pollutants from passing traffic. This will only get worse with the increased traffic up and down this road if this housing development goes ahead. I am EXTREMELY WORRIED and CONCERNED about the potential damage to my young grand daughter©s health, that would result from the inevitable increase in particulate pollution due to a higher traffic flow should this development go ahead.
8787 PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1223762 Full Name Mr William Goodes ID 5637 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant.
8788 Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as
8789 precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I believe the draft Local Plan is not legally compliant. not believe this policy to be The Local Plan does not adhere to National Policy and guidance issued by the Secretary of State, including positively prepared please the National Planning Policy Framework (NPPF) together with other guidance issued by the Government. explain why The Government and Ministers have repeatedly stated that Local Authorities must demonstrate they have exhausted all options before considering revision of Green Belt boundaries. This Local Plan is seeking substantial modifications to Green Belt boundaries including the removal of Green Belt designation of 13 areas within the Districts as well as modifying the Green Belt status of many local villages, including my own. It is clear that the Local Plan has not demonstrated that all other options have been fully explored and therefore does not adhere with government policy nor is it legally compliant. Furthermore that Paragraph 11 b) of the NPPF (and the footnotes thereto) require planning teams to provide for objectively assessed needs for housing and other uses unless the application of Framework policies (including Green Belt) provide a strong reason for restricting the overall scale, type or distribution of development in the plan area. Chiltern District & South Bucks are significantly constrained by development policies such as Green Belt & Areas of Outstanding Natural Beauty (AONB). The Local Plan is therefore inconsistent with National Guidance and as such it is not legally compliant for the Local Authority to claim that housing needs justify a review of these same Green Belt boundaries. One of the key features of Green Belts are their permanence. It is therefore wrong to claim that the combination of housing need and the presence of significant areas of development constraint policy collectively represent ªexceptional circumstancesº (as required in the NPPF) to justify modification of Green Belt boundaries. There are critical infrastructure limitations and funding gaps acknowledged within the Community Infrastructure Levy evidence that supports this Local Plan, of between £179m & £231m. Road and rail links are at capacity, the drainage and water treatment systems cannot cope with the additional demand and the town does not have the necessary retail infrastructure. Given this infrastructure is vital to ensure that development is sustainable (as also required by the NPPF) this further demonstrates the plan is both unsound and not legally compliant. The Government has also recently confirmed its aim for the UK to have net zero carbon emissions by 2050 and it is noted within the Sustainability Appraisal supporting this Draft Local Plan, that the Plan area is forecast to see carbon emission increase by 21% in the Plan Period. Accordingly, the Plan is inconsistent with Government Policy and therefore not legally compliant. PP Mods - Please specify as It is simply unsatisfactory to assert that the planning does not align with other local authorities because they precisely and succinctly as are different Functional Market Areas and that co-operation is therefore not necessary. Such align may result possible how you would in housing needs being relocated to more suitable locations. modify this policy to improve A more detailed appraisal of brownfield land opportunities should be undertaken. Some brownfield opportunities its alignment to this test of have been ignored or missed including the Chesham Masterplan by CIC Chesham Renaissance. Green Belt soundness. boundary reviews should only be considered after all other reasonable alternatives have been exhausted. In the face of NPPF guidance and a more thorough appraisal of Green Belt sites being considered, It may then be necessary to conclude that it is not possible to identify poor performing Green Belt sites that can accommodate all the OAN for housing. Consequently it may be necessary to accept that a lower housing provision figure is appropriate. Policy 1 - If you do not The land is also potentially an Asset Of Community Value and upon confirmation of this designation it would believe this policy to be afford a community group the right to bid for the land. The community group (Brown Not Green) have stated justified please explain why their intention is to preserve the land given that many hundreds of local people have habitually used the fields at Lye Green as of right for various informal outdoor recreational purposes. These uses themselves may mean that many local individuals may have acquired easements over and across the land through prescription (20 years uninterrupted use) not least of whom would be the many private residences bordering the fields that have rear garden gates onto the fields at Lye Green. The fields are used regularly for walking, running and dog walking so it is likely these easesments will be common. These easements and prescriptive rights may render the land very difficult to develop and make it undeliverable in planning terms. This land also provides an important habitat for wildlife that will be threatened by development of this land. It is perverse that the Local Authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Plan is unsound. The foregoing also points to flawed methodology of Green Belt site selection used by the Local Authority, which is neither effective, justified nor consistent with national policy and as such is unsound. Specifically,
8790 the selection of the land NE of Chesham at Lye Green (policy SP BP2) for removal from Green Belt designation is inconsistent with National Planning Policy Framework (NPPF). Paragraph 136 of the latest NPPF asserts that Green Belt boundaries should only be modified in ªexceptional circumstancesº. The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances. The Council engaged third party consultants to undertake the Part 1 Green Belt assessment and they identified numerous sites for ªfurther considerationº where exceptional circumstances ªmightº exist but expressly recommended further review of their assessment of each site against the 5 purposes of land being in Green Belt of all these sites. Unlike the neighbouring Local Authorities, the Part 2 Green Belt assessment was not undertaken by third party consultants but by the Local Authority itself who notably then did not undertake all the recommended reviews of each site including the land NE of Chesham at Lye Green (SP BP 2). Accordingly, this oversight in the Part 2 Green Belt assessment placed premature focus and fixation on releasing land at Lye Green NE of Chesham from Green Belt designation. The subsequent identification of the Chesham site for release is therefore unjustified. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not The proposals to release Green Belt land to meet housing targets (Generally, Spatial Policy SP SP1 & believe this policy to be specifically Policy SP BP2 at Lye Green NE of Chesham) are not justified from the evidence submitted by effective please explain why. the Councils. The Councils have stated that release of some Green Belt is necessary as part of an overall three part strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. Have all the brownfield land opportunities have been identified and should the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites and in particular the Green Belt site NE of Chesham at Lye Green. The development of such Green Belt sites involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient and unfunded. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham cannot accommodate any significant highways improvements anyway due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion, with further worsening air quality. Air pollution is a particular concern in Chesham due to the already poor air quality along Bekhamstead Road where there is a designated Air Quality Management Area that already is recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will generate more traffic will make the air quality even worse and insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this is not sustainable nor justified nor is it in accordance with government policy. The Green Belt site NE of Chesham (SP BP 2) is not a sustainable location. It is over 2Km away from the train station and slightly further still from the town centre but anyone who cares to walk or cycle this distance also has to negotiate steep hills. Such an unsustainable location cannot be made sustainable merely by upgrading a couple of public footpaths within the site into bridleways to facilitate cycling. Neither does adding a bus stop address the geography or topography of the area especially if the promised enhanced bus service (which is already infrequent) either does not materialise or, as is most likely, is not financially viable. Further doubt is cast upon the ªsoundnessº of this Plan by virtue of there being conflicting policies within it. The Council seem to think that the Green Belt site NE of Chesham is sustainable and provides easy access to public transport including the tube station yet the same Plan promotes a considerable increase in retail development in the town (local draft plan policy SP EP3), part of which would be built on the very car park that serves the Chesham tube station. This is inconsistent and unsound. For this Plan to sound it must also be effective. Unfortunately, further review of the proposal to remove land NE of Chesham at Lye Green from Green Belt designation is not effective as there are serious questions about the deliverability of this land. The main landowner is a farmer who has asserted publicly and in a letter to the editor of Your Chesham, that he is not prepared to release all of the land in his ownership for development. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not These comments apply equally to proposals effecting the villages in the Green Belt ± policies SP PP1 & DM believe this policy in PP1) consistent with the National The primary aim of Green Belt land (as recited in NPPF 133) is to prevent urban sprawl and to preserve the Planning Policy Framework openness of the area. The Lye Green site (SP BP2) self-evidently performs this function well and has done Feb 2019 please explain why so for decades. Another aim of Green Belt land stated in NPPF paragraph 134, is to prevent neighbouring towns and settlements from merging into one another.The Green Belt land NE of Chesham performs exceptionally well in maintaining a distinct separate between settlements of Chesham & Lye Green as well as helping to maintain separate identities of other nearby communities at Orchard Leigh, Botley, Whelpley Hill, Ashley Green. It is
8791 perverse and inconsistent with national guidance to allocate this land for removal from Green Belt in light of these facts especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if earmarked for development. A further aim of Green Belt designation stated in the NPPF at paragraph 134 (e) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. By allocating Green Belt land NE of Chesham for development, undermines this aim within Chesham. A community lead not for profit organisation called Chesham Renaissance CIC has been striving to create Chesham Masterplan that would not only provide many genuinely affordable homes in more sustainable locations nearer the town centre, but which would also regenerate some of the more deprived wards within Chesham. The Local Authority's proposals (policy SP EP3) are inconsistent with this local initiative and are therefore also inconsistent with national guidance and are consequently unsound. The Council have asserted that Government planning policy requires local councils to review Green Belt boundaries when considering how to accommodate the development needed in their areas. Just because the Council may be required to look, does not mean the Council should review Green Belt boundaries which as previously stated should only be modified in ªexceptional circumstancesº. National Planning Policy Framework (NPPF) as revised only last year, states in paragraph11 (b) I, directs ªplan makersº to create policies that are required in Local Plans for housing and other uses unless Framework policies (expressly including Green Belt) ªprovides a strong reason for restricting the overall scale type or distribution of development in the plan areaº Accordingly, I submit that given all of the above the land being proposed for release from Green Belt designation around Chesham is unjustified and contrary to national guidance. I am supportive of the Brown Not Green organisation's initiative to have the land listed as an Asset of Community Value and I feel they speak for me in respect of their objections to the draft Local Plan. Accordingly, I request that any representations made by them at any future examination in public regarding the soundness of this Local Plan be considered as an extension of my own comments herein. I feel the land NE of Chesham is an unsustainable location for development, that has been habitually used by the community for improved health & wellbeing for decades and the land performs well against Green Belt aims and objectives. Exceptional circumstances for reviewing Green Belt boundaries at this location, either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by Govt Policy and therefore the plan is unsound. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5493623 Please attach any supporting evidence
Person ID 1223726 Full Name David Zerny ID 5647 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you
8792 consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible.
8793 Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I wish to object specifically to two sites that are identified for Policy SP BP2- Chesham, and believe this policy in Policy SP BP6- Little Chalfont. consistent with the National Planning Policy Framework Both are valuable areas of Green Belt, and the NPPF states: Feb 2019 please explain why ª133. The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence. 134. Green Belt serves five purposes: a) to check the unrestricted sprawl of large built-up areas; b) to prevent neighbouring towns merging into one another; c) to assist in safeguarding the countryside from encroachment; d) to preserve the setting and special character of historic towns; and e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban landº. And ªProposals affecting the Green Belt 143. Inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances. 144. When considering any planning application, local planning authorities should ensure that substantial weight is given to any harm to the Green Belt. `Very special circumstances' will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm resulting from the proposal, is clearly outweighed by other considerationsº. On this basis, I believe that building here is inappropriate and a breach of the NPPF. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1223652
8794 Full Name Eleanor Freedman ID 5670 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness?
8795 Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The information I have read regarding this proposed plan is nonsensical, deficient and even contradicts itself. not believe this policy to be I have picked out a few examples, your text is in black, my thoughts are in blue. And also expands on the positively prepared please above. explain why It states: *The Business Plan's purpose is: to enhance Chiltern and South Bucks Districts as a desirable place to live, work, visit and enjoy. To achieve this, the Councils will strive to conserve the environment whilst also promoting sustainable economic growth: Apart from the obvious and embarrassing text error ± fills you with no confidence when the writer cannot even use the checks built into MS Word. It is mutually inconsistent trying to conserve the environment - when you are tarmacking over it! I'm sure the ramblers love to come and wander around housing estates¼ well worth a visit. Parliament has declared a Climate Emergency and has been advised that the 2 trees per garden that could be planted by current households = 45 million trees, is only 3% of what is needed by 2050 (see https://www.bbc.co.uk/news/uk-england-49163306?) So how building on green-belt assists with this I fail to understand. It is not building a sustainable planet. I understand there are targets but it is also our responsibility to do our bit ± perhaps go further and lead by example. Not much point striving to achieve ªsustainable economic growthº if the world is dead. I like to base my thoughts and actions on evidence, hard facts and science not just wishes, hopes and dreams and ignorance. Those who deny climate change are merely sticking their fingers in their ears and going ªla la laº. The globally rare chalk streams, which are already suffering, depend on the rainfall seeping into the earth so unless you have mechanisms (which you have been keeping quiet on) to ensure that the rain can replenish the water table.You are committing ecological destruction on a smaller scale but equivalent to cutting down the rain forest. Well done - something to tell the grandchildren. Oh but they won't be around because you killed the planet.
8796 Another apparently irrelevant fact that the people moving into the area will be working in London, so not around here. How are you going to improve the rail links? Seeing as the Mayor of London and TfL will not even put money towards improvements in Watford! Even the 6.30am train from Chesham is already busy with often all seats taken leaving Chalfont & Latimer. It takes 21mins for a train to leave Chalfont turn at Chesham and return. If it has not been slowed for any reason. So it is impractical to increase the numbers of trains per hour. The only alternative is to put in a second line. I can foresee many financial and logistical problems. So not feasible. *Play an active role in the Oxford to Cambridge Arc Growth Board This is not realistic, it is ridiculous. Having worked recently in Cambridge and Oxford it is obvious that we are not even on their radar we are too distant and the public transport is not good enough.You need to go into London and come out again. And the Government wants to reduce car ownership so that it can meet its environmental targets.You are promoting the opposite, so you will then have to put in later fixes which will be more expensive. So contradictions and inaccuracies abound, inconvenient truths ignored. 3.4.2 Achieve sustainable development ± to meet the local needs of today without compromising our ability to meet the needs of tomorrow, supporting our communities to be resilient and adaptive to climate change and secure enduring social, economic and environmental benefits. Nice words but this obviously completely contradicts your proposal. Please don't think you can lie and we won't notice or care ± we will and we do. 3.4.5 Continue to protect and enhance our treasured local built and undeveloped environments contributing to local identity, community wellbeing and biodiversity. Importantly, the Chilterns Area of Outstanding Natural Beauty, This is mind blowingly not what you are doing! You've just put a housing estate over it! 3.5.4 To improve and support resilient and adaptive settlements to combat climate change, with new developments contributing positively towards sustainable development and promoting positive behavioural changes. Behavioural changes I guess you are referring to not driving.The residents will have to drive to get anywhere. The site is 2.5km outside of the town and it is a hilly area, rendering walking unfeasible. I used to use the buses but they are impractical, unreliable and fail to go where needed, when they are needed. For example try getting a bus to Berkhamsted train station so that you can catch the 7.30 train. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not Ref the badly thought out plan to build on the green belt. believe this policy in Yes I am upset and angry that you are destroying the Green Belt. I have grown up in the area and watched consistent with the National infilling and the nature of the area change unrecognisably. People come into the area because it is beautiful Planning Policy Framework ± then destroy a patch of it, by cutting down trees or erecting buildings ± however they can make money out Feb 2019 please explain why of it and then move on. So excuse my fed up attitude - you are supposed to be serving the area and you consistently fail to preserve and protect it. This plan is obviously the easy option for whoever is in charge. It is not beneficial to the local area in anyway shape or form. It would not be so disappointing if it was effective and justified but it is not and alternatives have been ignored. And worse it is not in accord with National Guidance. We live in an Area of Outstanding Natural Beauty and the name says it all. It will no longer be an Area of Outstanding Natural Beauty if we continue to build all over it.The government has given us a quota of houses to build - that does not mean that we should not push back against these, rather than blindly following orders. In fact we are advised to provide for housing unless Green Belt policies provide a strong reason not to.There are strong reasons not to.You are going against government policy. We do not have the ªexceptional circumstancesº to justify the redefinement of Green Belt boundaries.Y our policies are not in line with NPPF and are in opposition to the Courts of Law. It sets a bad example when the authorities break the law.You
8797 might say it sets a precedence.You will lose the moral high ground and be unable come down on others who do breach planning law. By continuing down this path Chesham will follow in Aylesbury and Hemel's footsteps linking the villages and become one large town. If that is the aim, some transparency please. I do travel for work and was stunned at the amount of building space available to other areas who are also only an hour from London ie. Swindon, Milton Keynes these places also have the infrastructure to cope with more people. We do not. Schools and doctor's are already beyond capacity. Air pollution caused by excess traffic exceeding limits. It seems you can't manage with what it already here so expanding is only going to make you look even more incompetent. Milton Keynes jealously guard their green spaces perhaps we could take a leaf out of their book? No reasonable alternative has apparently been considered. It is not a robust plan that will solve the issue of the whole town but exacerbate them, the plan is not justified and not effective, which I will expand upon further on. It is not consistent ± more of this in a moment. There are so many deficiencies in the plan ± it is not fit for purpose. If I presented a plan like this at work I would be unemployed within the week.The decision making is opaque and undemocratic, this has been shoved at us and will most likely be bulldozed into action. This will not serve the locals well but I'm sure that the folks coming out of London and will continue to work in London will love it. At least the high levels of air pollution will be the same so they should feel at home. What are your intentions to reduce this? I failed to find this information! Are these Londoners the people you serve, the community you support? I also must have missed the prior consultation on ªGreen Belt Villages Policyº ± NO it didn't happen. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1213372 Full Name Mr Peter Keane ID 5675 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-03-14 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally
8798 compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be
8799 as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not The proposals to release Green Belt land to meet housing targets (Generally, Spatial Policy SP SP1 & believe this policy to be specifically Policy SP BP2 at Lye Green NE of Chesham) are not justified from the evidence submitted by justified please explain why the Councils. The Green Belt site NE of Chesham (SP BP 2) is not a sustainable location. It is 2.4K away from the tube station and further still from the town centre but anyone walking or cycling this distance also has to negotiate a steep hill that rises some 55 metres in 200metres, with very narrow footpaths and road narrowing on the hill. Such an unsustainable location cannot be made sustainable merely by upgrading a couple of public footpaths within the site into bridleways to facilitate cycling.The Plan policies also admit that the site transport will not be fully sustainable, and no full mitigation can be realised. The development of such Green Belt sites involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient and unfunded. In Chesham, the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham cannot accommodate any significant highways improvements anyway due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion, with further worsening air quality. Air pollution is a particular concern in Chesham due to the already poor air quality along Bekhampstead Road where there is a designated Air Quality Management Area (since 2007) that already is recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will generate more traffic will make the air quality even worse and insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable nor justified nor is it in accordance with Government policy. The supporting Sustainability Appraisal (SA), states there are no Air Quality issues near the site, but this is factually incorrect as the Chesham AQMA is just 1Km from the southern boundary of the site Water Pollution. The site has the potential to pollute the chalk streams that provide Chesham©s water, as noted in the SA, the policy on mitigation, is inadequate. There is also an inadequate policy to mitigate the effects on the Chesham Water Treatment works, which is struggling to meet current demand for Chesham. It is admitted in the SA that the Chalk streams in the Chilterns, and in particular Chesham are in Crisis, through climate change and over extraction by Affinity Water, but the plan provides no mitigation strategies. The site also has flooding issues, and again the plan provide no mitigation strategies. Therefore the plan is unsound with these major issues still outstanding. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I believe that the draft Local Plan is NOT legally compliant because it has not demonstrated sufficient regard believe this policy in to the National Planning Policy Framework, and guidance issued by the Secretary of State. consistent with the National The National Planning Policy Framework (NPPF) has guidance for local authorities that they MUST Planning Policy Framework demonstrate they have exhausted all options BEFORE considering revision of Green Belt boundaries. This Feb 2019 please explain why Local Plan is seeking substantial modifications to Green Belt boundaries including the removal of Green Belt designation of 13 areas within the Districts as well as modifying the Green Belt status of many local villages. I contend this draft Local Plan has not demonstrated that all other options have been fully explored and as such this Plan is not justified, sound or in accordance with National Policy and accordingly is not legally compliant. It is not sufficient for this plan to simply claim that the combination of housing need and the presence of significant areas of development constraint policy collectively represent ªexceptional circumstancesº (as required in the NPPF) to justify modification of Green Belt boundaries especially given the NPPF states that one of the key features of Green Belts are their permanence.
8800 Contained in the Sustainability Appraisal supporting this Draft Local Plan, that the Plan area is forecast to see carbon emission increase by 21% in the Plan Period. Accordingly, the Plan is inconsistent with Government Policy, which is to aim for net zero carbon emissions, and therefore not legally compliant. There is also a significant infrastructure funding gap acknowledged within the Community Infrastructure Levy evidence that supports this Local Plan, of between £179m & £231m. Given this infrastructure is vital to ensure that development is sustainable (as also required by the NPPF) this further demonstrates the Plan is both unsound and not legally compliant. It is contradictory that the Local Authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Plan is unsound. Given the ACV designation, this highlights the poor methodology of Green Belt site selection originally used by the Local Authority, which is neither effective, justified nor consistent with national policy and as such is unsound. Specifically, the selection of the land NE of Chesham at Lye Green (policy SP BP2) for removal from Green Belt designation is inconsistent with National Planning Policy Framework (NPPF). Paragraph 136 of the latest NPPF asserts that Green Belt boundaries should only be modified in ªexceptional circumstancesº. The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances. The Council has struggled to demonstrate this via the previous reviews, only the ©exceptional circumstances may exist©. The current version of the Plan does not demonstrate this clearly either. The identification of the Chesham site for release is therefore unjustified. These comments apply equally to proposals effecting the villages in the Green Belt ± policies SP PP1 & DM PP1) The primary aim of Green Belt land (as recited in NPPF 133) is to prevent urban sprawl and to preserve the openness of the area. The Lye Green site (SP BP2) self-evidently performs this function well and has done so for decades. Another aim of Green Belt land stated in NPPF paragraph 134, is to prevent neighbouring towns and settlements from merging into one another.The Green Belt land NE of Chesham performs exceptionally well in maintaining a distinct separate between settlements of Chesham & Lye Green as well as helping to maintain separate identities of other nearby communities at Orchard Leigh, Botley, Whelpley Hill, Ashley Green. It is inconsistent with national guidance to allocate this land for removal from the Green Belt in light of these facts. Policy 3a - Please specify as The Plan needs to be modified by; precisely and succinctly as Co-operating with other nearby authorities. Not just Aylesbury. It is simply unsatisfactory to assert this cannot possible how you would be done because they are different Functional Market Areas and that co-operation is not necessary therefore. modify this policy to improve its alignment to this test of Exploring such wider co-operation may result in further housing needs being taken elsewhere. soundness. The local council, and local planners, have not performed a detailed appraisal of brownfield land opportunities, and the Plan must be reviewed to include these. As an example; in the case of POLICY SP BP 2, the site to the NE of Chesham, the planners and Council Planning Committee have completely ignored and refused to consider the Chesham Masterplan, developed by Chesham Renaissance, as a viable alternative. This plan is a much more comprehensive and closer to a deliverable state than the Local Plan, and has many benefits for Chesham.). As per NPPF guidance, Green Belt boundary reviews should only be considered AFTER all other reasonable alternatives have been exhausted. If it is not possible to identify poor performing Green Belt sites that can accommodate all the OAN for housing, then it may be necessary to accept that a lower housing provision figure is appropriate. I would propose that. All other options are re-assessed, including increased density of development of brownfield land and in respect of the land NE of Chesham (policy SP BP 2), I support the review and inclusion of the plan and the policies encompassed by the Chesham Masterplan, developed by the CIC, Chesham Renaissance. Green Belt land should only be considered when all other options are exhausted and in any event the proposals for developing land NE of Chesham (policy SP BP 2) should be removed as it is an unsustainable location the development of which will cause harm to the wider town including loss of an asset that improves the well-being for the community. Policy-level file upload - Please attach any supporting evidence
Person ID 1215395 Full Name Mrs Anusha Gilley ID 5685 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2017-04-12 Received:
8801 Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance
8802 with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do 1. The plan itself is not positively prepared. The planned housing / site selection with respect to Lye Green not believe this policy to be is too far from practical public transport, and at the top of a steep hill. Any future resident would be forced to positively prepared please using a car (promoting it©s usage in fact) to get to the nearest train station (Chesham is a single track line explain why heading East - and is already full to capacity from 7am in the morning during the week, including the station car park). Supporting infrastructure in a broader sense is therefore not available. 2. The plan itself will destroy the hamlet of Lye Green and encourage sprawl of the town in an insensitive manner. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not The plan is not justified, there has been very little attempt to explore all the potential brownfield sites. The believe this policy to be Chesham Renaissance (now named The Chesham Society) have made a very thoughtful proposal to justified please explain why rejuvenating the town and meeting the local housing needs - but it does not appear to have been given the consideration it deserves Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not . The plan is not effective. Time and time again, our local councillors seem intent on approving A Local Plan, believe this policy to be versus the Right plan, and a more strategic vision for Chesham. effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not It also does not appear to be consistent with national policy - there is no exceptional circumstance for releasing believe this policy in green belt. consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve
8803 its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1223550 Full Name Mr Naresh Mistry ID 5688 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible.
8804 Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not The proposals to release Green Belt land to meet housing targets (Generally, Spatial Policy SP SP1 & believe this policy to be specifically Policy SP BP2 at Lye Green NE of Chesham) are not justified from the evidence submitted by justified please explain why the Councils. The Councils have stated that release of some Green Belt is necessary as part of an overall three part strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. I question the soundness of such a general policy and whether all the brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites and in particular the Green Belt site NE of Chesham at Lye Green.
8805 The development of such Green Belt sites involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient and unfunded. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham cannot accommodate any significant highways improvements anyway due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion, with further worsening air quality. Air pollution is a particular concern in Chesham due to the already poor air quality along Berkhampstead Road where there is a designated Air Quality Management Area that already is recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will generate more traffic will make the air quality even worse and insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable nor justified nor is it in accordance with Government policy. The Green Belt site NE of Chesham (SP BP 2) is not a sustainable location. It is over 2Km away from the train station and slightly further still from the town centre but anyone who cares to walk or cycle this distance also has to negotiate a steep hill too. Such an unsustainable location cannot be made sustainable merely by upgrading a couple of public footpaths within the site into bridleways to facilitate cycling. Neither does adding a bus stop address the geography or topography of the area especially if the promised enhanced bus service (which is already infrequent) either does not materialise or if it subsequently fails to be maintained after a few years. For this Plan to sound it must also be effective. Unfortunately, further review of the proposal to remove land NE of Chesham at Lye Green from Green Belt designation is not effective as there are serious questions about the deliverability of this land. The main landowner is a farmer who has asserted publicly and in a letter to the editor of Your Chesham that he is not prepared to release all of the land in his ownership for development. The land is also potentially an Asset Of Community Value and upon confirmation of this designation it would afford a community group the right to bid for the land. The community group (Brown Not Green) have stated their intention is to preserve the land given that many hundreds of local people have habitually used the fields at Lye Green as of right for various informal outdoor recreational purposes. These uses themselves may mean that many local individuals may have acquired easements over and across the land through prescription (20 years uninterrupted use) not least of whom would be the many private residences bordering the fields that have rear garden gates onto the fields at Lye Green. These easements and prescriptive rights may render the land very difficult to develop and make i undeliverable in planning terms. This land also provides an important habitat for wildlife that will be threatened by development of this land. It is perverse that the Local Authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Plan is unsound. The foregoing also points to flawed methodology of Green Belt site selection used by the Local Authority, which is neither effective, justified nor consistent with national policy and as such is unsound. Specifically, the selection of the land NE of Chesham at Lye Green (policy SP BP2) for removal from Green Belt designation is inconsistent with National Planning Policy Framework (NPPF). Paragraph 136 of the latest NPPF asserts that Green Belt boundaries should only be modified in ªexceptional circumstancesº. The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances. The Council engaged third party consultants to undertake the Part 1 Green Belt assessment and they identified numerous sites for ªfurther considerationº where exceptional circumstances ªmightº exist but expressly recommended further review of their assessment of each site against the 5 purposes of land being in Green Belt of all these sites. Unlike the neighbouring Local Authorities, the Part 2 Green Belt assessment was not undertaken by third party consultants but by the Local Authority itself who notably then did not undertake all the recommended reviews of each site including the land NE of Chesham at Lye Green (SP BP 2). Accordingly, this oversight in the Part 2 Green Belt assessment placed premature focus and fixation on releasing land at Lye Green NE of Chesham from Green Belt designation. The subsequent identification of the Chesham site for release is therefore unjustified. These comments apply equally to proposals affecting the villages in the Green Belt ± policies SP PP1 & DM PP1) The primary aim of Green Belt land (as recited in NPPF 133) is to prevent urban sprawl and to preserve the openness of the area. The Lye Green site (SP BP2) self-evidently performs this function well and has done so for decades. Another aim of Green Belt land stated in NPPF paragraph 134, is to prevent neighbouring towns and settlements from merging into one another.The Green Belt land NE of Chesham performs exceptionally well in maintaining a distinct separate between settlements of Chesham & Lye Green as well as helping to maintain separate identities of other nearby communities at Orchard Leigh, Botley, Whelpley Hill, Ashley Green. It is perverse and inconsistent with national guidance to allocate this land for removal from Green Belt in light of these facts especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if earmarked for development. The Council have asserted that Government planning policy requires local councils to review Green Belt boundaries when considering how to accommodate the development needed in their areas. Just because the Council may be required to look, does not mean the Council should review Green Belt boundaries which as previously stated should only be modified in ªexceptional circumstancesº. National Planning Policy Framework (NPPF) as revised only last year, states in paragraph11 (b) I, directs ªplan makersº to create policies that are required in Local Plans for housing and other uses unless Framework policies (expressly including Green Belt) ªprovides a strong reason for restricting the overall scale type or distribution of development in the plan areaº Accordingly, I submit that given all of the above the land being proposed for release from Green Belt designation around Chesham is unjustified and contrary to national guidance.
8806 I am supportive of the Brown Not Green organisation's initiative to have the land listed as an Asset of Community Value and I feel they speak for me in respect of their objections to the draft Local Plan. Accordingly, I request that any representations made by them at any future examination in public regarding the soundness of this Local Plan be considered as an extension of my own comments herein. I feel the land NE of Chesham is an unsustainable location for development, that has been habitually used by the community for improved health & wellbeing for decades and the land performs well against Green Belt aims and objectives. Exceptional circumstances for reviewing Green Belt boundaries at this location, either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by Government Policy and therefore the plan is unsound. Policy 2a - Please specify as I refer to the comments previously submitted but in summary would advocate that; precisely and succinctly as All other options are fully explored including increased density of development of brownfield land and the possible how you would policies emerging from Chesham Masterplan. modify this policy to improve its alignment to this test of Green Belt land should only be considered when all other options are exhausted and in any event the soundness. proposals for developing land NE of Chesham (policy SP BP 2) should be removed as it is an unsustainable location the development of which will cause harm to the wider town including loss of an asset that improves the well-being for the community. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I believe the draft Local Plan is NOT legally compliant because it has not demonstrated sufficient regard to believe this policy in the National Policy and guidance issued by the Secretary of State. consistent with the National The National Planning Policy Framework (NPPF) together with other guidance issued by the Government Planning Policy Framework is also supported by recent ministerial statements that have made it clear that Local Authorities MUST Feb 2019 please explain why demonstrate they have exhausted all options BEFORE considering revision of Green Belt boundaries. This Local Plan is seeking substantial modifications to Green Belt boundaries including the removal of Green Belt designation of 13 areas within the Districts as well as modifying the Green Belt status of many local villages. I contend this draft Local Plan has not demonstrated that all other options have been fully explored and as such this Plan is not justified, sound or in accordance with National Policy and accordingly is not legally compliant. Furthermore that Paragraph 11 b) of the NPPF (and the footnotes thereto) require Plan Makers to provide for objectively assessed needs for housing and other uses UNLESS the application of Framework policies (including Green Belt) provide a strong reason for restricting the overall scale, type or distribution of development in the plan area Chiltern District & South Bucks are significantly constrained by development policies such as Green Belt & Areas of Outstanding Natural Beauty (AONB). The Local Plan is therefore inconsistent with National Guidance and as such it is not legally compliant for the Local Authority to claim that housing needs justify a review of these same Green Belt boundaries. It is perverse to claim that the combination of housing need and the presence of significant areas of development constraint policy collectively represent ªexceptional circumstancesº (as required in the NPPF) to justify modification of Green Belt boundaries especially given the NPPF states that one of the key features of Green Belts are their permanence. The Government has also recently confirmed its aim for the UK to have net zero carbon emissions by 2050 and it is noted within the Sustainability Appraisal supporting this Draft Local Plan, that the Plan area is forecast to see carbon emission increase by 21% in the Plan Period. Accordingly, the Plan is inconsistent with Government Policy and therefore not legally compliant. There is also a significant infrastructure funding gap acknowledged within the Community Infrastructure Levy evidence that supports this Local Plan, of between £179m & £231m. Given this infrastructure is vital to ensure that development is sustainable (as also required by the NPPF) this further demonstrates the Plan is both unsound and not legally compliant. Policy 3a - Please specify as The Plan needs to be modified by; precisely and succinctly as Co-operating with other nearby authorities. Not just Aylesbury. It is simply unsatisfactory to assert this cannot possible how you would be done because they are different Functional Market Areas and that co-operation is not necessary therefore. modify this policy to improve its alignment to this test of Exploring such wider co-operation may result in further housing needs being taken elsewhere. soundness. A more detailed appraisal of brownfield land opportunities MUST be undertaken. Some brownfield opportunities have been ignored or missed. Closer scrutiny of alternative options for housing delivery should be explored (such as Chesham Masterplan by CIC Chesham Renaissance). Green Belt boundary reviews should only be considered AFTER all other reasonable alternatives have been exhausted. In the face of NPPF guidance and a more thorough appraisal of Green Belt sites being considered, it may then be necessary to conclude that it is not possible to identify poor performing Green Belt sites that can accommodate all the OAN for housing. Consequently it may be necessary to accept that a lower housing provision figure is appropriate.
8807 Policy-level file upload - 5512596 Please attach any supporting evidence
Person ID 1213063 Full Name Mrs Merrin Molesworth ID 5735 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-03-14 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications
8808 to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I dispute the high number of dwellings allocated for Chesham ± SP Bp2 ± Chesham 500 not believe this policy to be Carbon footprint positively prepared please explain why The Sustainability Appraisal supporting this Draft Local Plan, shows the Plan area is forecast to see carbon emission increase by 21% in the Plan Period. This makes it inconsistent with Government Policy for the UK to have net zero carbon emissions by 2050, and therefore not legally compliant. The carbon footprint will go up to 21% while the population is only increasing by some 11%. Infrastructure How can it be called a LP if it doesn't consider infrastructure? A significant infrastructure funding gap is acknowledged within the Community Infrastructure Levy evidence that supports this Local Plan, of between £179m and £231m. Infrastructure is vital to ensure that development is sustainable (as also required by the NPPF) so this further demonstrates the Plan is both unsound and not legally compliant The Lye Green Green Belt site at the top of a hill north east of Chesham (SP BP 2) is not a sustainable location for housing. It is over 2km away from the train station and still further from the town centre. Walkers or cyclists have to negotiate the steep hill on busy roads. An unsustainable location cannot be made sustainable by merely upgrading a couple of public footpaths within the site into bridleways to facilitate cycling. Neither would adding a bus stop address the geography or topography of the area. The promised enhanced bus service (which is already infrequent) probably will not materialise. Sustainability All new development should provide facilities for conserving rainwater eg, water butts, grey water systems, lower flow taps etc. New construction should provide a renewable energy contribution eg solar generation and/or heat pumps to provide at least 30% of power consumption would be an improvement. The Plan needs to ensure that future development does not have a detrimental impact on important chalk streams. It does not adequately take into consideration the likely impacts of climate change, specifically regarding the increase in flooding events and also the impact on available water resources in future. These
8809 factors will limit both the level of development and its location. The chalk aquifer is over-abstracted and the situation requires a moratorium on development until solutions are found. The plan should also refer to the Chilterns Chalk Streams Project (a partnership project based at the Chilterns Conservation Board and including the water companies, Environment Agency, Wildlife Trusts, Chiltern Society and Chiltern District) as parties to consult over whether a planning proposal is acceptable. PP Mods - Please specify as In summary I advocate that; precisely and succinctly as All other options are fully explored or accommodation the housing allocation, including increased density of possible how you would development of brownfield land and the policies demonstrated by CRCIC/ Chesham Masterplan. modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not Green Belt depredation believe this policy to be Proposals to release Green Belt land to meet housing targets (generally, Spatial Policy SP SP1 & specifically justified please explain why Policy SP BP2 at Lye Green NE of Chesham) are not justified from the evidence submitted. The Councils claim it needs to release some Green Belt as part of an overall three part strategy involving [1] focus on built-up areas to build dwellings on previously developed land, [2] an exported proportion of housing need to go to the Aylesbury District and [3] through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. I question whether all the brownfield land opportunities have been identified. Housing need does not create an exceptional circumstance for altering the Greenbelt boundary. The Council should be looking at higher densities of development on sites which are closer to the town centre ie more sustainable locations than Green Belt sites. I am dismayed to find no reference to CRCIC in the Local Plan documents. Housing numbers could be accommodated in the town centre, as demonstrated by the community lead not-for-profit organisation CRCIC (Chesham Renaissance Community Interest Company also known as Chesham Masterplan https://cheshammasterplan.org/ ) The entire housing allocation for Chesham can be accommodated in the town centre with good compact design and such measures as placing parking beneath the buildings. A large proportion will be affordable housing and infrastructure will be incorporated and mandatory. (I declare an interest as a member of the Chesham Society which initiated the idea). I wonder if there is a conflict of interest with CD&SBD's own newly formed Consilio Property Limited, incorporated after CRCIC on 15 September 2017, registered office address: South Bucks District Council Capswood, Oxford Road, Denham, United Kingdom, UB9 4LH Their website https://www.consilioproperty.co.uk . Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not The draft Local Plan is not legally compliant because there are specific areas where the NPPF (February believe this policy in 2019) has not been complied with. consistent with the National Green Belt Planning Policy Framework Feb 2019 please explain why The NPPF together with other guidance issued by the Government, and also recent ministerial statements, makes clear that Local Authorities must demonstrate they have exhausted all options before any revision of Green Belt boundaries. This Local Plan seeks substantial modifications to Green Belt boundaries including the removal of Green Belt designation from 13 areas. The Plan has not demonstrated that all other options have been fully explored and therefore is not sound. Housing need does not create an exceptional circumstance for altering the Greenbelt boundary. It is high time the public (and planners) realised that housing does not necessarily require a large footprint - housing can be flats or apartments ie built more densely, but must be well designed. Chiltern and South Bucks districts are significantly constrained by development policies such as Green Belt and Areas of Outstanding Natural Beauty (AONB). The Local Plan is therefore inconsistent with National Guidance and it is not legally compliant for the Local Authority to claim that housing needs justify a review of these same Green Belt boundaries. It cannot be claimed that the combination of housing need and the presence of significant areas of development constraint policies, collectively represent `exceptional circumstances' (as required in the NPPF) to justify modifying Green Belt boundaries. The NPPF states that one of the key features of Green Belts are their permanence. See the National Planning Policy Framework updated on 19 February 2019 para 136 `Once established, GB boundaries should only be altered where exceptional circumstances are fully evidenced and justified through the preparation or updating of plans. Strategic policies should establish the need for any
8810 changes to Green Belt boundaries having regard to their intended permanence in the long term so they can endure beyond the plan period. Where a need for changes to Green Belt boundaries has been established through strategic policies, detailed amendments to those boundaries may be made through non-strategic policies, including neighbourhood plans.' Policy SP LP1 I dispute the high number of dwellings allocated for Chesham ± SP Bp2 ± Chesham 500 Carbon footprint The Sustainability Appraisal supporting this Draft Local Plan, shows the Plan area is forecast to see carbon emission increase by 21% in the Plan Period. This makes it inconsistent with Government Policy for the UK to have net zero carbon emissions by 2050, and therefore not legally compliant. The carbon footprint will go up to 21% while the population is only increasing by some 11%. Infrastructure How can it be called a LP if it doesn't consider infrastructure? A significant infrastructure funding gap is acknowledged within the Community Infrastructure Levy evidence that supports this Local Plan, of between £179m and £231m. Infrastructure is vital to ensure that development is sustainable (as also required by the NPPF) so this further demonstrates the Plan is both unsound and not legally compliant. Green Belt boundaries should only be modified in `exceptional circumstances' and the courts have held that unmet local housing need is not exceptional circumstances. The Council engaged third party consultants to undertake the Part 1 Green Belt assessment and they identified numerous sites for `further consideration' where exceptional circumstances `might' exist but expressly recommended further review of their assessment of each site against the purposes of land being in Green Belt. Unlike the neighbouring Local Authorities, the Part 2 Green Belt assessment was not undertaken by third party consultants but by the Local Authority itself who notably then did not undertake all the recommended reviews of each site including the land NE of Chesham at Lye Green (SP BP2). Accordingly, this oversight in the Part 2 Green Belt assessment placed premature focus and fixation on releasing land at Lye Green NE of Chesham from Green Belt designation. The subsequent identification of the Chesham site for release is therefore unjustified. Green Belt land (as declaimed in NPPF 133) should prevent urban sprawl and preserve the openness of the area. The Lye Green site (SP BP2) performs this function well and has done so for decades. It also prevents neighbouring towns and settlements from merging into one another, NPPF paragraph 134. The Green Belt land NE of Chesham performs exceptionally well in maintaining a distinct separate between settlements of Chesham and Lye Green as well as helping to maintain separate identities of other nearby communities at Orchard Leigh, Botley, Whelpley Hill, Ashley Green. It is perverse and inconsistent with national guidance to allocate this land for removal from Green Belt in light of these facts especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if earmarked for development. Allocating Green Belt land NE of Chesham for development, undermines the further aim of Green Belt designation stated in the NPPF at paragraph 134 (e) to assist in urban regeneration by encouraging the recycling of derelict and other urban land. The community lead not-for-profit organisation called Chesham Renaissance CIC is working to create a Chesham Masterplan that would not only provide many genuinely affordable homes in more sustainable locations nearer the town centre, but which would also regenerate some of the more deprived wards within Chesham. The Local Authority's proposals (policy SP EP3) are inconsistent with this local initiative and are therefore also inconsistent with national guidance and are consequently unsound. Green Belt boundaries should only be modified in exceptional circumstances. National Planning Policy Framework (NPPF) as revised only last year, states in paragraph11 (b) I, directs `plan makers' to create policies that are required in Local Plans for housing and other uses unless Framework policies (expressly including Green Belt) `provides a strong reason for restricting the overall scale type or distribution of development in the plan area'. Given all of the above the land being proposed for release from Green Belt designation around Chesham is unjustified and contrary to national guidance. I value dark skies, tranquillity and remoteness. Not met Not consulted with neighbouring Dacorum. Much of the Local Plan area including Chesham, is classified as both AONB and Green Belt and should receive strong protection under the national policies in the National Planning Policy Framework (NPPF). It is essential that planning policies are considered across local authority boundaries to co-ordinate protection of this special area. Policy 3a - Please specify as The plan is unsound because it aims to meet the housing need (OAN) by proposing 5,200 homes within precisely and succinctly as areas to be removed from the Green Belt. This is an excessive land-take in such a highly sensitive location, possible how you would and justified wrongly on housing need. There is no evidence to demonstrate that exceptional circumstances modify this policy to improve exist for taking this much land out of the Green Belt and disrespecting the key Green Belt characteristics of its alignment to this test of openness and permanence. soundness. In the NPPF, section 11, there is provision for Councils to not fully meet their objectively assessed need (OAN) in instances where there is Green Belt and AONB in the locality. b) strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas5, unless: i. the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area6; or ii. any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole. Footnote 6 confirms that these clauses relate to Green Belt and AONB. Closer scrutiny of alternative options for housing delivery should be explored (such as the Chesham Masterplan by CIC Chesham Renaissance).
8811 Embark on cooperation with other nearby authorities including Dacorum and not just Aylesbury. Undertake a more detailed appraisal of brownfield land opportunities. Some brownfield opportunities have been ignored or missed. Policy-level file upload - 5511290 Please attach any supporting evidence
Person ID 1223714 Full Name Oliver Hannen ID 5816 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as
8812 precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The proposals to release Green Belt land to meet housing targets (Generally, Spatial Policy SP SP1 & not believe this policy to be specifically Policy SP BP2 at Lye Green NE of Chesham) are not justified from the evidence submitted by positively prepared please the Councils. explain why The Councils have stated that release of some Green Belt is necessary as part of an overall three part strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. I question the soundness of such a general policy and whether all the brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites and in particular the Green Belt site NE of Chesham at Lye Green. The development of such Green Belt sites involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient and unfunded. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. This is clear to see during rush hours! Chesham cannot accommodate any significant highways improvements anyway due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion, with further worsening air quality.
8813 Air pollution is a particular concern in Chesham due to the already poor air quality along Bekhampstead Road where there is a designated Air Quality Management Area that already is recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will generate more traffic will make the air quality even worse and insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable nor justified nor is it in accordance with Govt policy. The Green Belt site NE of Chesham (SP BP 2) is not a sustainable location. It is over 2Km away from the train station and slightly further still from the town centre and anyone who cares to walk or cycle this distance also has to negotiate a steep hill. Such an unsustainable location cannot be made sustainable merely by upgrading a couple of public footpaths within the site into bridleways to facilitate cycling. Neither does adding a bus stop address the geography or topography of the area especially if the promised enhanced bus service (which is already infrequent) either does not materialise or if it subsequently fails to be maintained after a few years. Further doubt is cast upon the ªsoundnessº of this Plan by virtue of there being conflicting policies within it. The Council seem to think that the Green Belt site NE of Chesham is sustainable and provides easy access to public transport including the tube station yet the same Plan promotes a considerable increase in retail development in the town (local draft plan policy SP EP3) , part of which would be built on the very car park that serves the Chesham tube station. This is inconsistent and unsound. The land is also potentially an Asset Of Community Value and upon confirmation of this designation it would afford a community group the right to bid for the land. The community group (Brown Not Green) have stated their intention is to preserve the land given that many hundreds of local people have habitually used the fields at Lye Green as of right for various informal outdoor recreational purposes. These uses themselves may mean that many local individuals may have acquired easements over and across the land through prescription (20 years uninterrupted use) not least of whom would be the many private residences bordering the fields that have rear garden gates onto the fields at Lye Green. These easements and prescriptive rights may render the land very difficult to develop and make i undeliverable in planning terms. This land also provides an important habitat for wildlife that will be threatened by development of this land. It is perverse that the Local Authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Plan is unsound. I feel the land NE of Chesham is an unsustainable location for development, that has been habitually used by the community for improved health & wellbeing for decades and the land performs well against Green Belt aims and objectives. Exceptional circumstances for reviewing Green Belt boundaries at this location, either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by Govt Policy and therefore the plan is unsound. PP Mods - Please specify as A further aim of Green Belt designation stated in the NPPF at paragraph 134 (e) is to assist in urban precisely and succinctly as regeneration by encouraging the recycling of derelict and other urban land. By allocating Green Belt land possible how you would NE of Chesham for development, undermines this aim within Chesham. A community lead not for profit modify this policy to improve organisation called Chesham Renaissance CIC has been striving to create Chesham Masterplan that would its alignment to this test of not only provide many genuinely affordable homes in more sustainable locations nearer the town centre, but soundness. which would also regenerate some of the more deprived wards within Chesham. The Local Authority's proposals (policy SP EP3) are inconsistent with this local initiative and are therefore also inconsistent with national guidance and are consequently unsound. Policy 1 - If you do not I refer to my comments previously submitted. believe this policy to be justified please explain why Policy 2a - Please specify as I refer to my comments previously submitted. precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not For this Plan to sound it must also be effective. Unfortunately, further review of the proposal to remove land believe this policy to be NE of Chesham at Lye Green from Green Belt designation is not effective as there are serious questions effective please explain why. about the deliverability of this land. The main landowner is a farmer who has asserted publicly and in a letter to the editor of Your Chesham, that he is not prepared to release all of the land in his ownership for development. PAa - Please specify as I refer to the comments previously submitted but in summary would advocate that; precisely and succinctly as All other options are fully explored including increased density of development of brownfield land and the possible how you would policies emerging from Chesham Masterplan. modify this policy to improve its alignment to this test of Green Belt land should only be considered when all other options are exhausted and in any event the soundness. proposals for developing land NE of Chesham (policy SP BP 2) should be removed as it is an unsustainable location the development of which will cause harm to the wider town including loss of an asset that improves the well-being for the community. Policy 3 - If you do not I believe the draft Local Plan is NOT legally compliant because it has not demonstrated much regard to the believe this policy in National Policy and guidance issued by the Secretary of State. consistent with the National The National Planning Policy Framework (NPPF) together with other guidance issued by the Government Planning Policy Framework is also supported by recent ministerial statements that have made it clear that Local Authorities MUST Feb 2019 please explain why demonstrate they have exhausted all options BEFORE considering revision of Green Belt boundaries. This Local Plan is seeking substantial modifications to Green Belt boundaries including the removal of Green Belt designation of 13 areas within the Districts as well as modifying the Green Belt status of many local villages.
8814 I contend this draft Local Plan has not demonstrated that all other options have been fully explored and as such this Plan is not justified, sound or in accordance with National Policy and accordingly is not legally compliant. Furthermore that Paragraph 11 b) of the NPPF (and the footnotes thereto) require Plan Makers to provide for objectively assessed needs for housing and other uses UNLESS the application of Framework policies (including Green Belt) provide a strong reason for restricting the overall scale, type or distribution of development in the plan area Chiltern District & South Bucks are significantly constrained by development policies such as Green Belt & Areas of Outstanding Natural Beauty (AONB). The Local Plan is therefore inconsistent with National Guidance and as such it is not legally compliant for the Local Authority to claim that housing needs justify a review of these same Green Belt boundaries. It is perverse to claim that the combination of housing need and the presence of significant areas of development constraint policy collectively represent ªexceptional circumstancesº (as required in the NPPF) to justify modification of Green Belt boundaries especially given the NPPF states that one of the key features of Green Belts are their permanence. The Government has also recently confirmed its aim for the UK to have net zero carbon emissions by 2050 and it is noted within the Sustainability Appraisal supporting this Draft Local Plan, that the Plan area is forecast to see carbon emission increase by 21% in the Plan Period. Accordingly, the Plan is inconsistent with Government Policy and therefore not legally compliant. There is also a significant infrastructure funding gap acknowledged within the Community Infrastructure Levy evidence that supports this Local Plan, of between £179m & £231m. Given this infrastructure is vital to ensure that development is sustainable (as also required by the NPPF) this further demonstrates the Plan is both unsound and not legally compliant. The foregoing also points to flawed methodology of Green Belt site selection used by the Local Authority, which is neither effective, justified nor consistent with national policy and as such is unsound. Specifically, the selection of the land NE of Chesham at Lye Green (policy SP BP2) for removal from Green Belt designation is inconsistent with National Planning Policy Framework (NPPF). Paragraph 136 of the latest NPPF asserts that Green Belt boundaries should only be modified in ªexceptional circumstancesº. The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances. The Council engaged third party consultants to undertake the Part 1 Green Belt assessment and they identified numerous sites for ªfurther considerationº where exceptional circumstances ªmightº exist but expressly recommended further review of their assessment of each site against the 5 purposes of land being in Green Belt of all these sites. Unlike the neighbouring Local Authorities, the Part 2 Green Belt assessment was not undertaken by third party consultants but by the Local Authority itself who notably then did not undertake all the recommended reviews of each site including the land NE of Chesham at Lye Green (SP BP 2). Accordingly, this oversight in the Part 2 Green Belt assessment placed premature focus and fixation on releasing land at Lye Green NE of Chesham from Green Belt designation. The subsequent identification of the Chesham site for release is therefore unjustified. The primary aim of Green Belt land (as recited in NPPF 133) is to prevent urban sprawl and to preserve the openness of the area. The Lye Green site (SP BP2) self-evidently performs this function well and has done so for decades. Another aim of Green Belt land stated in NPPF paragraph 134, is to prevent neighbouring towns and settlements from merging into one another.The Green Belt land NE of Chesham performs exceptionally well in maintaining a distinct separate between settlements of Chesham & Lye Green as well as helping to maintain separate identities of other nearby communities at Orchard Leigh, Botley, Whelpley Hill, Ashley Green. It is perverse and inconsistent with national guidance to allocate this land for removal from Green Belt in light of these facts especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if earmarked for development. The Council have asserted that Government planning policy requires local councils to review Green Belt boundaries when considering how to accommodate the development needed in their areas. Just because the Council may be required to look, does not mean the Council should review Green Belt boundaries which as previously stated should only be modified in ªexceptional circumstancesº. National Planning Policy Framework (NPPF) as revised only last year, states in paragraph11 (b) I, directs ªplan makersº to create policies that are required in Local Plans for housing and other uses unless Framework policies (expressly including Green Belt) ªprovides a strong reason for restricting the overall scale type or distribution of development in the plan areaº Accordingly, I submit that given all of the above the land being proposed for release from Green Belt designation around Chesham is unjustified and contrary to national guidance. Policy 3a - Please specify as The Plan needs to be modified by; precisely and succinctly as Co-operating with other nearby authorities. Not just Aylesbury. It is simply unsatisfactory to assert this cannot possible how you would be done because they are different Functional Market Areas and that co-operation is not necessary therefore. modify this policy to improve its alignment to this test of Exploring such wider co-operation may result in further housing needs being taken elsewhere. soundness. A more detailed appraisal of brownfield land opportunities MUST be undertaken. Some brownfield opportunities have been ignored or missed. Closer scrutiny of alternative options for housing delivery should be explored (such as Chesham Masterplan by CIC Chesham Renaissance). Green Belt boundary reviews should only be considered AFTER all other reasonable alternatives have been exhausted. In the face of NPPF guidance and a more thorough appraisal of Green Belt sites being considered, it may then be necessary to conclude that it is not possible to identify poor performing Green Belt sites that can accommodate all the OAN for housing. Consequently it may be necessary to accept that a lower housing provision figure is appropriate.
8815 Policy-level file upload - 5512714 Please attach any supporting evidence
Person ID 1223596 Full Name Mrs Sarah Hannen ID 5751 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications
8816 to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The proposals to release Green Belt land to meet housing targets (Generally, Spatial Policy SP SP1 & not believe this policy to be specifically Policy SP BP2 at Lye Green NE of Chesham) are not justified from the evidence submitted by positively prepared please the Councils. explain why The Councils have stated that release of some Green Belt is necessary as part of an overall three part strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. I question the soundness of such a general policy and whether all the brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites and in particular the Green Belt site NE of Chesham at Lye Green. The development of such Green Belt sites involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient and unfunded. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. This is clear to see during rush hours! Chesham cannot accommodate any significant highways improvements anyway due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion, with further worsening air quality. Air pollution is a particular concern in Chesham due to the already poor air quality along Berkhampstead Road where there is a designated Air Quality Management Area that already is recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will generate more traffic will make the air quality even worse and insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable nor justified nor is it in accordance with Government policy.
8817 The Green Belt site NE of Chesham (SP BP 2) is not a sustainable location. It is over 2Km away from the train station and slightly further still from the town centre and anyone who cares to walk or cycle this distance also has to negotiate a steep hill. Such an unsustainable location cannot be made sustainable merely by upgrading a couple of public footpaths within the site into bridleways to facilitate cycling. Neither does adding a bus stop address the geography or topography of the area especially if the promised enhanced bus service (which is already infrequent) either does not materialise or if it subsequently fails to be maintained after a few years. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I believe the draft Local Plan is NOT legally compliant because it has not demonstrated much regard to the believe this policy in National Policy and guidance issued by the Secretary of State. consistent with the National The National Planning Policy Framework (NPPF) together with other guidance issued by the Government Planning Policy Framework is also supported by recent ministerial statements that have made it clear that Local Authorities MUST Feb 2019 please explain why demonstrate they have exhausted all options BEFORE considering revision of Green Belt boundaries. This Local Plan is seeking substantial modifications to Green Belt boundaries including the removal of Green Belt designation of 13 areas within the Districts as well as modifying the Green Belt status of many local villages. I contend this draft Local Plan has not demonstrated that all other options have been fully explored and as such this Plan is not justified, sound or in accordance with National Policy and accordingly is not legally compliant. Furthermore that Paragraph 11 b) of the NPPF (and the footnotes thereto) require Plan Makers to provide for objectively assessed needs for housing and other uses UNLESS the application of Framework policies (including Green Belt) provide a strong reason for restricting the overall scale, type or distribution of development in the plan area Chiltern District & South Bucks are significantly constrained by development policies such as Green Belt & Areas of Outstanding Natural Beauty (AONB). The Local Plan is therefore inconsistent with National Guidance and as such it is not legally compliant for the Local Authority to claim that housing needs justify a review of these same Green Belt boundaries. It is perverse to claim that the combination of housing need and the presence of significant areas of development constraint policy collectively represent ªexceptional circumstancesº (as required in the NPPF) to justify modification of Green Belt boundaries especially given the NPPF states that one of the key features of Green Belts are their permanence. The Government has also recently confirmed its aim for the UK to have net zero carbon emissions by 2050 and it is noted within the Sustainability Appraisal supporting this Draft Local Plan, that the Plan area is forecast to see carbon emission increase by 21% in the Plan Period. Accordingly, the Plan is inconsistent with Government Policy and therefore not legally compliant. There is also a significant infrastructure funding gap acknowledged within the Community Infrastructure Levy evidence that supports this Local Plan, of between £179m & £231m. Given this infrastructure is vital to ensure that development is sustainable (as also required by the NPPF) this further demonstrates the Plan is both unsound and not legally compliant. Unsound The foregoing also points to flawed methodology of Green Belt site selection used by the Local Authority, which is neither effective, justified nor consistent with national policy and as such is unsound. Specifically, the selection of the land NE of Chesham at Lye Green (policy SP BP2) for removal from Green Belt designation is inconsistent with National Planning Policy Framework (NPPF). Paragraph 136 of the latest NPPF asserts that Green Belt boundaries should only be modified in ªexceptional circumstancesº. The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances. The Council engaged third party consultants to undertake the Part 1 Green Belt assessment and they identified numerous sites for ªfurther considerationº where exceptional circumstances ªmightº exist but expressly recommended further review of their assessment of each site against the 5 purposes of land being in Green Belt of all these sites. Unlike the neighbouring Local Authorities, the Part 2
8818 Green Belt assessment was not undertaken by third party consultants but by the Local Authority itself who notably then did not undertake all the recommended reviews of each site including the land NE of Chesham at Lye Green (SP BP 2). Accordingly, this oversight in the Part 2 Green Belt assessment placed premature focus and fixation on releasing land at Lye Green NE of Chesham from Green Belt designation. The subsequent identification of the Chesham site for release is therefore unjustified. These comments apply equally to proposals effecting the villages in the Green Belt ± policies SP PP1 & DM PP1) The primary aim of Green Belt land (as recited in NPPF 133) is to prevent urban sprawl and to preserve the openness of the area. The Lye Green site (SP BP2) self-evidently performs this function well and has done so for decades. Another aim of Green Belt land stated in NPPF paragraph 134, is to prevent neighbouring towns and settlements from merging into one another.The Green Belt land NE of Chesham performs exceptionally well in maintaining a distinct separate between settlements of Chesham & Lye Green as well as helping to maintain separate identities of other nearby communities at Orchard Leigh, Botley, Whelpley Hill, Ashley Green. It is perverse and inconsistent with national guidance to allocate this land for removal from Green Belt in light of these facts especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if earmarked for development. A further aim of Green Belt designation stated in the NPPF at paragraph 134 (e) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. By allocating Green Belt land NE of Chesham for development, undermines this aim within Chesham. A community lead not for profit organisation called Chesham Renaissance CIC has been striving to create Chesham Masterplan that would not only provide many genuinely affordable homes in more sustainable locations nearer the town centre, but which would also regenerate some of the more deprived wards within Chesham. The Local Authority's proposals (policy SP EP3) are inconsistent with this local initiative and are therefore also inconsistent with national guidance and are consequently unsound. The Council have asserted that Government planning policy requires local councils to review Green Belt boundaries when considering how to accommodate the development needed in their areas. Just because the Council may be required to look, does not mean the Council should review Green Belt boundaries which as previously stated should only be modified in ªexceptional circumstancesº. National Planning Policy Framework (NPPF) as revised only last year, states in paragraph11 (b) I, directs ªplan makersº to create policies that are required in Local Plans for housing and other uses unless Framework policies (expressly including Green Belt) ªprovides a strong reason for restricting the overall scale type or distribution of development in the plan areaº Accordingly, I submit that given all of the above the land being proposed for release from Green Belt designation around Chesham is unjustified and contrary to national guidance. I am supportive of the Brown Not Green organisation's initiative to have the land listed as an Asset of Community Value and I feel they speak for me in respect of their objections to the draft Local Plan. Accordingly, I request that any representations made by them at any future examination in public regarding the soundness of this Local Plan be considered as an extension of my own comments herein. I feel the land NE of Chesham is an unsustainable location for development, that has been habitually used by the community for improved health & wellbeing for decades and the land performs well against Green Belt aims and objectives. Exceptional circumstances for reviewing Green Belt boundaries at this location, either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by Government Policy and therefore the plan is unsound. Policy 3a - Please specify as Co-operating with other nearby authorities. Not just Aylesbury. It is simply unsatisfactory to assert this cannot precisely and succinctly as be done because they are different Functional Market Areas and that co-operation is not necessary therefore. possible how you would Exploring such wider co-operation may result in further housing needs being taken elsewhere. modify this policy to improve its alignment to this test of A more detailed appraisal of brownfield land opportunities MUST be undertaken. Some brownfield opportunities soundness. have been ignored or missed. Closer scrutiny of alternative options for housing delivery should be explored (such as Chesham Masterplan by CIC Chesham Renaissance). Green Belt boundary reviews should only be considered AFTER all other reasonable alternatives have been exhausted. In the face of NPPF guidance and a more thorough appraisal of Green Belt sites being considered, it may then be necessary to conclude that it is not possible to identify poor performing Green Belt sites that can accommodate all the OAN for housing. Consequently it may be necessary to accept that a lower housing provision figure is appropriate. Unsound I refer to the comments previously submitted but in summary would advocate that; All other options are fully explored including increased density of development of brownfield land and the policies emerging from Chesham Masterplan. Green Belt land should only be considered when all other options are exhausted and in any event the proposals for developing land NE of Chesham (policy SP BP 2) should be removed as it is an unsustainable location the development of which will cause harm to the wider town including loss of an asset that improves the well-being for the community. Policy-level file upload - 5512643 Please attach any supporting evidence
Person ID 1222560
8819 Full Name Tom Hickling ID 5851 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness?
8820 Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I would refer you to the article in the August edition of Your Chesham by Michael Shea which expresses my not believe this policy to be own thoughts most adequately. I would stress the concern over Parking which is a constant problem for our positively prepared please town. explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve
8821 its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222569 Full Name David Le Neve Foster (Chenies Parish Council) ID 5869 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Parish Council select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Chenies Parish Council Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible.
8822 Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Chenies Parish is not directly affected by the Chiltern and South Bucks Local Plan 2036 and by this not believe this policy to be we mean that there are no developments being proposed, nor any changes to the Green Belt, within positively prepared please explain why our parish. Our parish has 3.25 miles of the river Chess within or bordering its area. Much of the Chess Valley at this point and in the adjoining Latimer and Leyhill Parish lies within the Chenies and Latimer Conservation Area. The whole parish is within the Green Belt and AONB. The river is a significant feature within this protected landscape and is an internationally rare habitat. We do not consider it appropriate to comment individually on any of the thirteen site-specific policies since these are not in our parish although we will be affected particularly by Policy SP BP2 ±
8823 Chesham and SP BP6 ± Little Chalfont. We are also concerned about the emerging Three Rivers District Plan where it affects Chorleywood, our `local hub,' and which, whilst not part of this consultation, will have a major impact on the quality of life of our residents and will also be pertinent to our comments below. Section 10 Protected Places As correctly stated in the Plan at 10.1.1 ªThe fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently openº. Changes to Green Belt boundaries are only allowed through the Plan ªin exceptional circumstancesº. Central Government has imposed via a formulaic process new housing numbers in an area where such numbers cannot be delivered without changes to the Green Belt. We argue that the whole purpose of the Green Belt is circumvented by this approach which also lays the Green Belt open to further invasions in future years. Where is the permanence in this? Looking at the National Planning Policy Framework (NPPF) at Section 13. Protecting Green Belt Land 138. ª¼They should also set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt landº. In our view there is nothing in the plan about any compensatory measure thus rendering the plan both unsound and contrary to the NPPF. We would strongly urge retention of the existing Green Belt and that this protection should override development needs, which of course was its original purpose. Infrastructure and Sustainable Development Infrastructure as a whole should be properly planned, costed and in place prior to any development being completed. Our infrastructure is already under stress and investment is required to remedy this in addition to any improvements necessitated by new development.The Plan does not cover current lack of infrastructure. Looking at NPPF Section 2. Achieving sustainable development - Paragraph 8 sets out three ªoverarching objectivesº ± economic, social and environmental and the need to achieve net gains under all three headings. The provision of infrastructure is a key element. The provision of accessible services and the use of natural resources are also key. Bearing this in mind where is the water supply for the new homes proposed in the Plan?
PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not Introduction believe this policy in Water supply in the Chilterns is entirely taken from the aquifer. The present level of abstraction is causing consistent with the National unacceptable environmental damage to our chalk streams i.e. sections of them frequently dry up. Another Planning Policy Framework source of water will be needed to supply an increased population and this has not been planned for. The Feb 2019 please explain why water companies have the duty to supply water however as confirmed in the Sustainability Appraisal of the Chiltern and South Bucks Local Plan (SA) in its Non-Technical Summary at Paragraph N20 Item 11 ± Increased Stress of Water Resources ± ªThere is no water available for licensing in either the Colne or the Thames catchment area. The large quantity of development proposed in the Local Plan would be likely to increase pressures on water resourcesº. Whilst accepting that water companies have a duty to supply, it is unrealistic to plan for this volume of new housing without knowing if an alternative sustainable supply can be laid on before new developments begin. We are not talking here about laying on new pipe work from the existing network using the existing supply. An entirely new supply from outside the area is required and this is not currently available and would take many years to achieve. The SA Objective 6. Natural Resources. Here an assumption has been made that the EA will licence a sustainable water supply. There is no sustainable supply currently to licence. The developments proposed in the Local Plan will not therefore be sustainable.
8824 The Plan as currently drafted is therefore unsound and does not meet the requirements of the NPPF. Specifically Para 20. b) which states ªStrategic policies should set out an overall strategy for the pattern, scale and quality of development, and make sufficient provision for: b) infrastructure for¼.water supply, wastewater,¼º Many of the area's sewage works e.g. Chesham are already working at capacity and will need expansion. Such works take many years to design and build and it is not clear that Thames Water have this in hand or that new provision will be in place before new housing is built thus placing in this case the River Chess at risk of increased pollution. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5497996 Please attach any supporting evidence
Person ID 1223720 Full Name Teresa Shaw ID 5815 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible.
8825 Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I strongly object to the building of 500 dwellings in Lye Green and in such close proximity to Chesham not believe this policy to be altogether . The town has not got the infrastructure for such an undertaking . positively prepared please The town is at a standstill every week day at essential times including school and work times, it is already explain why very stressful which is unhealthy to both the pollution in and around town and the commuting traffic . Before a development of this size could begin in Chesham some kind of bypass would have to be put in place . I live in Ashley Green just outside Chesham and the bus service is so bad it is unusable. It stops before 18.00 and runs less than once an hour and everyone is forced into their cars. This undoubtably will be the same in Lye Green.
8826 With the removal of Lye Green from the greenbelt the impact will have a knock on effect on what is an area of outstanding beauty. Over the course of twenty years I have seen Aston Clinton begging for a bypass and getting one, only now with all the building on the outskirts of Aylesbury the village is nearly swallowed up by Aylesbury . Traffic in and out of Aylesbury is still at a standstill till after 19:00 . The removal of Lye Green from the green belt will see the same happening to Chesham . It is a very short sighted plan . A whole new town in a more rural part of the county would make more sense instead over stretching an already busy town . PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1223727 Full Name Mrs Victoria Mistry ID 5856 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID
8827 Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination
8828 Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The proposals to release Green Belt land to meet housing targets (Generally, Spatial Policy SP SP1 & not believe this policy to be specifically Policy SP BP2 at Lye Green NE of Chesham) are not justified from the evidence submitted by positively prepared please the Councils. explain why The Councils have stated that release of some Green Belt is necessary as part of an overall three part strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. I question the soundness of such a general policy and whether all the brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites and in particular the Green Belt site NE of Chesham at Lye Green. The development of such Green Belt sites involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient and unfunded. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham cannot accommodate any significant highways improvements anyway due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion, with further worsening air quality. Air pollution is a particular concern in Chesham due to the already poor air quality along Bekhampstead Road where there is a designated Air Quality Management Area that already is recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will generate more traffic will make the air quality even worse and insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable nor justified nor is it in accordance with Govt policy. The Green Belt site NE of Chesham (SP BP 2) is not a sustainable location. It is over 2Km away from the train station and slightly further still from the town centre but anyone who cares to walk or cycle this distance also has to negotiate a steep hill too. Such an unsustainable location cannot be made sustainable merely by upgrading a couple of public footpaths within the site into bridleways to facilitate cycling. Neither does adding a bus stop address the geography or topography of the area especially if the promised enhanced bus service (which is already infrequent) either does not materialise or if it subsequently fails to be maintained after a few years. Further doubt is cast upon the ªsoundnessº of this Plan by virtue of there being conflicting policies within it. The Council seem to think that the Green Belt site NE of Chesham is sustainable and provides easy access to public transport including the tube station yet the same Plan promotes a considerable increase in retail development in the town (local draft plan policy SP EP3) , part of which would be built on the very car park that serves the Chesham tube station. This is inconsistent and unsound. The land is also potentially an Asset Of Community Value and upon confirmation of this designation it would afford a community group the right to bid for the land. The community group (Brown Not Green) have stated their intention is to preserve the land given that many hundreds of local people have habitually used the fields at Lye Green as of right for various informal outdoor recreational purposes. These uses themselves may mean that many local individuals may have acquired easements over and across the land through prescription (20 years uninterrupted use) not least of whom would be the many private residences bordering the fields that have rear garden gates onto the fields at Lye Green. These easements and prescriptive rights may render the land very difficult to develop and make i undeliverable in planning terms. This land also provides an important habitat for wildlife that will be threatened by development of this land. It is perverse that the Local Authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Plan is unsound. I feel the land NE of Chesham is an unsustainable location for development, that has been habitually used by the community for improved health & wellbeing for decades and the land performs well against Green Belt aims and objectives. Exceptional circumstances for reviewing Green Belt boundaries at this location, either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by Govt Policy and therefore the plan is unsound.
8829 PP Mods - Please specify as I refer to the comments previously submitted but in summary would advocate that; precisely and succinctly as All other options are fully explored including increased density of development of brownfield land and the possible how you would policies emerging from Chesham Masterplan. modify this policy to improve its alignment to this test of Green Belt land should only be considered when all other options are exhausted and in any event the soundness. proposals for developing land NE of Chesham (policy SP BP 2) should be removed as it is an unsustainable location the development of which will cause harm to the wider town including loss of an asset that improves the well-being for the community. Policy 1 - If you do not I refer to my comments previously submitted believe this policy to be justified please explain why Policy 2a - Please specify as I refer to my comments previously submitted precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not For this Plan to sound it must also be effective. Unfortunately, further review of the proposal to remove land believe this policy to be NE of Chesham at Lye Green from Green Belt designation is not effective as there are serious questions effective please explain why. about the deliverability of this land. The main landowner is a farmer who has asserted publicly and in a letter to the editor of Your Chesham, that he is not prepared to release all of the land in his ownership for development. PAa - Please specify as I refer to my comments previously submitted precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I believe the draft Local Plan is NOT legally compliant because it has not demonstrated sufficient regard to believe this policy in the National Policy and guidance issued by the Secretary of State. consistent with the National The National Planning Policy Framework (NPPF) together with other guidance issued by the Government Planning Policy Framework is also supported by recent ministerial statements that have made it clear that Local Authorities MUST Feb 2019 please explain why demonstrate they have exhausted all options BEFORE considering revision of Green Belt boundaries. This Local Plan is seeking substantial modifications to Green Belt boundaries including the removal of Green Belt designation of 13 areas within the Districts as well as modifying the Green Belt status of many local villages. I contend this draft Local Plan has not demonstrated that all other options have been fully explored and as such this Plan is not justified, sound or in accordance with National Policy and accordingly is not legally compliant. Furthermore that Paragraph 11 b) of the NPPF (and the footnotes thereto) require Plan Makers to provide for objectively assessed needs for housing and other uses UNLESS the application of Framework policies (including Green Belt) provide a strong reason for restricting the overall scale, type or distribution of development in the plan area Chiltern District & South Bucks are significantly constrained by development policies such as Green Belt & Areas of Outstanding Natural Beauty (AONB). The Local Plan is therefore inconsistent with National Guidance and as such it is not legally compliant for the Local Authority to claim that housing needs justify a review of these same Green Belt boundaries. It is perverse to claim that the combination of housing need and the presence of significant areas of development constraint policy collectively represent ªexceptional circumstancesº (as required in the NPPF) to justify modification of Green Belt boundaries especially given the NPPF states that one of the key features of Green Belts are their permanence. The Government has also recently confirmed its aim for the UK to have net zero carbon emissions by 2050 and it is noted within the Sustainability Appraisal supporting this Draft Local Plan, that the Plan area is forecast to see carbon emission increase by 21% in the Plan Period. Accordingly, the Plan is inconsistent with Government Policy and therefore not legally compliant. There is also a significant infrastructure funding gap acknowledged within the Community Infrastructure Levy evidence that supports this Local Plan, of between £179m & £231m. Given this infrastructure is vital to ensure that development is sustainable (as also required by the NPPF) this further demonstrates the Plan is both unsound and not legally compliant. The foregoing also points to flawed methodology of Green Belt site selection used by the Local Authority, which is neither effective, justified nor consistent with national policy and as such is unsound. Specifically, the selection of the land NE of Chesham at Lye Green (policy SP BP2) for removal from Green Belt designation is inconsistent with National Planning Policy Framework (NPPF). Paragraph 136 of the latest NPPF asserts that Green Belt boundaries should only be modified in ªexceptional circumstancesº. The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances. The Council engaged third party consultants to undertake the Part 1 Green Belt assessment and they identified numerous sites for ªfurther considerationº where exceptional circumstances ªmightº exist but expressly recommended further review of their assessment of each site against the 5 purposes of land being in Green Belt of all these sites. Unlike the neighbouring Local Authorities, the Part 2 Green Belt assessment was not undertaken by third party consultants but by the Local Authority itself who notably then did not undertake all the recommended reviews of each site including the land NE of Chesham at Lye Green (SP BP 2). Accordingly, this oversight in the Part 2 Green Belt assessment placed premature focus and fixation on releasing land at Lye Green NE of Chesham from Green Belt designation. The subsequent identification of the Chesham site for release is therefore unjustified.
8830 The primary aim of Green Belt land (as recited in NPPF 133) is to prevent urban sprawl and to preserve the openness of the area. The Lye Green site (SP BP2) self-evidently performs this function well and has done so for decades. Another aim of Green Belt land stated in NPPF paragraph 134, is to prevent neighbouring towns and settlements from merging into one another.The Green Belt land NE of Chesham performs exceptionally well in maintaining a distinct separate between settlements of Chesham & Lye Green as well as helping to maintain separate identities of other nearby communities at Orchard Leigh, Botley, Whelpley Hill, Ashley Green. It is perverse and inconsistent with national guidance to allocate this land for removal from Green Belt in light of these facts especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if earmarked for development. A further aim of Green Belt designation stated in the NPPF at paragraph 134 (e) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. By allocating Green Belt land NE of Chesham for development, undermines this aim within Chesham. A community lead not for profit organisation called Chesham Renaissance CIC has been striving to create Chesham Masterplan that would not only provide many genuinely affordable homes in more sustainable locations nearer the town centre, but which would also regenerate some of the more deprived wards within Chesham. The Local Authority's proposals (policy SP EP3) are inconsistent with this local initiative and are therefore also inconsistent with national guidance and are consequently unsound. The Council have asserted that Government planning policy requires local councils to review Green Belt boundaries when considering how to accommodate the development needed in their areas. Just because the Council may be required to look, does not mean the Council should review Green Belt boundaries which as previously stated should only be modified in ªexceptional circumstancesº. National Planning Policy Framework (NPPF) as revised only last year, states in paragraph11 (b) I, directs ªplan makersº to create policies that are required in Local Plans for housing and other uses unless Framework policies (expressly including Green Belt) ªprovides a strong reason for restricting the overall scale type or distribution of development in the plan areaº Accordingly, I submit that given all of the above the land being proposed for release from Green Belt designation around Chesham is unjustified and contrary to national guidance. Policy 3a - Please specify as The Plan needs to be modified by; precisely and succinctly as Co-operating with other nearby authorities. Not just Aylesbury. It is simply unsatisfactory to assert this cannot possible how you would be done because they are different Functional Market Areas and that co-operation is not necessary therefore. modify this policy to improve its alignment to this test of Exploring such wider co-operation may result in further housing needs being taken elsewhere. soundness. A more detailed appraisal of brownfield land opportunities MUST be undertaken. Some brownfield opportunities have been ignored or missed. Closer scrutiny of alternative options for housing delivery should be explored (such as Chesham Masterplan by CIC Chesham Renaissance). Green Belt boundary reviews should only be considered AFTER all other reasonable alternatives have been exhausted. In the face of NPPF guidance and a more thorough appraisal of Green Belt sites being considered, it may then be necessary to conclude that it is not possible to identify poor performing Green Belt sites that can accommodate all the OAN for housing. Consequently it may be necessary to accept that a lower housing provision figure is appropriate. Policy-level file upload - 5512716 Please attach any supporting evidence
Person ID 1224132 Full Name Mr B Harman ID 5916 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID 1224130 Full Name Alex Dalton
8831 Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination
8832 Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible
Policy Level - PP - If you do 1.1. This policy is not positively prepared because it will not meet the areas objectively assessed needs. The not believe this policy to be policy is not deliverable in its entirety. Not all landowners are willing to bring the land forward for development positively prepared please and so the policy is not deliverable. The 2017 Green Belt Development Options Appraisal states: explain why ªLand Owner(s): Parts of the Option are being promoted by some landowners/developers however not all landowners are supportive. Unless this position changes comprehensive development is unlikely without Council intervention. At this point in time evidence suggests that landowner consensus does not exist and so the Preferred Option as set out in the Consultation Document is unlikely to be deliverable. ªTiming: The Housing Delivery Study for Buckinghamshire report concludes that due to the uncertainties surrounding willingness of landowners and likely need for the entire site to come forward recommends assuming that no homes are delivered in by March 2033. If issues are resolved then development could expect an annual delivery rate of up to 70 dwellings per annum once commenced.º 1.2. There is no update on this deliverability issue in the Council's more recent documents. We believe the owner who does not wish to bring the site forward owns the majority of the allocation adjoining Chesham to the south. 1.3. Part of the Policy criteria states that an integrated, coordinated and comprehensive planning approach will be taken to the site. The site will require a single master plan to ensure this is delivered. It is not clear how this can be achieved when part of the site cannot be delivered. 1.4. Another part of the criteria is for the provision of 15 pitches for Gypsies and Travellers. A key landowner has publically objected to this aspect of the allocation with an article in the Bucks Free Press `Land in Chesham ©not for sale to travellers©' (17th September 2013) [available from: https://www.bucksfreepress.co.uk/news/10679099.land-inchesham- not-for-sale-to-travellers/
PP Mods - Please specify as 1.5. The allocation should be reduced to cover only that land which is deliverable, and if this does not form precisely and succinctly as a logical boundary then the allocation should be removed from the plan and the land maintained within the possible how you would Green Belt. Additional allocations elsewhere in Chesham and other locations will be necessary to compensate modify this policy to improve for the undeliverable homes on this site. its alignment to this test of soundness.
Policy 1 - If you do not 2.1. This policy is not justified because the reasonable alternatives have not been taken into account. believe this policy to be 2.2. We have particular concerns about the robustness of the Council's Green Belt review work. Land & justified please explain why Partners has made separate representations on this issue but the relevance to Chesham is summarized here. Green Belt Assessment Part Two 2.3. A Draft Part Two was issued in 2016 but has been superseded by a 2019 Assessment.The methodology was refined in the 2019 Assessment in response to a number of issues identified through consultation. 2.4. Whilst 352 sites from HELAA nominations or consultation responses had been referred to in the 2016 draft, they are not mentioned in the 2019 version and site submissions are dealt with in the HELAA which discounts Green Belt sites. 2.5. The Part Two Green Belt Assessment has not dealt with 352 site nominations, including land north of Pheasant Rise, Chesham which we promote for development. 2.6. The Chesham site we promote has therefore not been given due consideration as it was automatically excluded by the 2019 HELAA. Boundary assessments and redefinitions are inconsistent.
8833 2.7.!The superseded draft Part Two had given the site north of Pheasant Rise an assessment under reference 4.040 but considered the site did not have permanent defensible Green Belt boundaries due to an area of woodland not being well-enough established. The woodland in question is mature and extensive and the Council have been invited to protect it with a TPO. Nevertheless, this earlier draft assessment has been superseded and site nominations do not feature in the final Part Two Assessment. 2.8. In some cases, non NPPF compliant boundaries have been used to dismiss sites, whereas at the land North of Chalfont St Peter (Epilepsy Centre Site) new Green Belt boundaries are proposed even though they fail the criteria used by the Council. The assessment of this site states that boundaries would follow hedge and fence lines and states that parts of it are unlikely to be permanent. This sort of boundary has been used to dismiss reasonable alternative sites and yet a site has been allocated with this form of boundary. Green Belt Development Options Appraisal November 2017 2.9. This document prejudges the strategy and Green Belt releases before the evidence base is complete. It is described as ªnot a consultation document but a published evidence base document to inform interested parties of the emerging positon likely to be recommended to the Councils' in due course.º 2.10. The document states ªThe Councils' have identified and have/are considering a range of Green Belt development optionsº through a range of documents including Calls for Sites and emerging final Part. Two Green Belt Assessment. 2.11. It suggests options have been assessed and already found unsuitable. ªThe Green Belt Assessment Part 2 is not yet complete but will be published as soon as it is available. This will include assessment details of additional options identified during the consultation however none of these options are expected to be recommended for further consideration based on work undertaken at the time of writing this report.º 2.12. Between this document and now there have been no assessments published of submitted site nominations. This document had already recommended none were to be taken forward. 2.13. The options recommended in this report closely align with the sites now allocated save for two sites which have been dropped. Policy 2a - Please specify as 2.14. In accordance with the PINS Procedural Guidance on Local Plan Examinations, an addendum to the precisely and succinctly as plan including a consultation on alternative/additional site allocations could be published. The addendum, possible how you would together with a sustainability appraisal [SA] of the proposed changes, should be published for consultation, modify this policy to improve on the same basis as the Regulation 19 consultation, before the plan is submitted for examination its alignment to this test of soundness. Policy 2 - If you do not 3.1. The policy is not effective because it is not deliverable over the plan period. One of the landowners is believe this policy to be not supportive. effective please explain why. PAa - Please specify as 3.2.The area should be reduced or the allocation removed. Other allocations will need to be found in Chesham precisely and succinctly as to meet local needs. Attached at Appendix A is a booklet demonstrating the suitability of a reasonable possible how you would alternative site within walking distance to Chesham railway station. modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5512743 Please attach any supporting evidence
Person ID 1224143 Full Name Land and Partners ID 5935 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee:
8834 Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID 1224130 Full Name Alex Dalton Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider
8835 the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible
Policy Level - PP - If you do 1.1. This policy is not positively prepared because it will not meet the areas objectively assessed needs. The not believe this policy to be policy is not deliverable in its entirety. Not all landowners are willing to bring the land forward for development positively prepared please and so the policy is not deliverable. The 2017 Green Belt Development Options Appraisal states: ªLand explain why Owner(s): Parts of the Option are being promoted by some landowners/developers however not all landowners are supportive. Unless this position changes comprehensive development is unlikely without Council intervention. At this point in time evidence suggests that landowner consensus does not exist and so the Preferred Option as set out in the Consultation Document is unlikely to be deliverable. ªTiming: The Housing Delivery Study for Buckinghamshire report concludes that due to the uncertainties surrounding willingness of landowners and likely need for the entire site to come forward recommends assuming that no homes are delivered in by March 2033. If issues are resolved then development could expect an annual delivery rate of up to 70 dwellings per annum once commenced.º
1.2. There is no update on this deliverability issue in the Council's more recent documents. We believe the owner who does not wish to bring the site forward owns the majority of the allocation adjoining Chesham to the south.
1.3. Part of the Policy criteria states that an integrated, coordinated and comprehensive planning approach will be taken to the site. The site will require a single masterplan to ensure this is delivered. It is not clear how this can be achieved when part of the site cannot be delivered.
1.4. Another part of the criteria is for the provision of 15 pitches for Gypsies and Travellers. A key landowner has publically objected to this aspect of the allocation with an article in the Bucks Free Press `Land in Chesham ©not for sale to travellers©' (17th September 2013) [available from: https://www.bucksfreepress.co.uk/news/10679099.land-inchesham- not-for-sale-to-travellers/ Last accessed 12th August 2019].
PP Mods - Please specify as 1.5. The allocation should be reduced to cover only that land which is deliverable, and if this does not form precisely and succinctly as a logical boundary then the allocation should be removed from the plan and the land maintained within the
8836 possible how you would Green Belt. Additional allocations elsewhere in Chesham and other locations will be necessary to compensate modify this policy to improve for the undeliverable homes on this site. its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5511992 Please attach any supporting evidence
Person ID 1224167 Full Name Mr Rob Smith ID 5943 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Director Growth, Strategy and Highways Buckinghamshire County Council Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you
8837 consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible.
8838 Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do This policy should include a comment on investigating a comment on investigating the opportunities to show not believe this policy to be surface water runoff into Chesham from this site by implementing strategic SuDS. This could also include a positively prepared please requirement to reduce the discharge rate from the site by X%. explain why Policy SP BP2 Comments Cannot require betterment. Transport mitigation is to include assessment of and any identified mitigation along the A416 corridor. Policy SP BP2 Comments Is this therefore proposed to be on the highway? Bullet point 4 Can this be demanded of a new development ± is this mitigating the developments impact or dealing with an existing issue? PP Mods - Please specify as Bullet point 2 should include measures to increase walking and cycling. precisely and succinctly as Bullet point 3 possible how you would modify this policy to improve (modification) its alignment to this test of ¼improvements¼ soundness. Bullet point 6 (modification) ¼safe drop off/pick up point¼ Bullet point 3 (modification in bold) 1. Assessments and any identified improvements to the A404/Burtons Lane junction; 2. Assessments and any identified improvements to the A404/Stony Lane/Church Grove junction Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
8839 Policy-level file upload - Please attach any supporting evidence
Person ID 1213657 Full Name Mr Bill Richards ID 6072 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Clerk Chesham Town Council Consultee Type - Please Parish Council select the type of consultee: Date Received - Date 2016-04-06 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible.
8840 Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The type of housing that Chesham needs includes small starter units, affordable housing and smaller homes not believe this policy to be for the elderly where people are typically less mobile. None of these are suitable or appropriate on a site positively prepared please such as this on the edge of town and isolated from crucial support facilities. The Town Council has a clear explain why preference for higher density housing closer to the town centre ,which we believe can delivered through credible alternative development plan which includes a number of different sites, for example , the site at Higham Mead. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
8841 Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1223223 Full Name Asad Raja ID 5993 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Sunnymede Avenue Residents Association Ltd Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You
8842 will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be
8843 positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not 1.0 UNJUSTIFIED USE OF GREENBELT LAND FOR DEVELOPMENT believe this policy in 1.1 The National Planning Policy Framework (NPPF) 133: The primary aim of Green Belt land is to prevent consistent with the National urban sprawl and to preserve the openness of the area. The Lye Green site (Policy SP BP 2) does exactly Planning Policy Framework that and to remove it from the Green Belt will be in breach of NPPF paragraph 134 which states that it is to Feb 2019 please explain why prevent neighbouring towns and settlements from merging. The Green Belt land North East of Chesham maintains a distinct separation between Chesham and Lye Green and helps to maintain the separate identities of other nearby rural communities at Orchard Leigh, Botley, Whelpley Hill and Ashley Green. It is perverse and inconsistent with national guidance to allocate this land for removal from Green Belt. 1.2 NPPF Paragraph 136 asserts that Green Belt boundaries should only be modified in ªexceptional circumstancesº. The courts have held that unmet local housing needs of an area are themselves not exceptional circumstancesº. The subsequent identification of the Chesham site for release is, therefore, not justified. 1.3 The recently revised NPPF paragraph 11(b)i, directs ªplan makersº to create policies that are required in Local Plans for housing and other uses unless Framework policies (expressly including Green Belt) ªprovides a strong reason for restricting the overall scale type or distribution of development in the plan areaº Consequently, the land around Chesham proposed for release from Green Belt designation is contrary to national guidance and, therefore, unjustified. DEVELOPMENT OF THE GREENBELT AROUND CHESHAM IS NOT SUSTAINABLE The draft Local Plan should adopt a strategy which seeks to meet objectively assessed development and infrastructure requirements and should be consistent with achieving sustainable development ± in short, the Local Plan should be positively prepared. The draft plan does not operate within the above parameters and is, therefore, unsound. 2.1 The Green Belt site North East of Chesham is not a sustainable location. It is over 2km away from the train station and slightly further still from the town centre but anyone who cares to walk or cycle this distance also has to negotiate a very steep hill in either White Hill or Nashleigh Hill. Such an unsustainable location cannot be made sustainable merely by upgrading a couple of public footpaths within the site into bridleways to facilitate cycling. Neither does adding a bus stop address the geography or topography of the area especially if the promised enhanced bus service (which is already infrequent) either does not materialise or if it subsequently fails to be maintained after a few years. 2.2. The development of the proposed Green Belt sites involving many hundreds of homes will inevitably increase the volume of traffic and although some highways improvements are suggested, they are insufficient. For example, in Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham cannot accommodate any significant highways improvements due to the already limited verges and space beside the highway and, combined with the topography of the town, this means that there will be significantly increased traffic congestion and further worsening air quality. 2.3 Existing levels of air pollution is a concern in Chesham due to the already poor air quality along Berkhamstead Road where there is a designated Air Quality Management Area that already is recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will generate more traffic which in turn will make the air quality even worse. The Councils' Sustainability Appraisal (CSA) makes reference to increases in air pollution (N58, N87). N98 table N4 ªThe Local Plan is anticipated to lead to a reduction in local air quality with implications for human health.º This is in direct opposition to NPPF 181.º Planning policies and decisions should sustain and contribute towards compliance with relevant limit values or national objectives for pollutants, taking into account the presence of Air Quality
8844 Management Areas.º It is incumbent on all authorities under national law, to actively promote measures that will decrease rather than increase pollution. 3.0 THE DRAFT LOCAL PLAN IS NOT SOUND 3.1 The Councils have stated that release of some Green Belt is necessary as part of an overall three-part strategy involving: (1) focus on built-up areas to build dwellings on previously developed land (2) an exported proportion of housing need to go to the Aylesbury District (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt We are not confident that the Councils have adequately considered all of the local brownfield land opportunities, nor have they explored the possibilities of higher densities of development on such sites which are generally closer to the town centre and, are, therefore, in more sustainable locations than Green Belt sites. This is particularly the case with the Green Belt site North East of Chesham at Lye Green which is inconsistent with NPPF 137 a) ªBefore changing Green belt boundaries, authorities should make as much use as possible of suitable brownfield sites and underutilised land;º 3.2 A further aim of Green Belt designation as stated in the NPPF at paragraph 134 (e) is to assist urban regeneration by encouraging the recycling of derelict another urban land. By allocating Green Belt land NE of Chesham for development, undermines this aim within Chesham. A community lead not for-profit organisation called Chesham Renaissance CIC has been striving to create a Chesham Masterplan that would not only provide many genuinely affordable homes in more sustainable locations nearer the town centre but which would also regenerate some of the more deprived wards within Chesham. The Local Authority's proposals completely disregard this local initiative. 3.3 The conflicting policies with the plan cast further doubt upon its effectiveness. The Council considers the Green Belt site North East of Chesham to be sustainable and able to provide easy access to public transport including the tube station, yet the same Plan promotes a considerable increase in retail development in the town (local draft plan policy SP EP3) part of which would be built on the very car park that serves the Chesham tube station. One of the key redeeming features of Chesham's town centre are the varied and highly valued, independent retailers who continue to survive in the failing ªhigh streetº retail industry. Setting up big brand shops in the immediate vicinity which inevitably damage their trade ± assuming that any trade is left when potential shoppers are unable to park near the shops. 4.0 THE DRAFT LOCAL PLAN IS NOT DELIVERABLE 4.1 For the Plan to be sound, it must also be deliverable. This Local Plan has an acknowledged funding gap from the Community Infrastructure Levy (CIL) of between £179m ± £231m. Many of the site allocations (including Lye Green Policy SP BP2) are excluded from CIL and developers will therefore be required to deliver infrastructure directly or make financial contributions to mitigate development impact. However, these contributions cannot be quantified because much of the costs or related infrastructure is not even specified and is awaiting the preparation of ªMasterplansº for each site. If these sites become undeliverable or, even worse, delivered without the appropriate infrastructure the negative impact upon the wider community could become significant. 4.2 With respect to the plan to remove land NE of Chesham at Lye Green from Green Belt designation, there are serious questions about the deliverability of this land. The main landowner is a farmer who has asserted publicly and in a letter to the editor of Your Chesham magazine that he is not prepared to release all the land in his ownership for development. 4.3 The land has recently become an Asset of Community Value and, as such, affords a community group the right to bid for the land.The community group (Brown Not Green) have stated their intention is to preserve the land given that many hundreds of local people have habitually used the field at Lye Green as of right for various informal outdoor recreational purposes.These uses themselves may mean that many local individuals may have acquired easements over and across the land through prescription (20 years uninterrupted use) not least of whom would be the many private residences bordering the fields that have rear garden gates onto the fields of Lye Green. These easements and prescriptive rights may render the land very difficult to develop and make it undeliverable in planning terms. It is perverse that the Local Authority would promote such a valued community asset for NPPF 96. ªAccess to a network of high-quality open spaces and opportunities for sport and physical activity is important for the health and well-being of communities.º NPPF 180 b)º identify and protect tranquil areas which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason;º The land at Lye Green, (Chesham 1) has recently been designated an Asset of Community Value by virtue of the fact that it `improves the wellbeing of the community'. In conclusion, the flawed proposal remove this valued piece of land from green belt protection undermines the objectives of the Localism Act 2011. 5.0 THE DRAFT LOCAL PLAN IS IN BREACH OF ENVIRONMENTAL POLICIES 5.1 The Natural Environment The Greenbelt land at Lye Green, North East of Chesham is of intrinsic value to wildlife, particularly due to the diversity of habitats contained within it. It is Grade 2 and 3 agricultural land (BMV land; Agricultural Land Classification Map) and comprises grazing and arable land, hedgerow, woodland, scrub as well as a large wildlife pond directly on its border. For this reason, a large diversity of bird, mammal, amphibian, and insect populations are present, including the flora to support them. CSA N56 states: ªA significant potential issue to be considered for Green belt locations is the fragmentation of habitats following development, reducing the connectivity of habitats.º CSA N86 states ªdevelopment is likely to result in a direct loss of habitat links.º These policies breach National Planning Policy Framework on two counts: NPPF 2.8c) ªan environmental objective ± to contribute to protecting and enhancing our natural environment; including helping to improve biodiversity.º NPPF 171 ªplans should: safeguard components of local wildlife-rich habitats.º 5.2 Biodiversity: Flora and Fauna
8845 The CSA N55 admits that ªDevelopment at all potential Green Belt locations is anticipated to have a negative effect on biodiversity for various reasons.º This is in direct contradiction to the NPPF 174 a ªPlans should protect and enhance biodiversityº NPPF174 b ªand identify and pursue opportunities for securing measurable net gains for biodiversity. The current state of nature is the UK is in serious trouble and the rapid decline of British wildlife is mirrored locally: in the last 40 years, eleven bird species have become extinct in this area, a further five species critically endangered and another twelve species in serious decline. It should be noted that the bird species most seriously affected are farmland birds. Of the bird species of the most highest conservation concern (red list), eleven species have been recorded at the Lye Green, North East of Chesham site together with a further eleven bird species on the Amber List (second most serious cause for concern). Given the local swift rate of decline, agricultural land able to support good bio-diversity should not be surrendered to developers. Further fauna occupying the land include three species of bats, badgers, hedgehogs, rabbits, foxes and muntjac deer are frequently seen. The large pond bordering the site is ideal for amphibians and may be inhabited by Great Crested newts. An extended phase 1 habitat survey which was carried out on part of the site in 2016 concluded that the site could be of value to protected species and recommended further surveys in order to adhere to wildlife legislation. Upon examination of the Councils' Evidence base, it does not appear that any of this work has been carried out. 5.3 Soil CSA N59 states ªSoil within the districts is a highly valuable and non-renewable resource. Many of the potential Green Belt locations are largely located on previously undeveloped land, which is undesirable due to potential for soil contamination, soil loss and erosion, loss of carbon sink and water filtering capabilities¼ many (sites) would require development of Grade 3 agricultural land. Development would therefore be likely to result in the loss of some of the district's most versatile and productive soils.º The land North East of Chesham is Grade 3 and some at Grade 2 (Agricultural Land Classification map London and the South East ALC007). Its current use is partly arable and partly grazing. CSA N91 states ªA significant quantity of development is proposed by the Local Plan, a large proportion on greenfield sites where it is expected that new buildings will result in the direct loss of the soil resource.The loss to BMV land would reduce the quantity of the most productive and flexible agricultural land that can best deliver food and non-food crops for future generations. Soil provides essential services to the local area that include nutrient cycling, abating flood risk, filtering water and carbon storage. Direct loss to soil through construction will reduce these essential ecosystem services.º The NPPF 170 states: ªPlanning policies and decisions should contribute to and enhance the natural and local environment by: a) protecting and enhancing¼.. soilsº 5.4 Water According to the CSA N60: ªNone of the potential Green Belt removal locations are anticipated to have a positive effect on water quality due to the significant increase in demand on water demand and treatment facilities. Water pollution may also be of concern. ªN92 ªThe Local Plan is likely to have negative impacts upon water. Inputs into the watercourse may cause significant harm to the quality of water. Development proposed within the Local Plan is likely to increase total water consumption. ª N87 ªDevelopment in the plan area¼ may exacerbate flood risk.º The NPPF 170 e) says: ªDevelopment should, wherever possible, help to improve local environmental conditions such as... water quality.º and NPPF 155. ªInappropriate development in areas at risk of flooding should be avoided..º Chesham Town Council believe that the development of the Green belt area at Lye Green would potentially lead to flooding. Brushwood Road and The Spinney, nearby already have a history of flooding issues. The capacity of Chesham Sewage Treatment works is already exceeded at periods of high rainfall. Thames Water confirmed that a further 20 waste storage tanks costing £20m would be needed to protect our chalk stream and natural environment but no additional capacity is planned. Local abstraction for the public water supply is already near the licensed limits. Multi-agency investigations have identified that the current level of abstraction from the local aquifer is having a detrimental impact on the River Chess. The Chess, which is an internationally rare chalk stream environment now runs dry for extended periods of time over a significant portion of its Chesham stretch. 5.5 Climate Change and Carbon Emissions CSA N87. ªProposed development within Local Plan is likely to increase the Plan area's carbon emissions by 21%º. This contradicts NPPF 148. ªThe planning system should support the transition to a low carbon future in a changing climate. It should help to: shape places in ways that contribute to radical reductions in greenhouse gas emissions.º Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5501587 Please attach any supporting evidence
Person ID 1212677 Full Name Mr Stephen Thorp ID 6143 Order 236
8846 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-03-12 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as
8847 precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The land North East of Chesham at Lye Green which has been identified as suitable to be taken out of green not believe this policy to be belt to meet housing targets; based on the evidence submitted by the Council is not soundly justified. positively prepared please It is claimed that the release of the green belt land is necessary as part of an overall three part strategy explain why involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. I have strong reservations about the soundness of such a broad policy and think the brownfield land opportunities that are generally closer to the town centre that are more sustainable than locations that are within Green Belt sites and in particular the Green Belt site NE of Chesham at Lye Green. The building on Green Belt land which will likely see many hundreds of dwellings will generate increased traffic, and although some highways improvements are suggested, they are insufficient and unfunded. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham is unable to accommodate any significant highway improvements anyway due to the already limited verges and space beside the highway, and combined with the topography of the town this means that there will be increased traffic congestion, with further worsening air quality. The air in Chesham has a huge problem due to the already poor air quality along Bekhampstead Road where there is a designated Air Quality Management Area that already is recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will make matters worse. Even with the introduction of cleaner automobiles which may result in Berhampstead Road's air quality falling within recognised safe limits, the level of traffic congestion due to the topography of Chesham will mean that massive delays will be present; the Council's traffic survey is out of date and flawed as it has not taken into account additional developments that have taken place in Hertfordshire since the traffic survey was carried out. The Green Belt site North East of Chesham (SP BP 2) is not a sustainable location. It is over 2Km away from the tube station and further still from the town centre but anyone who wishes to walk or cycle this distance also has to negotiate a very steep hill too. Such an unsustainable location cannot be made sustainable merely by upgrading a couple of public footpaths within the site into bridleways to facilitate cycling. Further doubt is put upon the ªsoundnessº of the Plan by the fact there being conflicting policies within it. The Council are of the view that the Green Belt site NE of Chesham is sustainable and provides easy access to public transport including the tube station yet the same Plan promotes a considerable increase in retail
8848 development in the town (local draft plan policy SP EP3), part of which would be built on the very car park that serves the Chesham tube station. This is inconsistent and unsound. Paragraph 136 of the latest NPPF asserts that Green Belt boundaries should only be modified in ªexceptional circumstancesº. The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances. The Council engaged third party consultants to undertake the Part 1 Green Belt assessment and they identified numerous sites for ªfurther considerationº where exceptional circumstances ªmightº exist but expressly recommended further review of their assessment of each site against the 5 purposes of land being in Green Belt of all these sites. Unlike the neighbouring Local Authorities, the Part 2 Green Belt assessment was not undertaken by third party consultants but by the Local Authority itself who notably then did not undertake all the recommended reviews of each site including the land NE of Chesham at Lye Green (SP BP 2). Accordingly, this oversight in the Part 2 Green Belt assessment placed premature focus and fixation on releasing land at Lye Green NE of Chesham from Green Belt designation. The subsequent identification of the Chesham site for release is therefore unjustified. These comments apply equally to proposals effecting the villages in the Green Belt ± policies SP PP1 & DM PP1). The primary aim of Green Belt land (as recited in NPPF 133) is to prevent urban sprawl and to preserve the openness of the area. Areas such as Lye Green and Orchard Leigh will become a part of Chesham and will lose their unique identity. A further aim of Green Belt designation stated in the NPPF at paragraph 134 (e) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. By allocating Green Belt land NE of Chesham for development, undermines this aim within Chesham. A community lead not for profit organisation called Chesham Renaissance CIC has been striving to create Chesham Masterplan that would not only provide many genuinely affordable homes in more sustainable locations nearer the town centre, but which would also regenerate some of the more deprived wards within Chesham. The Local Authority's proposals (policy SP EP3) are inconsistent with this local initiative and are therefore also inconsistent with national guidance and are consequently unsound. National Planning Policy Framework (NPPF) as revised only last year, states in paragraph11 (b) I, directs ªplan makersº to create policies that are required in Local Plans for housing and other uses unless Framework policies (expressly including Green Belt) ªprovides a strong reason for restricting the overall scale type or distribution of development in the plan areaº Accordingly, I submit that given all of the above the land being proposed for release from Green Belt designation around Chesham is unjustified and contrary to national guidance. I feel the land NE of Chesham is an unsustainable location for development, it is a registered asset of community value that has been habitually used by the community for improved health & wellbeing for decades and the land performs well against Green Belt aims and objectives. Exceptional circumstances for reviewing Green Belt boundaries at this location, either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by Govt Policy and therefore the plan is unsound. PP Mods - Please specify as I refer to the comments previously submitted but in summary would say that: precisely and succinctly as · All other options must be fully and diligently explored including increased density of possible how you would modify this policy to improve development of brownfield land and the policies emerging from the Chesham Masterplan. its alignment to this test of · Green Belt land should only be considered when all other options are fully exhausted and in any event the soundness. proposals for developing land NE of Chesham (policy SP BP 2) should be removed as it is an unsustainable location the development of which will cause harm to the wider town including loss of an asset that improves the well-being for the community. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I am of the opinion that the Local Plan is not legally compliant as it has not followed the National Policy and believe this policy in guidance issued by the Secretary of State. consistent with the National Local Authorities are required to adhere to the National Planning Policy Framework (NPPF) together with Planning Policy Framework other guidance issued by the Government and are required to show they have exhausted all options before Feb 2019 please explain why considering altering Green Belt boundaries. Regretfully the Local Plan seeks to change many Green Belt Boundaries and proposes to make modifications to 13 areas within the Districts along with changing the Green Belt status of Villages in the South Bucks and Chiltern areas. I therefore conclude that the authors of the draft Local Plan have not followed the relevant Government guidance requirements, resulting in a non-legally compliant draft Local Plan.
8849 Additionally, Paragraph 11b) of the NPPF (and associated footnotes) requires Planners to provide for objectively assessed needs for dwellings and other uses unless the application of the Framework polices (including Green Belt) provide a good reason for restricting the overall scale, type or distribution of development in the plan area. Both Chiltern and South Bucks are very much constrained by development policies that include Green Belts and Areas of Outstanding Natural Beauty. The Local Plan does not align with National Guidance - therefore the Local Authority is not compliant from a legal stance to claim that housing needs is a substantial enough reason to justify a review of Green Belt boundaries. The Government has also stated its aim for the UK to have net zero carbon emissions by 2050 and it is observed within the Sustainability Appraisal supporting this Draft Local Plan, that the Plan area is forecast to see carbon emission increase by 21% in the Plan Period; clearly the Plan is inconsistent with Government Policy and therefore not legally compliant. It can be determined that there is a large infrastructure funding gap too, as acknowledged within the Community Infrastructure Levy evidence that supports the Local Plan; it is estimated there is a shortfall of between £179m & £231m. Given this infrastructure is vital to ensure that proposed development is sustainable (as also required by the NPPF), this further demonstrates the Plan is both unsound and not legally compliant. Policy 3a - Please specify as 1. Working with other authorities in the region and not just Aylesbury. It is unreasonable to take the view this precisely and succinctly as cannot be done as they are different Functional Market Areas and that cooperation is not required. possible how you would 2. Seeking wider cooperation could result in additional housing requirements being taken elsewhere. modify this policy to improve its alignment to this test of 3. A closer review of existing brownfield land sites ought to be taken, there has been some excellent work soundness. carried out by Chesham Masterplan by CIC Chesham Renaissance) for example. 4. Changes to existing Green Belt boundaries should only be considered as a last resort only after all other options have been pursued. 5. Taking into account any developments, both current and or proposed that neighbouring authorities may have, i.e. Dacorum Council in Hertfordshire. Policy-level file upload - Please attach any supporting evidence
Person ID 1224583 Full Name Christopher Mead ID 6158 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to
8850 make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this
8851 to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The policy is not positively prepared because it does not achieve sustainable developments. Policy SP BP2 not believe this policy to be to allocate Green Belt land NE of Chesham for housing is deeply flawed on this count. AS the site is not near positively prepared please to the town centre, the development of 500 houses will increase traffic as most of the new residents will be explain why travelling by car to access the town centre or areas at greater distance. The evidence in Chesham shows that most of the road junctions and infrastructure is already operating above capacity. For example it is now impossible to get a seat on a Metro line train after 7 a.m in the rush hour. Chesham station is 2 Kms away which inevitably means that many more people will be using their cars, which, in turn, puts pressure on the car parks. WE are also concerned about the volume of traffic around Brushwood School on the ©school run© at present. In Chesham as a whole there is also the concern about air pollution. For example, the air quality along Berkhamstead Road is designated an Air Quality Management Area. The community lead not-for-profit organisation Chesham Renaissance C/C has been striving to create a Chesham Masterplan that would not only provide many affordable homes in more sustainable locations nearer the town centre but also regenerate areas of neglect in Chesham. The Local Authority©s proposals are inconsistent with this initiative and are, therefore, also inconsistent with national guidance.This is another reason for the Plans unsoundness. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not Firstly, we wish to state that the plan is not legally complicit on two counts. Policy SP BP2 to remove land believe this policy in NE of Chesham at Lye Green from the Green Belt does not comply with the National Planning Policy consistent with the National Framework which states that there have to be ©exceptional circumstances© for redefining Green Belt boundaries; Planning Policy Framework it cannot be for housing alone. Feb 2019 please explain why Furthermore, the plan is not the most appropriate strategy for development in Chesham. By allocating Green Belt land NE of Chesham for development the aim of Green belt designation as stated by the NPPF at paragraph 134 ©to assist in urban regeneration by encouraging the recycling of derelict and other urban land© is undermined. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1224136 Full Name Thames Water ID 6045 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details
8852 Consultee Type - Please Employer select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Thames Water Consultee is an agent on behalf of: Person ID 1223956 Full Name Carmelle Textor Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence
8853 Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Waste response not believe this policy to be The scale of development/s is likely to require upgrades to the wastewater network. It is recommended that positively prepared please the Developer and the Local Planning Authority liaise with Thames Water at the earliest opportunity to agree explain why a housing and infrastructure phasing plan. The plan should determine the magnitude of spare capacity currently available within the network and what phasing may be required to ensure development does not outpace delivery of essential network upgrades to accommodate future development/s. Failure to liaise with Thames Water will increase the risk of planning conditions being sought at the application stage to control the phasing of development in order to ensure that any necessary infrastructure upgrades are delivered ahead of the occupation of development. The developer can request information on network infrastructure by visiting the Thames Water website https://developers.thameswater.co.uk/Developing-a-large-site/Planning-your-development. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
8854 Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1213657 Full Name Mr Bill Richards ID 6073 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Clerk Chesham Town Council Consultee Type - Please Parish Council select the type of consultee: Date Received - Date 2016-04-06 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible.
8855 Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do A lack of a complimentary employment or mixed use development in Chesham will result in the likelihood of not believe this policy to be more residents working out of town, thus adding to the pressures on existing transportation provision and positively prepared please being of no material economic benefit to Chesham. explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
8856 Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1224612 Full Name Dr Lucy Murfett ID 6237 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Chilterns Conservation Board Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be
8857 as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public?
8858 Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not The Council's own landscape evidence Landscape Capacity Study for Green Belt Development options by believe this policy to be Terra Firma has been ignored in proceeding with this allocation, which recommends only a reduced justified please explain why development area (shown in purple hatching on the diagram below) for 115 dwellings.There is no landscape capacity for 500 dwellings. The Terra Firma report concludes that ªThe development of site 1 is constrained by the need to protect the separate identities of the settlement of Lye Green and Chesham, protect the setting of the AONB and retain characteristic views across the site. It is also constrained by the need to conserve the woodland blocks, trees and hedgerows for their ecological and landscape value, protect the setting of nearby listed buildings and protect the rural character of Lye Green Road.º It also recommends ªCompensatory landscape improvements to the remaining surrounding Green Belt land should take into account the guidelines of the Chiltern District Landscape Character Assessment and objectives of the Chilterns AONB to conserve and enhance its natural beauty and setting. Opportunities for enhancements include managing woodland, hedgerows, farmland for their landscape and biodiversity value and restoring orchards and pre 18th century field enclosures. Other improvements could include enhancing accessibility from Chesham and nearby settlements to the surrounding countryside and AONB whilst maintaining local character and biodiversity interest. Improvements and provision of green infrastructure where landscapes can provide multiple benefits including enhancing landscape character, providing opportunities for recreation and storage of carbon and water should also be explored.º But the policy does not take this forward, referring only to a `comprehensive landscaping schemeº which only covers the site itself and provides no off-site enhancements in the surrounding countryside. Policy 2a - Please specify as Reduce numbers to 115 and to the development area recommended in the Council's study. precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not This large greenfield site is in the setting of the Chilterns AONB. The policy should address the setting of believe this policy in the AONB, which is covered by CRoW Act Section 85 (ªor so as to affectº) and is the subject of a new consistent with the National paragraph of guidance in the July 2019 updates to the Government's Planning Practice Guidance: ªHow Planning Policy Framework should development within the setting of National Parks, the Broads and Areas of Outstanding Natural Beauty Feb 2019 please explain why be dealt with? Land within the setting of these areas often makes an important contribution to maintaining their natural beauty, and where poorly located or designed development can do significant harm. This is especially the case where long views from or to the designated landscape are identified as important, or where the landscape character of land within and adjoining the designated area is complementary. Development within the settings of these areas will therefore need sensitive handling that takes these potential impacts into account.º Paragraph: 042 Reference ID: 8-042-20190721. Revision date: 21 07 2019. The Chilterns Conservation Board considers that: · the proposed major expansion of Chesham is likely to increase traffic and air pollution through the AONB, · increase recreational pressure on the AONB, and · affect the chalk streams through increased abstraction to service the 500 new dwellings, most likely to be taken from Alma Road at the head of the River Chess, one of the finest chalk streams in the Chilterns which suffers from chronic low flows. A recent Environment Agency report ªThe Upper Chess Low Flows Investigationº confirms there is a causal link between current abstraction and low flows in the River Chess. There is also a threat from effects of increased sewage load on the Chesham STW which periodically releases sewage effluent into the River Chess.
8859 Policy 3a - Please specify as Reduce development to within environmental limits, based on a landscape-led approach, and protecting the precisely and succinctly as River Chess. possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1224518 Full Name Geltex Properties Limited ID 6260 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Other select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Geltex Properties Limited Consultee is an agent on behalf of: Person ID 1210980 Full Name Mr Gary Thomas Organisation Details Director Planning Works Ltd Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including
8860 references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would
8861 modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as The second part of the Policy beginning with "Planning permission will be granted for..." is precisely and succinctly as from original Framework guidance published in 2012 and should, therefore, be amended to reflect the possible how you would modify this policy to improve wording of the current Framework (paragraph 11) published in February 2019. The suggested its alignment to this test of replacement wording is: soundness. "Proposals that accord with this plan (and any relevant, with neighbourhood plan) will be granted planning permission without delay. Where there are no relevant development plan policies, or the policies which are most important for determining the application are outof- date, planning permission will also be granted unless: 1. the application of policies in the Framework that protect areas or assets of particular importance provides a clear reason for refusing the development proposed; or 2. any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies of the Framework taken as a whole." Policy-level file upload - Please attach any supporting evidence
Person ID 1223261 Full Name Vanessa Worship ID 6102 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Local Interest Group/Amenity Society select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Chesham Connect Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to
8862 relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary
8863 to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do We are writing on behalf of Chesham Connect to express our concerns about the recently published Local not believe this policy to be Plan for Chiltern and South Bucks and to submit our comments to the Independent Planning Inspector. positively prepared please Chesham Connect is the revitalisation group for Chesham and our aim is to support and encourage community explain why groups and charities to develop and improve the local area. We recognise the importance of the town centre and the vital role it plays in the lives of those who live and work in Chesham. As such we have been closely engaged in the development of the Chesham Masterplan and welcome opportunities to improve and enhance the town centre.We are also working with town centre businesses to understand more about their aspirations and ideas for the town as well as supporting wider tourism projects with the district council. We have come to the conclusion that the Local Plan as it stands is unsound for the following reasons: Firstly, according to LEPUS, the developments proposed in the Local Plan will result in an increase in the carbon footprint of the Chiltern/South Bucks area of 21% or more (Sustainability Appraisal of the Chiltern and South Bucks Local Plan, Table N4, p. xxxiii). Given the most recent research into climate change, this is not acceptable. Even if some mitigating steps were to be taken, there is no evidence proffered that these would offset the increase in greenhouse gas emissions. Secondly, there is the issue of additional housing. Chapter 3 - Sustainable Places, para. 3.1.2 states that `the Councils will strive to conserve the environment whilst also promoting sustainable economic growth' and will `conserve the Green Belt through the planning process, whilst balancing the need for housing'.Yet the Local Plan proposes to remove 60 hectares of Green Belt land at Lye Green on the outskirts of Chesham for housing (Policy SP BP 2). This site is 2.5 km from the town centre and at the top of a steep hill, not within practicable walking or cycling distance, so any future residents either working in Chesham or commuting to London would have to drive into the town. Clearly this development, if built, would substantially increase the present rush hour traffic congestion in the town, and add to air pollution, which is already at dangerous levels. For example, Berkhamstead Road is a designated Air Quality Management Area where the air quality is already above EU safe levels. Building on this site would also destroy an area which has recently been officially listed as an Asset of Community Value and thus plays a vital role in the health and well-being of the local population. We understand that there have to be `exceptional circumstances' in order for land to be removed from the Green Belt and that housing needs alone are not considered by the courts to be `exceptional circumstances'. Therefore we consider that this policy is unsustainable and therefore unsound. We would suggest that a viable alternative would be to look at more sustainable proposals, such as those provided by the Chesham Renaissance CIC Masterplan (https://cheshammasterplan.org). This envisages higher density housing developments on brownfield sites, within or close to the town centre, with the aim of revitalising Chesham and making it a better place to live and work. It seems extraordinary that this Masterplan, which has the approval of 70 per cent of Chesham residents who responded to a survey, many local councillors, and the MP for Amersham and Chesham, Cheryl Gillan, was totally ignored by the authors of this Local Plan. At the very least, a review of brownfield sites in the area needs to be carried out to identify sites which may have been overlooked previously or could perhaps provide higher density housing than a large out-of-town housing estate would offer. Our own research has shown that there is a need for more housing in Chesham but this is mainly for smaller one or two-bedroomed dwellings within walking distance of the station. Thirdly, we understand that the Local Plan has an infrastructure funding gap of between £179m and £231m (CIL Funding Gap Analysis June 2019). How can this be justified? Where is the additional funding going to come from? This is another indication that the Local Plan has not been thought through and is therefore unsound. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why.
8864 PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5501713 Please attach any supporting evidence
Person ID 1224518 Full Name Geltex Properties Limited ID 6283 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Other select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Geltex Properties Limited Consultee is an agent on behalf of: Person ID 1210980 Full Name Mr Gary Thomas Organisation Details Director Planning Works Ltd Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally
8865 compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why
8866 PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
Policy 1 - If you do not 2.85 The principle of the proposed allocation is strongly supported in order to help meet the identified believe this policy to be development need of the Councils. justified please explain why 2.86 The proposed allocation (save for some inconsequential boundary differences) is wholly within the freehold ownership and/or control of two parties - Geltex Properties Limited and Countryside properties (UK) Limited as shown on Appendix 2 The allocation boundary should therefore be adjusted accordingly. 2.87 The allocation can, therefore, be delivered without reliance on any other third party land. 2.88 This includes the provision of public open space as part of the development alongside the non- residential uses proposed within the allocation. 2.89 Viability testing of the site against the Policy requirements (including public open space, the non- residential uses proposed and the provision of necessary infrastructure) has demonstrated (subject to some detailed comments below) that the proposed allocation is viable. In particular, the site will be able to deliver policy compliant levels of affordable housing. 2.90 The Councils evidence base on viability (produced by the Dixon Searle Partnership) has been reviewed and specific comments made in Appendix 5. There are concerns over some of the inputs and assumptions made in the Councils evidence base, including an assumed density of 35 dph. This density is less than the capacity masterplanning work has demonstrated which is robust and considered and which takes account of emerging DM policies (see Appendix 4). 2.91 The expected housing trajectory from the site (for both a single or double outlet) is set out in Appendix 6 and is based on case studies in other developments. 2.92 The Plan should include these trajectory figures. 2.93 In relation to the specific requirements of the Policy, there are some elements which need to be considered further.
Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1224455 Full Name John Stanley ID 6301 Order 236 Number 11.3
8867 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID 1224454 Full Name Ken Dijksman Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible.
8868 Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not This allocation does not provide a genuinely ªmixed-useº development incorporating a material quantity of believe this policy to be new commercial or industrial floor space and as such it fails in the economic aspects of sustainability. This justified please explain why new housing will generate an increased requirement for employment which is not being met in the immediate vicinity. It is suggested in the policy that public transport opportunities will be improved to existing employment within the town. However, to add at least 500 new dwellings to Chesham without a corresponding increase in employment is essentially unsustainable and is likely to give rise to out commuting which is undesirable and contrary to the broad intentions of both the emerging local plan and the NPPF.The Western boundary of the land is defined by the edge of the Area of Outstanding Natural Beauty. The land we wish to see allocated was specifically omitted from the AONB because topographically and in landscape terms it is distinct and separate from that protected landscape. Therefore, to extend the area of greenbelt release to the AONB boundary is logical and enables the allocation of additional land for employment purposes without causing landscape harm or undermining the purposes of the greenbelt in this vicinity. Policy 2a - Please specify as Extend the greenbelt release to the north-east of Chesham to include the area of land shown on the attached precisely and succinctly as plan. possible how you would · Allocate the 4.3 ha parcel of land shown on the accompanying location plan for employment purposes to modify this policy to improve be delivered in tandem with and as part of the masterplan for the Chesham urban extension. its alignment to this test of soundness. · The land proposed is available now and it benefits from an extensive road frontage and an existing access, it is deliverable. Policy 2 - If you do not Objections are raised to these policies on the basis that they are not in accordance with the clearly expressed believe this policy to be priorities of the NPPF (including paragraphs 8 to 11); they will not be effective in delivering sustainable effective please explain why. development. It is evident that the proposed removal of land to the
8869 north east of Chesham from the greenbelt and the associated allocation for a residential led development under policy SP BP 2 is an unsound proposal which is essentially unsustainable. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5512867 Please attach any supporting evidence
Person ID 1214979 Full Name Mrs Georgina Mead ID 6156 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-12-12 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this
8870 modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The policy is not positively prepared because it does not achieve sustainable developments. Policy SP BP2 not believe this policy to be to allocate Green Belt land NE of Chesham for housing is deeply flawed on this count. AS the site is not near positively prepared please to the town centre, the development of 500 houses will increase traffic as most of the new residents will be explain why travelling by car to access the town centre or areas at greater distance. The evidence in Chesham shows
8871 that most of the road junctions and infrastructure is already operating above capacity. For example it is now impossible to get a seat on a Metro line train after 7 a.m in the rush hour. Chesham station is 2 Kms away which inevitably means that many more people will be using their cars, which, in turn, puts pressure on the car parks. WE are also concerned about the volume of traffic around Brushwood School on the ©school run© at present. In Chesham as a whole there is also the concern about air pollution. For example, the air quality along Berkhamstead Road is designated an Air Quality Management Area. The community lead not-for-profit organisation Chesham Renasissance C/C has been striving to create a Chesham Masterplan that would not only provide many affordable homes in more sustainable locations nearer the town centre but also regenerate areas of neglect in Chesham. The Local Authority©s proposals are inconsistent with this initiative and are, therefore, also inconsistent with national guidance.This is another reason for the Plans unsoundness. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not Firstly, we wish to state that the plan is not legally complicit on two counts. Policy SP BP2 to remove land believe this policy in NE of Chesham at Lye Green from the Green Belt does not comply with the National Planning Policy consistent with the National Framework which states that there have to be ©exceptional circumstances© for redefining Green Belt boundaries; Planning Policy Framework it cannot be for housing alone. Feb 2019 please explain why Furthermore, the plan is not the most appropriate strategy for development in Chesham. By allocating Green Belt land NE of Chesham for development the aim of Green belt designation as stated by the NPPF at paragraph 134 ©to assist in urban regeneration by encouraging the recycling of derelict and other urban land© is undermined. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1211260 Full Name Mrs Sue Moffat ID 6347 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Town Clerk Gerrards Cross Town Council Consultee Type - Please Parish Council select the type of consultee: Date Received - Date 2016-02-09 Received:
8872 Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance
8873 with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do SP BP2 ± SP BP11 not believe this policy to be Should include exact increase in numbers of school places, health facilities required and how and where positively prepared please these will be made available ± the methodology of how numbers of school places, health facilities etc are explain why calculated should be included in the interests of transparency. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
8874 Policy-level file upload - Please attach any supporting evidence
8875 Person ID 1212464 Full Name Mrs Sally Barter ID 7058 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-03-13 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness?
8876 Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The objection is set out in full under SP LP 2 Homes - Site Allocations and its appendices not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve
8877 its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1213404 Full Name Prof David Thomas ID 527 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-03-14 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible.
8878 Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I believe that the draft local plan and the way it deals with the removal of land from the Green Belt for housing not believe this policy to be (particularly at the Lye Green Site) is unsound and goes against the wishes of the local community and the positively prepared please NPPF. explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
8879 Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not Green Belt boundaries should be modified only in exceptional circumstances (NPPF para 136). These are believe this policy in not. NPPF 133 specifies that the Green Belt is to prevent urban sprawl. the Lye green site does this and is consistent with the National a real asset for the local community. Green belt is also needed to prevent communities merging (NPPF para Planning Policy Framework 134).The Lye Green site does just that. The green belt assessment part 2 was done by the council itself Feb 2019 please explain why (unlike neighbouring authorities) rather than by 3rd party consultants. This has led to the premature fixation on this easy option of just releasing the land at Lye green from the Green Belt. Insufficient thought has been devoted to the very costly infrastructure these extra houses would require. Road improvement would be essential, but would be difficult with the restrictions imposed by Chesham topography. Lye Green is too far from the town centre for most people to walk and its too hilly for most to cycle. The town centre car parks couldn©t cope with the extra cars and yet the council are considering building on the station car park (local plan policy SP EP3)! urban regeneration should use brown field sites (NPFF para 134e). Chesham renaissance CIC has been working on a chesham master plan to provide the extra homes near the town centre, within easy access of the station. I support the BROWN NOT GREEN organisations initiatives to have the land at Lye Green lsited as an ©Asset of Community Value! furthermore, I am happy for them to speak for me re: objections to the draft local plan. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1213657 Full Name Mr Bill Richards ID 6594 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Clerk Chesham Town Council Consultee Type - Please Parish Council select the type of consultee: Date Received - Date 2016-04-06 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider
8880 the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to
8881 Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Chesham Town Council is not objecting to the Local Plan as a whole, but we are concerned that we were not believe this policy to be not involved in discussions on the development of the plan prior to the public consultation period. As a result, positively prepared please we have severe reservations about particular parts of the Local Plan. Our key areas of concern are: explain why · The decision to identify a large Green Belt site for development, rather than higher density housing in the town centre in line with the Chesham Masterplan. · Key Economic Sites continue to be located in the town centre, as opposed to the Masterplan's vision of sites on the periphery of the town. · Inadequate car parking provision in the town centre, which will damage the sustainability of the High Street, made worse by the proposed removal of existing car parks. · Retail allocation for Star Yard car park, which we are not confident will come forward. · A weak policy for sustainable drainage which will fail to protect Chesham from flooding and pollution. · The fact that the Sustainability Appraisal identifies that the Local Plan will reduce local water quality and increase pressure on water resources. · Inadequate planning for the increased demand for wastewater services. · The fact that the IDIDS that is out of date and doesn't articulate urgent infrastructure provision that is needed now and in the future. · The impact of the proposed areas of development on the town's air quality, particularly in the Air Quality Management Area. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not The Town Council does not believe that the identification of the site to the North East of Chesham is justified. believe this policy to be It does not accord with the Government's own National Guidance on Green Belt development, namely that justified please explain why it needs to be sustainable; should not have an unacceptable effect on the Green Belt and should only be considered in `exceptional circumstances': The Town council would strongly challenge the suitability of the site in terms of sustainability and viability for the following reasons: · The increased housing and resident numbers would lead to a projected 400% increase in traffic delays at the White Hill roundabout already deemed at full capacity. These figures do not yet include the inevitable additional traffic increases caused by the services and sub-contractors supporting the construction of HS2, which will further exacerbate our traffic congestion. This is particularly pertinent due to the proximity of the depot servicing the end of the tunnel near the site of the former Annie Bailey's restaurant in Hyde End. Moreover, Berkhampstead Road and Broad Street are already designated an Air Quality Management Area and it is incumbent on all authorities under national law, including the District Council, to actively promote measures that will decrease pollution levels rather than increase them. · The increase in housing would lead to a projected 200% increase in traffic delays at the Blucher Street roundabout already deemed at full capacity. Again, as a lead authority campaigning against HS2, it is vital that the District Council factor in the inevitable increases in traffic needed to service HS2. · The lengthy queues and delays caused by the above (exacerbated by limited public transport and additional traffic trying to access the Metropolitan Line station in the town centre for trains to London) would discourage people from visiting the town centre. This in turn would have a direct impact on the economic well-being of many small businesses and undermine a lot of good historic and ongoing work designed to revitalise the High Street.Work recognised by the District when they recently selected Chesham high street as the preferred settlement to be the subject of a Future High Street Fund application. The Town Council does not believe that the proposals for car parking and retail space are appropriate. In 2017, the SWOT analysis of Chesham town centre in Chiltern District Council's Retail and Leisure Study stated that Chesham is oversupplied with retail space. Retail floorspace projections in the Local Plan come from the Town Centre Retail and Leisure Study (TCRLS), which is based on outdated 2016 data. The 2019 Peer Review and Update of the TCRLS states that there is a limited need to allocate sites for comparison goods retail and food/beverage floorspace. It also says that January 2019 observations suggest the vacancy rate in Chesham town centre units has increased since the study was done. As vacant units can help to
8882 accommodate future growth, we believe that the amount of new floorspace should be revised downwards accordingly. In line with our support for higher density housing in Chesham town centre, the Town Council questions the soundness of the proposals for key land use in the town centre as specified within the Local Plan. We believe that the proposed enterprise/retail allocations for Chesham will severely limit possible housing development and will impact on the town centre's independent retail sector, with no guarantee that large scale retailers will come forward. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not The type of housing that Chesham needs includes small starter units, affordable housing and smaller homes believe this policy to be for the elderly where people are typically less mobile. None of these are suitable or appropriate on a site effective please explain why. such as this on the edge of town and isolated from crucial support facilities. The Town Council has a clear preference for higher density housing closer to the town centre, which we believe can be delivered through a credible alternative development plan which includes a number of different sites, for example, the site at Higham Mead. · Releasing this land from the Green Belt would encroach on the countryside, leading to urban sprawl. The location of this site would also result in the unacceptable absorption of the historic hamlet of Lye Green into Chesham. Lye Green includes three listed buildings, a historic farm and a pub of historic interest, which is also a community facility. Such absorption is in direct contravention of Green Belt policy PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1214441 Full Name Dr Caroline Houlihan-Burne ID 829 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-12-04 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider
8883 the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to
8884 Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not I consider the plan to be unsound. The land NE of Chesham is an unsustainable location for development. believe this policy to be It has been used by the local community for recreational purposes and it fulfils Green Belt aims and objectives. justified please explain why Exceptional circumstances for reviewing Green Belt boundaries at this location, either do not exist or are insufficient to warrant removal of this land from Green Belt designation as required by Government Policy. Policy 2a - Please specify as The plans to develop the land NE of Chesham (policy SP BP 2) should be removed due to its unsustainable precisely and succinctly as location and the fact that development with cause harm to the community of Chesham. possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not The foregoing also points to flawed methodology of Green Belt site selection used by the Local Authority, believe this policy in which is neither effective, justified nor consistent with national policy and as such is unsound. Specifically, consistent with the National the selection of the land NE of Chesham at Lye Green (policy SP BP2) for removal from Green Belt designation Planning Policy Framework is inconsistent with National Planning Policy Framework (NPPF). Feb 2019 please explain why Paragraph 136 of the latest NPPF asserts that Green Belt boundaries should only be modified in ªexceptional circumstancesº. The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances. The Council engaged third party consultants to undertake the Part 1 Green Belt assessment and they identified numerous sites for ªfurther considerationº where exceptional circumstances ªmightº exist but expressly recommended further review of their assessment of each site against the 5 purposes of land being in Green Belt of all these sites. Unlike the neighbouring Local Authorities, the Part 2 Green Belt assessment was not undertaken by third party consultants but by the Local Authority itself who notably then did not undertake all the recommended reviews of each site including the land NE of Chesham at Lye Green (SP BP 2). Accordingly, this oversight in the Part 2 Green Belt assessment placed premature focus and fixation on releasing land at Lye Green NE of Chesham from Green Belt designation. The subsequent identification of the Chesham site for release is therefore unjustified. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1213726
8885 Full Name Growth & Infrastructure Unit ID 6941 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Principal Infrastructure Officer Hertfordshire County Council Consultee Type - Please Local Authority select the type of consultee: Date Received - Date 2016-04-07 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness?
8886 Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve
8887 its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why
Policy 3a - Please specify as Policy SP BP2 suggested that on-site provision of a community hub which includes at least a one form entry precisely and succinctly as primary school and a pre-school will be possible how you would provided with the development, and further suggested that financial contributions would be arranged to fund modify this policy to improve secondary school places. Considering that the infrastructure will be provided either on-site or through financial its alignment to this test of contributions, the potential development proposed is unlikely to have any significant impact on school places soundness. in Bovingdon and Berkhamsted (that lie within the administrative boundary of Hertfordshire County Council)
Policy-level file upload - Please attach any supporting evidence
Person ID 1214236 Full Name Mr Richard Brock ID 6493 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-11-21 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be
8888 as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The low priority given to infrastructure given that Chesham can expect a huge number of new dwellings and not believe this policy to be probably a 20% growth in population. No real details are shown relating to increasing the number of doctor positively prepared please and dental surgeries and school places. Water supplies, sewage capacity and roads are also dealt with only explain why fleetingly. PP Mods - Please specify as precisely and succinctly as possible how you would
8889 modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1214336 Full Name Mrs Alice Adderley ID 382 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-11-29 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant,
8890 including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s),
8891 do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I believe this plan is not legally justified because it wants to allocate green belt land NE of Chesham for not believe this policy to be housing when this site has been used for decades for informal recreation and is probably going to be listed positively prepared please as an "Asset of community Value© and the courts have heard that housing needs alone are not "exceptional explain why circumstances". I also don©t believe the Spatial policy (SP SP1) for sustainable development (to promote the recycling of previously developed brownfield sites) is consistent with the plans other proposed uses of green belt land to meet housing needs specifically at Lye Green. PP Mods - Please specify as Remove the proposed site NE of Chesham from the draft local plan. precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not The local plan is unsound in so many ways in regard to the proposed site NE of Chesham: believe this policy to be In the local plan itself under ©sustainability objectives© it says: ©Safeguard and improve community health, justified please explain why safety and well-being© is one of the key targets. How can this be consistent with destroying several acres of arable land which is also used by dog walkers, runners, kite fliers and picnicers on a regular basis? This are is soon to be designated an Asset of Community Value all being well. I don©t regard the site selection methodology to be appropriate, given that the site here is good quality agricultural land which is up a very steep hill and is about 1.5 miles from the town centre. This will only generate more traffic congestion and worsen air quality in Chesham. In the Buckinghamshire and Milton Keynes regional air quality strategy in 2006 it specifically mentions Berkhamsted Road which is one of the main roads in Chesham and would be adversely affected by the addition of five hundred new homes up a narrow hill: There are no significant industrial sources of nitrogen dioxide in the Chiltern District, with vehicles producing the largest percentage of air pollutants. In July 2003, an air quality Updating & Screening Assessment was undertaken and this indicated that some locations would require further passive monitoring. It was therefore decided to review the Council's monitoring programme. This resulted in redeployment of passive monitoring to other areas of the district and intensification in those areas that showed the greatest potential for elevated levels of NO2. The number of sites now monitored is 25 (minimum number), which was an increase of about 50%. Buckinghamshire and Milton Keynes Regional Air Quality Strategy 2006 Page 53 CDC completed an annual Progress Report for air quality in 2004. It concluded that the air quality objectives were likely to be met for all pollutants and a detailed assessment would not be required. It did however recommend further monitoring with passive diffusion tubes along Berkhampstead Road in Chesham, as this area was showing the greatest elevations of nitrogen dioxide. Passive monitoring is generally used to indicate areas where further monitoring or modelling work is required
A second Progress Report was carried out in April 2005. This concluded that targets for carbon monoxide, benzene, 1,3-butadiene, lead, sulphur dioxide and PM10 would be met. Air quality is an evolving subject with a constant supply of updated information, models, factors and technical methods. For this reason, the very latest assumptions and numerical factors were available for use in the 2005 Progress Report. Using these newer factors nitrogen dioxide still appears to be exceeding targets along the Berkhampstead Road. Consideration has also been given to any new major developments or changes in vehicle flows in the District.
Also this plan is not consistent with other local plan policies to protect wildlife habitats or biodiversity or to protect our local chalk stream rivers. This plan undermines them. A recent CPRE press release states: Making better use of suitable brownfield land for housing is one of the best ways to protect the countryside. But our analysis of new government figures show that the proportion of houses built on brownfield has fallen to a 5-year low.
8892 We need a brownfield first approach to realise its potential and stop the unnecessary loss of the beautiful countryside. Why was there no prior consultation on ©Green Belt Village Policies© nor any consultation on proposals to build so many new shops in Chesham, mostly on the town car parks? How can this be justified, effective or sensible when the planned new homes will likely mainly be sold to incomers who will want to commute to London? Where will they park? it is ludicrous to think they will walk the 1.5 miles from the tube station to the proposed site up a very steep hill. This has not been thought through at all. Finally government guidance in the NPPF tells plan makers to provide for housing and other uses unless green belt policies provide a strong reason not to. Why is this council doing otherwise and implementing a local plan that predicts a carbon footprint increase of 21%? This is unjustified and ineffective. Policy 2a - Please specify as Remove the proposed development of the land NE of Chesham from the draft local plan. Make a concerted precisely and succinctly as effort to look for brownfield sites in the town. possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1214611 Full Name Mrs Frances Reynolds ID 896 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-12-10 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant.
8893 Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as
8894 precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The development of Green Belt sites involving many hundreds of homes will generate increased traffic, and not believe this policy to be although some highways improvements are suggested, they are insufficient and unfunded. In Chesham the positively prepared please evidence shows that most of the road junctions and infrastructure is already operating above capacity. explain why Chesham becomes gridlocked frequently and the causes are varied including accidents, broken down vehicles, roadworks. There is no alternative route for Chesham residents to use when trying to get through Chesham when it is at a standstill. The sheer volume of traffic is too great for the town to cope with during rush hours without adding another 500 homes with a possible extra 1000 cars using the roads. The Councils have stated that release of some Green Belt is necessary as part of an overall three part strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. I question the soundness of such a general policy and whether all the brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites and in particular the Green Belt site NE of Chesham at Lye Green. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not Chesham cannot accommodate any significant highways improvements due to the already limited verges believe this policy to be and space beside the highway and combined with the structure of the town this means that there will be justified please explain why increased traffic congestion, with further worsening air quality. Air pollution has been a significant concern in Chesham for years due to the already poor air quality along Bekhampstead Road where there is a designated Air Quality Management Area that already is recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will generate more traffic and this will make the air quality even worse and insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable nor justified nor is it in accordance with Govt policy. The Green Belt site NE of Chesham (SP BP 2) is not a sustainable location. It is over a mile away from from the town centre and train station and up a steep hill . Such an unsustainable location cannot be made sustainable by upgrading a couple of public footpaths within the site into bridleways to facilitate cycling. Adding a bus stop is not going to solve any issues even if an enhanced bus service is provided as the current public transport options for this area of town are inadequate, infrequent and unreliable. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not Further doubt is cast upon the ªsoundnessº of this Plan by virtue of there being conflicting policies within it. believe this policy to be The Council seem to think that the Green Belt site NE of Chesham is sustainable and provides easy access effective please explain why. to public transport including the tube station yet the same Plan promotes a considerable increase in retail development in the town (local draft plan policy SP EP3) , part of which would be built on the very car park that serves the Chesham tube station. This is inconsistent and unsound. For this Plan to be sound it must also be effective. Unfortunately, further review of the proposal to remove land NE of Chesham at Lye Green from Green Belt designation is not effective as there are serious questions about the deliverability of this land. The main landowner is a farmer who has asserted publicly and in a letter to the editor of Your Chesham, that he is not prepared to release all of the land in his ownership for development. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve
8895 its alignment to this test of soundness. Policy 3 - If you do not The land is also potentially an Asset Of Community Value and upon confirmation of this designation it would believe this policy in afford a community group the right to bid for the land. The community group (Brown Not Green) have stated consistent with the National their intention is to preserve the land given that many hundreds of local people including myself and my Planning Policy Framework family have habitually used the fields at Lye Green as of right for various informal outdoor recreational Feb 2019 please explain why purposes. These uses themselves may mean that many local individuals including myself and family may have acquired easements over and across the land through prescription (20 years uninterrupted use) not least of whom would be the many private residences bordering the fields that have rear garden gates onto the fields at Lye Green. These easements and prescriptive rights may render the land very difficult to develop and make it undeliverable in planning terms. This land also provides an important habitat for wildlife that will be threatened by development of this land. It is perverse that the Local Authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Plan is unsound. The primary aim of Green Belt land (as recited in NPPF 133) is to prevent urban sprawl and to preserve the openness of the area. The Lye Green site (SP BP2) self-evidently performs this function well and has done so for decades. Another aim of Green Belt land stated in NPPF paragraph 134, is to prevent neighbouring towns and settlements from merging into one another.The Green Belt land NE of Chesham performs well in maintaining a partition between settlements of Chesham & Lye Green as well as helping to maintain separate identities of other nearby communities at Orchard Leigh, Botley, Whelpley Hill, Ashley Green. It is perverse and inconsistent with national guidance to allocate this land for removal from Green Belt in light of these facts especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if earmarked for development. A further aim of Green Belt designation stated in the NPPF at paragraph 134 (e) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. By allocating Green Belt land NE of Chesham for development, undermines this aim within Chesham. A community lead not for profit organisation called Chesham Renaissance CIC has been striving to create Chesham Masterplan that would not only provide many genuinely affordable homes in more sustainable locations nearer the town centre, but which would also regenerate some of the more deprived wards within Chesham. The Local Authority's proposals (policy SP EP3) are inconsistent with this local initiative and are therefore also inconsistent with national guidance and are consequently unsound. The Council have asserted that Government planning policy requires local councils to review Green Belt boundaries when considering how to accommodate the development needed in their areas. Just because the Council may be required to look, does not mean the Council should review Green Belt boundaries which as previously stated should only be modified in ªexceptional circumstancesº. I am supportive of the Brown Not Green organisation's initiative to have the land listed as an Asset of Community Value and I feel they speak for me in respect of their objections to the draft Local Plan. Accordingly, I request that any representations made by them at any future examination in public regarding the soundness of this Local Plan be considered as an extension of my own comments. Having lived in the area for over 50 years I have used the footpaths around this area frequently for family walks, dog walks and to access areas north of the town. I feel the land NE of Chesham is an unsustainable location for development, that has been habitually used by the community for improved health & wellbeing for decades and the land performs well against Green Belt aims and objectives. Exceptional circumstances for reviewing Green Belt boundaries at this location, either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by Govt Policy and therefore the plan is unsound. Policy 3a - Please specify as I refer to the comments previously submitted but in summary would emphasise that; precisely and succinctly as All other options are fully explored including increased density of development of brownfield land and the possible how you would policies emerging from Chesham Masterplan. modify this policy to improve its alignment to this test of Green Belt land should only be considered when all other options are exhausted and in any event the soundness. proposals for developing land NE of Chesham (policy SP BP 2) should be removed as it is an unsustainable location the development of which will cause harm to the wider town including loss of an asset that improves the well-being for the community. Policy-level file upload - 5492014 Please attach any supporting evidence
Person ID 1214453 Full Name Mr Steven Fayers ID 6607 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee:
8896 Date Received - Date 2016-11-29 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider
8897 the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The main drive from the plan seems to be to move people out of their cars onto foot, bicycle or public transport. not believe this policy to be The area covered under Policy SP BP2 to the NE of Chesham will not address any of these alternative modes positively prepared please for the following reasons: explain why Walking - The site is too far from the town centre, the main bus interchange and the Underground station. The site varies between 1.9km and 2.6km in distance with an elevation change of around 160 feet. As a healthy adult walking up White Hill (to my home which is not as far as the proposed site) I find it strenuous, and, if I have items to carry, I take the car. Cycling ± The primary roads from the proposed site to the town centre are not cycling friendly, and could even be considered unsafe.The roads are not wide enough, and the combined road andfootpath width would be insufficient to make a cycle friendly environment. The inclines of White Hill and Eskdale Avenue make cycling uphill virtually impossible for all but keen sportsmen. Public Transport ± The main public transport in Chesham is the Underground station terminus only providing routes southbound to London.Train frequency can be as low as 2 per hour. In comparison, Amersham station is both an Underground and main-line station, providing a higher frequency of trains southbound to London and options to travel northbound. Similarly Chalfont and Latimer station is both an Underground and main-line station benefitting from approximately double the frequency of trains to, and more importantly back from London. As a resident of Crossway, closer to Chesham Underground station than the proposed site I regularly drive to Chalfont and Latimer station to take a train to London. The primary reason is to avoid up to 30 minute wait for the `right train' home. It is likely that new residents in the proposed area would do the same, contributing to the traffic through Botley, Ley Hill and Latimer with some single-track roads already subject to unsustainable traffic levels. Driving ± Not everybody's journey follows public transport routes and thus use of the private motor car is a fact-of-life and increasing the number of homes will increase car-use. Any other factors such as incentives to switch from car use to other modes, or decreases of pollution linked to electric vehicles only vary the baseline upon which car-use will increase with increased homes. Chesham is already constrained in the ability for cars to get in and out of the area, with 2 main routes ± to the A41 via Ashley Green (primarily to link to the northern section of the M25 for journeys eastbound or the link to the M1 via Hemel Hempstead) and via the Chesham-Amersham corridor to the A416 and A355 (primarily to link to the M40 and western M25 for southbound journeys including to Heathrow and Gatwick Airports, and link to the M4 for westbound journeys). PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
8898 Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not The Chesham-Amersham corridor is specifically mentioned already in section 3.5.5 of the plan as a highway believe this policy to be network problem. To get to the Chesham-Amersham corridor from the proposed site, journeys would have effective please explain why. to be made through the natural valley that runs through Chesham where pollution is already a problem. Berkhampsted Road is already a designated Air Quality Management Area with pollution levels worse than EU safe levels. It does not address the needs of an ageing population (section 3.4.3) as it is too far from the town centre, amenities and medical facilities without the need to use a private car or taxi service. The policy SP EP3 aiming to increase retail capacity within Chesham town centre would further exacerbate traffic congestion and air quality problems. Given the transport considerations, the policy SP BP2 is not deliverable, it is ineffective and thus unsound. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1214939 Full Name Mrs Lyn Tarn ID 1009 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-11-23 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant.
8899 Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as
8900 precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I am writing this email to object to the use of the Green belt as apposed to Brown field sites. not believe this policy to be The loss of the Green belt only benefits those who move into the area, invariably from outer London, at the positively prepared please expense of those in Chesham who you are supposed to be representing. explain why Use of the Green belt will impact on everyone in Chesham who use it for recreation in its many forms, and which in my experience, brings together all members of the community regardless of background. The plan does not appear to make provision for Doctors surgeries, Dental Practices or Schools which are already at capacity and struggling to accommodate those who already use the service. It does not provide provision for a Police service which has impacted already on the crime rate in and around Chesham. It does not take into consideration the impact on the roads in and around Chesham which are also at breaking point due to the volume of traffic and the state of the roads in general. There are many Brown field sites which are suitable for development. In other areas, they build up rather than providing homes with gardens. This would provide more housing within a smaller area, potentially fulfilling the obligation to provide the number of homes required. Maybe flats with underground parking with communal gardens. I do not believe there is reason to object to the development of areas which are currently Brown field sites. I am aware that prior to the opinion of those in and around Chesham, the local plan was already signed off and that this is just for the benefit of saying that we had a say. This was mentioned by a member of the council to whom I was speaking a while ago. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
8901 Policy-level file upload - Please attach any supporting evidence
Person ID 1215326 Full Name Mr Anthony Usher ID 440 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-12-08 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications
8902 to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I question the soundness of the Local Plan general policy and whether all of the brownfield land opportunities not believe this policy to be have been identified and whether the council should be looking at higher densities of development on such positively prepared please sites which are generally closer to the town centre that are more sustainable locations than green belt sites explain why and in particular the green belt site North-East of Chesham at Lye Green. One of the main drivers for more homes is the rapid increase in single occupancy in dwellings which is ideally suited to high density living in town centres with relevent facilities for travel, work and leisure. The development of Green Belt sites involving many hundreds of homes will generate increased traffic and although some highways improvements are suggested they are insufficient. For example in Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham cannot accommodate any signifiant highways improvements due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion and further worsening of air quality. Air pollution is a particular concern in chesham due to the already poor air quality along Berkhamstead Road where there is a designated Air Quality Management Area that already is recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town in the Green Belt will generate more traffic which in turn will make the air quality even worse. Insofar as this relates to the green belt site at lye green NE of Chesham, this cannot be sustainable nor justified no is it in accordance with Government policy. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve
8903 its alignment to this test of soundness. Policy 1 - If you do not The Green Belt site NE of Chesham is not a sustainable location. It is over 2km away from the tube station believe this policy to be and slightly further still from the town centre but anyone who cares to walk or cycle this distance also has to justified please explain why negotiate a very steep hill in either white Hill or Nashleigh hill. Adding a bus stop does not address the geography or topography of the area unless the bus frequency is increased several fold from the current totally inadequate service. The demand for school places, doctors surgeries would exceed Chesham©s capacity which is already full. Chesham town centre is regularly flooded. The Green Belt site development would decrease grass area for water absorption and therefore increase flooding risk at the bottom of the hill. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not For this Plan to be sound it must also be effective. Unfortunately further review of the proposal to remove believe this policy to be land North East of Chesham at Lye Green from Green Belt designation is not effective as there are serious effective please explain why. questions about the deliverability of this land.The main landowner is a farmer who has asserted publicly and in a letter to the editor of "Your Chesham" magazine that he is not prepared to release all of the land in his ownership for development. The land is also potentially an asset of community value and upon confirmation of the designation it would afford a community group the right to bid for the land. The community group [Brown not Green] have stated their intention is to preserve the land given that many hundreds of local people have habitually used the fields at Lye Green as of right for various informal outdoor recreational purposes. These uses themselves may mean that many local individuals have acquired easements over and across the land from prescription [20 years uninterrupted use] not least of whom would be the many private residences bordering the fields that have rear garden gates into the fields at Lye Green.These easements and prescriptive rights may render the land very difficult to develop and make it undeliverable in planning terms. It is perverse that the local authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2001. As such this aspect of the plan is unsound. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not The foregoing also points to flawed methodology of Green Belt site selection used by the Local Authority believe this policy in which is neither effective, justified or consistent with national policy and as such is unsound. Specifically, the consistent with the National selection of the land NE of Chesham at Lye Green for removal from the Green Belt designation is inconsistent Planning Policy Framework with NPPF. Feb 2019 please explain why Paragraph 136 of the latest NPPF asserts that Green Belt boundaries should only be modified in ©exceptional circumstances©.The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances. The council engages third party consultants to undertake part 1 Green Belt assessment and they identified numerous sites for further consideration"where exceptional circumstances ©might© exist but expressly recommended further review of their assessment of each site against the 5 purposes of land being in Green Belt in all these sites. Unlike the neighbouring Local Authorities, the part 2 Green Belt assessment was not undertaken by third party consultants but by the Local Authority itself who notably then did not undertake all the recommended reviews of each site including the land NE of Chesham at Lye Green. Accordingly, this oversight in the part 2 Green Belt assessment placed premature focus and fixation on releasing land at Lye Green NE of Chesham from Green Belt designation. The subsequent identification of the Chesham sites for release is therefore unjustified. The primary aim of Green Belt [as recited in NPPF 133] is to prevent urban sprawl and to preserve the openness of the area. The Lye Green site self-evidently performs this function well and has done so for decades. Another aim of the Green Belt Land in NPPF paragraph 134 is to prevent neighbouring towns and settlements from merging into one another.The Green Belt Land NE chesham performs exceptionally well in maintaining a distinct separation between the settlements of Chesham and Lye Green as well as helping to maintain separate identities of other nearby communities of Orchard Leigh, Botley, Ley Hill, Whelpley Hill and Ashley Green. It is perverse and inconsistent with national guidance to allocate this land for removal from Green Belt in light of these facts, especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if earmarked for development. A further aim of Green Belt designation as stated in the NPPF at paragraph 134(e) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. Allocating Green Belt land NE of Chesham for development undermines this aim within Chesham. A community lead not-for-profit organisation called ©Chesham Renaissance CIC© "has been striving to create a Chesham masterplan that would not only provide many genuinely affordable homes in more sustainable locations nearer the town centre but which would also regenerate some of the more deprived wards of Chesham". This well researched plan has been totally ignored by Chiltern District Council. The local authority©s proposals are inconsistent with this local initiative and are therefore also inconsistent with national guidance and are consequently unsound. The Council have asserted that Government planning policy requires local councils to review Green Belt boundaries when considering how to accommodate the development needed in their areas. Just because the Council may be required to look does not mean that the council should review Green Belt boundaries, which as previously stated, should only be modified in ©exceptional circumstances©. The NPPF as revised
8904 only last year, states in paragraph 11[b]I, directs ©planning makers© to create policies that are required in local plans for housing and other uses unless framework policies [expressly including Green Belt] ©provides a strong reason for restricting overall scale, type or distribution in the plan area©. Accordingly, we submit that given all of the above the land being proposed for release from Green Belt designation around Chesham is unjustified and contrary to national guidance. We are supportive of the Brown Not Green organisations initiative to have the land listed as an Asset of Community Value and I feel they speak for us in respect of their objections to the draft Local Plan. Accordingly, we request that any representations made by them at any future examination in public regarding soundness of this Local Plan be considered as an extension of our own comments herin. We feel the land NE Chesham is an unsustainable location for development, that has been habitually used by the community for improved health and wellbeing for decades and the land performs well against green belt aims and objectives. Exceptional circumstances for reviewing Green Belt boundaries at this location either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by Government Policy and therefore the plan is unsound. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1216729 Full Name Mr Neil Lamond ID 72 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested
8905 modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be
8906 positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not Proposed planning permission to develop Green Belt land for 500 homes at Lye Green, Chesham, Bucks. believe this policy to be I would welcome the Inspector's intervention into what I and hundreds of others in our community believe is justified please explain why a very badly drafted housing plan for our Chiltern's town.The proposal fails on so many accounts that should be high in the Council's priorities and are clearly being side-lined. Firstly, removal of Green Belt status should be for only the most extraneous of circumstances, the Council have provided none that could remotely be considered fit into that category. In sacrificing our Green Belt ªlungº new build property should then be sustainable in this case it is most certainly not. We already experience over extraction of water by Affinity Water from our chalk aquifers, such that our precious chalk stream River Chess (a rarity in the world) has all but dried up in many places in the town. This has happened in the 45 years I have lived here and the town has expanded causing the issue. Sustainability also means we consider any increase in the carbon footprint, Chiltern District Council seem to have no idea what increase in the carbon footprint their actions will introduce. The proposed settlement is approximately 2 miles from Chesham town and will most certainly increase traffic flow along an already overcrowded single linear road through the town which is at the foot of a valley with no prospect of any relief road being built into the hillsides around it. It does nothing to reduce reliance on motor cars even when/if they eventually become electric. I understand the pollution in the Chesham valley floor (an Air Quality Management Area AQMA) from the current traffic is already four times the EU recommended levels and I would like the Inspector to decide if any increase is supportable along a road where children walk daily to and from schools. Please do not be misled by any cycle plans, the hills leading up to these green fields were designated a testing climb in the ªTour of Britainº when it passed through here a few years ago. What is put forward is not the most appropriate plan, something nearing that has been put forward by a local independent group and is called the ªChesham Renaissance CIC Master Planº.This plan has been developed over a number of years and has been shown over this long development period to the community for mass comment. It is sad that our elected Chiltern District Council figure no where in how they develop and communicate a far-reaching plan for the community, theirs was only released this month (June 2019). Surely the community matters most or maybe it doesn't! We must now put our faith in you, The Inspector, please do not let us and our next generations down. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1218099 Full Name Ann Goldstein ID 770 Order 236 Number 11.3
8907 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible.
8908 Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I really cannot believe that this development is even being considered. The area as it is becomes grid-locked not believe this policy to be at certain times of the day, especially along Chesham Road, Berkhamsted Road, Vale Road and Nashleigh positively prepared please Hill. The recent housing development at the top of Nashleigh Hill has further exacerbated the congestion explain why and traffic problems and nowhere in the proposed plan does it mention how these current problems will be addressed before the development begins, let alone with the increased congestion/pollution further development will create. The ©infrastructure© is not there to meet current demand. Getting an appointment to see the G.P. is like being granted an audience to see the queen - let alone hospital waiting times for specialist consultants/surgery. Again, creating these new developments will only add to the strain on already depleted services. Schools. All schools are over-subscribed and as a Consultant in Special Educational Needs and Disabilities I am acutely aware of the increasing numbers of children presenting with additional needs. Not only will this have an impact on local schools, it will also impact on the other services involving health (Speech and Language Therapy, Occupational Therapy, Physiotherapy, to name a few). My work is in North London where there are numerous housing initiatives and the impact on local nurseries, PVIs (Private, Voluntary and Independent nurseries) Childminders etc. has been unimaginable. These children often come from the most vulnerable families, requiring social services intervention. However, in addition to all of the above, I am absolutely devastated to think that Green Belt land is slowly but inexorably being ©stolen© from future generations. The law establishing Green Belts and other protected areas is there for a reason - we need it. The issue of climate change is not going to go away, especially if we continue to abuse our natural resources and think of only the here and now, not of the future. If you create this additional housing, what then? You are creating an environment which will in time create even more need as families have increasing numbers of children, who in turn will need housing. We must begin to take responsibility for our own futures and consider whether or not we can actually afford to have children/increase the population. If you provide more housing now, it©s only a sticking plaster on what the underlying problems are. Look at the motorways - create more lanes to meet demand, use then increases, this then leads to the need for more lanes. Simple - it©s not rocket science!! I note the plan uses phrases such as sustainability, environmental impact assessments, infrastructure etc but where is the evidence of what these will entail - words are cheap I©m afraid and evidence of broken promises/assurances is on every news item, in every paper, on every street. The attitude then is ©well it©s too late now, what are you going to do about it©? I©m furious South Bucks are even considering these plans. Common sense has gone out of the window and the ©I©m all right Jack© mentality is everywhere to be seen. Developers ride rough shod over the people they encounter because ultimately, they are the ones with the money to pay the lawyers to fight the average person into submission.They couldn©t care less about ©communities©. How many times do we hear the phrase ©lessons will be learnt© surely common sense is the only lesson we need.
8909 I really sincerely and fervently hope these plans are rejected. I have witnessed similar schemes all over the North West of England and all that it©s done is erode the nature of the existing communities and replace them with miles and miles of faceless boxes where people sit in their cars, polluting the atmosphere as they attempt to ©escape© from their homes each morning, only to face the same nightmare each evening. This is social engineering and needs to be put a stop to now otherwise we will begin to lose even more of our cultural identity and lose the very things which make our country so beautiful. PP Mods - Please specify as Look at the Brown Field sites. There are so many in and around Chesham which can be developed to create precisely and succinctly as much more environmentally sustainable housing. possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not You cannot justify the removal of Green Belt - it was designated as such for a reason. believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not It is very short sighted - demand will increase as a result of the development. It©s a quick fix for one problem believe this policy to be which will in itself cause so many additional problems. effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not This is nonsense - you cannot legislate and say we must build x number of homes regardless of the overall believe this policy in impact they will have! The plan should look at how this policy can be met through the development of the consistent with the National Brown field sites without only considering the cheaper option to build on the pristine, un-spoilt Green Belt Planning Policy Framework land. Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1215583 Full Name Mr Roger Smith ID 7000 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Director Chesham Renaissance Community Interest Company Consultee Type - Please Local Interest Group/Amenity Society select the type of consultee: Date Received - Date 2018-12-06 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID 1211027 Full Name Mr Colin Wilson
8910 Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination
8911 Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not The proposals to release Green Belt land to meet housing targets (Generally, Spatial Policy SP believe this policy to be SP1 & specifically Policy SP BP2 at Lye Green NE of Chesham) are not justified based on the evidence justified please explain why submitted by the Councils. The Councils have stated that release of some Green Belt is necessary as part of an overall three part strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. We question the soundness of such a general policy given that the council has repeatedly failed to demonstrate that it has sought to identify and rigorously assess the suitability of brownfield land opportunities, and the desirability of achieving higher densities of development on these sites, which are generally closer to the town centre and more consistent with the Councils' strategic objectives. The development of Green Belt sites to the north of Chesham involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient, unfunded and not planned for completion before development of the sites. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity with air pollution already a significant issue. The Councils are aware that Air pollution is a particular concern in Chesham due to the already poor air quality along Berkhamsted Road. The designated Air Quality Management Area there is already recording air quality levels considerably worse than legal safe levels. The traffic associated with additional housing will further exacerbate this issue unless significant remodelling of local roads and transport infrastructure is carried out. Again, these changes need to be made in advance of any significant addition to housing and local populations. In particular, from the point of view of transportation and travel the Green Belt site NE of Chesham (SP BP 2) is not a sustainable location. It is over 2Km away from the train station and slightly further still from the town centre. The Councils declared intent to increase use of, for example, cycling or walking in order to reduce environmental impact are unrealistic given the steep hill that separates the planned development from the town centre's shops, health services, schools, sites of employment and transportation links. Policy 2a - Please specify as Modifications precisely and succinctly as We refer to the comments previously submitted but in summary would advocate that: possible how you would modify this policy to improve · All other options are fully explored including increased density of development of brownfield land its alignment to this test of · As it relates to Chesham, the Councils embody and embrace in their plans the community-focused policies soundness. and exciting opportunities for the future development of Chesham as outlined in the Chesham Masterplan and the work being undertaken by CIC Chesham Renaissance. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would
8912 modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I believe the draft Local Plan is NOT legally compliant because it has not demonstrated sufficient regard to believe this policy in the National Policy and guidance issued by the Secretary of State. consistent with the National The National Planning Policy Framework (NPPF) together with other guidance issued by the Government Planning Policy Framework is also supported by recent ministerial statements that have made it clear that Local Authorities MUST Feb 2019 please explain why demonstrate they have exhausted all options BEFORE considering revision of Green Belt boundaries. This Local Plan is seeking substantial modifications to Green Belt boundaries including the removal of Green Belt designation of 13 areas within the Districts as well as modifying the Green Belt status of many local villages. I contend this draft Local Plan has not demonstrated that all other options have been fully explored and as such this Plan is not justified, sound or in accordance with National Policy and accordingly is not legally compliant. Furthermore that Paragraph 11 b) of the NPPF (and the footnotes thereto) require Plan Makers to provide for objectively assessed needs for housing and other uses UNLESS the application of Framework policies (including Green Belt) provide a strong reason for restricting the overall scale, type or distribution of development in the plan area Chiltern District and South Bucks are significantly constrained by development policies such as Green Belt & Areas of Outstanding Natural Beauty (AONB). The Local Plan is therefore inconsistent with National Guidance and as such it is not legally compliant for the Local Authority to claim that housing needs justify a review of these same Green Belt boundaries. It is perverse to claim that the combination of housing need and the presence of significant areas of development constraint policy collectively represent ªexceptional circumstancesº (as required in the NPPF) to justify modification of Green Belt boundaries especially given the NPPF states that one of the key features of Green Belts are their permanence. The Government has also recently confirmed its aim for the UK to have net zero carbon emissions by 2050 and it is noted within the Sustainability Appraisal supporting this Draft Local Plan, that the Plan area is forecast to see carbon emission increase by 21% in the Plan Period. Accordingly, the Plan is inconsistent with Government Policy and therefore not legally compliant. There is also a significant infrastructure funding gap acknowledged within the Community Infrastructure Levy evidence that supports this Local Plan, of between £179m & £231m. Given this infrastructure is vital to ensure that development is sustainable (as also required by the NPPF) this further demonstrates the Plan is both unsound and not legally compliant. · The selection of the land NE of Chesham at Lye Green (policy SP BP2) for removal from Green Belt designation is inconsistent with National Planning Policy Framework (NPPF). Policy 3a - Please specify as The Plan needs to be modified by: precisely and succinctly as Demonstrating that you have cooperated fully with neighbouring and nearby authorities -not just Aylesbury. possible how you would Your assertion this cannot be done because they are different Functional Market Areas and that co-operation modify this policy to improve is not necessary makes no sense and is counter to the declared strategic aims of the authority. its alignment to this test of soundness. Exploring such wider co-operation may result in further housing needs being taken elsewhere or opportunities to optimise investments in infrastructure, improve environmental sustainability, and increase economic growth in the region. As mentioned in earlier responses to earlier consultation rounds, an integrated plan responding to all Strategic goals ± rather than one that focuses disproportionately on housing provision is required. It should take account of the excellent work already done by, for example, CIC Chesham Renaissance in its Chesham Masterplan. Specifically, more detailed appraisals of brownfield land opportunities MUST be undertaken. Many brownfield opportunities have been ignored or missed. Green Belt boundary reviews should only be considered AFTER all other reasonable alternatives have been exhausted. The authority has repeatedly failed to respond to this point, which has been made repeatedly in earlier rounds of consultation. In the face of NPPF guidance and a more thorough appraisal of Green Belt sites, it may then be necessary to conclude that it is not possible to identify poor performing Green Belt sites that can accommodate all the OAN for housing. Consequently, it may be necessary to accept that a lower housing provision figure is appropriate. Policy-level file upload - Please attach any supporting evidence
Person ID 1218123 Full Name Mr Tim Geraghty ID 183 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee:
8913 Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider
8914 the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The rolling back of Greenbelt land in Lye Green is not sound or necessary. It is a lazy solution, rather than not believe this policy to be tackling the rejuvenation of Chesham central brownfield sites to make a more vibrant town, with walking positively prepared please distance amenities. explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not Poorer Air quality, increased traffic on minor roads, pressure on local schools, the undoubted mission creep believe this policy to be of further homes being built on the site, which is capable of another 500 homes on top of the current proposal. justified please explain why It brings nothing to the town other than negatives. I believe the Chesham master plan to be a far superior proposal and in tune with the inhabitants of the area. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve
8915 its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1218605 Full Name Mark Moffat ID 512 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible.
8916 Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do This Policy is NOT Positively Prepared. It develops Green Belt which is contrary to the feedback from the not believe this policy to be 2015 consultation process. Non-development of Green Belt received the highest number of responses and positively prepared please yet the Council is ignoring public consultation. This is urban sprawl at its worst. explain why PP Mods - Please specify as Focus on Brownfield sites in Chesham town centre. This is lazy planning, broad brush planning so boxes precisely and succinctly as can be ticked on number of houses. It takes longer and harder work to identify and redevelop Brownfield possible how you would sites but is the BEST solution. modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not It is NOT justified. Reasonable alternatives have not been fully considered or presented. Chesham does not believe this policy to be have the housing pressure that requires 500 new homes. Property prices have been flat/declining for five justified please explain why years. Policy 2a - Please specify as Development of Brownfield Sites and the Conversion of Offices to flats is a better solution. The ©market© precisely and succinctly as indicates 500 new homes are simply not required. possible how you would modify this policy to improve its alignment to this test of soundness.
8917 Policy 2 - If you do not This proposal is NOT effective. It hollows out Chesham town centre. Current enlightened policy creates believe this policy to be desirable residential properties in town centres and this in turns leads to a thriving retail centre. Note the effective please explain why. various development of apartments in Amersham on the Hill is revitalising the town centre with large new restaurants and shops. The proposal drags development out of Chesham town centre. PAa - Please specify as Change of use from B1 (office) to C3 (residential) should be used more widely in Chesham. Allow more precisely and succinctly as development of small in-fill apartment blocks in Chesham town centre. possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not It is NOT consistent with the NPPF. 1) Destroys Greenbelt against local public wishes; 2) Does not take believe this policy in advantage of Change of Use from B1 to C3; 3) removes parking provision; and 4) adds no Community Value; consistent with the National 4) does not provide for infrastructure requirements. Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as A. More use of Brownfield sites (note "Brownfield" is mentioned just once in the entire 225 page plan); precisely and succinctly as B. More Change of Use from Office to Residential; and possible how you would modify this policy to improve C. More low rise apartments (e.g. Amersham on the Hill). its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1218700 Full Name Mrs Natalie Lonie ID 540 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested
8918 modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Following careful consideration of the above, I am forced to conclude that the council©s local plan will cause not believe this policy to be harm to the wider town of Chesham and is unsound. Specific areas of concern include
8919 positively prepared please - loss of Green Belt around Chesham with all of the environmental implications explain why - More traffic congestion and worsening air quality in Chesham - Loss of land with community value in Chesham which supports wildlife and recreation - Outward sprawl of the town which will result in Lye Green becoming part of ©Greater Chesham© - Failure to recognize an opportunity for urban development and regeneration It appears that the council has decided to take the easy option and develop green belt land (specifically 13 GB sites in Chiltern and South bucks) which is unjustified, ineffective and inconsistent with national policy. The view is supported by the fact that the council©s policy for green belt release is part of an overall strategic objective that promotes sustainable development as reflected in local plan SP SP1. Such sites are generally not sustainable, and to designate them as such is unsound. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not In addition, there are insufficient ©exceptional circumstances© generally to justify Green Belt release and believe this policy in specifically at Lye Green in this instance. Paragraph 136 of the latest National Planning Policy Framework consistent with the National (NPPF) asserts that Green Belt boundaries should be modified only in ©exceptional circumstances©. The Planning Policy Framework courts have held that unmet local housing needs of an area are themselves not exceptional circumstances Feb 2019 please explain why and Lye Green is not sustainable location being too far from the town centre with a steep hill to negotiate too. Quite simply, Green Belt land should not be the first choice for development when other, less damaging options exist nearer the Chesham town centre and the underground station. I question the soundness of the local plan which fails to identify the brownfield land opportunities that have been identified by others such as the Chesham Renaissance CIC masterplan. The council should be looking at higher densities of development on such sites as are generally closer to the town centre. In short, I believe that the council has used flawed methodology for identifying sites to meet local housing needs and that Lye Green is an unsustainable location and, therefore, its release from Green Belt is unjustified. I am concerned that the many hundreds of proposed homes will generate increased traffic and its attendant air pollution, already at alarming levels in the Chesham area. the designated Air Quality Management Area along Berkhampstead Road is already recording air quality that is considerably worse than EU safe levels. The council©s proposals are inconsistent with Local Plan Policy DM DP5 relating to ©Climate Responsive development© and Policy DM DP9 ©Reducing reliance on private cars© and DP DM15 ©Blue green infrastructure©. The council©s wilful failure to take these into account will only make things worse and cannot be justified under recent national government policy.These considerations alone should be sufficient grounds to reconsider the entire draft local plan which is unsound in this matter. There are suggestions of mitigating the air quality but where is the proof these measures will be delivered or that they will even work? The Green Belt site NE of Chesham is over two kilometres from the underground station and Chesham town centre and is therefore an unsustainable location. The council seems to think that the Lye Green site is sustainable and provides easy access to public transport including the underground station, yet the same Local Plan promotes a considerable increase in retail development in the town (draft Local Plan Policy SP EP3 which I also feel is unsound), part of which would be built on the very car park that serves the Chesham underground station, thus undermining the use of public transport and resulting in the greater use of private cars, which, in turn will lead to more traffic congestion. This is inconsistent and unsound. The flawed methodology used by the Local Authority to select the Green Belt site was not effective, justified or consistent with the National Planning Policy Framework (NPPF) and has resulted in their choice of Lye Green which is unsound. The selection of the land at Lye Green as suitable for removal from Green Belt is inconsistent with National Planning Policy Framework (NPPF) not only for the reasons so far states, but also for the fact that the land supports wildlife and is an important recreational site for nearby communities. Most Green Belt areas do not have widespread public access making this land at Lye Green unusual and a rare feature that improves community wellbeing and to allocate such an important site for development is unjustified. Lye Gren is a
8920 potential asset of community value and confirmation of this designation will afford a community group the right to bid for the land in order to preserve it for the hundreds of local people who have long used it for recreational purposes. It is perverse that the local authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Local Plan is unsound. The fundamental aim of green belt policy is to prevent urban sprawl by keeping land permanently open. This is government policy as set out in paragraph 133 of the NPPF 2018. The Lye Green site self-evidently does this well and has done so for decades. A further aim of Green belt land (stated in paragraph 134) is to prevent neighbouring towns and settlements from merging into one another. The preservation of Lye Green as Green Belt land is vital in maintaining a distinct seperation from as well as helping to mainain the separate identities of other nearby communities. In view of these facts, it is perverse and inconsistent with national guidance to allocate this land for removal from Green Belt, especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if the land is developed. A further aim of Green belt designation (as stated in the NPPF at paragraph 134(e) is to assist in urban regeneration by encouraging and recycling of derelict and other urban land. Allocating Green Belt land at Lye Green as an area for development completely undermines this aim by failing to recognize the opportunities that exist within Chesham. A community led not-for-profit organisation called Chesham Renaissance CIC has developed the Chesham masterplan that would not only provide many genuinly affordable homes in more sustainable locations nearer the town centre, but which also would regenerate some of the more deprived wards within Chesham. While the local plan promotes a considerable increase in retail development in the town, development alone is not required. A simple stroll down Chesham High Street would reveal at least ten empty shops. The problem is not insufficient retail spaces but a lack of thoughtful redevelopment that promotes and supports existing retail premises. Indeed the proposals to build shops on the car parks actively undermines the Chesham Renaissance CIC masterplan. The local authority proposals re inconsistent with this local initiative and are therefore also inconsistent with national guidance and are consequently unsound. Everyone in Chesham, not just Lye Green, will be impacted by the addition of 500 homes on this area of Green Belt. I am supportive of the Brown Not Green organisation©s initiative to have the land listed as an Asset of Community Value, and i feel they speak for me in respect of their objections to the draft local plan. Accordingly, I request that any representations made by them at any future examination in public regarding the soundness of this local plan be considered as an extension of my own comments herein. I feel the land NE of Chesham at Lye Green is an unsustainable location for development, that has been habitually used by the community for improved health and wellbeing for decades and that the land peforms well against Green belt aims and objectives. Exceptional circumstances for reviewing green belt boundaries at this location either do not exist or are insufficient to warrant the removal of this land from green belt designation as required by government policy and, therefore, the local plan is unsound. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1218692 Full Name David Green ID 1006 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name
8921 Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination
8922 Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I am concerned about the way the local plan for Chesham is developing as I feel there are several major not believe this policy to be issues which haven©t been adequately considered and so I wish to raise them: positively prepared please - Infrastructure. Clearly the Chesham infrastructure is already at creaking point with long queues through explain why Chesham during rush hour, tubes which are full during rush hour even though Chesham is the first station on the line with people having to stand all the way into London, schools, doctors etc. I appreciate that there is the CIL but even taking that into account there is a funding gap (https://www.chiltern.gov.uk/planning/cil page 3) and so how will this be dealt with? I appreciate new houses need to be built in the area but it doesn©t sound like responsible planning to me if the project starts without sufficient funding to ensure adequate money is spent on infrastrusture because otherwise it will damage Chesham and deter people from coming here. Therefore what guarantees are in place that the developers will contribute enough to the instructure? - Environment. There is clearly going to be a negative environmental impact as the development is too far from the town centre for people to walk and so there will be an increased carbon footprint which goes against the green initiative that councils are meant to have. It is also a damaging trend to start releasing green belt instead of looking for alternatives (e.g. what is wrong with the Chesham Renaissance ideas?) because if this development goes ahead then is there a legal way to stop lots more greenbelt land being reclassified once the precedence is in place? I look forward to hearing your thoughts David Green PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as
8923 possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1218696 Full Name Peter Casselden ID 526 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as
8924 precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The world is suffering from over-population. England is heavily over-populated. This has led to the damaging not believe this policy to be of the natural environment and the human environment. In the 1960s and 1970s government reports expressed positively prepared please great concern about the effects of over-population. Britain©s population would have peaked c1990 but political explain why decisions since then have led to unprecedented levels of immigration that have sent population levels surging upwards. Government, once worried about the consequences of over-population now just buries its head in the sand. You cannot invite millions of extra people to live here without needing housing for millions of extra people. There has been no planning for this and the British people were never consulted. The consequence has been that housing has been built all over southern England with no regard for the consequences in places we would never have dreamed of putting houses when proper planning was in place. Building on flood plains has been rife. Near Stoke Mandeville hospital a housing development has just been finished on a field that regularly floods in winter signed off by planners who knew it was wrong. 500 Homes should not be built on Green Belt land to the NE of Chesham. Chesham does not have work for 500 households. Virtually all the people who would occupy those houses would have to commute to work. local roads are already heavily congested in the peak rush hours. Making the roads even more congested damages the lives of everyone who needs to be on the roads in the morning rush hour.They will all experience longer delays. Family life will be further eaten into. Commercial drivers will experience longer delays further damaging their productivity.This includes district nurses, ambulance drivers, paramedics who will take longer to get to patients. Where is the costing of all this? How many extra lives will be lost?
8925 A proportion of the occupiers of 500 new homes on Green Belt to the north east of Chesham will want to travel to work on the metropolitan line from Chesham. Unfortunately the station car park at Chesham is now full.You can walk through the car park on a weekday and not see a single free space. Commuters are already parking their cars all over Chesham on unrestricted roads. The line of parked commuters cars up Chartridge lane has now reached Chiltern Hills Academy School. Everyone knows this place is a farce - that it breaches the whole concept of good planning. We are all of us for protecting the environment but carry on making plans that destroy the environment. I oppose taking any land out of the green belt. If we are to protect our environment, both the natural and the human we must stop its destruction NOW PP Mods - Please specify as Two things needs to happen. precisely and succinctly as First we must stop immigration adding to the population. We need to restrict numbers entering Britain to the possible how you would number that left Britain in the previous year. modify this policy to improve its alignment to this test of Second we need to manage the present situation by utilizing the present housing stock more effectively soundness. (there are too many empty houses) and only building on Brown Field Sites. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1218697 Full Name Mrs Patricia Hambelton ID 539 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of:
8926 Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is
8927 incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Following careful consideration of the above, I am forced to conclude that the council©s local plan will cause not believe this policy to be harm to the wider town of Chesham and is unsound. Specific areas of concern include positively prepared please - loss of Green Belt around Chesham with all of the environmental implications explain why - More traffic congestion and worsening air quality in Chesham - Loss of land with community value in Chesham which supports wildlife and recreation - Outward sprawl of the town which will result in Lye Green becoming part of ©Greater Chesham© - Failure to recognize an opportunity for urban development and regeneration It appears that the council has decided to take the easy option and develop green belt land (specifically 13 GB sites in Chiltern and South bucks) which is unjustified, ineffective and inconsistent with national policy. The view is supported by the fact that the council©s policy for green belt release is part of an overall strategic objective that promotes sustainable development as reflected in local plan SP SP1. Such sites are generally not sustainable, and to designate them as such is unsound. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not In addition, there are insufficient ©exceptional circumstances© generally to justify Green Belt release and believe this policy in specifically at Lye Green in this instance. Paragraph 136 of the latest National Planning Policy Framework consistent with the National (NPPF) asserts that Green Belt boundaries should be modified only in ©exceptional circumstances©. The Planning Policy Framework courts have held that unmet local housing needs of an area are themselves not exceptional circumstances Feb 2019 please explain why and Lye Green is not sustainable location being too far from the town centre with a steep hill to negotiate too. Quite simply, Green Belt land should not be the first choice for development when other, less damaging options exist nearer the Chesham town centre and the underground station. I question the soundness of the local plan which fails to identify the brownfield land opportunities that have been identified by others such as the Chesham Renaissance CIC masterplan. The council should be looking at higher densities of
8928 development on such sites as are generally closer to the town centre. In short, I believe that the council has used flawed methodology for identifying sites to meet local housing needs and that Lye Green is an unsustainable location and, therefore, its release from Green Belt is unjustified. I am concerned that the many hundreds of proposed homes will generate increased traffic and its attendant air pollution, already at alarming levels in the Chesham area. the designated Air Quality Management Area along Berkhampstead Road is already recording air quality that is considerably worse than EU safe levels. The council©s proposals are inconsistent with Local Plan Policy DM DP5 relating to ©Climate Responsive development© and Policy DM DP9 ©Reducing reliance on private cars© and DP DM15 ©Blue green infrastructure©. The council©s wilful failure to take these into account will only make things worse and cannot be justified under recent national government policy.These considerations alone should be sufficient grounds to reconsider the entire draft local plan which is unsound in this matter. There are suggestions of mitigating the air quality but where is the proof these measures will be delivered or that they will even work? The Green Belt site NE of Chesham is over two kilometres from the underground station and Chesham town centre and is therefore an unsustainable location. The council seems to think that the Lye Green site is sustainable and provides easy access to public transport including the underground station, yet the same Local Plan promotes a considerable increase in retail development in the town (draft Local Plan Policy SP EP3 which I also feel is unsound), part of which would be built on the very car park that serves the Chesham underground station, thus undermining the use of public transport and resulting in the greater use of private cars, which, in turn will lead to more traffic congestion. This is inconsistent and unsound. The flawed methodology used by the Local Authority to select the Green Belt site was not effective, justified or consistent with the National Planning Policy Framework (NPPF) and has resulted in their choice of Lye Green which is unsound. The selection of the land at Lye Green as suitable for removal from Green Belt is inconsistent with National Planning Policy Framework (NPPF) not only for the reasons so far states, but also for the fact that the land supports wildlife and is an important recreational site for nearby communities. Most Green Belt areas do not have widespread public access making this land at Lye Green unusual and a rare feature that improves community wellbeing and to allocate such an important site for development is unjustified. Lye Gren is a potential asset of community value and confirmation of this designation will afford a community group the right to bid for the land in order to preserve it for the hundreds of local people who have long used it for recreational purposes. It is perverse that the local authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Local Plan is unsound. The fundamental aim of green belt policy is to prevent urban sprawl by keeping land permanently open. This is government policy as set out in paragraph 133 of the NPPF 2018. The Lye Green site self-evidently does this well and has done so for decades. A further aim of Green belt land (stated in paragraph 134) is to prevent neighbouring towns and settlements from merging into one another. The preservation of Lye Green as Green Belt land is vital in maintaining a distinct seperation from as well as helping to mainain the separate identities of other nearby communities. In view of these facts, it is perverse and inconsistent with national guidance to allocate this land for removal from Green Belt, especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if the land is developed. A further aim of Green belt designation (as stated in the NPPF at paragraph 134(e) is to assist in urban regeneration by encouraging and recycling of derelict and other urban land. Allocating Green Belt land at Lye Green as an area for development completely undermines this aim by failing to recognize the opportunities that exist within Chesham. A community led not-for-profit organisation called Chesham Renaissance CIC has developed the Chesham masterplan that would not only provide many genuinly affordable homes in more sustainable locations nearer the town centre, but which also would regenerate some of the more deprived wards within Chesham. While the local plan promotes a considerable increase in retail development in the town, development alone is not required. A simple stroll down Chesham High Street would reveal at least ten empty shops. The problem is not insufficient retail spaces but a lack of thoughtful redevelopment that promotes and supports existing retail premises. Indeed the proposals to build shops on the car parks actively undermines the Chesham Renaissance CIC masterplan. The local authority proposals re inconsistent with this local initiative and are therefore also inconsistent with national guidance and are consequently unsound. Everyone in Chesham, not just Lye Green, will be impacted by the addition of 500 homes on this area of Green Belt. I am supportive of the Brown Not Green organisation©s initiative to have the land listed as an Asset of Community Value, and i feel they speak for me in respect of their objections to the draft local plan. Accordingly, I request that any representations made by them at any future examination in public regarding the soundness of this local plan be considered as an extension of my own comments herein. I feel the land NE of Chesham at Lye Green is an unsustainable location for development, that has been habitually used by the community for improved health and wellbeing for decades and that the land peforms well against Green belt aims and objectives. Exceptional circumstances for reviewing green belt boundaries at this location either do not exist or are insufficient to warrant the removal of this land from green belt designation as required by government policy and, therefore, the local plan is unsound. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
8929 Policy-level file upload - Please attach any supporting evidence
Person ID 1218729 Full Name Mrs Sandy Duducu ID 538 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications
8930 to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Following careful consideration of the above, I am forced to conclude that the council©s local plan will cause not believe this policy to be harm to the wider town of Chesham and is unsound. Specific areas of concern include positively prepared please - loss of Green Belt around Chesham with all of the environmental implications explain why - More traffic congestion and worsening air quality in Chesham - Loss of land with community value in Chesham which supports wildlife and recreation - Outward sprawl of the town which will result in Lye Green becoming part of ©Greater Chesham© - Failure to recognize an opportunity for urban development and regeneration It appears that the council has decided to take the easy option and develop green belt land (specifically 13 GB sites in Chiltern and South bucks) which is unjustified, ineffective and inconsistent with national policy. The view is supported by the fact that the council©s policy for green belt release is part of an overall strategic objective that promotes sustainable development as reflected in local plan SP SP1. Such sites are generally not sustainable, and to designate them as such is unsound. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why
8931 Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not In addition, there are insufficient ©exceptional circumstances© generally to justify Green Belt release and believe this policy in specifically at Lye Green in this instance. Paragraph 136 of the latest National Planning Policy Framework consistent with the National (NPPF) asserts that Green Belt boundaries should be modified only in ©exceptional circumstances©. The Planning Policy Framework courts have held that unmet local housing needs of an area are themselves not exceptional circumstances Feb 2019 please explain why and Lye Green is not sustainable location being too far from the town centre with a steep hill to negotiate too. Quite simply, Green Belt land should not be the first choice for development when other, less damaging options exist nearer the Chesham town centre and the underground station. I question the soundness of the local plan which fails to identify the brownfield land opportunities that have been identified by others such as the Chesham Renaissance CIC masterplan. The council should be looking at higher densities of development on such sites as are generally closer to the town centre. In short, I believe that the council has used flawed methodology for identifying sites to meet local housing needs and that Lye Green is an unsustainable location and, therefore, its release from Green Belt is unjustified. I am concerned that the many hundreds of proposed homes will generate increased traffic and its attendant air pollution, already at alarming levels in the Chesham area. the designated Air Quality Management Area along Berkhampstead Road is already recording air quality that is considerably worse than EU safe levels. The council©s proposals are inconsistent with Local Plan Policy DM DP5 relating to ©Climate Responsive development© and Policy DM DP9 ©Reducing reliance on private cars© and DP DM15 ©Blue green infrastructure©. The council©s wilful failure to take these into account will only make things worse and cannot be justified under recent national government policy.These considerations alone should be sufficient grounds to reconsider the entire draft local plan which is unsound in this matter. There are suggestions of mitigating the air quality but where is the proof these measures will be delivered or that they will even work? The Green Belt site NE of Chesham is over two kilometres from the underground station and Chesham town centre and is therefore an unsustainable location. The council seems to think that the Lye Green site is sustainable and provides easy access to public transport including the underground station, yet the same Local Plan promotes a considerable increase in retail development in the town (draft Local Plan Policy SP EP3 which I also feel is unsound), part of which would be built on the very car park that serves the Chesham underground station, thus undermining the use of public transport and resulting in the greater use of private cars, which, in turn will lead to more traffic congestion. This is inconsistent and unsound. The flawed methodology used by the Local Authority to select the Green Belt site was not effective, justified or consistent with the National Planning Policy Framework (NPPF) and has resulted in their choice of Lye Green which is unsound. The selection of the land at Lye Green as suitable for removal from Green Belt is inconsistent with National Planning Policy Framework (NPPF) not only for the reasons so far states, but also for the fact that the land supports wildlife and is an important recreational site for nearby communities. Most Green Belt areas do not have widespread public access making this land at Lye Green unusual and a rare feature that improves community wellbeing and to allocate such an important site for development is unjustified. Lye Gren is a potential asset of community value and confirmation of this designation will afford a community group the right to bid for the land in order to preserve it for the hundreds of local people who have long used it for recreational purposes. It is perverse that the local authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Local Plan is unsound. The fundamental aim of green belt policy is to prevent urban sprawl by keeping land permanently open. This is government policy as set out in paragraph 133 of the NPPF 2018. The Lye Green site self-evidently does this well and has done so for decades. A further aim of Green belt land (stated in paragraph 134) is to prevent neighbouring towns and settlements from merging into one another. The preservation of Lye Green as Green Belt land is vital in maintaining a distinct seperation from as well as helping to mainain the separate identities of other nearby communities. In view of these facts, it is perverse and inconsistent with national guidance to allocate this land for removal from Green Belt, especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if the land is developed. A further aim of Green belt designation (as stated in the NPPF at paragraph 134(e) is to assist in urban regeneration by encouraging and recycling of derelict and other urban land. Allocating Green Belt land at Lye Green as an area for development completely undermines this aim by failing to recognize the opportunities that exist within Chesham. A community led not-for-profit organisation called Chesham Renaissance CIC has developed the Chesham masterplan that would not only provide many genuinly affordable homes in more sustainable locations nearer the town centre, but which also would regenerate some of the more deprived wards within Chesham. While
8932 the local plan promotes a considerable increase in retail development in the town, development alone is not required. A simple stroll down Chesham High Street would reveal at least ten empty shops. The problem is not insufficient retail spaces but a lack of thoughtful redevelopment that promotes and supports existing retail premises. Indeed the proposals to build shops on the car parks actively undermines the Chesham Renaissance CIC masterplan. The local authority proposals re inconsistent with this local initiative and are therefore also inconsistent with national guidance and are consequently unsound. Everyone in Chesham, not just Lye Green, will be impacted by the addition of 500 homes on this area of Green Belt. I am supportive of the Brown Not Green organisation©s initiative to have the land listed as an Asset of Community Value, and i feel they speak for me in respect of their objections to the draft local plan. Accordingly, I request that any representations made by them at any future examination in public regarding the soundness of this local plan be considered as an extension of my own comments herein. I feel the land NE of Chesham at Lye Green is an unsustainable location for development, that has been habitually used by the community for improved health and wellbeing for decades and that the land peforms well against Green belt aims and objectives. Exceptional circumstances for reviewing green belt boundaries at this location either do not exist or are insufficient to warrant the removal of this land from green belt designation as required by government policy and, therefore, the local plan is unsound. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1218747 Full Name Mr Keith Fletcher ID 584 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance?
8933 Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible
8934 Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not I don©t think the plan can be justified taking away current green belt areas or in accordance with NPPF to believe this policy to be remove land from green belt for housing. i think the council should be looking at developing brown field sites justified please explain why where ever possible as proposed in the Chesham Renaissance CIC Masterplan. How can it be justified to allocate land at Lye Green to be used for housing ?This site has been used for yearsfor recreation purposes and is possibly to be listed as an Asset of Community Value. I am not convinced that the implications of this plan have been considered particularly in regard to redefining Green Belt boundaries such as Lye Green ( Policy SP BP2 ) and I am appalled at the suggestion of removing our local villages fro Green Belt or permitting infilling as proposed in policies SP PP1 & DM PP1. Are these policies justified or in accordance with NPPF. Policy 2a - Please specify as Is this Green Belt land release plan consistent with other local plan policies concerning the protection of precisely and succinctly as wildlife habitats or biodiversity or even more importantly to protect our wonderful local chalk streams or does possible how you would the plan violate them ? We need to preserve these treasures as a matter of utmost priority. modify this policy to improve The council should be looking to develop higher density housing on brownfield sites closer to the town centre its alignment to this test of which would help to rejuvenate Chesham Town Centre soundness. The council should be looking to develop higher density housing on brownfield sites closer to the town centre which would help to rejuvenate Chesham Town Centre. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1218849 Full Name Mr & Mrs Seton & Isabel Owens ID 631 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body?
8935 Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act
8936 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The DLP intention to remove Green Belt status particularly from the area N.East of Chesham at Lye Green not believe this policy to be and other intended areas considered for development are unsound. positively prepared please There are numerous brownfield sites closer to the centre of Chesham which would be more suitable for high explain why density development. Have all these sites been identified? PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not Chesham has one main road passing through the centre of town which is operating at capacity. There is believe this policy to be little room for highway improvement. We already have poor air quality along Berkhamsted Road, higher than justified please explain why EU safe levels. A development of over 500 homes on the Lye Green site will increase the problem of traffic flow and air pollution considerably and is not justified. The Lye Green proposed site is over 2km away from the station and town centre. The approach to the town is either White Hill or Nasleigh Hill, both very steep hills. Doing the weekly shop certainly requires a car to cope with the steep hills and cycling would be quite a challenge. It is not a suitable location. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not The fields at Lye Green intended for development are habitually used by many people for recreational believe this policy in purposes i.e. dog walking, running, nature enthusiasts etc. We have used the areas for dog walking for over consistent with the National 27 years and others for much longer. the area is a major Asset of Community Value. Planning Policy Framework The National Planning Policy Framework (NPPF) paragraph 136 asserts that Green Belt boundaries should Feb 2019 please explain why only be modified in exceptional circumstances. The courts have held that unmet housing needs of an area are themselves not exceptional circumstances. The part 2 Green Belt assessment was not undertaken by a third party but by the local authority itself who therefore did not undertake the necessary reviews of each site, including the land NE of Chesham at Lye Green. This oversight in the Part 2 Green belt assessment placed premature focus and fixation on releasing land at Lye Green NE of Chesham from green belt designation. the subsequent identification of this Chesham site for release is therefore unjustified.
8937 The primary aim of green belt land is to prevent urban sprawl. The Lye Green site provides this function well and had done so for decades. It represents good quality agricultural land and an environment for many species of wild life. All will be lost by this development. A community led not for profit organisation called Chesham Renaissance has been creating a Chesham Master Plan that would provide many affordable homes in more sustainable locations nearer the town centre. The Local authorities proposals are inconsistent with this local initiative and are inconsistent with national guidance and are therefore unsound. The BBC news on Sunday 23rd June brought to our attention the dire straits of chalk streams in Buckinghamshire and Hertfordshire. Affinity water abstracts water from the River Chess to supply to the Chesham area. The area is heavily dependent on ground water from chalks aquifers to meet the demands. This competes with the chalk streams which have been dying out, some permanently since 2014. The groundwater levels are now extremely low due to decreased rainfall over the last few years. An extra 500 houses etc. to the Chesham area will put an ever greater strain on water supplies that are already at emergency levels. Also the sewage system is at full capacity and has leaked into the river Chess on occasions. Considering all of the points made I would consider that land N.East of Chesham is an unsustainable location for development. I am supportive of the Brown not Green organisation©s initiative to have the land listed as an Asset of Community Value and i feel they speak for me in respect of their objections to the draft local plan. Accordingly, I request that any representations made by them at any future examination in public regarding the soundness of the local plan be considered as an extensions of my own comments herein. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1218976 Full Name Dr Gemma Buckland-Merrett ID 6789 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible.
8938 Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the
8939 examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The proposals to release Green Belt land to meet housing targets (Generally, Spatial Policy SP SP1 & not believe this policy to be specifically Policy SP BP2 at Lye Green NE of Chesham) are not justified from the evidence submitted by positively prepared please the Councils. explain why The Councils have stated that release of some Green Belt is necessary as part of an overall three part strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. I question the soundness of such a general policy and whether all the brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites and in particular the Green Belt site NE of Chesham at Lye Green. The development of such Green Belt sites involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient and unfunded. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. The Green Belt site NE of Chesham (SP BP 2) is not a sustainable location. It is over 2Km away from the train station and slightly further still from the town centre but anyone who cares to walk or cycle this distance also has to negotiate a steep hill too. Such an unsustainable location cannot be made sustainable merely by upgrading a couple of public footpaths within the site into bridleways to facilitate cycling. Neither does adding a bus stop address the geography or topography of the area especially if the promised enhanced bus service (which is already infrequent) either does not materialise or if it subsequently fails to be maintained after a few years. I feel the land NE of Chesham is an unsustainable location for development, that has been habitually used by the community for improved health & wellbeing for decades and the land performs well against Green Belt aims and objectives. Exceptional circumstances for reviewing Green Belt boundaries at this location, either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by Govt Policy and therefore the plan is unsound. PP Mods - Please specify as All other options are fully explored including increased density of development of brownfield land and the precisely and succinctly as policies emerging from Chesham Masterplan. possible how you would Green Belt land should only be considered when all other options are exhausted and in any event the modify this policy to improve proposals for developing land NE of Chesham (policy SP BP 2) should be removed as it is an unsustainable its alignment to this test of location the development of which will cause harm to the wider town including loss of an asset that improves soundness. the well-being for the community. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not The foregoing also points to flawed methodology of Green Belt site selection used by the Local Authority, believe this policy in which is neither effective, justified nor consistent with national policy and as such is unsound. Specifically, consistent with the National the selection of the land NE of Chesham at Lye Green (policy SP BP2) for removal from Green Belt designation Planning Policy Framework is inconsistent with National Planning Policy Framework (NPPF). Feb 2019 please explain why Paragraph 136 of the latest NPPF asserts that Green Belt boundaries should only be modified in ªexceptional circumstancesº. The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances. The Council engaged third party consultants to undertake the Part 1 Green Belt assessment and they identified numerous sites for ªfurther considerationº where exceptional circumstances ªmightº exist but expressly recommended further review of their assessment of each site against the 5 purposes of land being in Green Belt of all these sites. Unlike the neighbouring Local Authorities, the Part 2 Green Belt assessment was not undertaken by third party consultants but by the Local Authority itself who notably then did not undertake all the recommended reviews of each site including the land NE of Chesham at Lye Green (SP BP 2). Accordingly, this oversight in the Part 2 Green Belt assessment placed premature focus and fixation on releasing land at Lye Green NE of Chesham from Green Belt designation. The subsequent identification of the Chesham site for release is therefore unjustified.
8940 The primary aim of Green Belt land (as recited in NPPF 133) is to prevent urban sprawl and to preserve the openness of the area. The Lye Green site (SP BP2) self-evidently performs this function well and has done so for decades. The Council have asserted that Government planning policy requires local councils to review Green Belt boundaries when considering how to accommodate the development needed in their areas. Just because the Council may be required to look, does not mean the Council should review Green Belt boundaries which as previously stated should only be modified in ªexceptional circumstancesº. National Planning Policy Framework (NPPF) as revised only last year, states in paragraph11 (b) I, directs ªplan makersº to create policies that are required in Local Plans for housing and other uses unless Framework policies (expressly including Green Belt) ªprovides a strong reason for restricting the overall scale type or distribution of development in the plan areaº Accordingly, I submit that given all of the above the land being proposed for release from Green Belt designation around Chesham is unjustified and contrary to national guidance. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1218886 Full Name Miss Angela Ryan ID 6948 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the
8941 Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why
8942 PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not The proposals to release Green Belt land to meet housing targets (Generally, Spatial Policy SP SP1 & believe this policy to be specifically Policy SP BP2 at Lye Green NE of Chesham) are not justified from the evidence submitted by justified please explain why the Councils. The Councils have stated that release of some Green Belt is necessary as part of an overall three part strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. I question the soundness of such a general policy and whether all the brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites and in particular the Green Belt site NE of Chesham at Lye Green. The development of such Green Belt sites involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient and unfunded. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham cannot accommodate any significant highways improvements anyway due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion, with further worsening air quality. Air pollution is a particular concern in Chesham due to the already poor air quality along Bekhampstead Road where there is a designated Air Quality Management Area that already is recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will generate more traffic will make the air quality even worse and insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable nor justified nor is it in accordance with Govt policy. The Green Belt site NE of Chesham (SP BP 2) is not a sustainable location. It is over 2Km away from the train station and slightly further still from the town centre but anyone who cares to walk or cycle this distance also has to negotiate a steep hill too. Such an unsustainable location cannot be made sustainable merely by upgrading a couple of public footpaths within the site into bridleways to facilitate cycling. Neither does adding a bus stop address the geography or topography of the area especially if the promised enhanced bus service (which is already infrequent) either does not materialise or if it subsequently fails to be maintained after a few years. Further doubt is cast upon the ªsoundnessº of this Plan by virtue of there being conflicting policies within it. The Council seem to think that the Green Belt site NE of Chesham is sustainable and provides easy access to public transport including the tube station yet the same Plan promotes a considerable increase in retail development in the town (local draft plan policy SP EP3) , part of which would be built on the very car park that serves the Chesham tube station. This is inconsistent and unsound. For this Plan to sound it must also be effective. Unfortunately, further review of the proposal to remove land NE of Chesham at Lye Green from Green Belt designation is not effective as there are serious questions about the deliverability of this land. The main landowner is a farmer who has asserted publicly and in a letter to the editor of Your Chesham, that he is not prepared to release all of the land in his ownership for development. The land is also potentially an Asset Of Community Value and upon confirmation of this designation it would afford a community group the right to bid for the land. The community group (Brown Not Green) have stated their intention is to preserve the land given that many hundreds of local people have habitually used the fields at Lye Green as of right for various informal outdoor recreational purposes. These uses themselves may mean that many local individuals may have acquired easements over and across the land through prescription (20 years uninterrupted use) not least of whom would be the many private residences bordering the fields that have rear garden gates onto the fields at Lye Green. These easements and prescriptive rights may render the land very difficult to develop and make i undeliverable in planning terms. This land also provides an important habitat for wildlife that will be threatened by development of this land. It is perverse that the Local Authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Plan is unsound. The foregoing also points to flawed methodology of Green Belt site selection used by the Local Authority, which is neither effective, justified nor consistent with national policy and as such is unsound. Specifically, the selection of the land NE of Chesham at Lye Green (policy SP BP2) for removal from Green Belt designation is inconsistent with National Planning Policy Framework (NPPF). Paragraph 136 of the latest NPPF asserts that Green Belt boundaries should only be modified in ªexceptional circumstancesº. The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances. The Council engaged third party consultants to undertake the Part 1 Green Belt assessment and they identified numerous sites for ªfurther considerationº where exceptional circumstances ªmightº exist but expressly recommended further review of their assessment of each site against the 5 purposes of land being in Green Belt of all these sites. Unlike the neighbouring Local Authorities, the Part 2 Green Belt assessment was not undertaken by third party consultants but by the Local Authority itself who notably then did not undertake all the recommended reviews of each site including the land NE of Chesham at Lye Green (SP BP 2). Accordingly, this oversight in the Part 2 Green Belt assessment placed premature focus and fixation on releasing land at Lye Green NE of Chesham from Green Belt designation. The subsequent identification of the Chesham site for release is therefore unjustified.
8943 These comments apply equally to proposals effecting the villages in the Green Belt ± policies SP PP1 & DM PP1) The primary aim of Green Belt land (as recited in NPPF 133) is to prevent urban sprawl and to preserve the openness of the area. The Lye Green site (SP BP2) self-evidently performs this function well and has done so for decades. Another aim of Green Belt land stated in NPPF paragraph 134, is to prevent neighbouring towns and settlements from merging into one another.The Green Belt land NE of Chesham performs exceptionally well in maintaining a distinct separate between settlements of Chesham & Lye Green as well as helping to maintain separate identities of other nearby communities at Orchard Leigh, Botley, Whelpley Hill, Ashley Green. It is perverse and inconsistent with national guidance to allocate this land for removal from Green Belt in light of these facts especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if earmarked for development. A further aim of Green Belt designation stated in the NPPF at paragraph 134 (e) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. By allocating Green Belt land NE of Chesham for development, undermines this aim within Chesham. A community lead not for profit organisation called Chesham Renaissance CIC has been striving to create Chesham Masterplan that would not only provide many genuinely affordable homes in more sustainable locations nearer the town centre, but which would also regenerate some of the more deprived wards within Chesham. The Local Authority's proposals (policy SP EP3) are inconsistent with this local initiative and are therefore also inconsistent with national guidance and are consequently unsound. The Council have asserted that Government planning policy requires local councils to review Green Belt boundaries when considering how to accommodate the development needed in their areas. Just because the Council may be required to look, does not mean the Council should review Green Belt boundaries which as previously stated should only be modified in ªexceptional circumstancesº. National Planning Policy Framework (NPPF) as revised only last year, states in paragraph11 (b) I, directs ªplan makersº to create policies that are required in Local Plans for housing and other uses unless Framework policies (expressly including Green Belt) ªprovides a strong reason for restricting the overall scale type or distribution of development in the plan areaº Accordingly, I submit that given all of the above the land being proposed for release from Green Belt designation around Chesham is unjustified and contrary to national guidance. I am supportive of the Brown Not Green organisation's initiative to have the land listed as an Asset of Community Value and I feel they speak for me in respect of their objections to the draft Local Plan. Accordingly, I request that any representations made by them at any future examination in public regarding the soundness of this Local Plan be considered as an extension of my own comments herein. I feel the land NE of Chesham is an unsustainable location for development, that has been habitually used by the community for improved health & wellbeing for decades and the land performs well against Green Belt aims and objectives. Exceptional circumstances for reviewing Green Belt boundaries at this location, either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by Govt Policy and therefore the plan is unsound. Policy 2a - Please specify as I refer to the comments previously submitted but in summary would advocate that; precisely and succinctly as All other options are fully explored including increased density of development of brownfield land and the possible how you would policies emerging from Chesham Masterplan. modify this policy to improve its alignment to this test of Green Belt land should only be considered when all other options are exhausted and in any event the soundness. proposals for developing land NE of Chesham (policy SP BP 2) should be removed as it is an unsustainable location the development of which will cause harm to the wider town including loss of an asset that improves the well-being for the community. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5492026 Please attach any supporting evidence
Person ID 1219008
8944 Full Name Mrs Ann Crisp ID 841 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness?
8945 Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not Having already signed a previous petition I am contacting you once again re the plans to permit the building believe this policy to be of 500 houses, one shop, and 15 Travellor's pitches on what is currently Green Belt land. justified please explain why A shop in this development seems to me to be a sop, all the small local shops have disappeared in this part of Chesham as they are not sustainable. There are large supermarkets locally and not sufficient, consistent trade to sustain a viable business. The shops onHilltops, Botley Rd, Lye Green Rd. had to close many years ago because of this. The approach roads to this site are all narrow and will create congestion and pollution problems both during construction and on completion, as most households now have at least one car. When there are brown sites available it is, not to put too fine a point on it, immoral to break into green belt land. These areas provide a vital space ecologicallly, agriculturally, and psychologically. I appreciate that some development within the town, preferably affordable homes for couples wanting to maintain a continuity in the community, is needed but these plans seem to me to be a developers' delight. Please do not wrap them up in wording to suggest that they are advantageous to Chesham. They lack sensitivity and practicality. Policy 2a - Please specify as precisely and succinctly as
8946 possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1219013 Full Name Mrs Edith Turnock ID 734 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally
8947 compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be
8948 as precise and succinct as possible Policy Level - PP - If you do Following careful consideration of the above, I am forced to conclude that the council©s Local Plan will cause not believe this policy to be harm to the wider town of Chesham and is unsound. Specific areas of concern include: positively prepared please - loss of Green Belt around Chesham with all of the environmental implications explain why - more traffic congestion and worsening air quality in Chesham - Loss of land with Community Value in Chesham which supports wildlife and recreation - Outward sprawl of the town which will result in Lye Green becoming part of ©Greater Cehsham© - Failure to recognise an opportunity for urban development and regeneration PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not I am concerned that the many hundreds of proposed homes will generate increased traffic and its attendant believe this policy to be air pollution, already at alarming levels in the Chesham area. The designated Air Quality Management Area justified please explain why along Berkhamstead Road is already recording air quality that is considerably worse than EU safe levels. The council©s proposals are inconsistent with Local Plan Policy DM DP5 relating to ©climate responsive development© and policy DM DP9 ©reducing reliance on private cars© and DM DP15 ©BLue Green infrastructure©. The council©s wilful failure to take these into account will only make things worse and cannot be justified under recent national government policy.These considerations alone should be sufficient grounds to reconsider the entire draft local plan which is unsound in this matter. there are suggestions of mitigating the air quality but where is the proof these measures will be delivered or that they will work? The Green Belt site NE of Chesham is over two kilometres from the underground station and Chesham town centre and is therefore an unsustainable location. The council seems to think that the Lye Green site is sustianble and provides easy access to public transport including the underground station , yet the same local plan promotes a considerable increase in retail development in the town (draft local plan policy SP EP3 which I also feel is unsound), part of which would be built on the very car park that serves the Chesham underground station, thus undermining the use of public transport and resulting in the greater use of private cars, which, in turn will lead to more traffic congestion. This is inconsistent and unsound. The flawed methodology used by the Local Authority to select the Green Belt site was not effective, justified or consistent with the national planning policy framework (NPPF) and has resulted in their choice of Lye Green which is unsound. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not It appears that the council has decided to take the easy option and develop Green Belt land (specifically believe this policy in 13GB sites in Chiltern and South Bucks), which is unjustified, ineffective and inconsistent with national policy. consistent with the National This view is supported by the fact that the councils policy for Green Belt release is part of an overall strategic Planning Policy Framework objective that promotes sustainable development as reflected in Local Plan Policy SP SP1. Such sites are Feb 2019 please explain why generally not sustainable, and to designate them as such is unsound. In additional, there are insufficient ©exceptional circumstances© generally to justify Green Belt release and specifically at Lye Green in this instance. Paragraph 136 of the latest National Planning Policy Framework (NPPF) asserts that Green Belt boundaries should be modified only in ©exceptional circumstances©. The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances and Lye Green is not a sustainable location being too far from the town centre with a steep hill to negotiate too. Quite simply, Green Belt land should not be the first choice for development when other, less damaging options exist nearer the Chesham town centre and the underground station. I question the soundness of the local plan which fails to identify the brownfield land opportunities that have been identified by other such as the Chesham Renaissance CIC Masterplan.The council should be looking at higher densities of development on such sites as are generally closer to the town centre. In short, i believe that the council has used flawed methodology for identifying sites to meet local housing needs and that Lye Green is an unsustainable location and, therefore, its release from the Green Belt is unjustified. The selection of the land at Lye Green as suitable for removal from Green Belt is inconsistent with National Planning Policy Framework (NPPF) not only for the reasons so far stated, but also for the fact that the land supports wildlife and is an important recreational site for nearby communities. Most Green Belt areas do not
8949 have widespread public access making this land Lye Green unusual and a rare feature that improves community well being and to allocate such an important sit for development is unjustified. Lye Green is a potential Asset of Community Value and confirmation of this designation will afford a community group the right to bid for the land in order to preserve it for the hundreds of local people who have long used it for recreation purposes. It is perverse that the local authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Local Plan is unsound. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open. This is government policy as set out in paragraph 133 of NPPF 2018. The Lye Green site self-evidently does this well and has done so for decades. A further aim of Green Belt land (stated in NPPF paragraph 134) is to prevent neighbouring towns and settlements from merging into one another. The preservation of Lye Green as Green Belt Land is vital in maintaining a distinct separation from as well as helping to maintain the separate identities of other nearby communities. In view of these facts, it is perverse and inconsistent with national guidance to allocate this land for removal from green belt, especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if the land is developed. Given the above the land being proposed for release form Green Belt designation around Chesham is unjustified and contrary to national guidance. A further aim of Green Belt designation (as stated in the NPPF at paragraph 134(e)) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. Allocating Green Belt land at Lye Green as an area for development completely undermines this aim by failing to recognize the opportunities that exist within Chesham. A community led not-for-profit organisation called Chesham Renaissance CIC has developed the Chesham Masterplan that would not only provide more sustainable locations nearer the town centre, but which would also regenerate some of the more deprived wards within Chesham. While the local plan promotes a considerable increase in retail development alone is not required. A simple stroll down Chesham High Street would reveal at least 10 empty shops. The problem is not insufficient retail spaces but a lack of thoughtful redevelopment that promotes and supports existing retail premises. Indeed the proposals to build shops on the car parks actively undermines the Chesham Renaissance CIC Masterplan. The local authority©s proposals are inconsistent with the local initiative and are therefore also inconsistent with national guidance and are consequently unsound. Everyone in Chesham, not just Lye Green, will be impacted by the addition of 500 homes on this area of Green Belt. I am supportive of the Brown not Green organisation©s initiative to have the land listed as an Asset of Community Value, and I feel they speak for me in respect of their objections to the draft local plan. Accordingly, I request that any representations made by them at any future examination in public regarding the soundness of this local plan be considered as an extension of my own comments herein. I feel the land NE of Chesham at Lye Green is an unsustainable location for development, that has been habitually used by the community for improved health and wellbeing for decades and that the land performs well against Green Belt aims and objectives. Exceptional Circumstances for reviewing Green Belt boundaries at this location either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by government policy, and therefore, the local plan is unsound. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1218986 Full Name Mrs Elizabeth Okey ID 834 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of:
8950 Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is
8951 incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not The development of housing at Lye Green is unsound. It is 2.5km from the town centre and up a steep hill believe this policy to be (white hill and Eskdale Ave and will massively increase traffic along these routes increasing air pollution justified please explain why here. The nature of Chesham as. gap town means all roads are squeezed to go through the centre and there is already a massive build up of traffic here at peak times We do not need new shops built on the car parks. They are not needed and this is not sensible. We do not need so many new houses built at this distance from the town centre on Greenbelt land. I believe , having read the Chesham renaissance CIC masterplan that this constitutes IMPROVED development plans which WILL rejuvenate Chesham Policy 2a - Please specify as There should be no necessity to build shops on the current car parks in the town as we have many shops precisely and succinctly as empty or designated charity shops. possible how you would To revitalise our town centre we need houses and flats converted nearer the town centre and the car parks modify this policy to improve left as they are, providing good parking for the residents. Multi storeys are ugly and become places for its alignment to this test of vandalisation and crime. soundness. Berkhamsted is a larger town than Chesham, yet has better shops and NO multi storey car parks . It is a pleasure to shop there. We do not want a town plan that creates such horrible, ugly and unnecessary development in Chesham. We could use the unwanted agricultural land at lye green to increase tree planting and wild flower meadows to make a healthier town for Chesham This is in accordance with afire planned local policies. There was NO PRIOR CONSULTATION on Green Belt Village Policies ( SP PP1 and DMPP1) Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not Is the plan justified in its removal from the Green Belt for housing at Lye Green. There are no exceptional believe this policy in circumstances that could allow this (courts have ruled that housing needs alone are NOT exceptional consistent with the National circumstances). Planning Policy Framework Brownfield sites exist which are closer to the town centre. And doing this will rejuvenate Chesham without Feb 2019 please explain why the necessity of over burdening the roads leading into the town.. there roads could become very much more congested and worsen the air pollution and air quality problem in Chesham.
8952 The plan is NOT in accord with National Guidance, the national planning policy framework. Policy 3a - Please specify as The new awareness of the climate change emergency urges councils to release any land possible for green precisely and succinctly as purposes. For example, planting trees recaptures the carbon causing global warming. Wild flower sites can possible how you would restore biodiversity, encouraging insects and pollen makers. The land at Lye Green should and must be modify this policy to improve used for these purposes to make a healthy environment for local people possible. its alignment to this test of The present plan INCREASES the carbon footprint and there is NO PROOF that the mitigation will be soundness. delivered or even work Local Plans policies SHOULD seek to protect our wildlife habitats and to protect our globally scarce chalk stream rivers and this Plan undermines them Policy-level file upload - Please attach any supporting evidence
Person ID 1219018 Full Name Mr Stewart Pike ID 726 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness?
8953 Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not The roads are already congested with unacceptable and illegal levels of pollution. Why is another 21% believe this policy to be increase in the carbon footprint acceptable? The large Lye Green proposal is 2.5km from the town, and justified please explain why would cause an increased in traffic congestion and pollution.
8954 The doctors surgeries are overloaded, with long waiting times to see a doctor.The hospitals are overcrowded already without a large additional influx of new residents who will require treatment.Then there is the density of pupils in local schools to be considered. How are all these extra residents going to be accommodated if the Local Plan is implemented? We discern that there is no reference of this in the Local Plan. How is all of the proposed development going to be paid for? This is at present unspecified we understand. A huge funding gap exists. Policy 2a - Please specify as We exhort that this ill thought-out Draft Local Plan be rejected precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not Once substantial areas of Green Belt land are released for building there will be no limit on the amount that believe this policy in will be released in the future - a precedent will have to be set. If local villages are removed from the Green consistent with the National Belt the result will be infilling and the creation of ©Greater chesham©. The uniqueness of these hamlets will Planning Policy Framework be lost forever. Recreational countryside and valuable farmland will disappear under concrete. We live in Feb 2019 please explain why ©The Chilterns©, an area of outstanding natural beauty, let©s not ruin it for future generations. Build housing on brown field sites near Chesham town centre. The release of green belt land goes against other local plans to protect the environment. The National Planning Policy Framework informs policy makers to provide housing etc, unless Green Belt policies provide a powerful reason not to. Why is this local plan doing otherwise? Why was there no prior consultation on ©Green Belt Villages Policies©? Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1219020 Full Name Mrs Wah Choo Pike ID 727 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider
8955 the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to
8956 Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not The roads are already congested with unacceptable and illegal levels of pollution. Why is another 21% believe this policy to be increase in the carbon footprint acceptable? The large Lye Green proposal is 2.5km from the town, and justified please explain why would cause an increased in traffic congestion and pollution. The doctors surgeries are overloaded, with long waiting times to see a doctor.The hospitals are overcrowded already without a large additional influx of new residents who will require treatment.Then there is the density of pupils in local schools to be considered. How are all these extra residents going to be accommodated if the Local Plan is implemented? We discern that there is no reference of this in the Local Plan. How is all of the proposed development going to be paid for? This is at present unspecified we understand. A huge funding gap exists. Policy 2a - Please specify as We exhort that this ill thought-out Draft Local Plan be rejected. precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not Once substantial areas of Green Belt land are released for building there will be no limit on the amount that believe this policy in will be released in the future - a precedent will have to be set. If local villages are removed from the Green consistent with the National Belt the result will be infilling and the creation of ©Greater chesham©. The uniqueness of these hamlets will Planning Policy Framework be lost forever. Recreational countryside and valuable farmland will disappear under concrete. We live in Feb 2019 please explain why ©The Chilterns©, an area of outstanding natural beauty, let©s not ruin it for future generations. Build housing on brown field sites near Chesham town centre. The release of green belt land goes against other local plans to protect the environment. The National Planning Policy Framework informs policy makers to provide housing etc, unless Green Belt policies provide a powerful reason not to. Why is this local plan doing otherwise? Why was there no prior consultation on ©Green Belt Villages Policies©? Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
8957 Person ID 1219026 Full Name SA Huphrey ID 722 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness?
8958 Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I©m not directly inconvenienced, but I do believe strongly that this policy has not been positively prepared. not believe this policy to be I have a granddaughter in local schools that already have over 30 pupils in a class. positively prepared please explain why Already have to wait for a doctors appointment. With another 500 houses in the district this will only get worse. The roads into and out of Chesham already are a nightmare. I know more housing is needed but use brown field sites first. I am also very disappointed that it would appear the local councillors have not put out more of an objection to this plan.Yet again it would appear that the voices of local people have not been listened too... Another possible 1000 residents to the area plus cars would have a devastating effect on our environment PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
8959 Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1219030 Full Name Tim Watts ID 720 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You
8960 will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I question the soundness of the plan. not believe this policy to be
8961 positively prepared please I have seen reports of the criticisms of the plan from Chesham Renaissance and from Brown not Green and explain why support much of what they have to say. Their points and arguements are much more detailed than anything I can say as they have applied great expertise (which i do not have) in the study of the legality of the process and the full implications of the draft plan. More importantly, they suggest a number of alternatives that seem better to answer the questions. I commend them. The plan is out-of-date. It is clear that the draft plan has been a number of years in preparation but it appears that some of the underlying assumptions ignore how life has developed over this period. To be blunt, it does not reflect the significant changes in public attitudes that have occurred in the last year or two in terms of the very real concerns about preserving resources and how all elements of government should be doing more to plan sustainability and with an eye for protecting the environment. The method suggested by the plan for finding space for new housing appears to be relaxing the protection of the green belt. How is that good for the environment? A large area of Chesham, presently given over to car parking (and which barely adequate for that purpose at present - where can cars be parked?) is earmarked for retail. This seems to include the station car park (full most days before the rush hour ends - it needs expanding). Have those writing the plan not noticed that public shopping habits and eating habits have moved on with much shopping now arranged online and more drinking now done within the home. Chesham already has many closed retail outlets with no new businesses take over the empty properties. This seems out-of-touch. The plan calls for new homes, but the make up of the suggested new stock seems a continuation of old policies of individual homes or small apartment blocks for which large areas of land are needed. Where is the vision of new solutions to meet demand by better use of previously built on sites - indeed, not just new solutions but also perhaps old solutions such as the Prince of Wales© suggestion of Mansion Blocks. Little that I can see in the plan seems to envisage new infrastructure. From where, for example, is the supply of water for the new residents to come? Domestic water is taken by abstraction from acquifers in our area, but we read that the water within the whole of Chiltern Hills area is severely depleted with dire consequences for our chalk streams and that the globally rare habitats they supported have gone with the streams often being dry. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1219034 Full Name Mrs Coral Sills ID 738
8962 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as
8963 precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Following careful consideration of the above, I am forced to conclude that the council©s Local Plan will cause not believe this policy to be harm to the wider town of Chesham and is unsound. Specific areas of concern include: positively prepared please - loss of Green Belt around Chesham with all of the environmental implications explain why - more traffic congestion and worsening air quality in Chesham - Loss of land with Community Value in Chesham which supports wildlife and recreation - Outward sprawl of the town which will result in Lye Green becoming part of ©Greater Cehsham© - Failure to recognise an opportunity for urban development and regeneration PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not I am concerned that the many hundreds of proposed homes will generate increased traffic and its attendant believe this policy to be air pollution, already at alarming levels in the Chesham area. The designated Air Quality Management Area justified please explain why along Berkhamstead Road is already recording air quality that is considerably worse than EU safe levels. The council©s proposals are inconsistent with Local Plan Policy DM DP5 relating to ©climate responsive development© and policy DM DP9 ©reducing reliance on private cars© and DM DP15 ©BLue Green infrastructure©. The council©s wilful failure to take these into account will only make things worse and cannot be justified under recent national government policy.These considerations alone should be sufficient grounds to reconsider the entire draft local plan which is unsound in this matter. there are suggestions of mitigating the air quality but where is the proof these measures will be delivered or that they will work? The Green Belt site NE of Chesham is over two kilometres from the underground station and Chesham town centre and is therefore an unsustainable location. The council seems to think that the Lye Green site is sustianble and provides easy access to public transport including the underground station , yet the same local plan promotes a considerable increase in retail development in the town (draft local plan policy SP EP3 which I also feel is unsound), part of which would be built on the very car park that serves the Chesham underground station, thus undermining the use of public transport and resulting in the greater use of private cars, which, in turn will lead to more traffic congestion. This is inconsistent and unsound.
8964 The flawed methodology used by the Local Authority to select the Green Belt site was not effective, justified or consistent with the national planning policy framework (NPPF) and has resulted in their choice of Lye Green which is unsound. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not It appears that the council has decided to take the easy option and develop Green Belt land (specifically believe this policy in 13GB sites in Chiltern and South Bucks), which is unjustified, ineffective and inconsistent with national policy. consistent with the National This view is supported by the fact that the councils policy for Green Belt release is part of an overall strategic Planning Policy Framework objective that promotes sustainable development as reflected in Local Plan Policy SP SP1. Such sites are Feb 2019 please explain why generally not sustainable, and to designate them as such is unsound. In additional, there are insufficient ©exceptional circumstances© generally to justify Green Belt release and specifically at Lye Green in this instance. Paragraph 136 of the latest National Planning Policy Framework (NPPF) asserts that Green Belt boundaries should be modified only in ©exceptional circumstances©. The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances and Lye Green is not a sustainable location being too far from the town centre with a steep hill to negotiate too. Quite simply, Green Belt land should not be the first choice for development when other, less damaging options exist nearer the Chesham town centre and the underground station. I question the soundness of the local plan which fails to identify the brownfield land opportunities that have been identified by other such as the Chesham Renaissance CIC Masterplan.The council should be looking at higher densities of development on such sites as are generally closer to the town centre. In short, i believe that the council has used flawed methodology for identifying sites to meet local housing needs and that Lye Green is an unsustainable location and, therefore, its release from the Green Belt is unjustified. The selection of the land at Lye Green as suitable for removal from Green Belt is inconsistent with National Planning Policy Framework (NPPF) not only for the reasons so far stated, but also for the fact that the land supports wildlife and is an important recreational site for nearby communities. Most Green Belt areas do not have widespread public access making this land Lye Green unusual and a rare feature that improves community well being and to allocate such an important sit for development is unjustified. Lye Green is a potential Asset of Community Value and confirmation of this designation will afford a community group the right to bid for the land in order to preserve it for the hundreds of local people who have long used it for recreation purposes. It is perverse that the local authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Local Plan is unsound. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open. This is government policy as set out in paragraph 133 of NPPF 2018. The Lye Green site self-evidently does this well and has done so for decades. A further aim of Green Belt land (stated in NPPF paragraph 134) is to prevent neighbouring towns and settlements from merging into one another. The preservation of Lye Green as Green Belt Land is vital in maintaining a distinct separation from as well as helping to maintain the separate identities of other nearby communities. In view of these facts, it is perverse and inconsistent with national guidance to allocate this land for removal from green belt, especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if the land is developed. Given the above the land being proposed for release form Green Belt designation around Chesham is unjustified and contrary to national guidance. A further aim of Green Belt designation (as stated in the NPPF at paragraph 134(e)) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. Allocating Green Belt land at Lye Green as an area for development completely undermines this aim by failing to recognize the opportunities that exist within Chesham. A community led not-for-profit organisation called Chesham Renaissance CIC has developed the Chesham Masterplan that would not only provide more sustainable locations nearer the town centre, but which would also regenerate some of the more deprived wards within Chesham. While the local plan promotes a considerable increase in retail development alone is not required. A simple stroll down Chesham High Street would reveal at least 10 empty shops. The problem is not insufficient retail spaces but a lack of thoughtful redevelopment that promotes and supports existing retail premises. Indeed the proposals to build shops on the car parks actively undermines the Chesham Renaissance CIC Masterplan. The local authority©s proposals are inconsistent with the local initiative and are therefore also inconsistent with national guidance and are consequently unsound. Everyone in Chesham, not just Lye Green, will be impacted by the addition of 500 homes on this area of Green Belt. I am supportive of the Brown not Green organisation©s initiative to have the land listed as an
8965 Asset of Community Value, and I feel they speak for me in respect of their objections to the draft local plan. Accordingly, I request that any representations made by them at any future examination in public regarding the soundness of this local plan be considered as an extension of my own comments herein. I feel the land NE of Chesham at Lye Green is an unsustainable location for development, that has been habitually used by the community for improved health and wellbeing for decades and that the land performs well against Green Belt aims and objectives. Exceptional Circumstances for reviewing Green Belt boundaries at this location either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by government policy, and therefore, the local plan is unsound. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
8966 Person ID 1219036 Full Name Mrs Cath Keys ID 736 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness?
8967 Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Following careful consideration of the above, I am forced to conclude that the council©s Local Plan will cause not believe this policy to be harm to the wider town of Chesham and is unsound. Specific areas of concern include: positively prepared please - loss of Green Belt around Chesham with all of the environmental implications explain why - more traffic congestion and worsening air quality in Chesham - Loss of land with Community Value in Chesham which supports wildlife and recreation - Outward sprawl of the town which will result in Lye Green becoming part of ©Greater Cehsham© - Failure to recognise an opportunity for urban development and regeneration PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not I am concerned that the many hundreds of proposed homes will generate increased traffic and its attendant believe this policy to be air pollution, already at alarming levels in the Chesham area. The designated Air Quality Management Area justified please explain why along Berkhamstead Road is already recording air quality that is considerably worse than EU safe levels. The council©s proposals are inconsistent with Local Plan Policy DM DP5 relating to ©climate responsive development© and policy DM DP9 ©reducing reliance on private cars© and DM DP15 ©BLue Green infrastructure©. The council©s wilful failure to take these into account will only make things worse and cannot be justified under recent national government policy.These considerations alone should be sufficient grounds to reconsider the entire draft local plan which is unsound in this matter. there are suggestions of mitigating the air quality but where is the proof these measures will be delivered or that they will work? The Green Belt site NE of Chesham is over two kilometres from the underground station and Chesham town centre and is therefore an unsustainable location. The council seems to think that the Lye Green site is sustianble and provides easy access to public transport including the underground station , yet the same local plan promotes a considerable increase in retail development in the town (draft local plan policy SP EP3
8968 which I also feel is unsound), part of which would be built on the very car park that serves the Chesham underground station, thus undermining the use of public transport and resulting in the greater use of private cars, which, in turn will lead to more traffic congestion. This is inconsistent and unsound. The flawed methodology used by the Local Authority to select the Green Belt site was not effective, justified or consistent with the national planning policy framework (NPPF) and has resulted in their choice of Lye Green which is unsound. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not It appears that the council has decided to take the easy option and develop Green Belt land (specifically believe this policy in 13GB sites in Chiltern and South Bucks), which is unjustified, ineffective and inconsistent with national policy. consistent with the National This view is supported by the fact that the councils policy for Green Belt release is part of an overall strategic Planning Policy Framework objective that promotes sustainable development as reflected in Local Plan Policy SP SP1. Such sites are Feb 2019 please explain why generally not sustainable, and to designate them as such is unsound. In additional, there are insufficient ©exceptional circumstances© generally to justify Green Belt release and specifically at Lye Green in this instance. Paragraph 136 of the latest National Planning Policy Framework (NPPF) asserts that Green Belt boundaries should be modified only in ©exceptional circumstances©. The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances and Lye Green is not a sustainable location being too far from the town centre with a steep hill to negotiate too. Quite simply, Green Belt land should not be the first choice for development when other, less damaging options exist nearer the Chesham town centre and the underground station. I question the soundness of the local plan which fails to identify the brownfield land opportunities that have been identified by other such as the Chesham Renaissance CIC Masterplan.The council should be looking at higher densities of development on such sites as are generally closer to the town centre. In short, i believe that the council has used flawed methodology for identifying sites to meet local housing needs and that Lye Green is an unsustainable location and, therefore, its release from the Green Belt is unjustified. The selection of the land at Lye Green as suitable for removal from Green Belt is inconsistent with National Planning Policy Framework (NPPF) not only for the reasons so far stated, but also for the fact that the land supports wildlife and is an important recreational site for nearby communities. Most Green Belt areas do not have widespread public access making this land Lye Green unusual and a rare feature that improves community well being and to allocate such an important sit for development is unjustified. Lye Green is a potential Asset of Community Value and confirmation of this designation will afford a community group the right to bid for the land in order to preserve it for the hundreds of local people who have long used it for recreation purposes. It is perverse that the local authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Local Plan is unsound. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open. This is government policy as set out in paragraph 133 of NPPF 2018. The Lye Green site self-evidently does this well and has done so for decades. A further aim of Green Belt land (stated in NPPF paragraph 134) is to prevent neighbouring towns and settlements from merging into one another. The preservation of Lye Green as Green Belt Land is vital in maintaining a distinct separation from as well as helping to maintain the separate identities of other nearby communities. In view of these facts, it is perverse and inconsistent with national guidance to allocate this land for removal from green belt, especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if the land is developed. Given the above the land being proposed for release form Green Belt designation around Chesham is unjustified and contrary to national guidance. A further aim of Green Belt designation (as stated in the NPPF at paragraph 134(e)) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. Allocating Green Belt land at Lye Green as an area for development completely undermines this aim by failing to recognize the opportunities that exist within Chesham. A community led not-for-profit organisation called Chesham Renaissance CIC has developed the Chesham Masterplan that would not only provide more sustainable locations nearer the town centre, but which would also regenerate some of the more deprived wards within Chesham. While the local plan promotes a considerable increase in retail development alone is not required. A simple stroll down Chesham High Street would reveal at least 10 empty shops. The problem is not insufficient retail spaces but a lack of thoughtful redevelopment that promotes and supports existing retail premises. Indeed the proposals to build shops on the car parks actively undermines the Chesham Renaissance CIC Masterplan.
8969 The local authority©s proposals are inconsistent with the local initiative and are therefore also inconsistent with national guidance and are consequently unsound. Everyone in Chesham, not just Lye Green, will be impacted by the addition of 500 homes on this area of Green Belt. I am supportive of the Brown not Green organisation©s initiative to have the land listed as an Asset of Community Value, and I feel they speak for me in respect of their objections to the draft local plan. Accordingly, I request that any representations made by them at any future examination in public regarding the soundness of this local plan be considered as an extension of my own comments herein. I feel the land NE of Chesham at Lye Green is an unsustainable location for development, that has been habitually used by the community for improved health and wellbeing for decades and that the land performs well against Green Belt aims and objectives. Exceptional Circumstances for reviewing Green Belt boundaries at this location either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by government policy, and therefore, the local plan is unsound. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1219038 Full Name James Pitt ID 718 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally
8970 compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why
8971 PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not Regarding the planned proposals for development of 500 houses, shop and traveller pitches to be belt on believe this policy to be green belt land we strongly endorse all the issues raised by Brown not Green Chesham limited. justified please explain why We feel that the green belt should be preserved at all costs and all brown field sites in the Chiltern District should be utilised first. There is insufficient infrastructure to accommodate the number of proposed dwellings. The medical and doctor facilities are already overloaded. Walk in medical facilities are only available at Stoke Mandeville, High Wycombe or Hemel Hempstead which is not Buckinghamshire. We have insufficient police presence with only a part time police station. School places would also need to be provided for the addition of all the extra children where would these schools be built? Already in the mornings the traffic can trail back to Ashley Green with vehicles coming off the A41 queuing to get through Chesham. The Green belt is too precious resource to be bulldozed in such a drastic way. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1219031 Full Name Mr Barry Holt ID 860 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of:
8972 Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is
8973 incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do As housing needs alone are not considered as "exceptional circumstances" I can©t see justification for the not believe this policy to be refining of Green Belt boundaries at Lye Green (policy SP BP 2) and the removing and infilling of villages positively prepared please (policies SP PP1 and DM PP 1). The sites are too far from town centres generating more car use, pollution explain why and carbon footprint. There appears to be little indication of what infrastructure will be needed or provided. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1219032 Full Name Mrs Gwenda Hudson ID 735
8974 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as
8975 precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Following careful consideration of the above, I am forced to conclude that the council©s Local Plan will cause not believe this policy to be harm to the wider town of Chesham and is unsound. Specific areas of concern include: positively prepared please - loss of Green Belt around Chesham with all of the environmental implications explain why - more traffic congestion and worsening air quality in Chesham - Loss of land with Community Value in Chesham which supports wildlife and recreation - Outward sprawl of the town which will result in Lye Green becoming part of ©Greater Cehsham© - Failure to recognise an opportunity for urban development and regeneration PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not I am concerned that the many hundreds of proposed homes will generate increased traffic and its attendant believe this policy to be air pollution, already at alarming levels in the Chesham area. The designated Air Quality Management Area justified please explain why along Berkhamstead Road is already recording air quality that is considerably worse than EU safe levels. The council©s proposals are inconsistent with Local Plan Policy DM DP5 relating to ©climate responsive development© and policy DM DP9 ©reducing reliance on private cars© and DM DP15 ©BLue Green infrastructure©. The council©s wilful failure to take these into account will only make things worse and cannot be justified under recent national government policy.These considerations alone should be sufficient grounds to reconsider the entire draft local plan which is unsound in this matter. there are suggestions of mitigating the air quality but where is the proof these measures will be delivered or that they will work? The Green Belt site NE of Chesham is over two kilometres from the underground station and Chesham town centre and is therefore an unsustainable location. The council seems to think that the Lye Green site is sustianble and provides easy access to public transport including the underground station , yet the same local plan promotes a considerable increase in retail development in the town (draft local plan policy SP EP3 which I also feel is unsound), part of which would be built on the very car park that serves the Chesham underground station, thus undermining the use of public transport and resulting in the greater use of private cars, which, in turn will lead to more traffic congestion. This is inconsistent and unsound.
8976 The flawed methodology used by the Local Authority to select the Green Belt site was not effective, justified or consistent with the national planning policy framework (NPPF) and has resulted in their choice of Lye Green which is unsound. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not It appears that the council has decided to take the easy option and develop Green Belt land (specifically believe this policy in 13GB sites in Chiltern and South Bucks), which is unjustified, ineffective and inconsistent with national policy. consistent with the National This view is supported by the fact that the councils policy for Green Belt release is part of an overall strategic Planning Policy Framework objective that promotes sustainable development as reflected in Local Plan Policy SP SP1. Such sites are Feb 2019 please explain why generally not sustainable, and to designate them as such is unsound. In additional, there are insufficient ©exceptional circumstances© generally to justify Green Belt release and specifically at Lye Green in this instance. Paragraph 136 of the latest National Planning Policy Framework (NPPF) asserts that Green Belt boundaries should be modified only in ©exceptional circumstances©. The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances and Lye Green is not a sustainable location being too far from the town centre with a steep hill to negotiate too. Quite simply, Green Belt land should not be the first choice for development when other, less damaging options exist nearer the Chesham town centre and the underground station. I question the soundness of the local plan which fails to identify the brownfield land opportunities that have been identified by other such as the Chesham Renaissance CIC Masterplan.The council should be looking at higher densities of development on such sites as are generally closer to the town centre. In short, i believe that the council has used flawed methodology for identifying sites to meet local housing needs and that Lye Green is an unsustainable location and, therefore, its release from the Green Belt is unjustified. The selection of the land at Lye Green as suitable for removal from Green Belt is inconsistent with National Planning Policy Framework (NPPF) not only for the reasons so far stated, but also for the fact that the land supports wildlife and is an important recreational site for nearby communities. Most Green Belt areas do not have widespread public access making this land Lye Green unusual and a rare feature that improves community well being and to allocate such an important sit for development is unjustified. Lye Green is a potential Asset of Community Value and confirmation of this designation will afford a community group the right to bid for the land in order to preserve it for the hundreds of local people who have long used it for recreation purposes. It is perverse that the local authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Local Plan is unsound. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open. This is government policy as set out in paragraph 133 of NPPF 2018. The Lye Green site self-evidently does this well and has done so for decades. A further aim of Green Belt land (stated in NPPF paragraph 134) is to prevent neighbouring towns and settlements from merging into one another. The preservation of Lye Green as Green Belt Land is vital in maintaining a distinct separation from as well as helping to maintain the separate identities of other nearby communities. In view of these facts, it is perverse and inconsistent with national guidance to allocate this land for removal from green belt, especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if the land is developed. Given the above the land being proposed for release form Green Belt designation around Chesham is unjustified and contrary to national guidance. A further aim of Green Belt designation (as stated in the NPPF at paragraph 134(e)) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. Allocating Green Belt land at Lye Green as an area for development completely undermines this aim by failing to recognize the opportunities that exist within Chesham. A community led not-for-profit organisation called Chesham Renaissance CIC has developed the Chesham Masterplan that would not only provide more sustainable locations nearer the town centre, but which would also regenerate some of the more deprived wards within Chesham. While the local plan promotes a considerable increase in retail development alone is not required. A simple stroll down Chesham High Street would reveal at least 10 empty shops. The problem is not insufficient retail spaces but a lack of thoughtful redevelopment that promotes and supports existing retail premises. Indeed the proposals to build shops on the car parks actively undermines the Chesham Renaissance CIC Masterplan. The local authority©s proposals are inconsistent with the local initiative and are therefore also inconsistent with national guidance and are consequently unsound. Everyone in Chesham, not just Lye Green, will be impacted by the addition of 500 homes on this area of Green Belt. I am supportive of the Brown not Green organisation©s initiative to have the land listed as an
8977 Asset of Community Value, and I feel they speak for me in respect of their objections to the draft local plan. Accordingly, I request that any representations made by them at any future examination in public regarding the soundness of this local plan be considered as an extension of my own comments herein. I feel the land NE of Chesham at Lye Green is an unsustainable location for development, that has been habitually used by the community for improved health and wellbeing for decades and that the land performs well against Green Belt aims and objectives. Exceptional Circumstances for reviewing Green Belt boundaries at this location either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by government policy, and therefore, the local plan is unsound. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1219035 Full Name Mrs Valerie Taylor ID 737 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible.
8978 Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Following careful consideration of the above, I am forced to conclude that the council©s Local Plan will cause not believe this policy to be harm to the wider town of Chesham and is unsound. Specific areas of concern include: positively prepared please - loss of Green Belt around Chesham with all of the environmental implications explain why - more traffic congestion and worsening air quality in Chesham - Loss of land with Community Value in Chesham which supports wildlife and recreation - Outward sprawl of the town which will result in Lye Green becoming part of ©Greater Cehsham© - Failure to recognise an opportunity for urban development and regeneration
8979 PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not I am concerned that the many hundreds of proposed homes will generate increased traffic and its attendant believe this policy to be air pollution, already at alarming levels in the Chesham area. The designated Air Quality Management Area justified please explain why along Berkhamstead Road is already recording air quality that is considerably worse than EU safe levels. The council©s proposals are inconsistent with Local Plan Policy DM DP5 relating to ©climate responsive development© and policy DM DP9 ©reducing reliance on private cars© and DM DP15 ©BLue Green infrastructure©. The council©s wilful failure to take these into account will only make things worse and cannot be justified under recent national government policy.These considerations alone should be sufficient grounds to reconsider the entire draft local plan which is unsound in this matter. there are suggestions of mitigating the air quality but where is the proof these measures will be delivered or that they will work? The Green Belt site NE of Chesham is over two kilometres from the underground station and Chesham town centre and is therefore an unsustainable location. The council seems to think that the Lye Green site is sustianble and provides easy access to public transport including the underground station , yet the same local plan promotes a considerable increase in retail development in the town (draft local plan policy SP EP3 which I also feel is unsound), part of which would be built on the very car park that serves the Chesham underground station, thus undermining the use of public transport and resulting in the greater use of private cars, which, in turn will lead to more traffic congestion. This is inconsistent and unsound. The flawed methodology used by the Local Authority to select the Green Belt site was not effective, justified or consistent with the national planning policy framework (NPPF) and has resulted in their choice of Lye Green which is unsound. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not It appears that the council has decided to take the easy option and develop Green Belt land (specifically believe this policy in 13GB sites in Chiltern and South Bucks), which is unjustified, ineffective and inconsistent with national policy. consistent with the National This view is supported by the fact that the councils policy for Green Belt release is part of an overall strategic Planning Policy Framework objective that promotes sustainable development as reflected in Local Plan Policy SP SP1. Such sites are Feb 2019 please explain why generally not sustainable, and to designate them as such is unsound. In additional, there are insufficient ©exceptional circumstances© generally to justify Green Belt release and specifically at Lye Green in this instance. Paragraph 136 of the latest National Planning Policy Framework (NPPF) asserts that Green Belt boundaries should be modified only in ©exceptional circumstances©. The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances and Lye Green is not a sustainable location being too far from the town centre with a steep hill to negotiate too. Quite simply, Green Belt land should not be the first choice for development when other, less damaging options exist nearer the Chesham town centre and the underground station. I question the soundness of the local plan which fails to identify the brownfield land opportunities that have been identified by other such as the Chesham Renaissance CIC Masterplan.The council should be looking at higher densities of development on such sites as are generally closer to the town centre. In short, i believe that the council has used flawed methodology for identifying sites to meet local housing needs and that Lye Green is an unsustainable location and, therefore, its release from the Green Belt is unjustified. The selection of the land at Lye Green as suitable for removal from Green Belt is inconsistent with National Planning Policy Framework (NPPF) not only for the reasons so far stated, but also for the fact that the land supports wildlife and is an important recreational site for nearby communities. Most Green Belt areas do not have widespread public access making this land Lye Green unusual and a rare feature that improves community well being and to allocate such an important sit for development is unjustified. Lye Green is a potential Asset of Community Value and confirmation of this designation will afford a community group the right to bid for the land in order to preserve it for the hundreds of local people who have long used it for recreation purposes. It is perverse that the local authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Local Plan is unsound. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open. This is government policy as set out in paragraph 133 of NPPF 2018. The Lye Green site self-evidently does this well and has done so for decades.
8980 A further aim of Green Belt land (stated in NPPF paragraph 134) is to prevent neighbouring towns and settlements from merging into one another. The preservation of Lye Green as Green Belt Land is vital in maintaining a distinct separation from as well as helping to maintain the separate identities of other nearby communities. In view of these facts, it is perverse and inconsistent with national guidance to allocate this land for removal from green belt, especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if the land is developed. Given the above the land being proposed for release form Green Belt designation around Chesham is unjustified and contrary to national guidance. A further aim of Green Belt designation (as stated in the NPPF at paragraph 134(e)) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. Allocating Green Belt land at Lye Green as an area for development completely undermines this aim by failing to recognize the opportunities that exist within Chesham. A community led not-for-profit organisation called Chesham Renaissance CIC has developed the Chesham Masterplan that would not only provide more sustainable locations nearer the town centre, but which would also regenerate some of the more deprived wards within Chesham. While the local plan promotes a considerable increase in retail development alone is not required. A simple stroll down Chesham High Street would reveal at least 10 empty shops. The problem is not insufficient retail spaces but a lack of thoughtful redevelopment that promotes and supports existing retail premises. Indeed the proposals to build shops on the car parks actively undermines the Chesham Renaissance CIC Masterplan. The local authority©s proposals are inconsistent with the local initiative and are therefore also inconsistent with national guidance and are consequently unsound. Everyone in Chesham, not just Lye Green, will be impacted by the addition of 500 homes on this area of Green Belt. I am supportive of the Brown not Green organisation©s initiative to have the land listed as an Asset of Community Value, and I feel they speak for me in respect of their objections to the draft local plan. Accordingly, I request that any representations made by them at any future examination in public regarding the soundness of this local plan be considered as an extension of my own comments herein. I feel the land NE of Chesham at Lye Green is an unsustainable location for development, that has been habitually used by the community for improved health and wellbeing for decades and that the land performs well against Green Belt aims and objectives. Exceptional Circumstances for reviewing Green Belt boundaries at this location either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by government policy, and therefore, the local plan is unsound. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1219039 Full Name Gillian Pitt ID 719 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant.
8981 Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as
8982 precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not Regarding the planned proposals for development of 500 houses, shop and traveller pitches to be belt on believe this policy to be green belt land we strongly endorse all the issues raised by Brown not Green Chesham limited. justified please explain why We feel that the green belt should be preserved at all costs and all brown field sites in the Chiltern District should be utilised first. There is insufficient infrastructure to accommodate the number of proposed dwellings. The medical and doctor facilities are already overloaded. Walk in medical facilities are only available at Stoke Mandeville, High Wycombe or Hemel Hempstead which is not Buckinghamshire. We have insufficient police presence with only a part time police station. School places would also need to be provided for the addition of all the extra children where would these schools be built? Already in the mornings the traffic can trail back to Ashley Green with vehicles coming off the A41 queuing to get through Chesham. The Green belt is too precious resource to be bulldozed in such a drastic way. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1219128 Full Name Mrs Diane Kolka
8983 ID 980 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its
8984 alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not The proposals to release Green Belt land to meet housing targets (Generally, Spatial Policy SP SP1 & believe this policy to be specifically Policy SP BP2 at Lye Green NE of Chesham) are not justified from the evidence submitted by justified please explain why the Councils. The Councils have stated that release of some Green Belt is necessary as part of an overall three part strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. I question the soundness of such a general policy and whether all the brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites and in particular the Green Belt site NE of Chesham at Lye Green. The development of such Green Belt sites involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient and unfunded. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham cannot accommodate any significant highways improvements anyway due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion, with further worsening air quality. Air pollution is a particular concern in Chesham due to the already poor air quality along Berkhampstead Road where there is a designated Air Quality Management Area that already is recording air quality that is
8985 considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will generate more traffic will make the air quality even worse and insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable nor justified nor is it in accordance with Govt policy. The Green Belt site NE of Chesham (SP BP 2) is not a sustainable location. It is over 2Km away from the train station and slightly further still from the town centre but anyone who cares to walk or cycle this distance also has to negotiate a steep hill too. Such an unsustainable location cannot be made sustainable merely by upgrading a couple of public footpaths within the site into bridleways to facilitate cycling. Neither does adding a bus stop address the geography or topography of the area especially if the promised enhanced bus service (which is already infrequent) either does not materialise or if it subsequently fails to be maintained after a few years. Paragraph 136 of the latest NPPF asserts that Green Belt boundaries should only be modified in ªexceptional circumstancesº. The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances. The Council engaged third party consultants to undertake the Part 1 Green Belt assessment and they identified numerous sites for ªfurther considerationº where exceptional circumstances ªmightº exist but expressly recommended further review of their assessment of each site against the 5 purposes of land being in Green Belt of all these sites. Unlike the neighbouring Local Authorities, the Part 2 Green Belt assessment was not undertaken by third party consultants but by the Local Authority itself who notably then did not undertake all the recommended reviews of each site including the land NE of Chesham at Lye Green (SP BP 2). Accordingly, this oversight in the Part 2 Green Belt assessment placed premature focus and fixation on releasing land at Lye Green NE of Chesham from Green Belt designation. The subsequent identification of the Chesham site for release is therefore unjustified. These comments apply equally to proposals effecting the villages in the Green Belt ± policies SP PP1 & DM PP1) The primary aim of Green Belt land (as recited in NPPF 133) is to prevent urban sprawl and to preserve the openness of the area. The Lye Green site (SP BP2) self-evidently performs this function well and has done so for decades. Another aim of Green Belt land stated in NPPF paragraph 134, is to prevent neighbouring towns and settlements from merging into one another.The Green Belt land NE of Chesham performs exceptionally well in maintaining a distinct separate between settlements of Chesham & Lye Green as well as helping to maintain separate identities of other nearby communities at Orchard Leigh, Botley, Whelpley Hill, Ashley Green. It is perverse and inconsistent with national guidance to allocate this land for removal from Green Belt in light of these facts especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if earmarked for development. A further aim of Green Belt designation stated in the NPPF at paragraph 134 (e) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. By allocating Green Belt land NE of Chesham for development, undermines this aim within Chesham. A community lead not for profit organisation called Chesham Renaissance CIC has been striving to create Chesham Masterplan that would not only provide many genuinely affordable homes in more sustainable locations nearer the town centre, but which would also regenerate some of the more deprived wards within Chesham. The Local Authority's proposals (policy SP EP3) are inconsistent with this local initiative and are therefore also inconsistent with national guidance and are consequently unsound Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not Further doubt is cast upon the ªsoundnessº of this Plan by virtue of there being conflicting policies within it. believe this policy to be The Council seem to think that the Green Belt site NE of Chesham is sustainable and provides easy access effective please explain why. to public transport including the tube station yet the same Plan promotes a considerable increase in retail development in the town (local draft plan policy SP EP3) , part of which would be built on the very car park that serves the Chesham tube station. This is inconsistent and unsound. For this Plan to sound it must also be effective. Unfortunately, further review of the proposal to remove land NE of Chesham at Lye Green from Green Belt designation is not effective as there are serious questions about the deliverability of this land. The main landowner is a farmer who has asserted publicly and in a letter to the editor of Your Chesham, that he is not prepared to release all of the land in his ownership for development. The land is also potentially an Asset Of Community Value and upon confirmation of this designation it would afford a community group the right to bid for the land. The community group (Brown Not Green) have stated their intention is to preserve the land given that many hundreds of local people have habitually used the fields at Lye Green as of right for various informal outdoor recreational purposes. These uses themselves may mean that many local individuals may have acquired easements over and across the land through prescription (20 years uninterrupted use) not least of whom would be the many private residences bordering the fields that have rear garden gates onto the fields at Lye Green. These easements and prescriptive rights may render the land very difficult to develop and make i undeliverable in planning terms. This land also provides an important habitat for wildlife that will be threatened by development of this land. It is perverse that the Local Authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Plan is unsound. The foregoing also points to flawed methodology of Green Belt site selection used by the Local Authority, which is neither effective, justified nor consistent with national policy and as such is unsound. Specifically,
8986 the selection of the land NE of Chesham at Lye Green (policy SP BP2) for removal from Green Belt designation is inconsistent with National Planning Policy Framework (NPPF). PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I believe the draft Local Plan is NOT legally compliant because it has not demonstrated sufficient regard to believe this policy in the National Policy and guidance issued by the Secretary of State. consistent with the National The National Planning Policy Framework (NPPF) together with other guidance issued by the Government Planning Policy Framework is also supported by recent ministerial statements that have made it clear that Local Authorities MUST Feb 2019 please explain why demonstrate they have exhausted all options BEFORE considering revision of Green Belt boundaries. This Local Plan is seeking substantial modifications to Green Belt boundaries including the removal of Green Belt designation of 13 areas within the Districts as well as modifying the Green Belt status of many local villages. I contend this draft Local Plan has not demonstrated that all other options have been fully explored and as such this Plan is not justified, sound or in accordance with National Policy and accordingly is not legally compliant. Furthermore that Paragraph 11 b) of the NPPF (and the footnotes thereto) require Plan Makers to provide for objectively assessed needs for housing and other uses UNLESS the application of Framework policies (including Green Belt) provide a strong reason for restricting the overall scale, type or distribution of development in the plan area Chiltern District & South Bucks are significantly constrained by development policies such as Green Belt & Areas of Outstanding Natural Beauty (AONB). The Local Plan is therefore inconsistent with National Guidance and as such it is not legally compliant for the Local Authority to claim that housing needs justify a review of these same Green Belt boundaries. The combination of housing need and the presence of significant areas of development constraint policy collectively do not represent ªexceptional circumstancesº (as required in the NPPF) to justify modification of Green Belt boundaries especially given the NPPF states that one of the key features of Green Belts are their permanence. The Government has also recently confirmed its aim for the UK to have net zero carbon emissions by 2050 and it is noted within the Sustainability Appraisal supporting this Draft Local Plan, that the Plan area is forecast to see carbon emission increase by 21% in the Plan Period. Accordingly, the Plan is inconsistent with Government Policy and therefore not legally compliant. There is also a significant infrastructure funding gap acknowledged within the Community Infrastructure Levy evidence that supports this Local Plan, of between £179m & £231m. Given this infrastructure is vital to ensure that development is sustainable (as also required by the NPPF) this further demonstrates the Plan is both unsound and not legally compliant. Policy 3a - Please specify as The Plan needs to be changed by; precisely and succinctly as Co-operating with all nearby authorities. It is simply unsatisfactory to only consult with Aylesbury it should possible how you would not be maintained that it cannot be done because they are different Functional Market Areas and that modify this policy to improve co-operation is not necessary therefore. its alignment to this test of soundness. Exploring such wider co-operation may result in further housing needs being taken elsewhere. A more detailed appraisal of brownfield land opportunities MUST be undertaken. Some brownfield opportunities have been ignored or missed. Closer scrutiny of alternative options for housing delivery should be explored (such as Chesham Masterplan by CIC Chesham Renaissance). Green Belt boundary reviews should not be considered.There are a number of other reasonable alternatives have been exhausted. Policy-level file upload - 5492137 Please attach any supporting evidence
Person ID 1221063 Full Name Mr Damian Sullivan ID 7007 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body?
8987 Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act
8988 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Nashleigh Hill, Chesham not believe this policy to be Thakeham Homes also consider that land at Nashleigh Hill, Chesham is suitable for residential development positively prepared please and that as such it should be included as an additional housing allocation in the Local Plan. explain why The site comprises approximately 3.4 hectares (8.4 acres). The red line site location plan is included with this representation at Appendix 2. The site is a sustainable location with a large range of services and facilities in nearby Chesham. It is adjacent to the settlement boundary for Chesham and abuts residential development on three of its boundaries.Whilst the site is located within the Green Belt, any development would have limited impacts, in view of the topography, and would not create any coalescence. It is considered that the site would integrate well with the existing settlement. The site has a high coverage of trees and incorporates Lycombe Wood. An arboricultural survey will be undertaken, and any recommendations incorporated in to the design of any proposals. It is acknowledged that the coverage of trees is likely to restrict the developable area of the site. To the north of the site, beyond Nashleigh Hill, is the Chilterns Area of Outstanding Natural Beauty (AONB). Part of the site is within an area at risk of flooding from surface water. This area runs parallel to Nashleigh Hill.The entire site is located within a Critical Drainage Area. It is recognised that this will need to be considered in the design of any proposals and could potentially reduce the developable area of the site. There are no other known constraints. The site is Flood Zone 1 and at no risk of flooding. There are no listed buildings on the site or in its vicinity. Access could be taken from Nashleigh Hill (A416). The site was identified, as part of a larger site (Option 1 ± North East of Chesham), for release from the Green Belt in the Green Belt Development Options Appraisal (November 2017). See the map extract below. However, the site has not been included within the subsequent housing allocation) Policy SP BP2 - Land to the North East of Chesham). See the map extract below. It is considered that the site has the potential to accommodate 20-30 dwellings. The following paragraphs demonstrate that the site is available, suitable and achievable, and therefore deliverable in accordance with Planning Practice Guidance (PPG). Availability The PPG provides the following guidance in regard to considering whether a site is available for development: ªA site is considered available for development, when, on the best information available, there is confidence that there are no legal or ownership problems, such as unresolved multiple ownerships, ransom strips tenancies or operation requirements of landowners.This will often mean that land is controlled by a developer or landowner who has expressed an intention to develop PPG Paragraph 021 Ref. 3-020-20140306 The site is controlled by Thakeham Homes and we are keen to actively engage with the Council prior to further promotion and the subsequent submission of a Full Planning Application for residential development. Suitability The PPG provides the following guidance when considering whether a site is suitable for development: ªSites in existing development plans or with planning permission will generally be considered suitable for development although it may be necessary to assess whether circumstances have changed which would alter their suitabilityº PPG Paragraph 019 Ref. 019-20140306
8989 The site is located adjacent to the settlement boundary for Chesham and could deliver much needed housing and affordable housing. As such, we consider that the site is suitable for the delivery of residential development and the settlement boundary should be extended to include this site to positively bring forward sustainable development. Achievability In determining whether a site is achievable for development, the PPG provides the following guidance: ªA site is considered achievable for development where there is a reasonable prospect that the particular type of development will be developed on the site at a particular point in time.This is essentially a judgement about the economic viability of the site and the capacity of the developer to complete and let or sell the development over a certain periodº PPG, Paragraph 021 Ref. 021-20140306 Given the housing need within the district, the allocation of the site within the emerging Local Plan will contribute towards the Council being able to meet its own housing land requirements without relying on the Vale of Aylesbury. As stated above, Thakeham has a proven track record for delivering schemes of a similar size and scale throughout the South East and has the capacity to deliver the development of the site to provide much needed new homes within the first 5 years of the plan period, should the site be allocated for housing. Deliverability For the reasons above, the site is available, suitable and achievable, and therefore deliverable in accordance with the PPG. As such, we consider that the site could provide much needed housing development within the plan period. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1219225 Full Name Nick Moss ID 961 Order 236 Number 11.3 Title Policy SP BP2 - Chesham
8990 Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible.
8991 Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do We consider this proposal has not been positively prepared because possible brownfield sites have been not believe this policy to be insufficiently researched and the community led Chesham Masterplan which is more compliant witht he positively prepared please National planning policy has been ignored. explain why 11.3.3-4 - the infrastructure delivery schedule which accompanies the draft local plan provides very little detail about infrastructure provision to make the plan policies sustainable. neither is there sufficient detail as to how the very large funding gap for infrastructure will be filled.Thus, it seems to us that many of the policies proposed in the draft local plan are unsustainable. PP Mods - Please specify as We would urge you to reflect on the above and recognize the detailed innovative proposals that the Chesham precisely and succinctly as Masterplan contains. possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not While it can be seen as effective in providing housing, it cannot be justified to develop over the green belt in believe this policy to be this matter when there are brownfield options that would have beneficial effects on the vitality of the town justified please explain why centre. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in
8992 consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222712 Full Name Trisha Baptist ID 6719 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Landowner select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness?
8993 Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The land in question, which is hatched black on the plan, referred to in the correspondence is, in fact, bordered not believe this policy to be for the large part by buildings of various description: it cannot be used for agricultural purposes neither can positively prepared please it enhance the use and enjoyment of our property for leisure purposes. In conclusion, we feel it could benefit explain why both ourselves and the Council by providing a limited number of private and social housing units. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why
8994 Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1223554 Full Name Mrs Estelle Foster ID 7204 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to
8995 make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this
8996 to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Policy regarding ensuring impact upon green belt is minimised is unclear. Just saying that impact must be not believe this policy to be mitigated as far as possible is insufficient. It applications comply.Identify specific areas where new trees positively prepared please could be planted in the N East of Chesham. explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1224167 Full Name Mr Rob Smith ID 6742 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Director Growth, Strategy and Highways Buckinghamshire County Council Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID
8997 Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination
8998 Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do 11.3.4 not believe this policy to be Further modelling may be required to anticipate detailed impacts of junction changes / traffic flow changes. positively prepared please This should be undertaken as part of the Development Management process of BCC. explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1224207 Full Name St Congar Land ID 7020 Order 236 Number 11.3
8999 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - St Congar Land Consultee is an agent on behalf of: Person ID 1210992 Full Name Mrs Liz Alexander Organisation Details Principal Planner Bell Cornwell LLP Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible.
9000 Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do P BP2 (Chesham) is proposed to be allocated for 500 homes. This is a reduction from the original proposal not believe this policy to be which proposed 900 units. We are pleased that the Council has now removed the area of the site which the positively prepared please majority landowner had confirmed was not for sale. explain why We note from the policy that a single masterplan is delivered ± whilst we support this approach due to the number of land interests involved, we consider that this is likely to be a lengthy and challenging process which has the potential to considerably delay the delivery of the site. The site is also within the setting of the AONB. Whilst the policy for the site refers to the need for a comprehensive landscaping scheme, it is unclear whether the site can be delivered in a way which will not result in a detrimental impact on the AONB. This work should have been completed as part of the evidence base for the Plan as views in and out of the AONB are fundamental to the enjoyment of the AONB itself. The policy requirements set out within the site such as the provision of a community hub including a primary school and pre-school and the provision of a shopping parade are considerable and have the potential to impact on the viability of the proposal, showing a deficit if the site has to pay CIL. The scheme also has the potential to conflict with the Chesham Air Quality Management Area, and it seems an odd decision to allocate large scale development in the one part of the District that is already experiencing poor air quality. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
9001 Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1224512 Full Name Chesham & District Natural History ID 6383 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID 1224510 Full Name Ken Austin Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You
9002 will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do We are concerned about the plan to remove land from the Green Belt in Chesham for housing. There is no not believe this policy to be indication in the plan that a full assessment of land within the town boundary had been taken to accommodate the required housing needs.
9003 positively prepared please The Plan is confusing on the number of dwellings needed. The Green Belt Development Options stated 900 explain why houses in 26.1ha but the policy in the Plan (SP LP1) states 500 in 55.58ha. How was this change determined? Could it become a lower number? Assuming the Plan is the correct figure, it appears that way too much of the Green Belt is to be released. Compare the figure for Amersham Old Town - 400 in 11.36ha. Chesham 9 houses per ha; Amersham 44 per ha. The statement in para 3.5.7 of the Plan states that the aim is to ªEstablish a new, strengthened Green Belt boundary that will continue to meet national Green Belt purposes, prevent inappropriate developmentº. Just how this is be achieved is not mentioned. Once land is removed for the Green Belt, and 55.58ha is intended to include open spaces, we assume, then that land is up for grabs. A developer can submit plans for building and when refused will take it to appeal and be able to afford top barristers to argue the case ± can the Councils match that? Assuming the land must be taken out of the Green Belt for housing then the minimum area must be so released. It is to easy to draw straight lines on the map to fit perceived natural boundaries; new boundaries can be developed by tree planting etc. so that the new boundaries fit closer to the new built area. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not Para 11.3 of the Plan deals with the development. It is difficult to see how 11.3.5. with regard to air quality believe this policy to be in the local main residential roads can be achieved. justified please explain why The Green Belt Development Options under Option 1 states: ªThe Town is also in need of investment in its town centre and to assist employment restructuring and regeneration of its aging employment building stock.º It is difficult to tie this need in with additional housing on the edge of the town. Option 1 is very dismissive of the Biological Notification Site status under Wildlife Survey. This needs to be done in detail and properly taking into account. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1224546 Full Name Sustainable Chesham ID 6465 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details
9004 Consultee Type - Please Agent/Developer select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID 1224545 Full Name Alison Phillips Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence
9005 Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Looking into the removal of the land at Lye Green NE of Chesham from Green Belt designation further raises not believe this policy to be serious concerns over the deliverability of this land. The main landowner has publicly stated in a letter to positively prepared please Your Chesham that he is not prepared to release all of this land in his ownership for development. If this is explain why the case then the Plan is not only unsound, but also undeliverable. Furthermore, the land has recently been granted an Asset of Community Value and as such a local community group (Brown not Green) could bid for the land.This would mean that if successful in their bid, the community group could preserve the land given that many hundreds of local people have used this land for generations for various local recreational purposes. This would obviously be a far more sustainable use of the land and would be far preferable to housing development and the loss of Green Belt land. There are also many easements, gates into gardens from private houses bordering the fields and these rights may well render the land very difficult to develop and make the whole concept of housing development undeliverable. PP Mods - Please specify as All other options should be fully explored including increased density of development of Brownfield land and precisely and succinctly as the policies emerging from Chesham Masterplan. possible how you would Green belt land should only be considered once all other options have been exhausted. modify this policy to improve its alignment to this test of The proposals to develop the land to the NE of Chesham (policy SP BP 2) should be removed as it is wholly soundness. unsustainable in its location which would cause unnecessary and irreversible harm to the wider town of Chesham and a loss of a community asset which is beneficial to the well being of the community. Policy 1 - If you do not There is no evidence that all other options have been explored (in fact I will later comment on how other believe this policy to be options have in fact been ignored) and as such this Plan is not justified, sound or in accordance with National justified please explain why Policy and therefore it is not legally compliant. Another area of concern is the ambiguous and somewhat contradictory policies within the Plan. This makes it wholly unsound in my view as on the one hand the council say that they think the Green Belt land to the NE of Chesham is sustainable and provides easy access to public transport and the tube station, yet the same Plan promotes an increase in the retail development to the town by building on the very car park which serves the station. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not There are many reasons why I consider the Local Plan to be unsound.The main reason is one of sustainability. believe this policy to be The main area which concerns me as a resident of Chesham and Sustainable Chesham as a local community effective please explain why. group whose raison d'etre is to provide a more sustainable community, is that the development on Green Belt land NE of Chesham (SP BP 2) is a wholly UNSUSTAINABLE location. It is over 2 kilometres away from Chesham railway station and further still from the town centre. It is also located at the top of a big hill. Although
9006 it would be a welcome suggestion to upgrade footpaths to encourage cycling & walking, the reality is that most people would seek to drive to the station or into the town centre, both for work and recreational trips. This would increase the traffic on already congested roads, increase already poor air quality along Berkhamsted Road and White Hill and also lead to huge infrastructure issues on an already struggling infrastructure, not to mention the pressure on the water supply. Highway improvements to ease congestion are not possible due to the topography of the town so increasing traffic congestion, noise and air pollution would be inevitable. The roads in Chesham are already operating to capacity due to it being a through route and this would only make the situation far worse. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not The local plan is also inconsistent with National Guidance with regards to the need to objectively assess the believe this policy in needs for housing and other uses and it is not legally compliant. consistent with the National The local plan is also inconsistent with National Guidance with regards to the need to objectively assess the Planning Policy Framework needs for housing and other uses and it is not legally compliant to claim that housing needs justify a review Feb 2019 please explain why of these same Green Belt boundaries. Another area of particular interest to both myself and Sustainable Chesham is the government's recent confirmation that it is their aim to have net zero carbon emissions by 2050 and it is noted within the Sustainability Appraisal supporting this draft Local Plan that the Plan are is forecast to see carbon emissions INCREASE by 21% in the Plan Period. Therefore the Plan is totally inconsistent with Government Policy and not legally compliant. Lack of infrastructure for new development is an area of huge concern and it is demonstrated quite clearly within the Community Infrastructure Levy evidence that supports this Local Plan that there is a very significant infrastructure funding gap of between £179million and £231 million. Infrastructure is absolutely vital to ensure that development is sustainable (as well as being required by the NPPF) which just demonstrates the Plan is not only not legally compliant but wholly unsound. Policy 3a - Please specify as There are a number of ways in which the plan needs to be modified. precisely and succinctly as Brownfield sites in the local area should be fully appraised and assessed and any opportunities should be possible how you would considered and explored fully. Some brownfield sites seem to have been totally ignored or not included for modify this policy to improve some reason. its alignment to this test of soundness. There are other options available which seem to have been ignored. For example Chesham Renaissance's Masterplan which is a very thorough and reasonable study giving options for alternative housing delivery in the Chesham area. There seems to be no reason that this has not been considered as a viable alternative. I would like to see the council look at this proposal in detail and invite comment from the local community and engagement with Chesham Renaissance. Full discussion and cooperation with all nearby authorities should be a necessity and it should not be acceptable to suggest the different Functional Market Areas is a reason for non-cooperation. Green belt areas should only be considered AFTER all other options have been fully explored and ruled out. It is clear that this has not been done. Given the very restrictive nature of the area, with Green Belt and AONB if a thorough appraisal of Green Belt sites has been considered it may then be necessary to conclude it is not possible to identify poor performing Green Belt sites to accommodate all the OAN for housing and as such it may be necessary to accept a lower housing figure is more appropriate. Policy-level file upload - 5502988 Please attach any supporting evidence
Person ID 1224583 Full Name Christopher Mead ID 6639 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body?
9007 Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act
9008 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The plan is not positively prepared because it does not achieve sustainable development. Policy SP BP2 to not believe this policy to be allocate Green Belt land NE of Chesham for housing is deeply flawed on this count. As the site is not near positively prepared please to the town centre, the development of 500 houses will increase traffic as most of the new residents will be explain why travelling by car to access the town centre of areas of greater distance. The evidence in Chesham shows that most of the road junctions and infrastructure is already operating above capacity. For example it is now impossible to get a seat on a metro line train after 7am in the rush hour. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not Policy SP BP2 to remove land NE of Chesham at Lye Green from the Green Belt does not comply with the believe this policy in National Planning Policy Framework which states that there have to be ©exceptional circumstances© for consistent with the National redefining Green Belt boundaries; it cannot be for housing alone. This is also true of the proposals SP PP1 Planning Policy Framework and DM PP1 to remove numerous villages from the green belt. We fully support the area at Lye Green as Feb 2019 please explain why an Asset of Community Value. We walk in the fields and surrounding are every week recreational and moved to this location in the Chilterns because of its natural beauty which we feel will be seriously diminished if these plans go ahead. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
9009 Policy-level file upload - Please attach any supporting evidence
Person ID 1224527 Full Name Infinite Homes Ltd ID 6673 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Other select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Infinite Homes Ltd Consultee is an agent on behalf of: Person ID 1224526 Full Name Helen Locking Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications
9010 to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible
Policy Level - PP - If you do The site being promoted for inclusion within SP BP2 extends to an area of circa 1.7 hectares lying to the not believe this policy to be north of the residential properties (126-128 Lye Green Road). The site is shown hatched red on the positively prepared please explain why attached Local Plan extract. The land is largely laid to grass and woodland and currently forms part of the residential curtilages of our Clients properties (128 and 126 Lye Green Road). PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
Policy 1 - If you do not The strategic site allocation Chesham SP BP2 surrounds our Clients' land on three sides with the fourth believe this policy to be boundary being the residential properties along the north western side of Lye Green Road. The Green Belt justified please explain why analysis that identified the land as suitable for a strategic allocation/removal from the Green Belt included our Clients' land. It can only be assumed that our Clients land was not included within the strategic site allocation because the land was under private ownership and its availability for development had not been promoted to the Council. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve
9011 its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5513244 Please attach any supporting evidence
Person ID 1224973 Full Name Environment Agency ID 6452 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID 1224972 Full Name Richard Burr Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance?
9012 Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible
9013 Policy Level - PP - If you do Please note that this site is partially within a Source protection zone (SPZ) 3 for groundwater protection and not believe this policy to be is adjacent to historic landfill sites. Appropriate groundwater protection measures will need to be incorporated positively prepared please into the design and construction of any development. Please be aware that additional investigations will be explain why required at the planning stage. Remediation may also be required in certain cases if sites are shown to be causing pollution. Historic landfills can also have issues with land stability and gassing which should be taken into account when undertaking risk assessments and in this case allocating sites. We would like to see the below amendment to point j in the policy: `j. a comprehensive Landscaping Scheme to include: i. the retention of characteristic views across the site; ii. the conservation of the existing woodland blocks, trees and hedgerows; iii. mitigation and enhancement to provide biodiversity net gain, including orchard planting, native woodland planting and a strong planted edge adjacent to the open fields' PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1225278 Full Name Derek Atkinson ID 6642 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body?
9014 Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act
9015 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as This cycle of planning needs to be repeated, but with adequate consultation and representation from the precisely and succinctly as communities impacted.This would provide a way for the ill feeling by the communities be seen to be recognised possible how you would and a positive step being taken by the council to address the defects by working with the communities of modify this policy to improve residents. its alignment to this test of Please refer to the first question where I have inserted many of my responses to this plan. The main point soundness. is that it isn©t sustainable on carbon, other pollution, finances for construction and enhancing and mitigating existing local services and transport or our future food production needs. We already have the Chesham Renaissance Masterplan which achieves the National Planning Policy Framework goals without removing Green Belt and causing additional pollution and ongoing costs to the community Policy 3 - If you do not The plan includes changes to the Green Belt Village Policies which were sprung upon the communities. The believe this policy in options have not been the subject of discussion or consultation before issuing the plan. The council have consistent with the National not included the communities affected in the consideration of any options or the impact on those who live Planning Policy Framework there.The communities have not been able to exercise their right to determine the changes to the framework Feb 2019 please explain why and controls that affect their environment. The Sustainability Appraisal of this plan is inadequate. Major items of expenditure (traffic increase and road network, capacity increases to utilities infrastructure, capacity of local health and social care facilities, and other community services) are not addressed in sufficient detail which would lead to shortages of funding which would result in shortcuts in the implementation, additional burden on existing tax payers and even worse, damage to the existing environment and the abandoning of the plan. The long tenn additional costs to the services and road infrastructw´e has not been reviewed, and we know already that these are under very great financial pressure already.
9016 The plan for Chesham falls into the category of urban sprawl, whereas there are brown field locations within the town that are better suited for development. This plan consumes Green Belt when there are brown field locations in Chesham that are derelict and cwrently eyesores. By building at the periphery this plan fails to provide accommodation that is sustainable, as the distance and terrain will encourage more car journeys into Chesham for commuting from the underground station and for shopping. There is also inadequatecapacity in Chesham car parks for these additional users, which will lead to more congestion, pollution and on-street parking problems. Better plans already exist that would not cause this - Chesham Renaissance Masterplan. The increase in traffic that this plan will cause to the existing heavy traffic through Chesham at most times of the day will reduce car speeds, and increase pollution from cars slowly moving through the town. This plan makes no reference to the existing pollution levels or the envisaged increases or measures to mitigate for this. Building on the land at Chesham will remove the natural habitat for wildlife, and the communal use of the land that has been enjoyed by those living nearby for many generations.The plan makes reference to retaining the hedgerows, but does not indicate how this maintenance will be managed or paid for. Currently this is not a council expense, but it looks like this is intended to be borne by the community of Chesham. The plan indicates that this is good quality agricultural land, which will be lost if houses are built upon it. As we enter a new age where the carbon cost of bringing food from afar becomes a major concern to our carbon generation good quality local agricultural land like this needs to be preserved for future generations. Houses are fine, but food will become a more pressing shortage. This plan fails the tests for the exceptional circumstances for redefining the Green Belt boundaries, especially in the Lye Green area. The plan identifies a further parcel of agricultural Green Belt land beyond that which is included in this plan for development to the north east of the Chesham area that would certainly become the target for further development once it was spilt off from the area included in this plan.The plan includes changes to the Green Belt Village Policies which were sprung upon the communities. The options have not been the subject of discussion or consultation before issuing the plan. The council have not included the communities affected in the consideration of any options or the impact on those who live there. The communities have not been able to exercise their right to detennine the changes to the framework and controls that affect their environment. The plan for Chesham falls into the category of urban sprawl, whereas there are brown field locations within the town that are better suited for development. This plan consumes Green Belt when there are brown field locations in Chesham that are derelict and currently eyesores. By building at the periphery this plan fails to provide accommodation that is sustainable, as the distance and terrain will encourage more car journeys into Chesham for commuting from the underground station and for shopping.There is also inadequate capacity in Chesham car parks for these additional users, which will lead to more congestion, pollution and on-street parking problems. Better plans already exist that would not cause this -Chesham Renaissance Masterplan. The increase in traffic that this plan will cause to the existing heavy traffic through Chesham at most times of the day will reduce car speeds, and increase pollution from cars slowly moving through the town.This plan makes no reference to the existing pollution levels or the envisaged increases or measures to mitigate for this. Building on the land at Chesham will remove the natural habitat for wildlife, and the communal use of the land that has been enjoyed by those living nearby for many generations. The plan makes reference to retaining the hedgerows, but does not indicate how this maintenance will be managed or paid for. Cmrently this is not a council expense, but it looks like this is intended to be borne by the community of Chesham. The plan indicates that this is good quality agricultural land, which will be lost if houses are built upon it. As we enter a new age where the carbon cost of bringing food from afar becomes a major concern to our carbon generation good quality local agricultural land like this needs to be preserved for future generations. Houses are fine, but food will become a more pressing sho11age. This plan fails the tests for the exceptional circumstances for redefining the Green Belt boundaries, especially in the Lye Green area.The plan identifies a further parcel of agricultural Green Belt land beyond that which is included in this plan for development to the n011h east of the Chesham area that would certainly become the target for further development once it was spilt off from the area included in this plan. For Chesham there already exists a much better thought out and costed plan - Chesham Renaissance Masterplan which addresses many of the deficiencies listed above, and also provides for the community of Chesham to be developed where it needs to be, in the town centre, and not by urban sprawl. The Chesham Masterplan should have been included in the review of options, but there is no evidence than the Council have been competent in their review of options. There is no evidence that those preparing the plan have adequately consulted with the residents or the groups that the residents have created to find their own solutions. For Chesham there already exists a much better thought out and costed plan - Chesham Renaissance Masterplan which addresses many of the deficiencies listed above, and also provides for the community of Chesham to be developed where it needs to be, in the town centre, and not by urban sprawl. The Chesham Masterplan should have been included in the review of options, but there is no evidence than the Council have been competent in their review of options. No engagement has taken place with those residents of villages that would be impacted by the proposed changes to the Green Belt Villages policy. In preparing this policy the council have not adequately engaged with the community, evident by the ill feeling its publication has caused with residents.
9017 Options that already exist have not been considered, for example The Chesham Masterplan should have been included in the review of options, but there is no evidence than the Council have been competent in their review of options. No engagement has taken place with those residents of villages that would be impacted by the proposed changes to the Green Belt Villages policy. Policy 3a - Please specify as ,..There already exists a much better thought out and costed plan -Chesham Renaissance 1 fasterplan which precisely and succinctly as addresses many of the deficiencies listed above, and also provides for the community of Chesham to be possible how you would developed where it needs to be, in the town centre, and not by urban sprawl. modify this policy to improve ,,..he Chesham Masterplan should have been included in the review of options, but there is no evidence its alignment to this test of than the Council have been competent in their review of options. soundness. This cycle of planning needs to be repeated, but with adequate consultation and representation from the communities impacted.This would provide a way for the ill feeling by the communities be seen to be recognised and a positive step being taken by the council to address the defects by working with the communities of residents. Policy-level file upload - Please attach any supporting evidence
Person ID 1224822 Full Name Brown Not Green Chesham Ltd ID 6678 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Other select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Brown Not Green Chesham Ltd Consultee is an agent on behalf of: Person ID 1224533 Full Name Phillip Plato Organisation Details Chariman Brown not Green Chesham Ltd Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be
9018 as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible
Policy Level - PP - If you do 7. 2. A: - With regard to Lye Green & Chesham, BNG feel there is serious doubt about the site selection not believe this policy to be process and the flawed methodology for selecting the land at Lye Green for release from Green Belt positively prepared please explain why designation for housing allocation in the first place. (Policy SP BP2)
7. 3. Extensive evidence of the inconsistencies and flaws in the Green Belt site selection process is included within Annex 3 attached herein. Further evidence of this site
9019 being inappropriate for consideration comes from the fact that the land is now listed as an Asset of Community Value under s.88 of the Localism Act 2011. This designation now affords the BNG community group the Right to Bid for the land. (see ANNEX 5 attached herein)
7. 4. Allocating such an Asset of Community Value in a Local Plan for development is perverse as such a designation it will only add value to the land and consequently will make it much harder for the community to raise funds in order to exercise its Right to Bid. Accordingly, the allocation of such an Asset of Community Value for development within a Local Plan will undermine the purposes of the Localism Act 2011. It would also not be in accordance with paragraphs 96 & 97 of the NPPF which requires that, ªExisting open space, sports and recreational buildings and land, including playing fields, should not be built on¼.º 7. 5. This view would appear to accord with those of a Planning Inspector determining a S.78 appeal in April 2019 against refusal to grant planning permission for redeveloping a public house that was also listed as an Asset of Community Value4 . The appeal seeking to redevelop that Asset of Community Value was dismissed.
7. 6. The recent listing of the land as an Asset of Community Value should at least require the land to be reassessed under the GB quantitative and qualitative assessment of it meeting the purposes of Green Belt designation. (as explained in Annexes 3 & 4 herein). A further significant issue with proposed policy SP BP 2 is that it will represent outward sprawl of Chesham and will destroy the separate identity of Lye Green, which will become absorbed into ªgreater Cheshamº. The primary aim of Green Belt land (as recited in NPPF 133) is to prevent urban sprawl and to preserve the openness of the area. Historic decisions6 made at S.78 various appeals involving previous developer lead proposals on this land, have confirmed this has been a consideration in the past that has (in part) persuaded previous Inspectors to refuse consent on this land in order to prevent outward sprawl and loss of openness. These concerns are as valid today as they were in the late 1980's.
PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
Policy 1 - If you do not 2. 1. Another major concern is that BNG believes that not all brownfield land opportunities have been believe this policy to be identified. Also, that brownfield land development is not being considered at optimal densities to achieve justified please explain why best use of such land that would reduce the need to look at Green Belt release.
2. 2. BNG recommend that a more detailed appraisal of brownfield land opportunities must be undertaken before Green Belt is released. The Council's Brownfield Register was only instigated in November 2017 (nearly 2 years after the first public consultation proposing Green Belt release.). Accordingly, BNG feel that Green Belt has been the focus for development opportunities long before brownfield opportunities were reviewed and then only in response to a government directive in 2017.
2. 3. Accordingly, BNG are convinced that some brownfield opportunities have been ignored or missed or their potential provision underestimated. This review will identify opportunities for provision of additional housing and indeed initiatives are already demonstrating that to be true (such as Chesham Masterplan by CIC Chesham Renaissance).
2. 4. Green Belt boundary reviews should only be considered after all other reasonable alternatives have been exhausted. It is far from clear that brownfield land (previously developed or industrial land) is being considered in a sufficiently creative or positive way across the combined districts as an alternative sources of housing provision.
2. 5. BNG have undertaken their own research as far as they can with the resources available to them, in respect of areas in and around Chesham (being BNG's area of focus) and have discovered several examples of brownfield land being handled
9020 inefficiently. Details are contained in ANNEX 2 attached herewith. Given the limited geographical area considered by BNG, if such circumstances are replicated across the combined districts of Chiltern & S Bucks, BNG contend the need to consider Green Belt boundary reviews would be significantly reduced.
2. 6. An example of such a review of Brownfield land was highlighted by CPRE whose report ªThe State of Brownfield Land 2019º is also included within Annex 2. In one Case Study recited therein, involving the London Borough of Enfield, the research found space for 37,000 homes on a wide range of brownfield land, including through the appropriate intensification of existing sites. This is compared to just 2,170 homes initially identified on Enfield's most recently published brownfield register in December 2017. Therefore 17 times the number of dwellings were identified and even if this is an extreme example, if only double the estimated number were revealed to exist in Chiltern & South Bucks, there would still be merit in seeking an independent review of the brownfield opportunities within the combined Districts to mitigate the need to release Green Belt land for development.
The methodology adopted by Chiltern & South Bucks DC was openly criticized by Critical Friends (represented by Aylesbury Vale & Wycombe District Councils) in Appendix 13 of the final draft Part 2 Assessment in March 2016 including, amongst other comments, the fact that objectively assessed housing need alone does not justify ªexceptional circumstancesº to modify a Green Belt boundary Such inconsistencies and flaws are significant also because in April next year, local government reorganisation will occur whereby the current Chiltern & South Bucks District Councils will be abolished, and a new Unitary Authority for Buckinghamshire will come into existence. This will bring the neighbouring Districts of Wycombe & Aylesbury Vale together with the former Chiltern & South Bucks areas. Until the new Unitary Authority can undertake a Local Plan review, it will be reliant upon any adopted Local Plan(s) inherited from the former administrative districts. If there are inconsistencies between the former administrative areas regarding the method used for allocating Green Belt sites and how they were appraised and bought forward, this creates the real risk that the new Unitary Authority will not wish to adopt this Plan, and even if they do, it would be unfair upon the local communities living within the areas affected.
A related concern that is of special relevance to Chesham is the combined potential for flooding and need for improved drainage infrastructure. Chesham, whilst not in a listed flood zone related to coastal surge or overflowing watercourses, does suffered from periodic flooding. This is largely caused by local topography and surface water runoff especially during prolonged or intense periods of rainfall. Obviously, the valley floor (along Broad Street/Berkhamsted Road is particularly vulnerable but the flooding from rain water runoff does also occur elsewhere in the town including around Lye Green probably due to the combination of clay soils that do not drain well in heavy/prolonged rainfall together with inadequate drainage methods nearby that for surface water is reliant upon field ditches that can become overgrown. Obviously, the build-up of surface water on such relatively high ground does eventually also add to the problems of surface water flooding in the lower areas of the town itself in due course too. The aged drainage system of the town clearly cannot cope with prevailing needs of the town and any significant development upon Green Belt on high ground outside the town has obvious potential to make matters worse.
Policy 2a - Please specify as Consequently, it may then be necessary to accept that a lower housing provision figure is appropriate precisely and succinctly as especially given that a new Unitary Authority (involving a much larger area with a smaller percentage of possible how you would modify this policy to improve Green Belt land) will come into existence in April 2020. its alignment to this test of soundness.
Policy 2 - If you do not Policy SP BP2 refers to the need for sustainable transport provision but merely refers to bus stop believe this policy to be infrastructure and financial contributions. BNG asserts that the site is fundamentally unsustainable being effective please explain why. too far from the town centre and involving the negotiation of a very steep hill. Specialist expert advice has been sought on the traffic and sustainability issues of this site by SLR Consulting. Their Report on this
9021 topic is included within ANNEX 6 attached herein and in summarising states, ªSLR concludes that the site is unsustainable, very poor in terms of accessibility and therefore contrary to Core Strategy Policies CS4 and CS26 and does not meet various accessibility guidance and criteria,¼º. The site is clearly not at a sustainable location. The provision of a bus stop will not make it sustainable neither will the upgrading of public footpaths within the site to bridleways given that there is inadequate cycling infrastructure into the town combined with adverse topography (including a hill into the town with a 14% gradient) that would discourage cycling into and out of Chesham. Even the ªWalk Scoreº app5 states; ªThis location has a Walk Score of 18 out of 100. This location is a Car-Dependent neighbourhood so almost all errands require a car.º
7. 12. Any financial contributions that might be sought from a developer towards extensionof existing bus services cannot guarantee the long-term future of the bus service which as SLR recite, would need to run at very regular intervals of at least 15 minutes and at weekends and later than 7.30 pm at night as currently. If the bus service ceased to operate in subsequent years, then the potential for yet further increases in traffic generation from the site is obvious. For this Plan to be sound it must also be effective. Unfortunately, further review of the proposed Policy SP BP2 to remove land NE of Chesham at Lye Green from Green Belt designation is not effective as there are serious questions about the deliverability of this land.
7. 24. The main landowner is a farmer who has asserted publicly and in a letter to the editor of Your Chesham in 2018, that he is not prepared to release all the land in his ownership for development.
7. 25. More significantly is the fact that the land is now listed as an Asset of Community Value (ACV) and now affords the BNG community group the Right to Bid for the land. Brown Not Green have stated their intention is to preserve the land given that many hundreds of local people have habitually used the fields at Lye Green as of right for informal outdoor recreational purposes for decades. These uses themselves may mean that many local individuals may have acquired easements over and across the land through prescription (20 years uninterrupted use) not least of whom would be the many private residences bordering the fields that have rear garden gates onto the fields at Lye Green.
7. 26. Six informal footpaths exist that are additional to the adopted Public Rights of Way (PROW) that already cross the land at Lye Green. In remarkably similar circumstance to the facts related to Banner Hones vs St Albans City & District Council 2018 and in response to the landowner recently attempting to close off the unadopted footpaths, the use of which was persuasive in obtaining the ACV listing, the local community have now felt compelled to make a Definitive Map Modification Order (DMMO) to have the aforementioned informal paths adopted as PROW's.
PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
Policy 3 - If you do not i. BNG believe the draft Local Plan is NOT legally compliant because it has not demonstrated sufficient believe this policy in regard to the National Policy and guidance issued by the Secretary of State. consistent with the National Planning Policy Framework ii. Specifically, the Local Plan is advocating significant modifications to Green Belt Boundaries involving 13 Feb 2019 please explain why sites as well as modifying Green Belt designation boundaries around various villages within the District. The National Planning Policy Framework states that Plan Makers MAY modify Green Belt boundaries during the preparation of Local Plans (not that they SHOULD) and even then, the NPPF makes it clear in Paragraph 136 that ªOnce established, Green Belt boundaries should only be altered where
exceptional circumstances are fully evidenced & justified¼.º. We contend that the exceptional circumstances recited by the LPA are not fully evidenced & justified. iii. Paragraph 137 of NPPF further states that ªBefore concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policymaking
9022 authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development¼º. BNG contend that the LPA has not demonstrated that all other reasonable alternatives have been fully examined. One example of an alternative relates to Chesham Renaissance CIC Masterplan which is ignored in the Local Plan despite having been in development for nearly 4 years and published and publicly consulted upon in 2018. This community led initiate should have had greater consideration. iv. Paragraph 138 of NPPF also states that ªWhen drawing up or reviewing Green Belt boundaries, the need to promote sustainable patterns of development should be taken into account. Strategic policy- making authorities should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the outer Green Belt boundary. Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport. They should also set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land.º ± BNG have emboldened certain text above as it is of particular relevance;
o BNG believe the LPA policies are NOT promoting sustainable development (many of the allocated Green Belt sites especially site SP BP2 at Lye NE of Chesham) are not sustainable locations, o Some of the Green Belt sites and particularly site SP BP2 do not enjoy good access to public transport. o Finally, BNG can see no evidence of any mitigation of the impact of removing land from Green Belt or compensatory improvements. NPPF encourages Local Authorities to make compensatory improvements (paragraphs 32 & 176) but such improvements are not just related to loss of Green Belt but any impact upon other valued criteria such as biodiversity. o Most recent PPGs published on 23 July 2019 have outlined what is needed regarding compensatory improvements in greater detail including requirements where Green Belt is being lost. BNG feel that the Plan as currently drafted offers no compensatory improvements for its proposals and as such is contrary to National Guidance and is not therefore legally compliant. Paragraph 141 of NPPF also states, ªOnce Green Belts have been defined, local planning authorities should plan positively to enhance their beneficial use, such as looking for opportunities to provide access; to provide opportunities for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and biodiversity; or to improve damaged and derelict land.º - Again, the emboldened phrases above are most relevant;
vi. The land at Lye Green in respect of policy SP BP2, has been in Green Belt for decades and as evidenced by a recent application under s.88 of the Localism Act 2011, has been listed as an Asset of Community Value. Unlike most other Green Belt designated areas, it was demonstrated the land been habitually and widely used by the general public for all sorts of informal outdoor recreational uses for decades. It is perverse to allocate such land for development in the face of National Guidance to the contrary. vii. Furthermore, NPPF paragraph 11 b) i (and the footnotes thereto) require Plan Makers to provide for objectively assessed needs for housing and other uses unless the application of Framework policies (including Green Belt) provide a strong reason for restricting the overall scale, type or distribution of development in the plan area Chiltern District is subject to significant areas of land that are subject to development restraint policies including AONB and Green Belt that alone represents circa 87% of the land in the District. South Bucks is similarly constrained. It is therefore inconsistent with National Guidance and as such not legally compliant for the LPA to claim that housing needs justify a review of Green Belt boundaries. BNG feel that the proposed allocation of this site is neither effective, justified or in accordance with NPPF and that there are insufficient exceptional circumstances to justify its removal when it is at an unsustainable location that will generate more
9023 traffic and worsen local air quality. All the comments in section 7 herein, relate to BNG's comments under their first broad area of concern (category A ± paragraph 7.1). All of these concerns and the potential injurious affects described can easily be addressed merely by removing Policy SP BP2 from the Local Plan and leaving the land at Lye Green within Green Belt designation. The final bullet point of this paragraph 3.1.2, makes reference to the Council using a wholly owned property company referred to as Consilio Limited, to invest in the local and wider economic area to increase prosperity and benefiting local residents. BNG must query when and where was this policy consulted upon? Furthermore, Companies House records show that the company name quoted is incorrect and needs to be corrected to Consilio Property Ltd. However, with regards to this proposal itself, it is noted that Consilio Property Ltd is a private company owned entirely by South Bucks District Council but not jointly with Chiltern District Council. Given this is a joint Local Plan this seems strange. Further explanation is needed. What are the company objectives? What happens to any asset or profit in this company particularly when the local authority becomes part of the Bucks Unitary Authority in April 2020?
Policy 3a - Please specify as 1. CO-OPERATION WITH OTHER NEIGHBORING LPAs: precisely and succinctly as 1. 1. Given the MOU made with Aylesbury Vale under the Duty to Co-operate, BNG feel that further efforts possible how you would modify this policy to improve should be made with other areas such as Dacorum Borough Council in Herts. It is simply unsatisfactory to its alignment to this test of assert this is a different Functional Market Area and that co-operation is not necessary. Such co-operation soundness. may result in further housing (or other) needs being taken elsewhere.
1. 2. BNG have undertaken their own survey & research of Chesham and outlying villages around the town. This short survey was carried out post publication of the draft Local Plan to ascertain the views of the community on key issues pertaining to the Local Plan including the scale and extent of any economic or market activity across the border with neighbouring Dacorum.
1. 3. The results are included together with the survey results on other matters raised by BNG (and an earlier survey undertaken by Chesham Renaissance CIC) within ANNEX 1 attached herein. Key points that became evident from this exercise were that; o 75% of respondents in or around Chesham go to Hemel Hempstead in Dacorum at least 1 to 2 times per month and 72% of respondents go to Berkhamsted with a similar frequency. Others also claim to visit Tring & Berkhamsted regularly. o 7% of respondents travel into Dacorum for work or recreation every day. o Shopping appears to be the main reason for travelling into the western side of Hertfordshire with reasons given being the lack of parking and/or preferred types of shops to Chesham. o Recreation also was an important reason for visiting Dacorum for cinemas in Berkhamsted, Hemel Hempstead & Watford. Indeed, Section 5.8 of the Council's Retail Review confirms that 55% of the Districts population regularly visit any of nine cinemas none of which are within the LPA's administrative area with only some small local cinemas offering a total of circa 600 seats. 1 The Brown Not Green (BNG) organisation represents almost 1,800 signatories from all around Chesham to a Petition that was organised late in 2016 in response to (as then) emerging proposals by Chiltern & South Bucks District Council, to expand the town of Chesham by removing circa 60 ha of agricultural land from Green Belt on the NE of Chesham near a hamlet called Lye Green and developing this area mainly for new housing.
3. Many thoughtful material planning considerations have been raised by the community through Brown Not Green Chesham Ltd. BNG have retained professional legal & technical advisors and wish to present evidence to illustrate these considerations, specifically that;
o the LPA have overlooked a number of significant issues and carried forward errors in their research particularly regarding site selection, o they have made premature and flawed selection of Green Belt development opportunities & o in the case of the Lye Green site, have chosen an unsustainable location for
9024 development that will cause wider harm to the area including o increased traffic congestion, o worsening air quality that will make the existing AQMA in Chesham worse, o result in loss of good quality agricultural land and o loss of land that provides informal recreational benefits and improves the wellbeing to hundreds of people in the local community as well as o preventing coalescence of settlements and outward sprawl. o There is also concern about the effects upon local wildlife habitats and the impacts upon the local chalk stream rivers notably the River Chess after which the town of Chesham is named.
Policy-level file upload - 5513245 Please attach any supporting evidence
Person ID 1225409 Full Name W J & M Mash ID 6704 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID 1225406 Full Name Tom Holden Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible.
9025 Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The Plan is unsound in relation to Policy SP BP2 - Chesham and alterations to the Green Belt as detailed not believe this policy to be in Protected Places Chesham page 50 as the land owner remains unwilling to sell the majority of this site positively prepared please for development. Therefore the number of dwellings that can be achieved from this site is substantially less explain why than shown Policy SP LP1. The land owner has made representations in previous consultations including the Issues and Options Consultation 2016 and has had ongoing liaison with the Local Plans team in May 2017, that he was unwilling to sell the majority of his land and very un-keen to develop the remainder of his land, with the exception of a small area of land adjacent the school. Part of the land is suggested for development is leased by my client, so he makes no comment on the northern section of the proposed allocated site.The land to be omitted from
9026 the allocated development site and Green Belt Release is shown on the documents appended to this representation. PP Mods - Please specify as To amend the boundaries of the allocated development land for Chesham SP BP2 - Chesham to reduce the precisely and succinctly as available land, and to allocate land elsewhere for development. To amend and the boundaries of alterations possible how you would to the Green Belt as detailed in Protected Places Chesham page 50 modify this policy to improve The land to be omitted from the allocated development site and Green Belt Release is shown on the documents its alignment to this test of appended to this representation. soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1225849 Full Name Richard Gamester ID 7203 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider
9027 the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to
9028 Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I do not feel the plan is compliant, simply because no thought has been given to putting a large development not believe this policy to be in the area suggested for the following reasons: positively prepared please 1) The land is classified as Green Belt. explain why 2) It is in area which feeds the chalk river Chess. This river is already dry due to over extraction. A Local Plan is required, but not this one! There are groups in Chesham who can help make Chesham a better town and still provide some of the housing required. The ªBrown Not Greenº group has my full support in fighting this development. The Chesham Masterplan Group has developed alternative plans for the town,, but are being totally ignored, why? Chesham station is used by people who drive here to use the London Transport rates instead of using the train services in their area. This puts a strain on th parking, the station car park is normally full and local roads are being used for parking. The proposed housing will bring this to breaking point An alterative road should be considered to bypass Chesham in the same way as Amersham has its bypass. 3) No provision is made for schools and other amenities. 4) The local roads are already under great strain, additional traffic will be a disaster. 5) The air quality in Chesham is not good and there are no plans to address this. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not This plan seems to have been developed by people who do not know Chesham or even live near here. believe this policy to be They have take the easy route of grabbing lad designated as Green Belt, when there are areas near by like justified please explain why Bovindon Aerodrome and local many smaller ªbrown fieldº sites that would be suitable Duty of care? No, more of a hatchet job. No thought has been given to the town or its residents May I respectfully suggest that the planners talk to the town's people, and not just issue plans at the last minute that are so badly flawed. Policy 2a - Please specify as Please as the creators of this plan to hold a (well publicised) public meeting, so the town community groups precisely and succinctly as and their interested parties can suggest alternatives. possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as
9029 possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5503270 Please attach any supporting evidence
Person ID 1225903 Full Name Matthew Dawber ID 6856 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Countryside Properties, Geltex properties Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as
9030 precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I am writing on behalf of my client, Countryside Properties Ltd, and also Geltex Properties Limited (herein not believe this policy to be jointly referred to as `the Promoters') positively prepared please Countryside Properties Ltd has an option agreement in place with the owners of land, W J & M Mash Limited, explain why within the proposed allocation at North East Chesham (Policy SP BP2 in the Chiltern and South Bucks Local Plan 2036 Publication Version). This area is shown in the Option Plan which is enclosed with this letter. Geltex Properties Limited own the freehold on land in the north of this proposed allocation.This land is shown on the enclosed Ownership Plan. Jointly therefore the Promoters are in control of the land edged red on the enclosed Site Location Plan. This broadly corresponds to the area that is identified as an allocation for residential development, with other associated uses, within SP BP2. There are some minor discrepancies which are referred to within representations on the Local Plan 2036 Publication Version. Both parties have prepared representations on the Local Plan 2036 Publication Version which have been prepared specifically to comment on the proposed allocation at North East Chesham, along with general policies of relevance. While these representations are submitted separately, they have been prepared in full cooperation between the Promoters and ensure that there are no contradictions between them. The reason behind the need to submit two versions is contractual and in order to articulate slight nuances that vary across the site. This should not be seen as an indication that the site is being promoted separately and without a comprehensive approach.
9031 Given the importance of North East Chesham to the meeting of the identified housing needs of the districts it is requested that both of the parties receive seats at all relevant hearing sessions of the Examination in Public to ensure that any questions raised by the Inspector can be answered appropriately. The Promoters look forward to continuing to work with the Council as the Local Plan 2036 progresses to examination and beyond. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1226292 Full Name Russell Monck ID 6971 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Team Leader West - Growth & Infrastructure Unit Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details
9032 Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has
9033 met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Policy SP BP2 (north- east) Chesham not believe this policy to be 2.4 It is suggested from the consultation document that approximately 500 dwellings are proposed North positively prepared please East of Chesham. The nearest settlements with a school in Hertfordshire are Bovingdon and Berkhamsted. explain why 2.5 Policy SP BP2 suggested that on-site provision of a community hub which includes at least a one form entry primary school and a pre-school will be provided with the development, and further suggested that financial contributions would be arranged to fund secondary school places. Considering that the infrastructure will be provided either on-site or through financial contributions, the potential development proposed is unlikely to have any significant impact on school places in Bovingdon and Berkhamsted (that lie within the administrative boundary of Hertfordshire County Council). 2.6 It is suggested from the consultation document that 700 dwellings are proposed south-east of Little Chalfont.The nearest settlements with primary schools in Hertfordshire are Chorleywood and Rickmansworth. However, few families from Little Chalfont seek primary school places in Hertfordshire. 2.7 Policy SP BP6 indicates that a primary school will be sought as part of the development. The latest primary school forecast indicates a small surplus across Chorleywood and Rickmansworth schools in the short term. However, it is unlikely that capacity will be available at Hertfordshire primary schools for families from this development. 2.8 In terms of secondary school, the schools in Chorleywood and Rickmansworth (the Rickmansworth education planning area) are at capacity and there is 2.9 CDC and SBDC need to ensure that sufficient school places are provide in tandem with the additional housing proposed in Little Chalfont. 2.10 It is suggested from the consultation document that approximately 360 homes (250 market and affordable homes and 110 retirement homes) are proposed in the north-east of Chalfont St Peter. 2.11 The nearest settlement with a primary school in Hertfordshire is Maple Cross. Maple Cross has a small net outflow of children to primary schools in Buckinghamshire. It is possible that growth in Chalfont St Peter could lead to a `push-back' of children and a (small) increase in pressure for primary school places in Maple Cross. However, the impact is not considered likely to be significant. 2.12 Policy SP BP7 mentioned that there will be financial contributions towards primary and secondary school places. 2.13 With regard to the secondary school phase, the settlement of Maple Cross falls within the Rickmansworth education planning area. As set out above, there is significant pressure on secondary school places in the south-west of Hertfordshire. It is possible that there will be some `push-back' of the current inflow of children from Buckinghamshire as local demand for secondary school places increases. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why.
9034 PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1225267 Full Name M Wolbold ID 6635 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its
9035 legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I would like to air my concerns about the Lye Green site. It is already the only place local residents can walk not believe this policy to be with their children or dogs without taking transport to Ley Hill Common - and as the bus route is not the most positively prepared please reliable already I can only think there will be making a common car park for people with transport - what explain why about the golfers and cricketers? PP Mods - Please specify as precisely and succinctly as
9036 possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1226454 Full Name G F Parr ID 7052 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is
9037 not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is
9038 proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The infrastructure of the proposed development at Lye Green could prove to be a disaster. not believe this policy to be a. The main approach from Chesham to the proposed development would be via White Hill and Eskdale positively prepared please Avenue, both very deep with dangerous bends. The proposed developments would attract at least 500 cars. explain why b. The adverse effect on air pollution in the town would be great c.The chaos caused to nearby schools e.g. Brushwood school by the arrival of so many school ages children PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1211381 Full Name Mr David Silverstone ID 1443 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-03-11 Received:
9039 Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance
9040 with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do 1. Questionable Assumptions not believe this policy to be The number of new homes calculated by the National Planning Policy Framework was formulated prior to positively prepared please the advent of Brexit. Nearly all think tanks, economists and institutions (government and otherwise) are explain why anticipating that Brexit will have a significant downward effect on economic activity which in turn will impact on net immigration figures and consequently the number of new homes needed. Has any revision been made to the original projections to take account of this likely scenario? 2. Transport System The road capacity through Chesham is currently at its limit. The main A416 road through Chesham from Berkhamsted and on to Amersham already suffers from considerable delays at peak times of the day. Traffic tail-backs of half-a-mile to a mile are a regular occurrence, particularly on the Chesham Amersham section but also through Chesham itself.The proposals do not contain major relief road plans to counteract the effect of an increase in traffic use which will result from the development proposals. 3. Environment and Pollution The increase in traffic generated as a consequence of the plans will cause further deterioration of air quality which will run counter to central government ambitions to improve air quality. One of the main routes from Chesham to the main development site off Lye Green Road runs up White Hill. This is a steep hill with the town at the bottom and Chesham Grammar School at the top. Elderly and infirm pedestrians already struggle when going up this hill; additional pollution can only exacerbate their problems and extra exhaust fumes from cars backed up on the hill at the very time when the children are going to and for poses an inherent health risk. One questions whether this has been considered in arriving at the plans and it would seem that the plans can only increase the carbon footprint at a time when central government is targeting a reduction. 4. Brownfield sites There appears to have been inadequate attention paid in the drawing up of the proposals to the alternative of concentrating on brown field sites rather than green belt land. I am therefore supportive of the Brown-not-Green proposals and do not believe that there are sufficient exceptional circumstances to justify building on the Green Belt. 5. Chesham town centre The proposals to increase the number of shops in the town centre is presumably, in part, to encourage additional trade. Where, however, are shoppers going to park? The increased numbers of visitors will have to park in a greatly reduced number of parking spaces as a result of the suggestion to build in part on the existing car parks. Furthermore it would appear that the plans for commercial development were drawn up prior to the advent of online shopping. The nature of retailing has changed dramatically, particularly in the past couple of years as is evidenced by numerous shop closures both locally and nationally. Have these proposals been re-examined in recent times to take account of these changes? The Chesham Masterplan seems to offer a much more logical solution and one must ask also whether this has been properly considered before issuing this consultation. 6. Finance Where is the money coming from to pay for any of the necessary infrastructure improvements? The amount required is suggested by the plan as being about £200m. it is simplistic to think that private developers will meet the full cost of this but Council Tax payers have not been consulted in advance of their willingness to fund the infrastructure gap. Is this fair or appropriate?
9041 PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1212393 Full Name Mr John Robertsonn ID 1760 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-03-13 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant.
9042 Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as
9043 precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Lye Green is good quality agricultural land that separates Lye Green from Chesham. The proposed site is not believe this policy to be almost 2.5km from the town centre and located at the top of a steep hill that will only generate more traffic positively prepared please congestion and worsen local air quality in Chesham means it is an unsustainable location to build on. explain why The proposed Green Belt release is not consistent with other local plan policies to protect wildlife habitats or biodiversity or to protect our globally scarce chalk stream rivers. This plan undermines these aims. A local plan that predicts an increased carbon footprint of +21% is not acceptable. Many of the site allocations (such as at Lye Green. Policy SP BP2) are excluded from CIL and developers will therefore be required to deliver infrastructure directly or make financial contributions to mitigate development impact. However , these contributions cannot be quantified because much of the costs or related infrastructure is not even specified and is awaiting the preparation if (as yet unpublished) "masterplans" for each site. The fear is that many sites will either be undeliverable /nonviable or worse, delivered without the appropriate infrastructure necessary to avoid adverse impacts on the wider area. PP Mods - Please specify as The council should be looking at more effective alternatives (ie: higher densities of housing development on precisely and succinctly as Brownfield sites) which are generally closer to the town centre and in more sustainable locations which will possible how you would also rejuvenate Chesham, as advocated by Chesham Renaissance CIC Masterplan. modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not A local plan with an acknowledged funding gap from the community infrastructure levy (CIL) of between believe this policy to be £179m - £231m is not justified, effective or even legal. justified please explain why It is not justified, effective or even legal to allocate Green Belt land NE of Chesham (Policy SP BP2) for housing that has been used for decades for informal recreation by locals and is potentially to be listed as an asset of community value. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not The Spatial Policy (SP BP1) for sustainable development (to promote the recycling of previous developed believe this policy to be Brownfield land) is not effective or consistent with the Plan©s other proposed uses of Green Belt land to meet effective please explain why. housing needs specifically at Lye Green. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not The plan is not in accordance with NPPF because it seeks to remove land from the Green Belt for housing. believe this policy in There are not satisfactory "exceptional circumstances" that exist for redefining belt boundaries such as at consistent with the National Lye Green (Policy SP BP2) and/or removing numerous villages from Green Belt or permitting the "infilling Planning Policy Framework of GB villages" as proposed by policies SP PP1 and DM PP1. Baring in mind that the courts have held that Feb 2019 please explain why housing needs to do not qualify as "exceptional circumstances". There was no prior consultation on "Green Belt Villages policies" (SP PP1 and DM PP1) nor any consultation on proposals to build disproportionately so many new shops in Chesham (mostly on town car parks). Govt guidance in NPPF tells plan makers to provide for housing and other uses unless Green Belt policies (for one) provide a strong reason not to. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
9044 Policy-level file upload - Please attach any supporting evidence
Person ID 1213793 Full Name Mrs Sandy Keenay ID 3076 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-02-09 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications
9045 to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The brownfield land opportunities have not been properly identified. Nor does it consider higher not believe this policy to be densities of development on such sites which are likely to be closer to the town centre than the Green Belt positively prepared please sites and in particular the Green Belt site NE of Chesham at Lye Green. explain why The proposed development at Lye Green involving many hundreds of homes will generate substantial increased traffic, and although some highways improvements are suggested, they are insufficient and unfunded. In Chesham the evidence shows that most of the road junctions and infrastructure are operating above capacity. A further concern is that air quality would be further impaired. The Lye Green site NE of Chesham is not a sustainable location. It is over 2Km and a steep hill away from the tube station, so access would not be easy. Hardly anyone would walk or cycle this distance. And it is not credible that a reasonable bus service would be provided and maintained long-term. Most of the residents would use cars. Further doubt is cast upon the soundness of this Plan due to its conflicting claim that there would be easy access to public transport including the tube station at the same time that car parking would be reduced by retail development. This is inconsistent and unsound. PP Mods - Please specify as Please see the comments above. We consider that the use of Green Belt land should only be considered precisely and succinctly as as an absolutely last resort and that the proposals for developing land NE of possible how you would Chesham (policy SP BP 2) should be removed in any event since it is an unsustainable modify this policy to improve its alignment to this test of location and such a development will cause serious harm to the town. soundness.
9046 Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1228031 Full Name Liz Pickering ID 7198 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Forward Planning Manager Department for Education Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be
9047 as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public?
9048 Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do No consideration appears to have been given to the potential long-term need to expand schools proposed not believe this policy to be on the allocation sites, particularly in view of their relatively small size when only one form of entry is being positively prepared please proposed. At this stage in the Local Plan's preparation it may be too late to safeguard additional land for explain why education as a specific policy requirement, but in the interests of demonstrating positive preparation of the plan, we recommend an addition to the supporting text which refers to open space being designated adjacent to school sites to allow for future expansion if required. This would then be explored in more detail through the masterplanning process, and would be consistent with Planning Practice Guidance on healthy and safe communities. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5498620 Please attach any supporting evidence
Person ID 1211045 Full Name Ms Annette Powell ID 3595 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-01-21 Received:
9049 Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance
9050 with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The traffic along Ley Green Road...is congested and Air Quality is very poor when the children are walking not believe this policy to be to schools in that area - Brushwood & Chesham Grammar positively prepared please I object to the use of good quality agricultural land that will be needed in years to come, to feed us all. explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
9051 Policy-level file upload - Please attach any supporting evidence
Person ID 1213793 Full Name Mrs Sandy Keenay ID 3077 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-02-09 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications
9052 to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
Policy 1 - If you do not Please note that we are supportive of the Brown Not Green organisation's representations in relation to this believe this policy to be Local Plan. They have made a much more detailed and professional study of the relevant statutes, case justified please explain why law, compliance failures and lack of soundness of this plan and their representations contain all of the necessary references. Please take the whole of our response as being in agreement with their response and incorporating the detailed references that they have provided. Our response here gives emphasis to particular areas of concern. Local Authorities are supposed to demonstrate that they have exhausted all other options before considering the revision of Green Belt boundaries. This Local Plan is seeking substantial modifications to Green Belt boundaries including the reckless removal of Green Belt designation of many areas within the Districts and modifying the Green Belt status of local villages without any comprehensive or convincing demonstration that all other options have been explored. We
9053 therefore consider that the Plan is not justified, sound or in accordance with National Policy and as a result not legally compliant. Policy 2a - Please specify as The Plan should be modified by wider co-operation with other nearby authorities which may precisely and succinctly as result in further housing needs being taken elsewhere. possible how you would modify this policy to improve A more detailed and genuine appraisal of brownfield land opportunities should be undertaken and other its alignment to this test of options for housing delivery explored (such as Chesham Masterplan by CIC Chesham Renaissance). soundness. This would much reduce or even eliminate the need to de-classify precious Green Belt land. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1218091 Full Name Michael Shea ID 1263 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible.
9054 Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the
9055 examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not I do not believe that the Local Plan has been positively prepared, because of the lack of detail and in some believe this policy to be cases the absence of important information. justified please explain why I do not believe the Local Plan is justified because there is no evidence given, other than algorithmic calculations, of the true need for development in the Chesham area I do not believe the Local Plan is effective because Lye Green is too far away from the town to be sustainable for development, likewise the villages hereabouts, and the infrastructure especially roads and drainage are already stretched to and beyond capacity. I do not believe the Local Plan is consistent with national policy, as an example, the predicted increase in CO2 emissions Policy 2a - Please specify as Please see my earlier comments precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not The Plan does not comply with the National Policy on several counts: believe this policy in 1) An inadequate amount of time was provided to evaluate the plan, with hundreds of pages of evidence consistent with the National being presented to Councillors the day before the vote Planning Policy Framework Feb 2019 please explain why 2) Several important pieces of ©evidence© were unquantified 3) Alternatives to the use of Green Belt, particularly at Lye Green were not adequately considered 4) The need for housing development is not an ©exceptional circumstance© warranting the development of Green Belt 5) Anyone who knows the area (or can read a map) will see that Lye Green is unsustainable for development due to its distance from the town centre, especially as that distance involves negotiating a steep hill. 6) The Local Plan is at odds with National Guidance in the matter of the constraints imposed on Chesham by development policies such as for Green Belt and Areas of Natural Beauty Policy 3a - Please specify as A more assiduous investigation of brown field sites for development should be included precisely and succinctly as Greater cooperation with other local authorities; county lines are artificial boundaries that have no significant possible how you would impact on the communities of the area. South Bucks borders Herts, for example, a few miles from Chesham. modify this policy to improve its alignment to this test of The basis on which the development housing need is calculated should be replaced with a more objective soundness. and local assessment of need. Mention of developing several car parks in the town centre for retail outlets should be scrapped. There are too few car parks as it is, without what we have being taken away. Policy-level file upload - 5492249 Please attach any supporting evidence
9056 Person ID 1214430 Full Name Mr Brian Whittall ID 1718 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-12-10 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness?
9057 Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The proposals to release Green Belt land to meet housing targets (Generally, Spatial Policy SP SP1 & not believe this policy to be specifically Policy SP BP2 at Lye Green NE of Chesham) are not justified from the evidence submitted by positively prepared please the Councils. The Councils have stated that release of some Green Belt is necessary as part of an overall explain why three part strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. I question the soundness of such a general policy and whether all the brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites and in particular the Green Belt site NE of Chesham at Lye Green. The development of such Green Belt sites involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient and unfunded. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham cannot accommodate any significant highways improvements anyway due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion, with further worsening air quality. Air pollution is a particular concern in Chesham due to the already poor air quality along Bekhampstead Road where there is a designated Air Quality Management Area that already is recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will generate more traffic will make the air quality even worse and insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable nor justified nor is it in accordance with Govt policy. The Green Belt site NE of Chesham (SP BP 2) is not a sustainable location. It is over 2Km away from the train station and slightly further still from the town centre but anyone who cares to walk or cycle this distance also has to negotiate a steep hill too. Such an unsustainable location cannot be made sustainable merely by upgrading a couple of public footpaths within the site into bridleways to facilitate cycling. Neither does adding a bus stop address the geography or topography of the area especially if the promised enhanced bus service (which is already infrequent) either does not materialise or if it subsequently fails to be maintained after a few years.
9058 Further doubt is cast upon the ªsoundnessº of this Plan by virtue of there being conflicting policies within it. The Council seem to think that the Green Belt site NE of Chesham is sustainable and provides easy access to public transport including the tube station yet the same Plan promotes a considerable increase in retail development in the town (local draft plan policy SP EP3) , part of which would be built on the very car park that serves the Chesham tube station. This is inconsistent and unsound. For this Plan to sound it must also be effective. Unfortunately, further review of the proposal to remove land NE of Chesham at Lye Green from Green Belt designation is not effective as there are serious questions about the deliverability of this land. The main landowner is a farmer who has asserted publicly and in a letter to the editor of Your Chesham, that he is not prepared to release all of the land in his ownership for development. The land is also potentially an Asset Of Community Value and upon confirmation of this designation it would afford a community group the right to bid for the land. The community group (Brown Not Green) have stated their intention is to preserve the land given that many hundreds of local people have habitually used the fields at Lye Green as of right for various informal outdoor recreational purposes. These uses themselves may mean that many local individuals may have acquired easements over and across the land through prescription (20 years uninterrupted use) not least of whom would be the many private residences bordering the fields that have rear garden gates onto the fields at Lye Green. These easements and prescriptive rights may render the land very difficult to develop and make i undeliverable in planning term This land also provides an important habitat for wildlife that will be threatened by development of this land. It is perverse that the Local Authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Plan is unsound. The foregoing also points to flawed methodology of Green Belt site selection used by the Local Authority, which is neither effective, justified nor consistent with national policy and as such is unsound. Specifically, the selection of the land NE of Chesham at Lye Green (policy SP BP2) for removal from Green Belt designation is inconsistent with National Planning Policy Framework (NPPF). Paragraph 136 of the latest NPPF asserts that Green Belt boundaries should only be modified in ªexceptional circumstancesº. The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances. The Council engaged third party consultants to undertake the Part 1 Green Belt assessment and they identified numerous sites for ªfurther considerationº where exceptional circumstances ªmightº exist but expressly recommended further review of their assessment of each site against the 5 purposes of land being in Green Belt of all these sites. Unlike the neighbouring Local Authorities, the Part 2 Green Belt assessment was not undertaken by third party consultants but by the Local Authority itself who notably then did not undertake all the recommended reviews of each site including the land NE of Chesham at Lye Green (SP BP 2). Accordingly, this oversight in the Part 2 Green Belt assessment placed premature focus and fixation on releasing land at Lye Green NE of Chesham from Green Belt designation. The subsequent identification of the Chesham site for release is therefore unjustified. These comments apply equally to proposals effecting the villages in the Green Belt ± policies SP PP1 & DM PP1). The primary aim of Green Belt land (as recited in NPPF 133) is to prevent urban sprawl and to preserve the openness of the area. The Lye Green site (SP BP2) self-evidently performs this function well and has done so for decades. Another aim of Green Belt land stated in NPPF paragraph 134, is to prevent neighbouring towns and settlements from merging into one another.The Green Belt land NE of Chesham performs exceptionally well in maintaining a distinct separate between settlements of Chesham & Lye Green as well as helping to maintain separate identities of other nearby communities at Orchard Leigh, Botley, Whelpley Hill, Ashley Green. It is perverse and inconsistent with national guidance to allocate this land for removal from Green Belt in light of these facts especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if earmarked for development. A further aim of Green Belt designation stated in the NPPF at paragraph 134 (e) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. By allocating Green Belt land NE of Chesham for development, undermines this aim within Chesham. A community lead not for profit organisation called Chesham Renaissance CIC has been striving to create Chesham Masterplan that would not only provide many genuinely affordable homes in more sustainable locations nearer the town centre, but which would also regenerate some of the more deprived wards within Chesham. The Local Authority's proposals (policy SP EP3) are inconsistent with this local initiative and are therefore also inconsistent with national guidance and are consequently unsound. The Council have asserted that Government planning policy requires local councils to review Green Belt boundaries when considering how to accommodate the development needed in their areas. Just because the Council may be required to look, does not mean the Council should review Green Belt boundaries which as previously stated should only be modified in ªexceptional circumstancesº. National Planning Policy Framework (NPPF) as revised only last year, states in paragraph11 (b) I, directs ªplan makersº to create policies that are required in Local Plans for housing and other uses unless Framework policies (expressly including Green Belt) ªprovides a strong reason for restricting the overall scale type or distribution of development in the plan areaº Accordingly, I submit that given all of the above the land being proposed for release from Green Belt designation around Chesham is unjustified and contrary to national guidance. I am supportive of the Brown Not Green organisation's initiative to have the land listed as an Asset of Community Value and I feel they speak for me in respect of their objections to the draft Local Plan. Accordingly, I request that any representations made by them at any future examination in public regarding the soundness of this Local Plan be considered as an extension of my own comments herein.
9059 I feel the land NE of Chesham is an unsustainable location for development, that has been habitually used by the community for improved health & wellbeing for decades and the land performs well against Green Belt aims and objectives. Exceptional circumstances for reviewing Green Belt boundaries at this location, either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by Govt Policy and therefore the plan is unsound. PP Mods - Please specify as Co-operating with other nearby authorities. Not just Aylesbury. It is simply unsatisfactory to assert this cannot precisely and succinctly as be done because they are different functional market areas and therefore co-operation is not necessary. possible how you would Exploring such wider co-operation may result in further housing needs being taken elsewhere. modify this policy to improve A more detailed appraisal of brownfield land opportunities must be undertaken. Some Brownfield opportunities its alignment to this test of have been ignored or missed. soundness. Closer scrutiny of alternative options for housing delivery should be explored (such as Chesham Masterplan and CIC Chesham by Chesham Renaissance). Green Belt boundary reviews should only be considered after all other reasonable alternatives have been exhausted. In the face of NPPF guidance and a more thorough appraisal of Green Belt sites being considered, it may then be necessary to conclude that it is not possible to identify poor performing Green Belt sites that can accommodate all the OAN for housing. Consequently it may be necessary to accept that a lower housing provision figure is appropriate. I refer to the comments previously submitted but in summary would advocate that; All other options are fully explored including increased density of development of brownfield land and the policies emerging from Chesham Masterplan. Policy 1 - If you do not I refer to my comments previously submitted. believe this policy to be justified please explain why Policy 2a - Please specify as I refer to my comments previously submitted. precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not I refer to my comments previously submitted. believe this policy to be effective please explain why. PAa - Please specify as I refer to my comments previously submitted. precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I believe the draft Local Plan is NOT legally compliant because it has not demonstrated sufficient regard to believe this policy in the National Policy and guidance issued by the Secretary of State. consistent with the National The National Planning Policy Framework (NPPF) together with other guidance issued by the Government Planning Policy Framework is also supported by recent ministerial statements that have made it clear that Local Authorities MUST Feb 2019 please explain why demonstrate they have exhausted all options before considering revision of Green Belt boundaries. This Local Plan is seeking substantial modifications to Green Belt boundaries including the removal of Green Belt designation of 13 areas within the Districts as well as modifying the Green Belt status of many local villages. I contend this draft Local Plan has not demonstrated that all other options have been fully explored and as such this Plan is not justified, sound or in accordance with National Policy and accordingly is not legally compliant. Furthermore that Paragraph 11 b) of the NPPF (and the footnotes thereto) require Plan Makers to provide for objectively assessed needs for housing and other uses UNLESS the application of Framework policies (including Green Belt) provide a strong reason for restricting the overall scale, type or distribution of development in the plan area Chiltern District & South Bucks are significantly constrained by development policies such as Green Belt & Areas of Outstanding Natural Beauty (AONB). The Local Plan is therefore inconsistent with National Guidance and as such it is not legally compliant for the Local Authority to claim that housing needs justify a review of these same Green Belt boundaries. It is perverse to claim that the combination of housing need and the presence of significant areas of development constraint policy collectively represent ªexceptional circumstancesº (as required in the NPPF) to justify modification of Green Belt boundaries especially given the NPPF states that one of the key features of Green Belts are their permanence. The Government has also recently confirmed its aim for the UK to have net zero carbon emissions by 2050 and it is noted within the Sustainability Appraisal supporting this Draft Local Plan, that the Plan area is forecast to see carbon emission increase by 21% in the Plan Period. Accordingly, the Plan is inconsistent with Government Policy and therefore not legally compliant. There is also a significant infrastructure funding gap acknowledged within the Community Infrastructure Levy evidence that supports this Local Plan, of between £179m & £231m. Given this infrastructure is vital to ensure that development is sustainable (as also required by the NPPF) this further demonstrates the Plan is both unsound and not legally compliant. Chiltern District Council were unable to state how infrastructure would support their plan. The plan does not address these problems (extra traffic on narrow roads and the lack of parking at already at Chesham tube
9060 station). Given any new housing development would see on average 2 vehicles per household means this plan is contrary to central government strategy in regard to clean air. The plan does not account for an infrastructure for alternative mode of transport, for example cycle lanes. Electric bikes now make the gradients of the Chilterns accessible, but no infrastructure has been thought about off set carbon emissions. Further any argument proposed by ChIltern District Council that electric cars are the answer, should look at recent motor manufacturers data.The purchase of such vehicles are lowering. The plan is unsound and not legally compliant. Policy 3a - Please specify as I refer to my comments previously submitted. precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1214493 Full Name Mrs Patricia Newland ID 1815 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-11-21 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible.
9061 Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The proposals to release Green Belt land to meet housing targets (Generally, Spatial Policy SP SP1 & not believe this policy to be specifically Policy SP BP2 at Lye Green NE of Chesham) are not justified from the evidence submitted by positively prepared please the Councils. explain why The Councils have stated that release of some Green Belt is necessary as part of an overall three part strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. I question the soundness of such a general policy and whether all the brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of
9062 development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites and in particular the Green Belt site NE of Chesham at Lye Green. The Lye Green site is a completely unsustainable location. Anyone who lives in or drives through Chesham will know that the road infrastructure cannot possibly sustain any more traffic. It cannot at the moment deal with the amount of cars and HGVs which pass through the centre of the town and another 500+ houses will increase the number of vehicles using our roads by 1,000. This is simply ridiculous. There is already an air pollution problem because of the huge amount of traffic through the town and your plan to increase air pollution even more is totally contrary to current recommendations on climate change. Parking in the town centre is at times impossible and for those using the Metropolitan line, there is little chance of finding a parking space at local station carparks after 9 am weekdays. The Council believes that the Green Belt site NE of Chesham is sustainable and provides easy access to public transport including the tube station and yet the Local Plan suggests an increase in retail development (local draft plan policy SP EP3), some of which would be built on the actual car park that local residents use when before using the tube. This is totally unsound. Local GP surgeries are already oversubscribed and waiting times at local hospital emergency departments regularly exceed the four hour maximum waiting time permitted.The addition of a further 1000 to 2000 people to the area would pose an impossible burden on local medical facilities which would necessitate the building of further surgeries and the recruitment of additional medical staff. We already have a serious shortage of GPs in this area. With the building of another 500 homes, local schools would be unable to cope with the additional 1000 places that could be required. Where are the new primary and secondary schools to be built? As a supporter of the Brown Not Green campaign, I cannot believe that this land remains in the new Local Plan despite all the objections and representations that have been made to the Council by hundreds of people over the last three years. It is possible that the land may shortly be listed as an Asset of Community Value and will improve the social wellbeing of the local and wider community. It is therefore quite inappropriate to earmark this land for development when potentially many members of the public may have long established rights of way over the land. The proposal, therefore, to remove this land from the green belt is unsound for numerous reasons and will cause harm to the residents of Chesham. For this Plan to sound it must actually be possible but the land may not be deliverable The main landowner is a farmer who has confirmed in a letter to the editor of Your Chesham, that he is not prepared to release all of the land in his ownership for development. There is an abundance of wildlife that will be threatened by development of this land. The local authority wishing to promote such a valued community asset for development is contrary to the objectives of the Localism Act 2011 and therefore this aspect of the Plan is unsound. In order to build on the Green Belt, there must be `exceptional circumstances' as stated in paragraph 136 of the current NPPF and the Courts have upheld that housing need does not constitute exceptional circumstances. This also applies to proposals affecting villages in the Green Belt ± policies SP PP1 and DM PP1. One of the primary purposes of Green Belt designation is to prevent the joining up of villages to other towns or villages as stated in NPPF 134. The Lye Green site, SP BP2, provides the required separation of Lye Green from Chesham and other surrounding villages. A community lead not for profit organisation, Chesham Renaissance CIC, has created a Chesham Masterplan that would not only provide affordable homes in more sustainable locations nearer the town centre, but which would also regenerate some of the more deprived wards within Chesham. The Local Authority's proposals (policy SP EP3) are inconsistent with this local initiative and are therefore also inconsistent with national guidance and are consequently unsound. The National Planning Policy Framework in paragraph11 (b) I, directs ªplan makersº to create policies that are required in Local Plans for housing and other uses unless Framework policies (expressly including Green Belt) ªprovides a strong reason for restricting the overall scale type or distribution of development in the plan areaº.This demonstrates that the proposal to removed land from the Green Belt around Chesham is contrary to national guidance. The land north east of Chesham is an unsustainable location for development. It has been enjoyed by the local community for many years and its community use complies with the requirements of Green Belt policy. Exceptional circumstances for reviewing Green Belt boundaries at this location, either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by Government Policy and therefore the plan is unsound. I am supportive of the Brown Not Green organisation's initiative to have the land listed as an Asset of Community Value and I feel they speak for me in respect of their objections to the draft Local Plan. Accordingly, I request that any representations made by them at any future examination in public regarding the soundness of this Local Plan be considered as an extension of my own comments stated above. PP Mods - Please specify as I refer to the comments previously submitted but in summary I strongly request that building on the Green precisely and succinctly as Belt should only be considered when all other options have been investigated. The development of land possible how you would north east of Chesham, police SP BP2, should be removed from the Local Plan which is a totally unsustainable modify this policy to improve location and will cause considerable and irreversible damage to the town and outskirts of Chesham and will its alignment to this test of remove what is a much needed area of Green Belt by the local community. soundness. The use of brownfield sites should be further considered and a close inspection of the suggestions of the Chesham Masterplan. Policy 1 - If you do not believe this policy to be justified please explain why
9063 Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I believe the draft Local Plan is NOT legally compliant because it does not reflect National Policy and guidance believe this policy in issued by the Secretary of State. consistent with the National ªExceptional circumstancesº are required under the National Planning Guidance in order to change green Planning Policy Framework belt boundaries. Housing needs do NOT constitute exceptional circumstances and this has been ruled on Feb 2019 please explain why by the Courts. The National Planning Policy Framework also requires that a local authority must have exhausted all other options re house building before altering green belt boundaries. This Local Plan aims to make considerable changes to the Green Belt boundaries including the removal of thirteen Green Belt areas and the modification of the Green Belt status of many local villages. It has not provided evidence that all other options have been explored and it is therefore not sound or in accordance with National Policy and is not legally compliant. Furthermore that Paragraph 11 b) of the NPPF (and the footnotes thereto) require Plan Makers to provide for objectively assessed needs for housing and other uses UNLESS the application of Framework policies (including Green Belt) provide a strong reason for restricting the overall scale, type or distribution of development in the plan area Chiltern District & South Bucks are significantly constrained by development policies such as Green Belt & Areas of Outstanding Natural Beauty (AONB). The Local Plan is therefore not consistent with National Guidance.The local authority is not complying with legislation and cannot claim that local housing needs jusify a review of the Green Belt. The UK Government's aim is to have net zero carbon emissions by 2050 and it can be seen in the Sustainability Appraisal supporting this Draft Local Plan that carbon emissions within the Plan area will rise by 21% in the period of the Plan. . Policy 3a - Please specify as The Plan needs to be modified by; precisely and succinctly as Demonstrating where this apparent housing need comes from ± who are the people that are going to be possible how you would living in the proposed housing units and where will they be working. modify this policy to improve its alignment to this test of Exploring options for house building in other areas where there may be more housing demand. soundness. Further examination of possible brownfield sites within the Chesham area. Further consideration of the housing options proposed by the Chesham Masterplan by CIC Chesham Renaissance. Policy-level file upload - 5495903 Please attach any supporting evidence
Person ID 1218813 Full Name Mr Michael Windett ID 1200 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID
9064 Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination
9065 Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Refer to the Chesham Masterplan which addresses and resolves all the issues the proposal raises. not believe this policy to be positively prepared please explain why PP Mods - Please specify as Refer to the Chesham Masterplan which addresses and resolves all the issues the proposal raises. precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not Refer to the Chesham Masterplan which addresses and resolves all the issues the proposal raises. believe this policy to be justified please explain why Policy 2a - Please specify as Refer to the Chesham Masterplan which addresses and resolves all the issues the proposal raises. precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not Refer to the Chesham Masterplan which addresses and resolves all the issues the proposal raises. believe this policy to be effective please explain why. PAa - Please specify as Refer to the Chesham Masterplan which addresses and resolves all the issues the proposal raises. precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not Green Belt was established for a reason and should be sacrosanct in all bar extreme circumstances, which believe this policy in I do not consider this Plan is. Therefore it is not in accord with national guidance nor justified. It is not the consistent with the National right way to solve the issues and will be neither effective nor in keeping with the environment. Planning Policy Framework I also support the Chesham Masterplan and think it is the solution to the issues and that the Brown not Green Feb 2019 please explain why campaign also has merit. The whole proposal seems unprepared and ill-conceived and I therefore strongly object to it. Policy 3a - Please specify as Refer to the Chesham Masterplan which addresses and resolves all the issues the proposal raises. precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1216352 Full Name Mr David Gilley ID 1386 Order 236
9066 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as
9067 precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not NPFF 2018, Chapter 13 ± The Green Belt, opens by stating that: believe this policy in
9068 consistent with the National ªThe Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to Planning Policy Framework prevent urban sprawl by keeping land permanently openº it also urges Local Planning Authorities to maximise Feb 2019 please explain why the use of suitable brownfield sites before considering changes to Green Belt boundaries and sets out the conditions that must be fulfilled for ªexceptional circumstancesº to exist, to justify such changes. This plan immediately attempts to defy this by modifying greenbelt boundaries without exhausting all other options. It is therefore not legally compliant as there is a lack of evidence that all alternatives have been exhausted. In the case of this plan, many of the `exceptional circumstances' cited for amending green belt in large swathes, particularly in respect of 11.3 Policy SP BP2 ± Chesham are merely ªhousing needº. The government's housing white paper (fixing our broken housing market) published in February 2017, reiterated the Government's commitment to the Green Belt. It emphasised that authorities should amend Green Belt boundaries only when they could demonstrate that they had examined fully all other reasonable options for meeting their identified development requirements. This plan does not demonstrate that all other options have been exhausted, it instead launches very quickly in attempting to justify Green Belt boundary change based on `housing need'. In addition the plan is inconsistent with the National Planning Framework, which states one of the purposes Green Belt exists is to encourage urban regeneration of derelict land. The plan fails to acknowledge the work of Chesham Renaissance in preparing a Masterplan alternative that utilizes brownfield sites, in respect of 11.3 Policy SP BP2 ± Chesham the release of Green Belt and ear marking for development before exhausting all brownfield sites is a diametric opposition to the NPFF, where builders will naturally choose the ease of building on green belt over developing multiple brownfield sites. This is exactly why Green Belt exists, this plan is unsound and inconsistent with National Planning policy. The plan does not acknowledge the work of this community led proposal and therefore how can it claim to have considered all alternatives. An issue raised by many in the community from the start is the lack of infrastructure to support most of the poorly paper planned proposals, the plan in its various draft forms has pushed this aside and in this latest draft continues to do so in the form of a huge funding gap to deliver the required infrastructure to support what is being proposed, the evidence of the Community Infrastructure Levy supporting the plan estimates this between £179 Million and £231 Million, further evidence this plan is not sound and not legally compliant nor viable. Policy 3a - Please specify as More detailed exploration of and improved analysis consideration and evidenced use of brownfield sites precisely and succinctly as Better localism - consideration of alternative options that have been developed by community led possible how you would modify this policy to improve initiatives such as the Chesham Masterplan by CIC Chesham Renaissance its alignment to this test of Cooperation with neighbouring areas other than `Aylesbury' soundness. Green belt boundaries should only be considered AFTER all other alternatives have been exhausted ± per NPFF Revisit housing estimates, particularly in light of recent eco-political climate Consider poor performing green belt sites may not exist in the number being demanded and accept a lower housing target is appropriate Policy-level file upload - 5492645 Please attach any supporting evidence
Person ID 1219101 Full Name Mr & Mrs Robin & Sarah Carne ID 1038 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant.
9069 Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as
9070 precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not The proposals to release Green Belt land to meet housing targets (Generally, Spatial Policy SP SP1 & believe this policy to be specifically Policy SP BP2 at Lye Green NE of Chesham) are not justified from the evidence submitted by justified please explain why the Councils. The Councils have stated that release of some Green Belt is necessary as part of an overall three part strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. I question the soundness of such a general policy and whether all the brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites and in particular the Green Belt site NE of Chesham at Lye Green. The development of such Green Belt sites involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient and unfunded. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham cannot accommodate any significant highways improvements anyway due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion, with further worsening air quality. Air pollution is a particular concern in Chesham due to the already poor air quality along Bekhampstead Road where there is a designated Air Quality Management Area that already is recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will generate more traffic will make the air quality even worse and insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable nor justified nor is it in accordance with Govt policy. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not The Green Belt site NE of Chesham (SP BP 2) is not a sustainable location. It is over 2Km away from the believe this policy to be train station and slightly further still from the town centre but anyone who cares to walk or cycle this distance effective please explain why. also has to negotiate a steep hill too. Such an unsustainable location cannot be made sustainable merely by upgrading a couple of public footpaths within the site into bridleways to facilitate cycling. Neither does adding a bus stop address the geography or topography of the area especially if the promised enhanced bus service (which is already infrequent) either does not materialise or if it subsequently fails to be maintained after a few years. Further doubt is cast upon the ªsoundnessº of this Plan by virtue of there being conflicting policies within it. The Council seem to think that the Green Belt site NE of Chesham is sustainable and provides easy access to public transport including the tube station yet the same Plan promotes a considerable increase in retail development in the town (local draft plan policy SP EP3) , part of which would be built on the very car park that serves the Chesham tube station. This is inconsistent and unsound. For this Plan to sound it must also be effective. Unfortunately, further review of the proposal to remove land NE of Chesham at Lye Green from Green Belt designation is not effective as there are serious questions about the deliverability of this land. The main landowner is a farmer who has asserted publicly and in a letter to the editor of Your Chesham that he is not prepared to release all of the land in his ownership for development.
9071 PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not We believe the draft Local Plan is NOT legally compliant because in our opinion it has not demonstrated believe this policy in sufficient regard to the National Policy and guidance issued by the Secretary of State. consistent with the National Also, the National Planning Policy Framework together with other guidance issued by the Government is Planning Policy Framework also supported by recent ministerial statements that have made it clear that Local Authorities MUST Feb 2019 please explain why demonstrate they have exhausted all options BEFORE considering revision of Green Belt boundaries. This Local Plan is seeking substantial modifications to Green Belt boundaries including the removal of Green Belt designation of 13 areas within the Districts as well as modifying the Green Belt status of many local villages and we argue that this draft Local Plan has not demonstrated that all other options have been fully explored and as such this Plan is not justified, sound or in accordance with National Policy and accordingly is not legally compliant. In addition that Paragraph 11 b) of the NPPF (and the footnotes thereto) require Plan Makers to provide for objectively assessed needs for housing and other uses UNLESS the application of Framework policies (including Green Belt) provide a strong reason for restricting the overall scale, type or distribution of development in the plan area. Chiltern District & South Bucks are significantly constrained by development policies such as Green Belt & Areas of Outstanding Natural Beauty (AONB). The Local Plan is therefore inconsistent with National Guidance and as such it is not legally compliant for the Local Authority to claim that housing needs justify a review of these same Green Belt boundaries. It is irrational to claim that the combination of housing need and the presence of significant areas of development constraint policy collectively represent ªexceptional circumstancesº (as required in the NPPF) to justify modification of Green Belt boundaries especially given the NPPF states that one of the key features of Green Belts are their permanence! The Government has also recently confirmed its aim for the UK to have net zero carbon emissions by 2050 and it is noted within the Sustainability Appraisal supporting this Draft Local Plan, that the Plan area is forecast to see carbon emission increase by 21% in the Plan Period. Accordingly, the Plan is inconsistent with Government Policy and therefore not legally compliant. There is also a significant infrastructure funding gap acknowledged within the Community Infrastructure Levy evidence that supports this Local Plan, of between £179m & £231m. Given this infrastructure is vital to ensure that development is sustainable (as also required by the NPPF) this further demonstrates the Plan is both unsound and not legally compliant. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5492158 Please attach any supporting evidence
Person ID 1218913 Full Name Mr & Mrs John & Ella Teh-Southwood ID 1178 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details
9072 Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has
9073 met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I believe the draft Local Plan is NOT legally compliant because it has not demonstrated sufficient regard believe this policy in to the National Policy and guidance issued by the Secretary of State. consistent with the National Planning Policy Framework The National Planning Policy Framework (NPPF) together with other guidance issued by the Feb 2019 please explain why Government is also supported by recent ministerial statements that have made it clear that Local Authorities MUST demonstrate they have exhausted all options BEFORE considering revision of Green Belt boundaries. This Local Plan is seeking substantial modifications to Green Belt boundaries including the removal of Green Belt designation of 13 areas within the Districts as well as modifying the Green Belt status of many local villages. I contend this draft Local Plan has not demonstrated that all other options have been fully explored and as such this Plan is not justified, sound or in accordance with National Policy and accordingly is not legally compliant. Furthermore that Paragraph 11 b) of the NPPF (and the footnotes thereto) require Plan Makers to provide for objectively assessed needs for housing and other uses UNLESS the application of Framework policies (including Green Belt) provide a strong reason for restricting the overall scale, type or distribution of development in the plan area Chiltern District & South Bucks are significantly constrained by development policies such as Green Belt & Areas of Outstanding Natural Beauty (AONB). The Local Plan is therefore inconsistent with National Guidance and as such it is not legally compliant for the Local Authority to claim that housing needs justify a review of these same Green Belt boundaries. It is perverse to claim that the combination of housing need and the presence of significant areas of
9074 development constraint policy collectively represent ªexceptional circumstancesº (as required in the NPPF) to justify modification of Green Belt boundaries especially given the NPPF states that one of the key features of Green Belts are their permanence. The Government has also recently confirmed its aim for the UK to have net zero carbon emissions by 2050 and it is noted within the Sustainability Appraisal supporting this Draft Local Plan, that the Plan area is forecast to see carbon emission increase by 21% in the Plan Period. Accordingly, the Plan is inconsistent with Government Policy and therefore not legally compliant. There is also a significant infrastructure funding gap acknowledged within the Community Infrastructure Levy evidence that supports this Local Plan, of between £179m & £231m. Given this infrastructure is vital to ensure that development is sustainable (as also required by the NPPF) this further demonstrates the Plan is both unsound and not legally compliant. In addition, there has been no information or provision regarding how our doctors surgeries and schools are going to accommodate this influx of people. Policy 3a - Please specify as Co-operating with other nearby authorities. Not just Aylesbury. It is simply unsatisfactory to assert this precisely and succinctly as cannot be done because they are different Functional Market Areas and that co-operation is not possible how you would modify this policy to improve necessary therefore. its alignment to this test of Exploring such wider co-operation may result in further housing needs being taken elsewhere. soundness. A more detailed appraisal of brownfield land opportunities MUST be undertaken. Some brownfield opportunities have been ignored or missed. Closer scrutiny of alternative options for housing delivery should be explored (such as Chesham Masterplan by CIC Chesham Renaissance). Green Belt boundary reviews should only be considered AFTER all other reasonable alternatives have been exhausted. In the face of NPPF guidance and a more thorough appraisal of Green Belt sites being considered, it may then be necessary to conclude that it is not possible to identify poor performing Green Belt sites that can accommodate all the OAN for housing. Consequently it may be necessary to accept that a lower housing provision figure is appropriate. Policy-level file upload - 5511446 Please attach any supporting evidence
Person ID 1218915 Full Name Mrs Judith Young ID 1176 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant,
9075 including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s),
9076 do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not Narrow access roads. All three routes into Chesham town centre are winding roads i.e Lye Green Road, believe this policy to be Eskdale Avenue and White Hill. justified please explain why Traffic through Chesham is already congested at rush hour, with long tail backs in the morning and the early evening, along Berkhamstead Road to the North and Amersham Hill to the south. This will be made even worse with 500 plus cars from the proposed development at Lye Green, together with 140 plus cars from the proposed development at Asheridge Road and more than 99 cars from the proposed development off Darvell Drive. Air Quality, already bad, will become worse. There will be increased pressure for places at playgroups, nurseries, primary schools and secondary schools in the town, as well as on dentists and doctors surgeries. I am concerned that building on land previously designated as Green Belt will lead to an urban sprawl, and I would prefer planners to consider brown field sites or redevelopment of the town centre as proposed in the Chesham Master Plan. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5492193 Please attach any supporting evidence
Person ID 1219286 Full Name Mrs Violet Coppin ID 3454 Order 236 Number 11.3
9077 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible.
9078 Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Following careful consideration of the above, I am forced to conclude that the council©s Local Plan will cause not believe this policy to be harm to the wider town of Chesham and is unsound. Specific areas of concern include: positively prepared please - loss of Green Belt around Chesham with all of the environmental implications explain why - more traffic congestion and worsening air quality in Chesham - Loss of land with Community Value in Chesham which supports wildlife and recreation - Outward sprawl of the town which will result in Lye Green becoming part of ©Greater Cehsham© - Failure to recognise an opportunity for urban development and regeneration PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not I am concerned that the many hundreds of proposed homes will generate increased traffic and its attendant believe this policy to be air pollution, already at alarming levels in the Chesham area. The designated Air Quality Management Area justified please explain why along Berkhamstead Road is already recording air quality that is considerably worse than EU safe levels. The council©s proposals are inconsistent with Local Plan Policy DM DP5 relating to ©climate responsive development© and policy DM DP9 ©reducing reliance on private cars© and DM DP15 ©BLue Green infrastructure©. The council©s wilful failure to take these into account will only make things worse and cannot be justified under recent national government policy.These considerations alone should be sufficient grounds to reconsider the entire draft local plan which is unsound in this matter. there are suggestions of mitigating the air quality but where is the proof these measures will be delivered or that they will work? The Green Belt site NE of Chesham is over two kilometres from the underground station and Chesham town centre and is therefore an unsustainable location. The council seems to think that the Lye Green site is sustianble and provides easy access to public transport including the underground station , yet the same local plan promotes a considerable increase in retail development in the town (draft local plan policy SP EP3 which I also feel is unsound), part of which would be built on the very car park that serves the Chesham underground station, thus undermining the use of public transport and resulting in the greater use of private cars, which, in turn will lead to more traffic congestion. This is inconsistent and unsound. The flawed methodology used by the Local Authority to select the Green Belt site was not effective, justified or consistent with the national planning policy framework (NPPF) and has resulted in their choice of Lye Green which is unsound.
9079 Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not It appears that the council has decided to take the easy option and develop Green Belt land (specifically believe this policy in 13GB sites in Chiltern and South Bucks), which is unjustified, ineffective and inconsistent with national policy. consistent with the National This view is supported by the fact that the councils policy for Green Belt release is part of an overall strategic Planning Policy Framework objective that promotes sustainable development as reflected in Local Plan Policy SP SP1. Such sites are Feb 2019 please explain why generally not sustainable, and to designate them as such is unsound. In additional, there are insufficient ©exceptional circumstances© generally to justify Green Belt release and specifically at Lye Green in this instance. Paragraph 136 of the latest National Planning Policy Framework (NPPF) asserts that Green Belt boundaries should be modified only in ©exceptional circumstances©. The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances and Lye Green is not a sustainable location being too far from the town centre with a steep hill to negotiate too. Quite simply, Green Belt land should not be the first choice for development when other, less damaging options exist nearer the Chesham town centre and the underground station. I question the soundness of the local plan which fails to identify the brownfield land opportunities that have been identified by other such as the Chesham Renaissance CIC Masterplan.The council should be looking at higher densities of development on such sites as are generally closer to the town centre. In short, i believe that the council has used flawed methodology for identifying sites to meet local housing needs and that Lye Green is an unsustainable location and, therefore, its release from the Green Belt is unjustified. The selection of the land at Lye Green as suitable for removal from Green Belt is inconsistent with National Planning Policy Framework (NPPF) not only for the reasons so far stated, but also for the fact that the land supports wildlife and is an important recreational site for nearby communities. Most Green Belt areas do not have widespread public access making this land Lye Green unusual and a rare feature that improves community well being and to allocate such an important sit for development is unjustified. Lye Green is a potential Asset of Community Value and confirmation of this designation will afford a community group the right to bid for the land in order to preserve it for the hundreds of local people who have long used it for recreation purposes. It is perverse that the local authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Local Plan is unsound. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open. This is government policy as set out in paragraph 133 of NPPF 2018. The Lye Green site self-evidently does this well and has done so for decades. A further aim of Green Belt land (stated in NPPF paragraph 134) is to prevent neighbouring towns and settlements from merging into one another. The preservation of Lye Green as Green Belt Land is vital in maintaining a distinct separation from as well as helping to maintain the separate identities of other nearby communities. In view of these facts, it is perverse and inconsistent with national guidance to allocate this land for removal from green belt, especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if the land is developed. Given the above the land being proposed for release form Green Belt designation around Chesham is unjustified and contrary to national guidance. A further aim of Green Belt designation (as stated in the NPPF at paragraph 134(e)) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. Allocating Green Belt land at Lye Green as an area for development completely undermines this aim by failing to recognize the opportunities that exist within Chesham. A community led not-for-profit organisation called Chesham Renaissance CIC has developed the Chesham Masterplan that would not only provide more sustainable locations nearer the town centre, but which would also regenerate some of the more deprived wards within Chesham. While the local plan promotes a considerable increase in retail development alone is not required. A simple stroll down Chesham High Street would reveal at least 10 empty shops. The problem is not insufficient retail spaces but a lack of thoughtful redevelopment that promotes and supports existing retail premises. Indeed the proposals to build shops on the car parks actively undermines the Chesham Renaissance CIC Masterplan. The local authority©s proposals are inconsistent with the local initiative and are therefore also inconsistent with national guidance and are consequently unsound. Everyone in Chesham, not just Lye Green, will be impacted by the addition of 500 homes on this area of Green Belt. I am supportive of the Brown not Green organisation©s initiative to have the land listed as an Asset of Community Value, and I feel they speak for me in respect of their objections to the draft local plan. Accordingly, I request that any representations made by them at any future examination in public regarding the soundness of this local plan be considered as an extension of my own comments herein.
9080 I feel the land NE of Chesham at Lye Green is an unsustainable location for development, that has been habitually used by the community for improved health and wellbeing for decades and that the land performs well against Green Belt aims and objectives. Exceptional Circumstances for reviewing Green Belt boundaries at this location either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by government policy, and therefore, the local plan is unsound. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1219300 Full Name Harry Brooke ID 3466 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness?
9081 Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The proposals to release Green Belt land to meet housing targets are not justified from the evidence submitted not believe this policy to be by the Councils. positively prepared please The Councils have stated that release of some Green Belt is necessary as part of an overall three part explain why strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. I question the soundness of such a general policy and whether all the brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites and in particular the Green Belt site NE of Chesham at Lye Green.
9082 The development of such Green Belt sites involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient. For example, In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham cannot accommodate any significant highways improvements anyway due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion, with further worsening air quality. Air pollution is a particular concern in Chesham due to the already poor air quality along Bekhampstead Road where there is a designated Air Quality Management Area that already is recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will generate more traffic will make the air quality even worse. Insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable nor justified nor is it in accordance with Govt policy. The Green Belt site NE of Chesham is not a sustainable location. It is over 2Km away from the train station and slightly further still from the town centre but anyone who cares to walk or cycle this distance also has to negotiate a steep hill too. Such an unsustainable location cannot be made sustainable merely by upgrading a couple of public footpaths within the site into bridleways to facilitate cycling. Neither does adding a bus stop address the geography or topography of the area especially if the promised enhanced bus service (which is already infrequent) either does not materialise or if it subsequently fails to be maintained after a few years. Further doubt is cast upon the ªsoundnessº of this Plan by virtue of there being conflicting policies within it. The Council seem to think that the Green Belt site NE of Chesham is sustainable and provides easy access to public transport including the tube station yet the same Plan promotes a considerable increase in retail development in the town (local draft plan policy SP EP3), part of which would be built on the very car park that serves the Chesham tube station. This is inconsistent and unsound. For this Plan to be sound it must also be effective, however, there are serious questions about the deliverability of this land. The main landowner is a farmer who has asserted publicly and in a letter to the editor of Your Chesham, that he is not prepared to release all of the land in his ownership for development. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not The land is also potentially an Asset Of Community Value. The community group (Brown Not Green) have believe this policy in stated their intention is to preserve the land given that many hundreds of local people have habitually used consistent with the National the fields at Lye Green as of right for various informal outdoor recreational purposes.These uses themselves Planning Policy Framework may mean that local individuals have acquired easements over and across the land through prescription (20 Feb 2019 please explain why years uninterrupted use) not least of whom would be the many private residences bordering the fields that have rear garden fences onto the field of Lye Green. These easements and prescriptive rights may render the land very difficult to develop and make it deliverable in planning terms. It is perverse that the Local Authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the plan in unsound. The foregoing also points to flawed methodology of Green Belt site selection used by the Local Authority which is neither effective, justified, nor consistent with national policy and as such is unsound. Specifically the selection of the land NE of Chesham at Lye Green for removal from Green Belt designation is inconsistent with the National Planning Policy Framework(NPPF). Paragraph 136 of the latest NPPF asserts that Green Belt boundaries should only be modified in ªexceptional circumstancesº. The courts have held that unmet local housing needs of an area themselves are not exceptional circumstances. The council engaged third party consultants to undertake the Part 1 Green Belt assessment and they identified numerous sites for ªfurther considerationº where exceptional circumstances ªmightº exist but expressly recommend further review of their assessment of each site against the 5 purposes of land being in Green Belt of all these sites. Unlike the neighbouring local authorities, the part 2 assessment
9083 was not undertaken by third party consultants but by the local authority itself who notably then did not undertake all the recommended reviews of each site including the land NE of Chesham at Lye Green. Accordingly, this oversight in the Part 2 Green Belt assessment placed premature focus and fixation on releasing land at Lye Green NE of Chesham from Green Belt designation. The subsequent identification of the Chesham site for release is therefore unjustified. The primary aim of Green Belt land (as recited in NPPF 133) is to prevent urban sprawl and to preserve the openness of the area. The Lye Green site (SP BP2) self-evidently performs this function well and has done so for decades. Another aim of Green Belt land stated in NPPF paragraph 134, is to prevent neighbouring towns and settlements from merging into one another.The Green Belt land NE of Chesham performs exceptionally well in maintaining a distinct separate between settlements of Chesham & Lye Green as well as helping to maintain separate identities of other nearby communities at Orchard Leigh, Botley, Whelpley Hill, Ashley Green. It is perverse and inconsistent with national guidance to allocate this land for removal from Green Belt in light of these facts especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if earmarked for development. A further aim of Green Belt designation stated in the NPPF at paragraph 134 (e) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. By allocating Green Belt land NE of Chesham for development, undermines this aim within Chesham. A community lead not for profit organisation called Chesham Renaissance CIC has been striving to create Chesham Masterplan that would not only provide many genuinely affordable homes in more sustainable locations nearer the town centre, but which would also regenerate some of the more deprived wards within Chesham. The Local Authority's proposals (policy SP EP3) are inconsistent with this local initiative and are therefore also inconsistent with national guidance and are consequently unsound. The Council has asserted that Government planning policy requires local councils to review Green Belt boundaries when considering how to accommodate the development needs in their areas. Just because the council may be required to look does not mean the Council should review Green Belt boundaries which as previously stated should only be modified in ªexceptional circumstancesº. The National Planning Policy Framework (NPPF) as revised only last year in paragraph 11(b)I, directs ªplan makersº to create policies that are required in Local Plans for housing and other uses unless Framework policies (expressly including Green Belt) ªprovides a strong reason for restricting the overall scale type or distribution of development in the plan areaº. Accordingly, I submit that given all of the above land being proposed for release from Green Belt designation around Chesham is unjustified and contrary to the national guidance. I feel the land NE of Chesham is an unsustainable location for development, which has been habitually used by the community to improve health & wellbeing for decades and the land performs well against Green Belt aims and objectives. Exceptional Circumstances for reviewing Green Belt boundaries at this location either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by Govt policy and therefore this plan is unsound. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1219084 Full Name Colin Peters ID 1101 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name
9084 Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination
9085 Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not The proposals to release Green Belt land to meet housing targets (Generally, Spatial Policy SP SP1 & believe this policy to be specifically Policy SP BP2 at Lye Green NE of Chesham) are not justified from the evidence submitted by justified please explain why the Councils. The Councils have stated that release of some Green Belt is necessary as part of an overall three part strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. I question the soundness of such a general policy and whether all the brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites and in particular the Green Belt site NE of Chesham at Lye Green. The development of such Green Belt sites involving many hundreds of homes will generate increased traffic, this would impact local business local schools local infrastructure ie shops and doctors and local amenities like Elgiva abd particyally the bus and coach routes through Chesham Chesham cannot accommodate any significant highways improvements anyway due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion, with further worsening air quality. Air pollution is a particular concern in Chesham due to the already poor air quality along Bekhampstead Road where there is a designated Air Quality Management Area that already is recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will generate more traffic will make the air quality even worse and insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable nor justified nor is it in accordance with Govt policy. The Green Belt site NE of Chesham (SP BP 2) is not a sustainable location. It is over 2Km away from the train station and slightly further still from the town centre but anyone who cares to walk or cycle this distance also has to negotiate a steep hill too. Such an unsustainable location cannot be made sustainable merely by upgrading a couple of public footpaths within the site into bridleways to facilitate cycling. Neither does adding a bus stop address the geography or topography of the area especially if the promised enhanced bus service (which is already infrequent) either does not materialise or if it subsequently fails to be maintained after a few years. Further doubt is cast upon the ªsoundnessº of this Plan by virtue of there being conflicting policies within it. The Council seem to think that the Green Belt site NE of Chesham is sustainable and provides easy access to public transport including the tube station yet the same Plan promotes a considerable increase in retail development in the town (local draft plan policy SP EP3) , part of which would be built on the very car park that serves the Chesham tube station. This is inconsistent and unsound The community group (Brown Not Green) have stated their intention is to preserve the land given that many hundreds of local people have habitually used the fields at Lye Green as of right for various informal outdoor recreational purposes. I personally use this land and have for over 20 years to walk my dog, walk with my children and family to explore the countryside and all animals that have this area as their habitat. This land is irreplaceable and therefore find your plan not justified or Sound or effective in solving the housing issues mentioned.
9086 The primary aim of Green Belt land (as recited in NPPF 133) is to prevent urban sprawl and to preserve the openness of the area. The Lye Green site (SP BP2) self-evidently performs this function well and has done so for decades. Another aim of Green Belt land stated in NPPF paragraph 134, is to prevent neighbouring towns and settlements from merging into one another.The Green Belt land NE of Chesham performs exceptionally well in maintaining a distinct separate between settlements of Chesham & Lye Green as well as helping to maintain separate identities of other nearby communities at Orchard Leigh, Botley, Whelpley Hill, Ashley Green. It is perverse and inconsistent with national guidance to allocate this land for removal from Green Belt in light of these facts especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if earmarked for development. A further aim of Green Belt designation stated in the NPPF at paragraph 134 (e) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. By allocating Green Belt land NE of Chesham for development, undermines this aim within Chesham. A community lead not for profit organisation called Chesham Renaissance CIC has been striving to create Chesham Masterplan that would not only provide many genuinely affordable homes in more sustainable locations nearer the town centre, but which would also regenerate some of the more deprived wards within Chesham. The Local Authority's proposals (policy SP EP3) are inconsistent with this local initiative and are therefore also inconsistent with national guidance and are consequently unsound. I am supportive of the Brown Not Green organisation's initiative to have the land listed as an Asset of Community Value and I feel they speak for me in respect of their objections to the draft Local Plan. Accordingly, I request that any representations made by them at any future examination in public regarding the soundness of this Local Plan be considered as an extension of my own comments herein. I feel the land NE of Chesham is an unsustainable location for development, that has been habitually used by me and my family and friends for improved health & wellbeing for decades and the land performs well against Green Belt aims and objectives. Exceptional circumstances for reviewing Green Belt boundaries at this location, either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by Govt Policy and therefore the plan is unsound. Policy 2a - Please specify as I refer to the comments previously submitted but in summary would advocate that; precisely and succinctly as All other options are fully explored including increased density of development of brownfield land and the possible how you would policies emerging from Chesham Masterplan. modify this policy to improve its alignment to this test of Green Belt land should only be considered when all other options are exhausted and in any event the soundness. proposals for developing land NE of Chesham (policy SP BP 2) should be removed as it is an unsustainable location the development of which will cause harm to the wider town including loss of an asset that improves the well-being for the community. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I believe the draft Local Plan is NOT legally compliant because it has not demonstrated sufficient regard to believe this policy in the National Policy and guidance issued by the Secretary of State. consistent with the National The National Planning Policy Framework (NPPF) together with other guidance issued by the Government Planning Policy Framework is also supported by recent ministerial statements that have made it clear that Local Authorities MUST Feb 2019 please explain why demonstrate they have exhausted all options BEFORE considering revision of Green Belt boundaries. This Local Plan is seeking substantial modifications to Green Belt boundaries including the removal of Green Belt designation of 13 areas within the Districts as well as modifying the Green Belt status of many local villages. In addition the infrastructure of Chesham will be severely undermined as I see this plan has not ben positively prepared nor is it justified or effective in addressing the major issues to infrastructure the Chiltern and South Bucks Local Plan reg19 delivers I contend this draft Local Plan has not demonstrated that all other options have been fully explored and as such this Plan is not justified, sound or in accordance with National Policy and accordingly is not legally compliant. There are considerable areas of Chesham and the surrounding areas that are already designated Brown-building areas that have not been identified to be used for further house building in preference to the green belt areas in the plan. Without pursuing these many Brown areas of Chesham then I cannot see how this plan is legally compliant and therefore I support the Brown not Green plan supported by the Chesham master plan to utilise these areas better I do not accept that or see that preparation / research has taken place to fully explore options that would be more effective and justified in the interest of the local community / business and people of the Chesham and surrounding areas. The Government has also recently confirmed its aim for the UK to have net zero carbon emissions by 2050 and it is noted within the Sustainability Appraisal supporting this Draft Local Plan, that the Plan area is forecast to see carbon emission increase by 21% in the Plan Period. Accordingly, the Plan is inconsistent with Government Policy and therefore not legally compliant. There is also a significant infrastructure funding gap acknowledged within the Community Infrastructure Levy evidence that supports this Local Plan, of between £179m & £231m. Given this infrastructure is vital to ensure
9087 that development is sustainable (as also required by the NPPF) this further demonstrates the Plan is both unsound and not legally compliant. Policy 3a - Please specify as The Plan needs to be modified by; precisely and succinctly as A more detailed appraisal of brownfield land opportunities MUST be undertaken. Some brownfield opportunities possible how you would have been ignored or missed. As far as I can see from the plan modify this policy to improve its alignment to this test of Closer scrutiny of alternative options for housing delivery should be explored (such as Chesham Masterplan soundness. by CIC Chesham Renaissance). Green Belt boundary reviews should only be considered AFTER all other reasonable alternatives have been exhausted In the face of NPPF guidance and a more thorough appraisal of Green Belt sites being considered, it may then be necessary to conclude that it is not possible to identify poor performing Green Belt sites that can accommodate all the OAN for housing. Consequently it may be necessary to accept that a lower housing provision figure is appropriate. I accept more housing in the Chesham area but to utilise Brown sites and to offer a solid plan for infrastructure improvements. Policy-level file upload - 5492159 Please attach any supporting evidence
Person ID 1219424 Full Name Mr Nick Tarling ID 1296 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be
9088 as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do We are writing to you to voice our concerns over a proposed by Chiltern and South Bucks local planning not believe this policy to be department, with regard to the removal of land from the green belt around 21 sites in Buckinghamshire and positively prepared please with special regard to land in the North East of Chesham, bordering the hamlet of Lye Green, and we question explain why as to whether this is a sound policy for the future of Chesham. The topography of Chesham is of a town built int he river valley surrounded by steep hills of the Chilterns, and as such all major roads to Chesham lead down these steep hills to one main thorough fare, carrying all the traffic through the town. The proposed land to be removed from the Green Belt, and to be used as a
9089 housing development is situated at the top of one of these hills leading into the town and is about 2km from the nearest tube station. The infrastructure of these roads are not able to meet the demands of currant traffic, so any increase in traffic cause by a development on the ouskirts of the town will have major repercussions on traffic flow in the town. Being in a narrow valley thee is little room to widen and improve the highway infrastructure and as such the proposed development is unsustainable. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not As I have used the land to exercise my dogs for over 25 years, I have noticed how heavy rain affects this believe this policy to be land. Periods of long and heavy rain leads to the area becoming very waterlogged and can result in justified please explain why ©temporary©ponds due to poor drainage. In heavy downpours or thunderstorms, flash floods occur, with water flowing down the fields and travelling down to Brushwood road, posing a flood risk to houses on the lower side of the road, before it continues on its way to The Spinney where the properties at the end of that road become flooded.With the removal of land to hold the water, there will be an increase in neighbouring properties of flooding, which needs to be addressed before a development takes place, again not a sustainable proposal. The land is also an important corridor for wildlife, woodpeckers have been seen, along with bats and barn owls use the woods bordering the land.The grassland itself provides food and shelter for the small mammals and invertebrates that these animals feed on. As well as some ancient Oak trees which grow around the land. This plan will have severe ecological effects on the area. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not With an increase in traffic congestion, there will be an increase in air pollution and there are areas of the believe this policy in town which have already been recognized as having poor air quality, and the government policy is to reduce consistent with the National air pollution not increase it! Planning Policy Framework The land in question is an area criss-crossed by several public footpaths and is used by many different Feb 2019 please explain why groups of people. Local residents, who live close to this area use the fields for exercising their dogs. There are groups of young people who use the area whilst doing their Duke of Edinburgh challenges, along with runner and ramblers. This land is a valuable asset for the local community and withdrawal of the land from the Green Belt would undermine the objective of the Localism Act 2011 and so therefore is an unsound aspect to the plan. I have been looking into the aims of the green belt policy, why and when it was first created. Its primary aim was to prevent urban sprawl and to preserve the openness of areas around towns and villages. By allowing development of the land, the hamlet of Lye Green, with it unique character will be compromised. This is also references to in NPPF paragraph 133, to prevent urban sprawl and this communities being swallowed up and their identity being lost, so removal of the local plan green belt it not consistent with the NPPF policy. Paragraph 143 of NPPF states that ©inappropriate development, is by definition harmful to the green belt and should be not approved except in very special circumstances©. and the removal of this land to build homes does not meet ©special circumstances© as there are brown field sites within chesham itself which have been explored by a non-profit making organisation called Chesham Rennaisance and the creation of a ©Chesham Masterplan©, which complies under NPPF point 13 protecting green belt land, paragraph 134 (e) which says ©to assist in urban regeneration by encouraging the recycling of derelict and other urban land© We support the brown not green organisation and its aim to have the land NE of Chesham listed as an Asset of Community Value, and we request that representations made by them, in regard to the local plan, is seen to be our comments as well. In conclusion, the plan for the removal of land in NE Chesham from the green belt and to be developed for housing is not ethical, ecological sustainable or sound and as such should not be approved. The green belt is there to safe guard the countryside for future generations. If there were no homes for sale within Chesham, it could be considered, but at the present time there is almost 200 properties for sale, the land is unsustainable location for development, due to poor infrastructure in form of highways and local transport. Its a place used by the local community for decades to improve health and well being and as it supports the aims of the green belt and there appears to be no exceptional circumstances that are explained by the NPPF, then there is no justification for it to be removed from the green belt. Policy 3a - Please specify as precisely and succinctly as
9090 possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1219426 Full Name D Reid ID 1073 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as
9091 precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I was born in Lye Green 92 years ago and would like to comment on the councils plan to release land in Lye not believe this policy to be Green from the protection of the green belt in order to build 500 houses, a shop and a travellers© site with positively prepared please 15 pitches. explain why As far as I remember, there were only a few cottages, three farms and the Black Cat Public house in Lycrome road. Since then, numerous houses have been built in the area, changing the landscape considerably. The Road is very narrow between the white house and a row of cottages where I was born. Even 2 cars have to give way to each other at this point in order to pass. Any more traffic on this road, and indeed, Lye Green Road would cause congestion, and also, neither road has a continuous footpath for pedestrians who might need to walk to Chesham. About five or six years ago the School and latterly the college at the end of Lycrome road was demolished to make way for a mixed development of 54 homes. If 500 more houses were built in Lye Gree, where would the children go to school? Schools, Doctor©s Surgeries and Hospitals apparently cannot cope with an already overloaded amount of people. Sewerage and other amenities are not in place to cope and the traffic all trying to enter Chesham will be horrendous. My memories of Lye Green are playing in the fields, at the insistence of the local farmer, freedom to walk for miles along footpaths, and even a football meadow opposite the Green at Lye Green. There is an abundance of wildlife in the area which would lose it©s natural habitat. I should like to support the Brown not Green campaign, or indeed the Chesham master plan in favour of releasing valuable green belt land at Lye Green
9092 PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not According to Wikipedia, the Green Belt was proposed by the Greater London Regional Planning Committee believe this policy in in 1935 "to provide a reserve supply of public open spaces and of recreational areas and to establish a green consistent with the National belt, or girdle of open space". The green belt has been fiercely protected by the council in this area and that Planning Policy Framework last house that I know of to be built near where I live on green belt land was in 1947. Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1219466 Full Name Mrs Ann Flower ID 3599 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant.
9093 Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as
9094 precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do There is a reason for Green Belt. not believe this policy to be Trees are vital to the wellbeing of palinating insects. positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1219468 Full Name Mrs A Poyser ID 3737 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee:
9095 Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider
9096 the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I write to add my opposition to the above scheme, which seems to me to be very detrimental to the town of not believe this policy to be Chesham and to the people living there. positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not We do not need the increased carbon footprint that the scheme would bring, think of global warming. believe this policy to be It is certainly not justified to bring "Green Belt Villages Policy" without prior consultation. justified please explain why To give up good quality agricultural land that separates Lye Green from Chesham in favour of a scheme that will only generate more traffic and worsen local air quality seems hardly sensible. What about building on brown field sites? It would seem to be a good idea to exhaust all the possibilities before thinking about destroying the Green belt. What about wildlife habitats or biodiversity? The greenbelt principle was set up to ensure that people and wildlife could live safely. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not This plan does not seem legally compliant or sound. Check again with policy SP13P2, initial policy SP BP1 believe this policy in or the Chesham Renaissance CIC Master plan. This plan will make living worse for the people living in consistent with the National Chesham. It does not seem to be a sensible idea. Please re-consider.
9097 Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1219471 Full Name Mrs E Wootton ID 3748 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you
9098 consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The proposal to build 500 houses north east of Chesham on green belt land will put more pressure on local not believe this policy to be services - i.e. schools, transport services, sewerage, car parking in the town. As a follow on from this the positively prepared please idea of building on Star Yard with more shops seems crazy when we have several empty shops in the town explain why and if you make parking more difficult people wont© want to come to the town anyway. Building should be done primarily on brownfield sites which are near the town centre. I object to the building on Green Belt because of one plan on green belt as agreed it will go on ad infintium. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
9099 Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1219473 Full Name Diane Shorey ID 3681 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be
9100 as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public?
9101 Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do To use greenfield for building instead of brown sites when agriculture is more likely to be needed. not believe this policy to be At the moment infrastructure such as medical centres, schools and sewage and water systems do not have positively prepared please the capacity for 500 more homes. We have no fire brigade, no hospital and the police station rarely opens. explain why The town being in the valley does not help when traffic continually travels through Chesham to get somewhere else especially large vehicles and the situation is getting worse.We are between the m1 and m25 so we are vunerbale to traffic and pollution. Asheridge and Springfield are brown sites but building means more traffic. if rates were lowered banks and empty shops would be enough. PP Mods - Please specify as A multistory car park near the station could help with this problem. precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1219477 Full Name Mrs E A Cooke ID 3479 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received:
9102 Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance
9103 with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Over the last few years proposals have been put forward by the Local Authority to release the Green Belt not believe this policy to be on the land to the North East of Chesham at Lye Green for development of many hundreds of houses. positively prepared please I do not believe that the release of this land to meet housing targets is justified from the evidence submitted. explain why This area is almost 2.5km away from both the town centre and the train station and would necessitate the use of more vehicles to access these amenities, thus increasing traffic and generating even more congestion on already congested roads. Traffic evidence in Chesham shows that most of the road junctions and infrastructure already operating above capacity and any significant highways improvement cannot be accommodated as lack of space and topography would not allow for this. It also raises major concerns regarding increased air pollution. The designated Air Quality Management Area along Berkhamstead Road is recording air quality that is considerably worse than EU safe levels ± and more housing generating more traffic on this Green Belt site will only make it worse. This cannot be sustainable nor justified, or indeed in accordance with Government Policy, especially as the Local Plane predicts an increased carbon footprint of 21%! PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not In addition to the sustainability of this site, the Local Plan also casts doubt regarding the deliverability of land believe this policy in at Lye Green, possibly making it ineffective. The main landowner has asserted publicly, and in writing to the consistent with the National editor of Young Chesham Magazine, that he is not prepared to release all of the land in his ownership for development. This land has been habitually used by many hundreds of people throughout the 43 years I
9104 Planning Policy Framework have lived there, providing the local community with an accessible area for various informal outdoor recreational Feb 2019 please explain why activities. Many private residences have rear garden gates onto the fields at Lye Green and easements and prescriptive rights that may render the land difficult to develop and make it undeliverable in planning terms. The Brown Not Green community are already seeking to apply for the area as a potential Asset of Community Value and if this designation were to be confirmed, it would afford a community group the right to bid for the land. At the same time the Local Plan is also proposing a considerable increase in retail development in the town (with no prior consultation) part of which would be built on current car parking areas, including the Chesham Tube Station car park, making the sustainability of the Lye Green site both inconsistent and unsound. The Local Plan does not appear to address the added strain that the demands of so many houses to be built on the Lye Green site would put on infrastructure. The drainage and sewerage systems in the area are already almost at full capacity. The adequacy of schools, doctor's surgeries, dentist's surgeries, hospital facilities and local transport are also put into question. Residents of Chesham are already having difficulty in getting children into the schools we currently have. Doctors are already struggling to cope with the numbers of patients they have to deal with and patient are having difficulty getting appointments with doctors. We no longer have any local hospitals that cover accident and emergency and the local train service is already running at full capacity with parking at a premium. In fact nothing appears to have been specified or addressed regarding the `masterplan' for this site. I believe all of this points towards a flawed methodology of Green Belt selection used by the Local Authority which is not justified, effective or consistent with national policy. It is my understanding that the primary purpose of Green Belt is to preserve the openness of an area and prevent urban sprawl, and it is evident that the Lye Green site has performed this purpose for decades. It maintains a distinct separation between the settlements of Chesham and Lye Green, as well as other nearby communities at Orchard Leigh, Botley, Whelpley Hill and Ashley Green, providing good quality agricultural land and an environment for many species of wildlife ± all of which will be lost. Again, there was no prior consultation at all on these' Green Belt Policies'. A further aim of Green Belt is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. A community led not-for-profit organisation called Chesham Renaissance CIC has been striving to create a master plan to provide genuinely affordable homes in sustainable locations near the town centre which would not only meet the housing needs but also regenerate some of the more deprived wards within Chesham. The Local Authority's proposals appear to be inconsistent with this local initiative and with national guidance. I am fully aware of the need to provide additional housing in the County but this could be achieved using brownfield sites around the area and I can see no justification to remove the Green Belt when no `exceptional circumstances' have been proved contrary to national guidance. I feel the land North East of Chesham is an unsustainable location for development, which has been habitually used by the community to improve health & wellbeing for decades and the land performs well against Green Belt aims and objectives. Exceptional Circumstances for reviewing Green Belt boundaries at this location either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by Government policy and therefore this plan is unsound. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1219479 Full Name Sue Robinson ID 1290 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID
9105 Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination
9106 Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I am writing to object to the plans to build 500-900 homes off Lye Green Road. I am amazed that the Council not believe this policy to be rushed these plans through recently, ignoring all objections to overturning Green Belt. Knowing that by 2020 positively prepared please the District council will be under Bucks County Council making this issue null & void. Because other brownfield explain why sites will become available under CC umbrella. Were the Councillors protecting their own jobs? There is a very good alternative in the Chesham Master Plan. This has been ignored. Also, what has been ignored is that there is no infrastructure to this proposal. Road/healthcare/schools/rail transport/water supplies I am also amazed at the Chesham retail planning opportunities, using space where carparks are or doctors surgeries. Both of which will be needed with the extra influx of people to the town. Ive included transport in my list, the extra vehicles on the roads. Chesham already has very bad pollution & traffic jams. Let alone when HS2 starts being built locally. The damage to that alone to green belt is appalling. Also Chesham station carpark is under risk. Again, with more people living near, how will the overcrowded trains cope & where will they park. From Lye Green - cars are the only way of getting to the station. Chesham already has problems with water supplies, even with the new houses in Asheridge Industrial estate, the supplies cannot cope. We hear this week that Asheridge road will be closed for a month to work on sewerage/drainage. Regardless of Asheridge villagers having to make a 5 mile detour. There are also plans for 99 homes & 240 odd in the same area. The system cannot cope now. Damage to our rare chalk streams are another issue. This needs protecting too. The plans include 15 Gypsy pitches, no doubt next to the affordable houses. I am sure that will be popular. Having had problems with Gypsies in Asheridge in the past. I sympathise with any new residents who will be their neighbours. The district councillors say this will be their final legacy in post or ©least worst option©. What a very sad statement to make & leave residents of Chesham dealing with the aftermath. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not Local residents use the green belt Lye green for dog walking on the many footpaths & enjoy the wildlife along believe this policy in the fields. Gates from the houses back onto the land to gain access & have done so for many years. In May
9107 consistent with the National the council overturned other green belt site in S bucks, much to our dismay. Once green belt has gone, its Planning Policy Framework gone forever. Brown field sites are much preferred. Will we still be AONB? Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1219423 Full Name Derek Roberts ID 1075 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness?
9108 Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I have been a resident here for some 16 years. I have used the woods and surrounding fields adjacent to not believe this policy to be my property for exercise, relaxation and appreciation of the flora and fauna for all of this time as have my positively prepared please friends and family. explain why I know that all the other residents in this road have gates into the woodland and also make good use of the natural facilities. Groups of youngsters also regularly use this area whilst orienteering in the Duke of Edinburgh challenges. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
9109 Policy 1 - If you do not Now it would seem that you seek to destroy all of this by changing green belt to brown in order to build a believe this policy to be housing estate. Such a construction would, by your own calculations, increase the carbon footprint by 20% justified please explain why of more. I understand that Chesha, town has already exceeded the recognised safe pollution levels set by the EU. The town often jams totally during rush hour. how can the removal of arable land and the surrounding green margins of large mature trees and hedgerows help in reducing carbon footprint and therefore aiding our climate. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not The proposed Local Plan does not stipulate how lawful access can be gained, there is no infrastructure such believe this policy to be as water, gas, electric or even sewerage as there is none on site. The building of some 500 dwellings must effective please explain why. impact on natural drainage.The proposed site is not near the town so an increase in traffic once road access is constructed is inevitable.The current sewage in Chesham has been failing and discharging into the Chess. The local water authority is now struggling to guarantee uninterrupted supply, particularly as Thames water also draws some from the aquifers. I understand that a community scheme called Chesham Renaissance CIC Masterplan which to me seemed a sound argument for using existing brownfield sites has been totally ignored. I don©t believe that this local plan presented by the council is sustainable or meets any government policies. I have taken numerous photographs of the regularly used walkways surrounding the fields and within the woodland area which may be use to the inspectorate. I am forwarding a copy of this letter to the Chairman of Brown not Green. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1219425 Full Name Mrs Clare Tarling ID 1295 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details
9110 Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has
9111 met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do We are writing to you to voice our concerns over a proposed by Chiltern and South Bucks local planning not believe this policy to be department, with regard to the removal of land from the green belt around 21 sites in Buckinghamshire and positively prepared please with special regard to land in the North East of Chesham, bordering the hamlet of Lye Green, and we question explain why as to whether this is a sound policy for the future of Chesham. The topography of Chesham is of a town built int he river valley surrounded by steep hills of the Chilterns, and as such all major roads to Chesham lead down these steep hills to one main thorough fare, carrying all the traffic through the town. The proposed land to be removed from the Green Belt, and to be used as a housing development is situated at the top of one of these hills leading into the town and is about 2km from the nearest tube station. The infrastructure of these roads are not able to meet the demands of currant traffic, so any increase in traffic cause by a development on the ouskirts of the town will have major repercussions on traffic flow in the town. Being in a narrow valley thee is little room to widen and improve the highway infrastructure and as such the proposed development is unsustainable. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not As I have used the land to exercise my dogs for over 25 years, I have noticed how heavy rain affects this believe this policy to be land. Periods of long and heavy rain leads to the area becoming very waterlogged and can result in justified please explain why ©temporary©ponds due to poor drainage. In heavy downpours or thunderstorms, flash floods occur, with water flowing down the fields and travelling down to Brushwood road, posing a flood risk to houses on the lower side of the road, before it continues on its way to The Spinney where the properties at the end of that road become flooded.With the removal of land to hold the water, there will be an increase in neighbouring properties of flooding, which needs to be addressed before a development takes place, again not a sustainable proposal. The land is also an important corridor for wildlife, woodpeckers have been seen, along with bats and barn owls use the woods bordering the land.The grassland itself provides food and shelter for the small mammals and invertebrates that these animals feed on. As well as some ancient Oak trees which grow around the land. This plan will have severe ecological effects on the area. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not With an increase in traffic congestion, there will be an increase in air pollution and there are areas of the believe this policy in town which have already been recognized as having poor air quality, and the government policy is to reduce consistent with the National air pollution not increase it! Planning Policy Framework The land in question is an area criss-crossed by several public footpaths and is used by many different Feb 2019 please explain why groups of people. Local residents, who live close to this area use the fields for exercising their dogs. There are groups of young people who use the area whilst doing their Duke of Edinburgh challenges, along with runner and ramblers. This land is a valuable asset for the local community and withdrawal of the land from
9112 the Green Belt would undermine the objective of the Localism Act 2011 and so therefore is an unsound aspect to the plan. I have been looking into the aims of the green belt policy, why and when it was first created. Its primary aim was to prevent urban sprawl and to preserve the openness of areas around towns and villages. By allowing development of the land, the hamlet of Lye Green, with it unique character will be compromised. This is also references to in NPPF paragraph 133, to prevent urban sprawl and this communities being swallowed up and their identity being lost, so removal of the local plan green belt it not consistent with the NPPF policy. Paragraph 143 of NPPF states that ©inappropriate development, is by definition harmful to the green belt and should be not approved except in very special circumstances©. and the removal of this land to build homes does not meet ©special circumstances© as there are brown field sites within chesham itself which have been explored by a non-profit making organisation called Chesham Rennaisance and the creation of a ©Chesham Masterplan©, which complies under NPPF point 13 protecting green belt land, paragraph 134 (e) which says ©to assist in urban regeneration by encouraging the recycling of derelict and other urban land© We support the brown not green organisation and its aim to have the land NE of Chesham listed as an Asset of Community Value, and we request that representations made by them, in regard to the local plan, is seen to be our comments as well. In conclusion, the plan for the removal of land in NE Chesham from the green belt and to be developed for housing is not ethical, ecological sustainable or sound and as such should not be approved. The green belt is there to safe guard the countryside for future generations. If there were no homes for sale within Chesham, it could be considered, but at the present time there is almost 200 properties for sale, the land is unsustainable location for development, due to poor infrastructure in form of highways and local transport. Its a place used by the local community for decades to improve health and well being and as it supports the aims of the green belt and there appears to be no exceptional circumstances that are explained by the NPPF, then there is no justification for it to be removed from the green belt. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1219456 Full Name Mr Robert Clow ID 1291 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be
9113 as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public?
9114 Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not Below is para. 84 of National Planning policy framework: believe this policy in 84. Planning policies and decision should recognise that sites to meet local business and community needs consistent with the National in rural areas may have to be found adjacent or beyond existing settlements, and in locations that are not Planning Policy Framework well served by public transport. In these circumstances it will be important to ensure that development is Feb 2019 please explain why sensitive to its surroundings, does not have an unacceptable impact on local roads and exploits any opportunities to make a location more sustainable (for example by improving the scope for access on foot, by cycling or by public transport). The use of previously developed land, and sites that are physically well-related to existing settlements, should be encouraged where suitable opportunities exist. The proposed development does not meet these criteria. There are no local business or community needs which need to be met.The proposed development is not sensitive to its surroundings and the impact on local roads (narrow and for the most part without foot-paths) which are already congested in the rush hours would be severe. Housing needs would be better met by utilising brownfield sights in and around chesham, suggestions for which i understand have been made to the council. There was a recent development by Cala homes at the end of Lycrome Road which I think added about 30 houses to the road and which is the type of development more sympathetic to the area. Chesham is not an ideal commuter centre for people working in London, which i suspect many working residents would have to resort to. Trains are infrequent, the station car park is already fully utilised and i understand there are plans to turn it into a retail centre. where train users would then park i have no idea. The station is not within walking distance and in any event there is a steep hill between the proposed site and the town. The plan in contrary to para. 134 of the National Planning Policy Framework Policy 3a - Please specify as If houses must be built to the North East of Chesham could not all the fields adjacent to Lycrome Road be precisely and succinctly as left in agricultural use thereby retaining the charecter of Lye Green as a separate village. possible how you would If some development to the NE of Chesham cannot be avoided is it not possible to scale it back to the area modify this policy to improve adjacent to the town based on a small number or roads running off Lye Green Road and to make up the its alignment to this test of numbers by developing brownfield sites in and around the town of chesham. There are already 6 small soundness. residential roads running off Lycrome Road which i would have thought was enough development for what is essentially a country road. If there are sufficient brownfield sites then cannot there be a number of smaller developments spread around other areas surrounding Chesham so that the character of the area is not visibly altered to any large degree. Policy-level file upload - Please attach any supporting evidence
Person ID 1219461
9115 Full Name Mrs Catherine Whittall ID 1304 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness?
9116 Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The development of such green belt sites involving many hundreds of homes will generate increased traffic not believe this policy to be and although some highway improvements are suggested they are insufficient. For example, in Chesham positively prepared please the evidence shows that most of the road junctions and infrastructure is already operating above capacity. explain why Air pollution is already a big concern in Chesham due to the already poor air quality along Berkhamstead Road where there is a designated Air Quality Management Area that already is recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town on the green belt will generate more traffic which in turn will make the air quality even worse. Insofar as this related to the green belt site at lye green NE of chesham, this cannot be sustainable nor justified nor is in accordance with government policy.There is a school on Berkhamstead Road and those working and attending the school will be adversely effected by the increased traffic due to construct the houses and afterwards by the extra cards of new residents. Chesham cannot accommodate any significant highways improvements due to the already limited verges and space beside the highway and combined with the topography of the town means that there will be increased traffic congestion with further worsening air quality. The Green belt site NE of Chesham is not a sustainable location. It is over 2km away from the train station and slightly further still from the town centre but anyone who cares to walk or cycle the distance also has to negotiate a very steep hill in either White hill or Nashleigh hill. I have been trying to find a route to cycle to Amersham town centre on an electric bike and have been unable to find a safe route that avoids dangerous roads. It is unrealistic to think that residents will bike unless the entire route to their desination is safe for cyclists, cycling to Chesham town centre or to amersham is currently not possible safely. Upgrading a couple of public footpaths within the site into bridleways o facilitate cycling will not be sufficient. Adding a bus stop will not address the geography or topography of the area especially if the promised enhanced bus service (which is already infrequent) either does not materialise or if it subsequently fails to be maintained after a few years, it is also expensive option to take a bus if you already have a car so people won©t do this as an alternative to driving. There will be significantly more traffic on the roads. Further doubt is cast upon the soundness of this plan by virtue of there being conflicting policies within it. The council seems to think that the green belt site NE of chesham is sustainable and provides easy access to public transport including the tube station yet the same plan promotes considerable increase in retail
9117 development in the town (local draft plan policy SP EP3), part of which would be built on the very car park that serves the Chesham tube station. This is inconsistent and unsound. Where are people then going to park, the side roads are already congested with cars? PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not For this plan to be sound if must also be effective. unfortunately, further review of the proposal is not effective believe this policy to be as there are serious questions about the deliver ability of this land. The main landowner is a farmer who has effective please explain why. asserted publicly and in a letter to the editor of your chesham magazine that he is not prepared to release all of the land in his ownership for development. The land is also potentially an Asset of Community Value and upon confirmation of this designation it would afford a community group the right to bid for the land. the community group (Brown not Green) have stated their intention to preserve the land igven that hundreds of local people have habitually used the fields at Lye Green as of right for various informal outdoor recreational purposes. These uses themselves may mean that many local individuals may have acquired easements over and across the land though prescription (20 years uninterrupted use) not least of whom would be the many private residences bordering the fields that have rear garden gates onto the fields at Lye Green.These easements and prescriptive rights may render the land very difficult to develop and make it undeliverable in planning terms. It is perverse that the local authority would promote such a valued community asset for development and undermines the objectives of the Localism act 2011. As such this aspect of the plan is unsound. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I wish to comment on the Draft Local Plan which I believe is fundamentally flawed and should be reconsidered. believe this policy in The proposals to release green belt to meet housing targets are not justified from the evidence submitted consistent with the National Planning Policy Framework The councils stated that releasing some green belt is necessary as part of an overall three part strategy Feb 2019 please explain why involving: 1) Focus on built-up areas to build dwellings on previously developed land 2) an exported proportion of housing need to go to the Ayelsbury District 3) through green belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the green belt. I question whether all the brownfield land opportunities have been identified and with an aging population believe that the council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than green belt sites and in particularly the green belt site NE of Chesham at Lye Green. The foregoing also points to flawed methodology of Green belt site selection used by the local authority which is neither effective, justified no consistent with national policy and as such is unsound. Specifically, the selection of the land NE of Chesham at Lye Green for removal from Green belt designation is inconsistent with national planning policy framework (NPPF) Paragraph 136 of the latest NPPF asserts that green belt boundaries should only be modified in ©exceptional circumstances©.The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances. The council engaged third party consultants to undertake the part 1 green belt assessment and they identified numerous sites for ©further consideration© where exceptional circumstances might exist but expressly reccommended further review of their assessment of each site against the 5 purposes of land being in green belt of all these sites. Unlike neighbouring local authorities, the part 2 green belt assessments was not undertaken by third party consultants but by the local authority itself who notably then did not undertake all the recommended reviews of each site including the land NE of Chesham at Lye Green. Accordingly, this oversight in the part 2 green belt assessment placed premature focus and fixation on releasing land at Lye Green NE of Cehsham from Green belt designation. The subsequent identification of the Chesham site for release is therefore unjustified. The primary aim of green belt land (as recited in NPPF 133) is to prevent urban sprawl and to preserve the openness of the area. The Lye Green site self evidently performs this function well and has done so for decades. Another aim of green belt land in NPPF paragraph 134 is to prevent neighbouring towns and settlements from merging into one another.The green belt land NE of chesham performs exceptionally well in maintaining a distinct separate between settlements of Chesham and Lye Green as well as helping to maintain separate
9118 identities of other nearby communities at Orchard Leigh, Botley, Whelpley Hill and Ashley Green. It is perverse and inconsistent with national guidance to allocate this land for removal from green belt in light of these facts especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if earmarked for development. A further aim of green belt designation as stated in NPPF at para 134 (e) is to assist in urban regeneration by encouragin the recycling of derelict and other urban land. By allocating green belt land, undermines aim within chesham. A community lead not-for-profit organisation called Chesham Renaissance CIC has been striving to create a chesham masterplan that would not only provide many genuinly affordable homes in more sustainable locations nearer the town centre but which would also regenerate some of the more deprived wards within chesham.The local authority proposals are inconsistent with this local initiative and are therefore also inconsistent with national guidance and consequently unsound. The council have asserted that government planning policy requires local councils to review green belt boundaries when considering how to accommodate the development needed in their areas. Just because the council may be required to look does not mean the council should review green belt boundaries which as previously stated should only be modified in ©exceptional circumstances©. National planning policy framework (NPPF) as revised only last year, states in para 11(b)i, directs ©plan makers© to create policies that are required in local plans for gousing and other uses unless framework policies (expressly including green belt) ©provides a strong reason for restricting the overall scale type or distribution of development in the plan area© Accordingly, I submit that given all of the above the land being proposed for release from green belt designation around Chesham is unjustified and contrary to national guidance. I am supportive of the Brown not Green organisations initiative to have the land listed as an Asset of Community Value and i feel they speak for me in respect of their objections to the draft local plan. Accordingly, I request that any representations made by them at any future examination in public regarding the soundness of this local plan be considered as an extension of my own comments herein. I feel the land NE of chesham is unsustainable location for development, that has been habitually used by the community for improved health & wellbeing for decades and the land performs well against Green belt aims and objectives. Exceptional circumstances for reviewing the green belt boundaries at this location either do not exist or are insufficient to warrant the removal of this land from green belt designation as required by govt policy and therefore the plan is unsound. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1219802 Full Name Mr Greg Mitchell ID 1399 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you
9119 consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible.
9120 Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do It is a shame that the outer villages of Chesham are going to have housing etc hoisted upon them as there not believe this policy to be is plenty of brown field sites in Chesham which are better suited for development with existing infrastructure positively prepared please already in place. The plan offered by other local plans such as the Chesham Renaissance CIC Masterplan explain why offer a much more radical yet ultimately sustainable long term solution to our town, providing for future investment and growth. PP Mods - Please specify as Please reconsider the breaking of green belt land around Chesham and look again more seriously at precisely and succinctly as developing brown field sites in the town. possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1219483 Full Name Adrienne Capron ID 1257 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee:
9121 Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider
9122 the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I would like to express my concerns with regard to the local plan for chesham and surrounding area. not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not I believe there should be a commitment to retain the green belt designated zones and our towns and villages believe this policy to be and prevent urban sprawl. Green belt land has always been tightly controlled and protected and therefore justified please explain why the local plan to build on green belt surely cannot be justified. Once we start eating into green belt land a precedent will have been set and infilling of green sites will continue to decimate our beautiful surrounding countryside. To take away this cherished asset is taking away something of immense value from future generations not giving them the opportunity to love it as we do. Green belt land acts as the green lungs of our urban areas and something i feel strongly should be protected, it allows us to connect with nature and improve our wellbeing the impact of losing this asset would be distinct and profound. Policy 2a - Please specify as In order to protect the pleasure and benefit we all derive from our green belt spaces surely the brown-field precisely and succinctly as sites should be prioritized for building new homes. Re purposing and developing brown field land to build possible how you would new housing is as important as recycling our household waste and valued countryside will not be lost, to do modify this policy to improve otherwise while brown field sites exists is to damage our beautiful and unique countryside. its alignment to this test of soundness. Policy 2 - If you do not I acknowledge the need for more housing, all available evidence support the claim that young people are believe this policy to be increasingly less likely to own their own home. The gap in affordability has grown over the years leading to effective please explain why. young local first time buyers being squeezed out of the market. Perhaps higher density housing aimed at the first time buyer on brown-field sites might help this situation. Affordability is a big factor so one hopes this is taken into account when planning permission is granted to any prospective developers. Considetaion should also be given to the proximity to services and employment. Accessing school places and medical services, does planning take into account the extra service provision needed to cope with the extra demand. There will be far more car journeys taken on our roads with increased traffic congestion and with it I fear the danger of losing our small town atmosphere. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
9123 Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1219896 Full Name Mr Robert Land ID 1520 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness?
9124 Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I would like the planning department to consider that unless they actually live in the proposed development not believe this policy to be area, then they are doing a NIMBY positively prepared please Green Belt areas were established to protect, not just for the present population, but the future generations explain why to have and enjoy the wonderful country side of rolling fields and a healthy atmosphere for youngsters to grow. Once the Green Belt has been destroyed, it may never be replaced. The proposed plan does not show the cost to the environment in carbon increase etc. It does not explain how the necessary services have been incorporated other than overloading the existing facilities of schooling and Doctors. The roads in this area are narrow, and traffic is increasing not just in numbers, but speeding beyond the regulated speed limits.
9125 I support the Brown not Green campaign and the Chesham Masterplan alternative, which will be more readily accepted by the local residents. Is it possible, that the mix of houses will include smaller single accommodation rather than multiple bedrooms which are at a price range beyond the younger couples of today to afford for their first time purchase. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5492675 Please attach any supporting evidence
Person ID 1219853 Full Name Jayne Dobbie ID 1442 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details
9126 Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has
9127 met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The proposals to release green belt land to meet housing targets (Lye Green) are not justified from the not believe this policy to be evidence submitted by the councils. positively prepared please It seems it is felt it is necessary to release green belt land however development of housing should be nearer explain why the town centre or on brownfield sites where infrastructure is already in place. Environmental issues are of paramount importance. Building hundreds of new homes at Lye Green will not only increase traffic but will add to the poor air quality along Berkhamsted Road. This cannot be sustainable or justified, it is not in accordance with government policy. The proposed development is over 2 km from Chesham station and town. The public bus service is already infrequent and when public spending is cut, the urban routes are always the first to be affected. The farmer who owns the land at Lye Green has made It clear he isn©t prepared to sell for housing development. This wildlife would also be threatened. It is inconsistent with national guidance that this land should be removed from the green belt as it is not only good agricultural land but it separates, thus preventing the merger, of the local communities, which is one aim of the green belt. I feel the land at Lye Green is not sustainable for development. Exceptional circumstances for reviewing green belt boundaries are insufficient and the plan is unsound. PP Mods - Please specify as Please see previous comments precisely and succinctly as All alternative options should be considered regarding brownfield sites and all options from the Chesham possible how you would Masterplan. modify this policy to improve its alignment to this test of Any other options should be considered only when all other options have been exhausted and proposals for soundness. developing the land at Lye Green should be removed. I support the BNG organisation©s initiative to have the land listed as an Asset of Community Value and I feel they speak for me in respect of their objections to the dealt Local Plan. I therefore request that any representations made by them at any future examination in public regarding the soundness of this Local Plan can be considered as an extension of my own comments. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not The Local Plan is looking for changes in green belt boundaries and removing areas within the districts. believe this policy in However I don©t believe all other options have been explored. I feel this is not justified or in accordance with consistent with the National the national policy and therefore not legally compliant. Planning Policy Framework The aim of the government is to have net zero carbon emissions by 2050, however the plan area is forecast Feb 2019 please explain why to see carbon emissions increase by over 20%. Therefore this too is not legally compliant with government policy. Policy 3a - Please specify as There are brownfield areas such as suggested by the Chesham Masterplan which should be explored. precisely and succinctly as
9128 possible how you would A more detailed appraisal of brownfield must be undertaken. modify this policy to improve Green belt reviews should only be considered after all alternatives have been eliminated. its alignment to this test of soundness. Policy-level file upload - 5492654 Please attach any supporting evidence
Person ID 1219909 Full Name Colin Parker ID 1547 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as
9129 precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do We want to protest in the strongest possible terms about the Draft Local Plan as proposed by Chiltern District not believe this policy to be Council. positively prepared please It is proposed to build at Lye Green, 500 dwellings, a site for 15 traveller families, a 5000 sq. ft. shop and a explain why Community Hub. This is good agricultural land and is in the Green Belt. It goes against the governments own guidance which instructs Plan Makers to provide for housing and other uses UNLESS Green Belt policies provide a reason not to. The Local Authority is going against this guidance. They have previously stated that they want to remove this land from the Green Belt in order to better protect it. How is this protecting it if it is proposed to build hundreds of houses on it? If this plan is approved it will add considerably to the traffic congestion in Chesham which is already heavily congested. It will add to air pollution which in places is already at unacceptable levels. It will further increase the pressure on doctor's surgeries and schools. It will add to the pressure on our fragile water supply and also on drainage.There are no exceptional circumstances that exist for removing Lye Green from the Green Belt or the numerous other local villages as proposed by this plan. Indeed, the courts have held that housing needs alone are not exceptional circumstances. It is therefore not legally compliant or sound. We support the Brown not Green campaign which shows that there are many alternative brownfield sites in Chesham itself which can be recycled for housing. There was no prior consultation on `Green Belt Village Policies' or any consultation to build so many new shops in Chesham, many of them on existing car parks. Where will vehicles be parked if these are built on - on roads and pavements? Finally, we do not find it acceptable that this Local Plan predicts an increase of 21% on the carbon footprint
9130 PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1220005 Full Name Judith Hughes ID 1458 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant.
9131 Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as
9132 precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Once building on green belt where will it stop? Once green belt is gone, its gone forever, there is no regaining not believe this policy to be it. Has consideration been given to the increase in the carbon footprint by parents on the outskirts of town positively prepared please driving their children into and from the town because all the schools except for Chesham prep are in town? explain why Courts have held that having needs alone are not "exceptional circumstances" for redefining green belt boundaries in policy SP BP2 which relates to Lye Green and infilling of GB villages or removing them from green belt and policies SP PP1 and DM PP1. Many sites may be nonviable or undeliverable without the appropriate infrastructure necessary to avert adverse impacts on the locality. PP Mods - Please specify as There is land available around Waitrose, churches, industrial sites such as Springfield road. Asheridge road precisely and succinctly as where factories have stood empty for years. possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not Is a local plan with an acknowledged funding gap of £179m - £231m justified effective or even legal? Who believe this policy to be is supposed to pay for this? justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not Would not the spatial policy (SP SP1) for sustainable development by recycling brown field land previously believe this policy to be developed sites be effective or consistent with the plans of other proposals to use Green Belt land at Lye effective please explain why. Green to meet housing needs? PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not Is the plan justified in accordance with NPPF to remove land from Greenbelt for housing especially NE of believe this policy in Chesham at Lye Green? consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1219930 Full Name O Margoninski ID 1328 Order 236 Number 11.3 Title Policy SP BP2 - Chesham
9133 Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible.
9134 Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The proposals to release Green Belt land to meet housing targets (Generally, Spatial Policy SP SP1 & not believe this policy to be specifically Policy SP BP2 at Lye Green NE of Chesham) are not justified from the evidence submitted by positively prepared please the Councils. explain why The Councils have stated that release of some Green Belt is necessary as part of an overall three part strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. I question the soundness of such a general policy and whether all the brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites and in particular the Green Belt site NE of Chesham at Lye Green. The development of such Green Belt sites involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient and unfunded. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham cannot accommodate any significant highways improvements anyway due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion, with further worsening air quality. Air pollution is a particular concern in Chesham due to the already poor air quality along Bekhampstead Road where there is a designated Air Quality Management Area that already is recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will generate more traffic will make the air quality even worse and insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable nor justified nor is it in accordance with Govt policy. The Green Belt site NE of Chesham (SP BP 2) is not a sustainable location. It is over 2Km away from the train station and slightly further still from the town centre but anyone who cares to walk or cycle this distance also has to negotiate a steep hill too. Such an unsustainable location cannot be made sustainable merely by upgrading a couple of public footpaths within the site into bridleways to facilitate cycling. Neither does adding a bus stop address the geography or topography of the area especially if the promised enhanced bus service (which is already infrequent) either does not materialise or if it subsequently fails to be maintained after a few years. It is further not clear how the TFL trains into Chesham, which are already full to capacity at peak hours, can sustain the additional passenger traffic, unless a significant increase in frequency during peak hours is planned. Further doubt is cast upon the ªsoundnessº of this Plan by virtue of there being conflicting policies within it. The Council seem to think that the Green Belt site NE of Chesham is sustainable and provides easy access
9135 to public transport including the tube station yet the same Plan promotes a considerable increase in retail development in the town (local draft plan policy SP EP3) , part of which would be built on the very car park that serves the Chesham tube station. This is inconsistent and unsound. For this Plan to sound it must also be effective. Unfortunately, further review of the proposal to remove land NE of Chesham at Lye Green from Green Belt designation is not effective as there are serious questions about the deliverability of this land. The main landowner is a farmer who has asserted publicly and in a letter to the editor of Your Chesham, that he is not prepared to release all of the land in his ownership for development. The land is also potentially an Asset Of Community Value and upon confirmation of this designation it would afford a community group the right to bid for the land. The community group (Brown Not Green) have stated their intention is to preserve the land given that many hundreds of local people have habitually used the fields at Lye Green as of right for various informal outdoor recreational purposes. These uses themselves may mean that many local individuals may have acquired easements over and across the land through prescription (20 years uninterrupted use) not least of whom would be the many private residences bordering the fields that have rear garden gates onto the fields at Lye Green. These easements and prescriptive rights may render the land very difficult to develop and make i undeliverable in planning terms. This land also provides an important habitat for wildlife that will be threatened by development of this land. It is perverse that the Local Authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Plan is unsound. The foregoing also points to flawed methodology of Green Belt site selection used by the Local Authority, which is neither effective, justified nor consistent with national policy and as such is unsound. Specifically, the selection of the land NE of Chesham at Lye Green (policy SP BP2) for removal from Green Belt designation is inconsistent with National Planning Policy Framework (NPPF). Paragraph 136 of the latest NPPF asserts that Green Belt boundaries should only be modified in ªexceptional circumstancesº. The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances. The Council engaged third party consultants to undertake the Part 1 Green Belt assessment and they identified numerous sites for ªfurther considerationº where exceptional circumstances ªmightº exist but expressly recommended further review of their assessment of each site against the 5 purposes of land being in Green Belt of all these sites. Unlike the neighbouring Local Authorities, the Part 2 Green Belt assessment was not undertaken by third party consultants but by the Local Authority itself who notably then did not undertake all the recommended reviews of each site including the land NE of Chesham at Lye Green (SP BP 2). Accordingly, this oversight in the Part 2 Green Belt assessment placed premature focus and fixation on releasing land at Lye Green NE of Chesham from Green Belt designation. The subsequent identification of the Chesham site for release is therefore unjustified. These comments apply equally to proposals effecting the villages in the Green Belt ± policies SP PP1 & DM PP1) The primary aim of Green Belt land (as recited in NPPF 133) is to prevent urban sprawl and to preserve the openness of the area. The Lye Green site (SP BP2) self-evidently performs this function well and has done so for decades. Another aim of Green Belt land stated in NPPF paragraph 134, is to prevent neighbouring towns and settlements from merging into one another.The Green Belt land NE of Chesham performs exceptionally well in maintaining a distinct separate between settlements of Chesham & Lye Green as well as helping to maintain separate identities of other nearby communities at Orchard Leigh, Botley, Whelpley Hill, Ashley Green. It is perverse and inconsistent with national guidance to allocate this land for removal from Green Belt in light of these facts especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if earmarked for development. A further aim of Green Belt designation stated in the NPPF at paragraph 134 (e) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. By allocating Green Belt land NE of Chesham for development, undermines this aim within Chesham. A community lead not for profit organisation called Chesham Renaissance CIC has been striving to create Chesham Masterplan that would not only provide many genuinely affordable homes in more sustainable locations nearer the town centre, but which would also regenerate some of the more deprived wards within Chesham. The Local Authority's proposals (policy SP EP3) are inconsistent with this local initiative and are therefore also inconsistent with national guidance and are consequently unsound. The Council have asserted that Government planning policy requires local councils to review Green Belt boundaries when considering how to accommodate the development needed in their areas. Just because the Council may be required to look, does not mean the Council should review Green Belt boundaries which as previously stated should only be modified in ªexceptional circumstancesº. National Planning Policy Framework (NPPF) as revised only last year, states in paragraph11 (b) I, directs ªplan makersº to create policies that are required in Local Plans for housing and other uses unless Framework policies (expressly including Green Belt) ªprovides a strong reason for restricting the overall scale type or distribution of development in the plan areaº Accordingly, I submit that given all of the above the land being proposed for release from Green Belt designation around Chesham is unjustified and contrary to national guidance. I am supportive of the Brown Not Green organisation's initiative to have the land listed as an Asset of Community Value and I feel they speak for me in respect of their objections to the draft Local Plan. Accordingly, I request that any representations made by them at any future examination in public regarding the soundness of this Local Plan be considered as an extension of my own comments herein. I feel the land NE of Chesham is an unsustainable location for development, that has been habitually used by the community for improved health & wellbeing for decades and the land performs well against Green Belt aims and objectives. Exceptional circumstances for reviewing Green Belt boundaries at this location,
9136 either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by Govt Policy and therefore the plan is unsound. PP Mods - Please specify as I refer to the comments previously submitted but in summary would advocate that; precisely and succinctly as All other options are fully explored including increased density of development of brownfield land and the possible how you would policies emerging from Chesham Masterplan. modify this policy to improve its alignment to this test of Green Belt land should only be considered when all other options are exhausted and in any event the soundness. proposals for developing land NE of Chesham should be maintained only if sufficient green public transport facilities are included to support it and it can be demonstrated that the new development will have no significant adverse impact on traffic congestion or air quality in Chesham and its vicinity. Policy 1 - If you do not I refer to my comments previously submitted believe this policy to be justified please explain why Policy 2a - Please specify as I refer to my comments previously submitted precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not I refer to my comments previously submitted believe this policy to be effective please explain why. PAa - Please specify as I refer to my comments previously submitted precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I believe the draft Local Plan is NOT legally compliant because it has not demonstrated sufficient regard to believe this policy in the National Policy and guidance issued by the Secretary of State with regard to preservation of green belt consistent with the National areas and the provision of adequate transportation infrastructure. Planning Policy Framework The National Planning Policy Framework (NPPF) together with other guidance issued by the Government Feb 2019 please explain why is also supported by recent ministerial statements that have made it clear that Local Authorities MUST demonstrate they have exhausted all options BEFORE considering revision of Green Belt boundaries. This Local Plan is seeking substantial modifications to Green Belt boundaries including the removal of Green Belt designation of 13 areas within the Districts as well as modifying the Green Belt status of many local villages. I contend this draft Local Plan has not demonstrated that all other options have been fully explored and as such this Plan is not justified, sound or in accordance with National Policy and accordingly is not legally compliant. Furthermore that Paragraph 11 b) of the NPPF (and the footnotes thereto) require Plan Makers to provide for objectively assessed needs for housing and other uses UNLESS the application of Framework policies (including Green Belt) provide a strong reason for restricting the overall scale, type or distribution of development in the plan area Chiltern District & South Bucks are significantly constrained by development policies such as Green Belt & Areas of Outstanding Natural Beauty (AONB). The Local Plan is therefore inconsistent with National Guidance and as such it is not legally compliant for the Local Authority to claim that housing needs justify a review of these same Green Belt boundaries. It is perverse to claim that the combination of housing need and the presence of significant areas of development constraint policy collectively represent ªexceptional circumstancesº (as required in the NPPF) to justify modification of Green Belt boundaries especially given the NPPF states that one of the key features of Green Belts are their permanence. The Government has also recently confirmed its aim for the UK to have net zero carbon emissions by 2050 and it is noted within the Sustainability Appraisal supporting this Draft Local Plan, that the Plan area is forecast to see carbon emission increase by 21% in the Plan Period. Accordingly, the Plan is inconsistent with Government Policy and therefore not legally compliant. There provisions in the plans for providing adequate, green public transport options for the extensive new developments planned (such as significantly increasing the frequency of TFL trains to Chesham and providing green, frequent and efficient transport options from Chesham train station to the new development on Lye Green, specifically as walking or riding a bike up the steep hill is not a realistic option for most people) There is also a significant infrastructure funding gap acknowledged within the Community Infrastructure Levy evidence that supports this Local Plan, of between £179m & £231m. Given this infrastructure is vital to ensure that development is sustainable (as also required by the NPPF) this further demonstrates the Plan is both unsound and not legally compliant. Policy 3a - Please specify as The Plan needs to be modified by; precisely and succinctly as Extending the transport infrastructure of the plan to clearly explain how transportation will be provided to the possible how you would new developments, and specifically to the one on Lye Green . Possible options may include increase in TFL modify this policy to improve train frequency to Chesham, a funicular, cable car or frequent electric bus service from the train station to its alignment to this test of the new development, or a new branch line from the mainline west coast railway line going through soundness. Berkhamsted. A more detailed appraisal of brownfield land opportunities MUST be undertaken. Some brownfield opportunities have been ignored or missed.
9137 Closer scrutiny of alternative options for housing delivery should be explored (such as Chesham Masterplan by CIC Chesham Renaissance). Green Belt boundary reviews should only be considered AFTER all other reasonable alternatives have been exhausted. Policy-level file upload - Please attach any supporting evidence
Person ID 1219971 Full Name Timandra Slade ID 1556 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or
9138 regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I am writing to oppose the Chiltern and South Bucks Draft local plan for an additional 500 houses in the not believe this policy to be immediate Green Belt area of Chesham on the basis that our local infrastructure cannot cope with the extra positively prepared please demands that will be placed on it. explain why These proposals further reduce the quality of life for those living in Chesham. During the day the centre is one of the most polluted areas I know outside London thanks to buses and cars sitting for long periods of time with idling engines. In 2007 a traffic pollution report highlighted Berkhamsted Road as being a cause for concern by the Chiltern Council. Traffic has steadily increased since then and the roads are struggling. Pollution cannot have eased in the last 12 years. Car parking is at a premium, Shop and office workers as well as commuters park on residential roads forcing home owners to buy parking permits so they can park in the street in which they live, as many of the roads near town are lined with terraced houses with little to no off road parking available. If anyone from the Council had tried to visit the town at midday on 10th July they would have had to cope with long queues at the Waterside junction courtesy of roadworks, then been stuck on St Mary's Lane thanks to a broken down crane prior to being sent on a long diversion round narrow country lanes only wide enough for small cars if they had wanted to visit anyone in Berkeley Avenue, again due to roadworks. If another 500 homes are built, either in the town as per the Chesham CIC Masterplan, or in the Lye Green area as per the Local Plan and it would not just be Berkhamsted Road suffering from heavy pollution but the whole length of the valley. In addition two of the roads that lead from Lye Green to the town centre are steep,
9139 twisty residential roads unsuitable for heavy traffic. I very much doubt the new shop will cater for all their grocery needs. Construction traffic for these homes will place an extra burden on our roads at a time when we have been threatened with construction traffic for HS2. Should a reasonable proportion of these additional 500 new residents wish to work in London somehow space will have to be found on our trains which only have seats for 306 passengers. They may get a seat travelling in in the morning, but it will be standing all the way home ± over an hour's journey for some. Some commuters may walk to the station, but many others will drive which leads to yet more pressure on roads and car parking ± mentioned previously. There will be an increased demand on water supplies. Living on top of a hill it is already impossible to have a steady hot water shower in the morning due to the low water pressure. Sewage has been reported to have been discharged from the sewage works into the River Chess in recent years when holding tanks have reached capacity. It is many years since the River Chess flowed freely from source to beyond the town for more than just a few months. Are there sufficient school places, doctors and dental surgeries for these additional homes? Will there be an increase in policing? In the early hours of the morning Berkhamsted Road and St Mary's Way is used as a racetrack with a post race get together held in Water Meadow carpark.The police can't deal with this ongoing situation; will they have the manpower to cover additional homes? HS2 was meant to alleviate the overcrowding of the south east. Are we to lose habitat for wildlife, potentially damage the source of water for our precious chalk streams, lose farmland, suffer years of construction traffic and STILL have to build large numbers of homes either on the edge of or in an overcrowded space? The Committee on Climate change has said that the UK is not tackling the problem seriously. Building on good quality farm land, overcrowding a valley town, increasing carbon footprint or removing Green Belt land is not the answer. Perhaps we should address a main cause of lack of housing ie the number of empty properties and second homes in this country before building more houses in overcrowded towns and villages such as are found in the Chilterns. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5492678 Please attach any supporting evidence
Person ID 1220098 Full Name Mrs Dorothy Rogers ID 1563 Order 236
9140 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as
9141 precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do 500 extra houses means 1,000 extra cars trying to get through or into Chesham. not believe this policy to be The traffic into Chesham is already bad enough and is only going to get worse with houses being built, let positively prepared please alone the strain on the infrastructure which we feel will be devastating. explain why These planning issues may result in Chesham being spoilt forever. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not We do not find it justified in any way to build on Green Belt land it should be preserved forever. believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in
9142 consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1220125 Full Name Clive and Mary Moody ID 1568 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness?
9143 Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Chesham consists of a green belt which provides recreational areas and defines the division between not believe this policy to be Chesham and other towns such as Berkhampstead and Bovingdon. We believe there is no case to build 500 positively prepared please new houses on Green belt. There must be many remaining Brown sites within Chesham. explain why It is well known that the River Chess has declined dramatically over recent years and yet Infinity Water continue to abstract water from it. We rely on aquifers which must be a worry in the light of climate change. Are there any plans for a reservoir to supplement our needs? Similarly, the sewage system must be nearing its limits. If 500 new houses were to be built some distance from the station, it seems likely that many occupants would wish to use the metropolitan line to work into London.The station car park is full soon after the morning rush. We would be very concerned if Star Yard were to become a retail development as we have enough charity shops, barbershops and eateries already. The proposed 500 new houses would undoubtedly put pressure on school places, particularly at Brushwood.
9144 If the new estate were built, how would occupants gain access? Presumably via new junctions with Lye Green Road and Lycrome Road. Manor Way is no longer a quiet residential road, It is heavily affected by traffic accessing the Hilltop estate, Brushwood school and the spinney as well as being on a bus route. Unless access from Brushwood Road to the new estate was blocked, it is inevitable that Manor Way would be adversely affected. With only one A&E hospital within easy reach, a further 500 houses in Chesham would increase the local population by at least 1500. This is in addition to the increases arising from other housing developments in the area, such as those off Asheridge Road and infilling. Local doctors© surgeries are stretched, resulting in long waiting times. Chesham roads are already heavily used, particularly Broad Street and St Mary©s Way. Much of the traffic may be due to drivers using them as a through route from the M1, A41 and A5 to the M25, M4 and M40. With an ever increasing flow of traffic, every effort should be made to make it widened and safer. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1220082 Full Name David Soulsby ID 1546 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body?
9145 Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act
9146 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The proposed removal form significant areas to the northeast of Chesham from the Green Belt and the not believe this policy to be building development in the Lye Green area. I am concerned about the costing gap, damage to the biodiversity, positively prepared please the loss of an area used for recreational purposes and the increased carbon footprint estimated at 21% or explain why more with no clear indication of its mitigation. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not The absence of more effective alternatives for housing in more sustainable locations on brownfield sites. believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not The legitimacy of removing this area from the Green Belt in accordance with NPPF. believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
9147 Person ID 1220091 Full Name Gillian Soulsby ID 1562 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness?
9148 Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I feel strongly that far from benefiting the town, it will have adverse effects including loss of open space, not believe this policy to be increased air pollution, harm to biodiversity and strain on infrastructure. positively prepared please The development is on a steep site with awkward road links and is too far from the town center to be sensible. explain why Such an increase in housing will have severe increased pressure on public transport, schools and medical services. The council has already acknowledged that drainage and road usage at Berkhampstead is at full capacity. The highways department has stated that the already poor air quality will be worsened by the inevitable increased congestion should the development proceed. There will also be increased pressure on the station and tube services as well as on the roads and station car parks. The land for building is prime agricultural land so productive farmland will be lost, as well as the openness and visual appearance of this part of the Chilterns. As well as the threat to the nature of Lye Green village, other local villages will be affected by the increased traffic, pollution etc. The Countryside is widely used by local walkers, riders and cyclists. While I appreciate the need for housing I do not believe this plan has been sufficiently evaluated from the environmental point of view and to lose Green Belt designation would be to the irreparable detriment of the town and surrounding area. PP Mods - Please specify as There are Brownfield sites in the town that are more advantageous for developing, and better situated to precisely and succinctly as use the town©s amenities. possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why
9149 Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1220142 Full Name Dianne and Stuart Inns ID 1579 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to
9150 make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this
9151 to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do We do not think it has been positively prepared, lets face it Chesham just does not have the infrastructure not believe this policy to be to support this plan, for example recent dramas with sewage leaks into the River Chess and insufficient roads positively prepared please that even now cannot cope with the traffic levels. explain why We do not want to see Chesham and the surrounding villages turned into yet another big urban mess. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1220146 Full Name Ms Natasha Zukas ID 1582 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name
9152 Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination
9153 Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do There is a significant infrastructure funding gap acknowledged within the community infrastructure levy not believe this policy to be evidence that supports this local plan, of between £179m & £231m. Given this infrastructure is vital to ensure positively prepared please that development is sustainable this further demonstrates the plan is both unsound and not legally compliant. explain why The development of such Green Belt sites involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient and unfunded. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham cannot accommodate any significant highways improvements anyway due to the already limited verges and space beside the highway and combined with the topography of the town this means there will be increased traffic congestion, with further worsening air quality. The Green Belt site NE of Chesham (SP BP 2) is not a sustainable location. It is over 2km away from the train station and slightly further still from the town centre but anyone who cares to walk or cycle the distance also has to negotiate a steep hill. Such an unsustainable location cannot be made sustainable merely by upgrading a couple of public footpaths within the site into bridleways to facilitate cycling. Neither does adding a bus stop address the geography or topography of the area especially if the promised enhanced bus service (which is already infrequent) either does not materialise or if it subsequently fails to be maintained after a few years. Further doubt is cast upon the "soundness" of this plan by virtue of there being conflicting policies within it. The council seems to think that the Green Belt site NE of Chesham is sustainable and provides easy access to public transport including the tube station yet the same plan promotes a considerable increase in retail development in the town (local draft plan policy SP EP3), part of which would be built on the very car park that serves the Chesham tube station. This is inconsistent and unsound. The main landowner is a farmer who has asserted publicly in a letter to the editor of your Chesham, that he is not prepared to release all of the land in his ownership for development. The land is also potentially an asset of community value and upon confirmation of this designation it would afford a community group the right to bid for the land. The community group (Brown not Green) have stated their intention is to preserve the land given that many hundreds of local people have habitually used the fields at Lye Green as of right for various informal outdoor recreational purposes. This land also provides an important habitat for wildlife that will be threatened by the development of this land. PP Mods - Please specify as The plan needs to be modified by; Co-operating with other nearby authorities. Not just Aylesbury. It is simply precisely and succinctly as unsatisfactory to assert this cannot be done because they are different functional market areas and therefore possible how you would co-operation is not necessary. Exploring such wider co-operation may result in further housing needs being modify this policy to improve taken elsewhere. its alignment to this test of A more detailed appraisal of brownfield land opportunities must be undertaken. Some Brownfield opportunities soundness. have been ignored or missed. Closer scrutiny of alternative options for housing delivery should be explored (such as Chesham Masterplan and CIC Chesham by Chesham Renaissance). It may be necessary to accept that a lower housing provision figure is appropriate. I would advocate that all other options are fully explored including increased density of development of brownfield land and the policies emerging from Chesham Masterplan. Policy 1 - If you do not Adding more homes on the outside of the town on the Green Belt will make the air quality even worse and believe this policy to be insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustained nor justified please explain why justified nor is it in accordance with govt policy. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
9154 Policy 2 - If you do not For this plan to be sound it must also be effective. Unfortunately, further review of the proposal to remove believe this policy to be land NE of Chesham at Lye Green from Green Belt designation is not effective as there are serious questions effective please explain why. about the deliverability of this land. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not The NPPF has made it clear that Local Authorities must demonstrate they have exhausted all options before believe this policy in considering revision of Green Belt boundaries. This local plan is seeking substantial modifications to Green consistent with the National Belt boundaries including the removal of Green Belt designation of 13 areas within the districts as well as Planning Policy Framework modifying the Green Belt status of many local villages. Feb 2019 please explain why I contend this draft local plan has not demonstrated that all other options have been fully explored and as such this plan is not justified, sound or in accordance with National policy and accordingly is not legally compliant. Furthermore that paragraph 11b) of the NPPF require plan makers to provide for objectively assessed needs for housing and other uses unless the application of framework policies (including Green Belt) provide a strong reason for restricting the overall scale, type or distribution of development in the plan area. Chiltern District and South Bucks are significantly constrained by development policies such as Green Belt and AONB. The local plan is therefore inconsistent with national guidance and as such it is not legally compliant for the local authority to claim that housing needs justify a review of these same Green Belt boundaries. It is perverse to claim that the combination of housing needs and the presence of significant areas of development constraint policy collectively represent "exceptional circumstances" (as required by the NPPF) to justify modification of Green Belt boundaries especially given the NPPF states that one of the key features of Green Belts are their permanence. Policy 3a - Please specify as - precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1220130 Full Name John Epiphaniou ID 1571 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to
9155 relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary
9156 to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The traffic along the Ley Green Road between 08:00 - 09:00 is very congested and air quality is very poor not believe this policy to be - when the children are walking to school in that area - Brushwood and Chesham Grammar. positively prepared please I object to the use of good quality agricultural land that will be needed in the years to come, to feed us all - explain why once it is gone, it is gone for good. I object to the fact that the infrastructure and services are inadequate ie, there is no police station in Chesham and the Fire station has been radically cut back, the nearest hospital is High Wycombe. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1220135 Full Name Mrs Daphne Willcox ID 1574 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received:
9157 Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance
9158 with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Lye Green is not a sustainable location being too far from the town centre with a steep hill to negotiate. not believe this policy to be Many hundreds of proposed homes will generate increased traffic and air pollution, already at alarming levels positively prepared please in the Chesham area. explain why The Green Belt site NE of Chesham is over two kilometers from the underground station and Chesham town centre and is therefore an unsustainable location. The local plan promotes a considerable increase in retail development in the town (draft local plan policy SP EP3 which I also feel is unsound), part of which would be built on the very car park that serves the Chesham underground station, thus undermining the use of public transport and resulting in the greater use of private cars, which, in turn will lead to more traffic congestion. This is inconsistent and unsound. The land NE of Chesham at Lye Green is an unsustainable location for development, that has been habitually used by the community for improved health and well being for decades and that the land performs well against Green Belt aims and objectives. Exceptional circumstances for reviewing Green Belt boundaries at this location either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by government policy and, therefore, the local plan is unsound. PP Mods - Please specify as Green Belt land should not be the first choice for development when other, less damaging options exist precisely and succinctly as nearer the Chesham town centre and underground station. The local plan fails to identify the brownfield possible how you would opportunities. modify this policy to improve A community led, non-profit organisation called Chesham Renaissance has developed the Chesham Master its alignment to this test of Plan that would not only provide many genuinely affordable homes in more sustainable locations nearer the soundness. town centre, but would also regenerate some of the more deprived wards within Chesham. While the local plan promotes a considerable increase in retail development in the town, development alone is not required. The problem is not insufficient retail spaces but a lack of thoughtful redevelopment that promotes and supports existing retail premises. The Local Authority©s proposals are inconsistent with this local initiative and are therefore also inconsistent with national guidance and are consequently unsound. Policy 1 - If you do not The decision to develop Green Belt land (specifically, 13 GB sites in Chiltern and South Bucks) is unjustified, believe this policy to be ineffective and inconsistent with national policy. justified please explain why Lye Green is an unsustainable location, and therefore its release from the Green Belt is unjustified. The council©s proposals are inconsistent with local plan policy DM DP5 relating to "Climate Responsive Development" and policy DM DP9 "Reducing Reliance on Private Cars" along with DM DP15 "Blue Green Infrastructure". The council©s wilful failure to take these into account will only make things worse and cannot be justified under recent national government policy. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
9159 Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not There are insufficient "exceptional circumstances" generally to justify Green Belt release and specifically at believe this policy in Lye Green in this instance. Paragraph 136 of the latest NPPF asserts that Green Belt boundaries should be consistent with the National modified only in "exceptional circumstances". The courts have held that unmet local housing needs of an Planning Policy Framework area are themselves not exceptional circumstances. Feb 2019 please explain why The selection of land at Lye Green as suitable for removal from Green Belt is inconsistent with NPPF not only for the reasons so far stated, but also for the fact that the land supports wildlife and is an important recreational site for nearby communities. A further aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open. Another aim of Green Belt land is to prevent neighboring towns and settlements form merging into one another (stated in NPPF paragraph 134). The preservation of Lye Green as Green Belt land is vital in maintaining a distinct separation from as well as helping to maintain the separate identities of other nearby communities. In view of these facts, it is perverse and inconsistent with national guidance to allocate this land for removal from the Green Belt. A further aim of Green Belt designation (as stated in the NPPF at paragraph 134 (e)) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. Allocating Green Belt land at Lye Green as an area for development completely undermines this government policy by failing to recognize the opportunities that exist within Chesham. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1220192 Full Name Stuart and Mary Mayall ID 1601 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to
9160 relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary
9161 to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Chesham itself has little commercial activity, a dying town centre, poor communications, yet people have to not believe this policy to be pass through to get to other destinations resulting in major congestion (due to poor previous planning) all positively prepared please the way from the bottom of the A416 at the Shell garage right through to Amersham itslelf. Lycrome Road explain why is a rat run both from the A41 and from the Hemel traffic seeking to get to the aforementioned Amersham. So if you add another 1000 cars to the issue and imagine what that will do to the crowded parking areas in Waitrose and Sainsbury©s on Saturday. It will drive more people away from the centre either to Apsley or Tesco©s in Amersham and become utter chaos. White Hill must rank with Gold Hill, Shaftesbury for steepness, very few of the new dwellers will walk down into Chesham to do their shopping. It will become cars or nothing. Irrespective of the rights and wrongs of 15 Gypsy pitches, who is going to pay £400k for a two bedroomed house with them on their doorstep? Move onto water, a massive concern, especially now that drought conditions are more common. So, leading on to 500 houses using a conservative 10 gallons per day equates to 1,825,000 gallons per annum. This may lead to a long term hose pipe ban for the rest of the Chesham residents. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not Alternative ideas? Look to smaller solutions rather than a mass takeover of Green Belt land encompassing believe this policy to be all the villages close by and bring local residents together rather than apart. justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5493133 Please attach any supporting evidence
Person ID 1220163 Full Name John Slatter ID 1593 Order 236 Number 11.3
9162 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible.
9163 Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do To build 500 more homes will put more strain on the infrastructure, schools, water supply etc. Pollution would not believe this policy to be also be a problem from 1000 extra cars. positively prepared please The River Chess is a river which should be protected otherwise we shall lose this unique chalkstream. explain why There are also plans to increase the retail sector by building on the existing car parks But there are already empty shops in the town. PP Mods - Please specify as Before any Green Belt is released all Brown Field sites should be considered for development. precisely and succinctly as The need to keep building near the capital is wrong. There are numerous areas in the country that would possible how you would benefit from regeneration and if people have to relocate too then the benefits could be good for all. modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National
9164 Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1220169 Full Name Unkown Gepard ID 1598 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you
9165 consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The Green Belt Land at Lye Green is particularly attractive being very rural in character, valuable agricultural not believe this policy to be land and the first area of flat land on the NE boundary of the Chilterns. positively prepared please The infrastructure of the proposed development at Lye Green could prove to be a disaster. explain why The main approach from Chesham to the proposed development would be via White Hill and Eskdale Avenue, both very steep with dangerous bends. The proposed development would attract at least 500 cars. The adverse effect on air pollution in the town would be great. The chaos caused to nearby schools e.g Brushwood School by the arrival of so many school age children would be tremendous. PP Mods - Please specify as The local authority have not considered all options prior to revoking Green Belt status.There are many Brown precisely and succinctly as Site areas in the district that could be used for housing without the whole scheme being sited at Lye Green possible how you would in Chesham. modify this policy to improve In addition to Brown Sites in Chesham there are many Brown sites in Amersham that could accommodate its alignment to this test of new housing. soundness.
9166 Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I consider that the local plan is not compliant with national policy. believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1220172 Full Name Mr and Mrs M Lutt ID 1600 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be
9167 as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public?
9168 Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The schools and doctors are full. The traffic at certain times is horrendous. Find somewhere else please it not believe this policy to be is the wrong place and the wrong town. positively prepared please explain why PP Mods - Please specify as Please could you find some Brown land or somewhere else entirely since Chesham does not have the room. precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1220217 Full Name Mr J W Naman ID 1786 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body?
9169 Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act
9170 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Many of the site allocations (such as at Lye Green. Policy SP BP2) are excluded from CIL and developers not believe this policy to be will therefore be required to deliver infrastructure directly or make financial contributions to mitigate positively prepared please development impact. However , these contributions cannot be quantified because much of the costs or explain why related infrastructure is not even specified and is awaiting the preparation if (as yet unpublished) "masterplans" for each site. The fear is that many sites will either be undeliverable /nonviable or worse, delivered without the appropriate infrastructure necessary to avoid adverse impacts on the wider area. A local plan that predicts an increased carbon footprint of +21% is not acceptable. PP Mods - Please specify as The council should be looking at more effective alternatives (ie: higher densities of housing development on precisely and succinctly as Brownfield sites) which are generally closer to the town centre and in more sustainable locations which will possible how you would also rejuvenate Chesham, as advocated by Chesham Renaissance CIC Masterplan. modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not The proposals to release Green Belt land to meet housing targets are not justified from the evidence submitted. believe this policy to be A more detailed appraisal of Brownfield land opportunities must be undertaken. Some Brownfield opportunities justified please explain why have been ignored or missed. Closer examination/review of alternative options of housing delivery should be explored (such as Chesham Masterplan by CIC Chesham Renaissance). Co-operating with other nearby authorities. Not just Aylesbury. It is simply unsatisfactory to assert this cannot be done because they are different functional market areas and therefore co-operation is not necessary. Exploring such wider co-operation may result in further housing needs being taken elsewhere. Green Belt boundary reviews should only be considered after all other reasonable alternatives have been exhausted. It is not justified, effective or even legal to allocate Green Belt land NE of Chesham (Policy SP BP2) for housing that has been used for decades for informal recreation by locals and is potentially to be listed as an asset of community value. The proposed site is almost 2.5km from the town centre and located at the top of a steep hill that will only generate more traffic congestion and worsen local air quality in Chesham. The proposed Green Belt release is not consistent with other local plan policies to protect wildlife habitats or biodiversity or to protect our globally scarce chalk stream rivers. This plan undermines these aims. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
9171 Policy 3 - If you do not The draft local plan, in my opinion is not legally compliant as it does not demonstrate sufficient regard to the believe this policy in National Policy and guidance issued by the secretary of state. consistent with the National The recent ministerial statements that have made it clear that Local Authorities MUST demonstrate they Planning Policy Framework have exhausted all options before considering revision of Green Belt boundaries. Feb 2019 please explain why This draft Local Plan has not demonstrated that all other options have been fully explored and as such this Plan is not justified, sound or in accordance with National Policy and accordingly is not legally compliant. Furthermore that Paragraph 11 b) of the NPPF (and the footnotes thereto) require Plan Makers to provide for objectively assessed needs for housing and other uses UNLESS the application of Framework policies (including Green Belt) provide a strong reason for restricting the overall scale, type or distribution of development in the plan area Chiltern District & South Bucks are significantly constrained by development policies such as Green Belt & Areas of Outstanding Natural Beauty (AONB). NPPF states one of the key features of Green Belts are their permanence, therefore the claim that the combination of housing need and the presence of significant areas of development constraint policy collectively represent "exceptional circumstances" (as required by the NPPF) is wrong to justify modifications of Green Belt boundaries. The Government has also recently confirmed its aim for the UK to have net zero carbon emissions by 2050 and it is noted within the Sustainability Appraisal supporting this Draft Local Plan, that the Plan area is forecast to see carbon emission increase by 21% in the Plan Period. Accordingly, the Plan is inconsistent with Government Policy and therefore not legally compliant. There is a significant infrastructure funding gap acknowledged within the CIL evidence that supports this local plan, of between £179m - £231m.The infrastructure is vital to ensure that the development is sustainable (as also required by the NPPF) therefore this further demonstrates the plan is both unsound and not legally compliant. This plan is not justified or in accordance with the NPPF to remove land from Green Belt for housing (especially policy SP BP2) which relates to the land NE of Chesham at Lye Green. There are not satisfactory "exceptional circumstances" that exist for redefining belt boundaries such as at Lye Green (Policy SP BP2) and/or removing numerous villages from Green Belt or permitting the "infilling of GB villages" as proposed by policies SP PP1 and DM PP1. Baring in mind that the courts have held that housing needs to do not qualify as "exceptional circumstances". There was no prior consultation on "Green Belt Villages policies" (SP PP1 and DM PP1) nor any consultation on proposals to build disproportionately so many new shops in Chesham (mostly on town car parks). Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1220221 Full Name Mavis Turl ID 1829 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant.
9172 Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as
9173 precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The risks entailed in this draft local plan threaten the sustainability which it claims to uphold. not believe this policy to be My particular concerns in regard to the proposed Lye Green site relate to the loss of countryside in order to positively prepared please construct an unspecified number of dwellings, almost 2.5km from the town centre. How can promises about explain why sustainability be assured given existing environmental pressures. Drought conditions are already threatening the water supply due to low levels of groundwater. A combination of rising demand, increasing population and the effects of climate change are contributing to this acute situation. Additional pressure on the drainage systems will also result. The proposed plan will have a negative impact on air quality. It will increase traffic congestion and encourage an outward sprawl of the town to a site presently rated as good agricultural land. Our green areas are vital to protect biodiversity and food security. PP Mods - Please specify as Shouldn©t the council be considering more effective alternatives for housing needs such as recycling previously precisely and succinctly as developed Brownfield sites closer to the town centre and in more sustainable locations? Such could lead to possible how you would the revival of the Chesham economy and its future as a thriving market town. modify this policy to improve I support Brown Not Green©s campaign to adopt viable alternatives such as the Chesham Masterplan. I would its alignment to this test of urge you to recommend rejection of the draft local plan as unsound and unjustified. soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not The proposed development at Lye Green is predicted to increase the area©s carbon footprint by 21% or more, believe this policy in contravening Government guidance, as set out in NPPF. This makes the plan inconsistent with government consistent with the National policy to achieve zero carbon emissions by 2050 and therefore legally questionable. Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1220196 Full Name Dr M I Appleby ID 1618 Order 236
9174 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as
9175 precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Re draft local plan to build 500 houses on Green Belt land NE of Chesham at Lye Green and to remove not believe this policy to be many local vilages from the Green Belt. positively prepared please We object to the above on the following grounds; explain why 1)The sewage works in Chesham barely cope now, let alone with an extra 500 houses. 2) There will be up to 1000 extra cars making air quality and pollution worse in Chesham. 3) There is already gridlock in Chesham now and the extra traffic will exaggerate traffic problems in Chesham. 4) No provision made for the extra school places or doctor©s patients. 5) Town centre car parking should not be lost. 6) The proposal site at Lye Green is good agricultural land, and is an asset to the local community, being used a lot by dog walkers. PP Mods - Please specify as The council should be looking at providing new houses on Brownfield sites not using Green Belt land. More precisely and succinctly as Brownfield sites are near the town centre and will help to revitalise the town centre. (as requested by the possible how you would Chesham Renaissance CIC Master Plan). modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why.
9176 PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not There should have been prior consultation on Green Belt village policies. believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1220197 Full Name Beryl Stannard ID 1628 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its
9177 legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do This good quality agricultural land that separates Lye Green from Chesham which is almost 2.5km from the not believe this policy to be town centre and on top of a steep hill which will only generate more traffic congestion and worsen local air positively prepared please quality in Chesham is not a sustainable location to build on. explain why PP Mods - Please specify as See CIC for June 2019 - funding gap analysis. precisely and succinctly as I support the Chesham Masterplan alternative.
9178 possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not The local plan is not justified, effective or even legal with an acknowledged funding gap of between £179m believe this policy to be - £231m. effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not It is not in accord with NPPF policy to allocate Green Belt land NE of Chesham for housing when that site believe this policy in has been used for decades for informal recreation by locals and is potentially to be listed as an "asset of consistent with the National community value". Planning Policy Framework There was no prior consultation to build a disproportionate amount of shops in Chesham. Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1220200 Full Name Mr Nigel Clark ID 1676 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is
9179 not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is
9180 proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The development at Lye Green envisages some 500 houses, shops and traveller pitches. That©s also an not believe this policy to be additional 1000 cars using our already congested roads in Chesham. The site is 2km away from the town positively prepared please centre and railway station. To get to the town centre from the site would require using Nashleigh Hill and the explain why Berkhamstead Road.The latter road is already a known area for poor air quality from vehicle exhaust pollution which is worse than EU safe levels. White Hill is another road that would be used by the new site, this road is steep narrow and already busy with a school at the top. The car parking in the town centre is already at capacity. The current schools are oversubscribed and more cars on school runs will, if they can get in, increase traffic congestion. The doctors© surgeries in town are already at capacity and existing patients face an increasing wait to see their G.P. More Chesham residents will aggravate an already serious problem. Building on more land will increase the flooding risk which Chesham is subject to. It is no good putting in new road gulleys to take away the rain fall as these soon become blocked up due to lack of maintenance. The sewage system is already up to capacity with regular sewage appearing in the River Chess. Additional demands from the new development will aggravate the position even more. Chalk streams in the Chilterns are a rare sight and they should be protected. The soundness of this plan is questionable as there are conflicting policies within it. The council seem to think that Lye Green provides easy access to public transport including the tube station. The plan promotes an increase in retail development in the town, part of which will be built on the car park serving Chesham tube station. There is currently no foot path along Lye Green Road or cycle paths towards the town. There are a number of of vacant retail spaces already in the town centre and building even more will make the situation worse. PP Mods - Please specify as The Chesham Renaissance CIC has been striving to create a Chesham Masterplan. This would provide precisely and succinctly as affordable homes in more sustainable locations nearer the town centre and would help to improve some possible how you would more deprived areas within Chesham. modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not I feel that the proposals to release Green Belt land at Lye Green are not justified.We cannot carry on removing believe this policy to be Green Belt land and building on it. justified please explain why As I understand, the primary purpose of Green Belt land is to prevent urban sprawl and to maintain the openness of the area. The Lye Green site performs this function very well and has done so for many very years. A further aim is to encourage building on derelict land and other urban land in preference. Policy 2a - Please specify as There are other Brownfield sites nearer the town centre which should be considered. There is a large site precisely and succinctly as on Asheridge Road where a factory was demolished some years ago and remains vacant and an eyesore. possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
9181 Policy-level file upload - Please attach any supporting evidence
Person ID 1220208 Full Name Christine Robertson ID 1783 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications
9182 to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Lye Green is good quality agricultural land that separates Lye Green from Chesham. The proposed site is not believe this policy to be almost 2.5km from the town centre and located at the top of a steep hill that will only generate more traffic positively prepared please congestion and worsen local air quality in Chesham means it is an unsustainable location to build on. explain why The proposed Green Belt release is not consistent with other local plan policies to protect wildlife habitats or biodiversity or to protect our globally scarce chalk stream rivers. This plan undermines these aims. A local plan that predicts an increased carbon footprint of +21% is not acceptable. Many of the site allocations (such as at Lye Green. Policy SP BP2) are excluded from CIL and developers will therefore be required to deliver infrastructure directly or make financial contributions to mitigate development impact. However , these contributions cannot be quantified because much of the costs or related infrastructure is not even specified and is awaiting the preparation if (as yet unpublished) "masterplans" for each site. The fear is that many sites will either be undeliverable /nonviable or worse, delivered without the appropriate infrastructure necessary to avoid adverse impacts on the wider area. PP Mods - Please specify as The council should be looking at more effective alternatives (ie: higher densities of housing development on precisely and succinctly as Brownfield sites) which are generally closer to the town centre and in more sustainable locations which will possible how you would also rejuvenate Chesham, as advocated by Chesham Renaissance CIC Masterplan. modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not A local plan with an acknowledged funding gap from the community infrastructure levy (CIL) of between believe this policy to be £179m - £231m is not justified, effective or even legal. justified please explain why It is not justified, effective or even legal to allocate Green Belt land NE of Chesham (Policy SP BP2) for housing that has been used for decades for informal recreation by locals and is potentially to be listed as an asset of community value.
9183 Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not The Spatial Policy (SP BP1) for sustainable development (to promote the recycling of previous developed believe this policy to be Brownfield land) is not effective or consistent with the Plan©s other proposed uses of Green Belt land to meet effective please explain why. housing needs specifically at Lye Green. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not The plan is not in accordance with NPPF because it seeks to remove land from the Green Belt for housing. believe this policy in There are not satisfactory "exceptional circumstances" that exist for redefining belt boundaries such as at consistent with the National Lye Green (Policy SP BP2) and/or removing numerous villages from Green Belt or permitting the "infilling Planning Policy Framework of GB villages" as proposed by policies SP PP1 and DM PP1. Baring in mind that the courts have held that Feb 2019 please explain why housing needs to do not qualify as "exceptional circumstances". There was no prior consultation on "Green Belt Villages policies" (SP PP1 and DM PP1) nor any consultation on proposals to build disproportionately so many new shops in Chesham (mostly on town car parks). Govt guidance in NPPF tells plan makers to provide for housing and other uses unless Green Belt policies (for one) provide a strong reason not to. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1220330 Full Name Mr and Mrs Diana and Stephen Taylor ID 1602 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be
9184 as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public?
9185 Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I feel that this policy is unsound, particularly as this local plan has not considered ANY of the numerous not believe this policy to be brownfield sites around the centre of Chesham. Higher densities of development here would be far more positively prepared please sustainable. The road system through Chesham is not fit for purpose now. With 500 more houses out at Lye explain why Green, the increase in traffic would make gridlock through Chesham even more common than it is now, and air quality would suffer greatly in consequence. I live parallel to Berkhamstead Road, and regularly walk into Chesham. Any planning should take account of the fact that the air quality along here is already considerably worse than EU safe levels. This Plan contains conflicting policies, which means that it is unsound. The Green Belt site NE of Chesham does not provide easy access to public transport. Anyone wanting to use the train will have to drive and will need to park their car in the station car park. However, the plan also promotes considerable retail development in the station car park, reducing its size. All this points to the flawed methodology of Green Belt site selection used by the Local Authority, which is not effective, justified or consistent with national policy. It is therefore unsound. I completely support Brown Not Green's initiative to have the land NE of Chesham listed as an Asset of Community Value. They speak for me in respect of their objections to the draft Local Plan. Accordingly, I request that any representations made by them at any future examination in public regarding the soundness of this Local Plan be considered as an extension of my own comments in this letter. The land NE of Chesham is an unsustainable location for development. It has been habitually used by the community for improved health and wellbeing for decades, and the land performs well according to Green Belt aims and objectives. Exceptional circumstances for building on Green Belt simply do not exist or are insufficient to warrant removal of this land from Green Belt designation as required by Government Policy. Therefore the plan is unsound. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances believe this policy to be ± as stated in Para 136 of the latest NPPF.The Council engaged third party consultants for Part 1 Green justified please explain why Belt Assessment and they identified numerous sites ªfor further considerationº. Other Local Authorities had the third party do the Part 2 Green Belt assessment. This Local Authority did the Part 2 assessment itself, and therefore premature focus and fixation on releasing land from Green Belt assessment was placed on Lye Green NE of Chesham. This makes the identification of this land for release totally unjustified. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not This Plan also needs to be effective. However, removal of this land at Lye Green from Green Belt designation believe this policy to be is not effective, as there are serious questions about its deliverability. Not only has the main landowner effective please explain why. asserted publicly that he is not prepared to release all of the land in his ownership for development, but it is an Asset of Community Value. Once this is confirmed, a community group would have the right to bid for the land. The community group, Brown Not Green, have stated their intention to preserve this land that many hundreds of people have habitually used for outdoor recreation. All this makes the land extremely difficult to develop and it would be undeliverable in planning terms. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not Building 500 homes NE of Chesham is therefore not sustainable, nor is it in accordance with Government believe this policy in policy. No one is going to walk the 2km to Chesham from Lye Green. It is common knowledge that Chesham consistent with the National is a very dangerous town to cycle through. So more cars, more congestion and further damage to air quality. Planning Policy Framework The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances Feb 2019 please explain why ± as stated in Para 136 of the latest NPPF.The Council engaged third party consultants for Part 1 Green Belt Assessment and they identified numerous sites ªfor further considerationº. Other Local Authorities had the third party do the Part 2 Green Belt assessment. This Local Authority did the Part 2 assessment itself, and therefore premature focus and fixation on releasing land from Green Belt assessment was placed on Lye Green NE of Chesham. This makes the identification of this land for release totally unjustified. Everything about this development goes against all the NPPF recommendations:
9186 Para 134: Green Belt is to prevent neighbouring towns and settlements from merging into one another. The Green Belt along Lye Green Road succeeds well at this, and helps to maintain the integrity of Botley, Whelpley Hill, Orchard Leigh and Ashley Green. It is also good agricultural land and maintains many species of wildlife. Para 134(e): To assist in urban regeneration by encouraging recycling of derelict and urban land. Allocating Green Belt totally undermines this aim in Chesham. Chesham renaissance CIC has created a Chesham Masterplan, which would actually make Chesham a better place to live. It would provide affordable homes in sustainable locations near the town centre and rejuvenate the town. Building 500 homes 2km outside the town centre is contrary to national guidance and therefore unsound. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5492687 Please attach any supporting evidence
Person ID 1220354 Full Name Roy Pound ID 1661 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible.
9187 Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I am a local resident, and have been for nearly 45 years! not believe this policy to be I have seen and read about many local plans during this time, some of which have been passed and some positively prepared please have blown up in the Council©s face! explain why Converting Green Open Space to Brown is a mad idea, especially as there are many little or unused Brown spaces in the Chesham area. eg Asheridge Road! This site has been unused for many years. I understand that this new plan is also going to increase the Carbon Footprint when the Government has decreed that the country will be carbon emision free by 2040! My final point is the apparent lack of thought of the necessity of local infrastructure increase to support ANY future development!
9188 there are already problems with water shortage - area drainage problems - as well as the need for increases in schools, medical services and police services. I know that there are other areas I have not mentioned but all in all you need to do a complete revision of this LOCAL PLAN. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1220364 Full Name David Frith ID 1586 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details
9189 Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has
9190 met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Storm water flooding, sewage provision, town©s water and abstraction all need fully addressing in any long not believe this policy to be term plan for sustainability in the local area of Chesham, as well as wider environmental concerns.The report positively prepared please is lacking in not paying sufficient attention to he issue which need addressing before the scale of the proposed explain why developments can proceed. A serious shortcoming. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1220421 Full Name Mrs Megan Steinhauer ID 1824 Order 236 Number 11.3
9191 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible.
9192 Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Please see above arguments as to why I believe the plan is unsound. not believe this policy to be positively prepared please explain why PP Mods - Please specify as A further examination of all Brown Field site options is required to comply with the National Planning Policy precisely and succinctly as Framework. possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I believe the Local Plan to release Green Belt land for development to the north-east of Chesham is not believe this policy in legally compliant and unsound.The Plan disregards the National Policy and guidance issued by the Secretary consistent with the National of State in particular that Local Authorities must demonstrate that they have exhausted all other options for Planning Policy Framework development before considering any revision of Green Belt boundaries. Feb 2019 please explain why
9193 In my opinion Green Belt land has been designated as such for a vitally important reason and any `chipping away' of boundaries here and there, due to short sighted decision making, will be disastrous for future generations. This country has already seen a loss of 97% of important wildflower meadow land since the end of the war with the accompanying adverse effect on the eco system. I am concerned that by adopting plans such as those currently considered by the council that our remaining green belt will go the same way with unrestricted urban sprawl. The ear-marked site north east of Chesham is not a sustainable location as it is too far from the town centre. Residents of the proposed new houses will need use of private cars or public buses in order to reach amenities which will put increased pressure on our already strained road system. More importantly however is the increase in pollution this will cause. The air quality in Chesham is already poor and research done by institutions such as Imperial College in London point to car pollution as a significant contributor to heart and lung disease particularly among town dwellers and alarmingly evidence is also appearing of brain development issues in young children regularly exposed to this pollution. In addition, by removing green land we will be taking away an important carbon trapper as grass has been shown to be just as effective at trapping carbon into the soil as trees. The selection of this land for development is flawed as the Local Authority did not undertake all the recommended reviews of each site and is therefore in direct contravention to government policy. There are plenty of brown field sites within Chesham in close proximity to amenities that are crying out for development and which will actually be of benefit to the town. The selection of the Lye Green site is therefore unjustified. I realise the need for affordable homes within the area and I am a whole hearted supporter of the `Brown Not Green' organisation. I would ask the Local Authority to please look again at the `Brown Not Green' initiatives rather than pursue the current unsound plans. Policy 3a - Please specify as The Local Authority must undertake a proper review of all the Brown Field site options available. precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5492708 Please attach any supporting evidence
Person ID 1220439 Full Name Ms Sharon Jones ID 1860 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible.
9194 Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the
9195 examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Chesham is saturated. The town is already congested. There is no sound justification for authorising any not believe this policy to be construction on our green belt. positively prepared please The council should make concerted efforts to have brown sites redeveloped. explain why There is no need to destroy our green belt.The council is struggling to manage existing infrastructure. Manage what you have please. PP Mods - Please specify as Please only consider brown sites for development. precisely and succinctly as Please scrap any plans to build on green belt. possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not Please utilise brown sites. believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not Building will tax local resources and water supplies. Additional population will increase air pollution which believe this policy in will damage existing residents health. consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as This development should not be built within the Chesham area and only brown sites should be used. No precisely and succinctly as green areas should be touched. possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1220440 Full Name Mr Paul Kirk ID 1861 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of:
9196 Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is
9197 incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The proposals to release Green Belt land to meet housing targets (Generally, Spatial Policy SP SP1 & not believe this policy to be specifically Policy SP BP2 at Lye Green NE of Chesham) are not justified from the evidence submitted by positively prepared please the Councils. explain why The Councils have stated that release of some Green Belt is necessary as part of an overall three part strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. I question the soundness of such a general policy and whether all the brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites and in particular the Green Belt site NE of Chesham at Lye Green. The development of such Green Belt sites involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient and unfunded. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. A development of the size proposed will entail significantly increased traffic on three routes into the centre of Chesham: Nashleigh Hill and Eskdale Avenue, leading to Broad Street, and White Hill. As a resident living off White Hill I can attest to the fact that entry to the road is already extremely difficult during peak hours, with reliance on the generosity of other drivers being the only means by which entry to White Hill can be secured. This will be exacerbated under the proposed scheme, due to the concomitant increase in traffic. The air pollution caused by Nitrogen Dioxide and Carbon Monoxide gases will also worsen, further affecting the school children who make their way to and from Chesham Grammar at busy times. Furthermore, these children will also be placed at further risk of harm caused by the increased traffic density and rise in the likelihood of potential accidents. Broad Street is already busy and overcrowded at peak times, and the increase in traffic from the access arteries of Nashleigh Hill and Eskdale Avenue will cause further, intolerable congestion. The remoteness of the proposed site will exacerbate the already acute parking shortages in the central areas of Chesham, since residents of the new development will be too far away to manage travel into the town comfortably on foot, and so will seek to drive for the sake of convenience. Free parking opportunities will be sought, particularly by those commuting into London for the day, to the detriment of residents in more central areas, who will see parking spaces close to their homes usurped. At peak times it is already common for passengers on the underground to have to stand even from the outset of their journey, with those joining at Little Chalfont having little or no chance at all to be seated. This issue will be significantly worsened if the population of Chesham is allowed to rise significantly, and standing will become more commonplace. For those commuting to London regularly or daily, this will have long-term effects on health. That improved footpaths or cycle paths should provide environmentally sustainable access into Chesham is disingenuous, since this pre-supposes that significant numbers of residents in the proposed development would use such facilities. In point of fact, given the geographical isolation of the site, and the topography of the vicinity, it is likely that most residents would rely on the comfort and expedience of private cars. Under local policy SP EP3, the removal of parking near the underground station would also mean that there would be an increased likelihood of these same drivers seeking free parking in the already congested residential streets in central areas of the town. Finally, I wish to point to the fact that building on the greenbelt will have inevitable impact on local ecology, something which I strongly object to unless all other avenues have been exhaustively explored. PP Mods - Please specify as I refer to the comments previously submitted but in summary would advocate that; precisely and succinctly as All other options are fully explored including increased density of development of brownfield land and the possible how you would policies emerging from Chesham Masterplan. modify this policy to improve its alignment to this test of Green Belt land should only be considered when all other options are exhausted and in any event the soundness. proposals for developing land NE of Chesham (policy SP BP 2) should be removed as it is an unsustainable
9198 location the development of which will cause harm to the wider town including loss of an asset that improves the well-being for the community. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I believe the draft Local Plan is NOT legally compliant because it has not demonstrated sufficient regard to believe this policy in the National Policy and guidance issued by the Secretary of State. consistent with the National The National Planning Policy Framework (NPPF) together with other guidance issued by the Government Planning Policy Framework is also supported by recent ministerial statements that have made it clear that Local Authorities MUST Feb 2019 please explain why demonstrate they have exhausted all options BEFORE considering revision of Green Belt boundaries. This Local Plan is seeking substantial modifications to Green Belt boundaries including the removal of Green Belt designation of 13 areas within the Districts as well as modifying the Green Belt status of many local villages. I contend this draft Local Plan has not demonstrated that all other options have been fully explored and as such this Plan is not justified, sound or in accordance with National Policy and accordingly is not legally compliant. Policy 3a - Please specify as The Plan needs to be modified by; precisely and succinctly as There should be cooperating with other nearby authorities not just Aylesbury Vale. It is simply unsatisfactory possible how you would to assert this cannot be done because they are in a different Functional Market Areas and that cooperation modify this policy to improve is not necessary. its alignment to this test of soundness. Exploring such wider cooperation may result in further housing needs being taken elsewhere. A more detailed appraisal of brownfield land opportunities must be undertaken. Some brownfield opportunities have been ignored or missed. Closer scrutiny of alternative options for housing delivery should be explored (such as Chesham Masterplan by CIC Chesham Renaissance). Green Belt boundary reviews should only be considered after all other reasonable alternatives have been exhausted. Policy-level file upload - 5492710 Please attach any supporting evidence
Person ID 1220453 Full Name Mr Tony Dickinson ID 1901 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name
9199 Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination
9200 Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The plan is unsound because: not believe this policy to be 1. it fails to recognise that the train system (single track tube line where twice-hourly trains are already full) positively prepared please and road system (already overloaded at peak times) can cope with 500 new houses explain why 2. it fails to recognise the serious air pollution impact of more houses and cars and less green spaces 3. it fails to consider brown field sites for new houses rather than green belt land 4. it fails to consider the fact that the High Street is struggling, proposing instead a range of new shops 5. it fails to consider the need for affordable parking around the High Street, and focuses instead on building new shops on town car parks PP Mods - Please specify as All of the points above should be addressed, and full attention should be given to the Brown Not Green and precisely and succinctly as Chesham Masterplan proposals on these points possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1220470
9201 Full Name Janet Cameron ID 1943 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness?
9202 Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do ( 1) l am absolutely against the Draft Local Plan for Chesham , proposed by Chiltern District Council not believe this policy to be (2) It is Vital that Greenbelt Status must be protected, at all costs, now and for future generations. I support positively prepared please BROWN NOT GREEN , wholeheartedly. And WILDLIFE TRUSTS for the preservation and monitoring of our explain why countryside and wildlife habitats. (3) On 7th Nov 2017 l wrote to Counciller Darby, Chairman Council Planning Committee concerning the Greenbelt Status at Lye Green, Chesham with the ongoing proposed plan for 900 new homes to be built on that site. ( 4) Now 2 years later 29/31 councillors have voted for 500 homes ( plus some extras at their own whim ) Justifying themselves because they have reduced the number! Do they think us residents are stupid or naive in thinking they have solved the problem? Once the Greenbelt Status is removed it gives these Developers Carte Blanche to do what they damn well like now and into the future. I said at that time " it is Vital that all Chesham©s residents concerns are heard, taken seriously, argued and addressed openly and publicly. Do us residents have a say or not" ? Why was there No prior consultation on " Green Belt Villages Policies"?? I state that every council member is in a privileged position to represent their constituents and wider community. I question with Great concern that this Plan was debated in a rushed © closed shop© scenario ! More time needs to be spent on addressing the environmental issues, infrastructure etc.and that needs to be done first; that is common sense.This is not permission for an extension on a single property. Get this Local Plan wrong and it will have Serious consequences for tens of thousands of local people in the future! (5 These proposals in the Local Plan undermine the CHESHAM RENAISSANCE CIC MASTERPLAN, a community lead project which l very much support. Many years of hard work have gone into this Plan, the alternative to desecrating Greenbelt. Never before has it been increasingly obvious that Local communities need to come together to fight for control and have their say in Local matters...Not just Local but nationwide! (6) l have lived in Chesham for 50 years and love this place! What will Chesham look like in 20years time? With the increasing population comes increasing cars on the roads, means more congestion and more pollution, especially on Berkhamstead Road where a school is situated.The parking situation is already dire, some roads have parked cars on both sides. 500 new homes probably 1000 more cars? More children, more pressure on schools. Why was the well established Cestreham school and playing field demolished in favour
9203 of a housing estate at the top of Nashleigh Hill? Utter madness. Pressure on local health provision. Pressure on water supply and drainage. I follow RIVER CHESS ASSOCIATION concerns about the state of our ( globally scarce) local chalk stream rivers and their ongoing demise because of the pressures of a rapidly increasing population. Please do your utmost for Chesham. Thank you for your consideration. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1220452 Full Name Mrs Elizabeth Dickinson ID 1900 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details
9204 Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has
9205 met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The plan is unsound because: not believe this policy to be 1. it fails to recognise that the train system (single track tube line where twice-hourly trains are already full) positively prepared please and road system (already overloaded at peak times) can cope with 500 new houses explain why 2. it fails to recognise the serious air pollution impact of more houses and cars and less green spaces 3. it fails to consider brown field sites for new houses rather than green belt land 4. it fails to consider the fact that the High Street is struggling, proposing instead a range of new shops 5. it fails to consider the need for affordable parking around the High Street, and focuses instead on building new shops on town car parks PP Mods - Please specify as All of the points above should be addressed, and full attention should be given to the Brown Not Green and precisely and succinctly as Chesham Masterplan proposals on these points possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1220607 Full Name Mrs Rosie Phillips ID 3773
9206 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Hawridge & Cholesbury Church of England School Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as
9207 precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not I am writing for I am very concerned about your plans to change green belt to brown belt, If you build lots of believe this policy to be homes on Chesham fields lots of habitats will be destroyed. Though the council voted for this it does not justified please explain why mean it is the right thing. We realise that there are a lot of people in Chesham but humans are not the only things on this planet there are animals too.You MUST change your mind. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
9208 Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1220645 Full Name Mrs Susan Dyer ID 2005 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness?
9209 Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The proposals to release Green Belt land to meet housing targets (Generally, Spatial Policy SP SP1 & not believe this policy to be specifically Policy SP BP2 at Lye Green NE of Chesham) are not justified from the evidence submitted by positively prepared please the Councils. explain why The Councils have stated that release of some Green Belt is necessary as part of an overall three part strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. I question the soundness of such a general policy and whether all the brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites and in particular the Green Belt site NE of Chesham at Lye Green.
9210 The development of such Green Belt sites involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient and unfunded. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham cannot accommodate any significant highways improvements anyway due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion, with further worsening air quality. Air pollution is a particular concern in Chesham due to the already poor air quality along Bekhampstead Road where there is a designated Air Quality Management Area that already is recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will generate more traffic will make the air quality even worse and insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable nor justified nor is it in accordance with Govt policy. The Green Belt site NE of Chesham (SP BP 2) is not a sustainable location. It is over 2Km away from the train station and slightly further still from the town centre but anyone who cares to walk or cycle this distance also has to negotiate a steep hill too. Such an unsustainable location cannot be made sustainable merely by upgrading a couple of public footpaths within the site into bridleways to facilitate cycling. Neither does adding a bus stop address the geography or topography of the area especially if the promised enhanced bus service (which is already infrequent) either does not materialise or if it subsequently fails to be maintained after a few years. Further doubt is cast upon the ªsoundnessº of this Plan by virtue of there being conflicting policies within it. The Council seem to think that the Green Belt site NE of Chesham is sustainable and provides easy access to public transport including the tube station yet the same Plan promotes a considerable increase in retail development in the town (local draft plan policy SP EP3) , part of which would be built on the very car park that serves the Chesham tube station. This is inconsistent and unsound. For this Plan to sound it must also be effective. Unfortunately, further review of the proposal to remove land NE of Chesham at Lye Green from Green Belt designation is not effective as there are serious questions about the deliverability of this land. The main landowner is a farmer who has asserted publicly and in a letter to the editor of Your Chesham, that he is not prepared to release all of the land in his ownership for development. The land is also potentially an Asset Of Community Value and upon confirmation of this designation it would afford a community group the right to bid for the land. The community group (Brown Not Green) have stated their intention is to preserve the land given that many hundreds of local people have habitually used the fields at Lye Green as of right for various informal outdoor recreational purposes. These uses themselves may mean that many local individuals may have acquired easements over and across the land through prescription (20 years uninterrupted use) not least of whom would be the many private residences bordering the fields that have rear garden gates onto the fields at Lye Green. These easements and prescriptive rights may render the land very difficult to develop and make i undeliverable in planning terms. This land also provides an important habitat for wildlife that will be threatened by development of this land. It is perverse that the Local Authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Plan is unsound. The foregoing also points to flawed methodology of Green Belt site selection used by the Local Authority, which is neither effective, justified nor consistent with national policy and as such is unsound. Specifically, the selection of the land NE of Chesham at Lye Green (policy SP BP2) for removal from Green Belt designation is inconsistent with National Planning Policy Framework (NPPF). Paragraph 136 of the latest NPPF asserts that Green Belt boundaries should only be modified in ªexceptional circumstancesº. The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances. The Council engaged third party consultants to undertake the Part 1 Green Belt assessment and they identified numerous sites for ªfurther considerationº where exceptional circumstances ªmightº exist but expressly recommended further review of their assessment of each site against the 5 purposes of land being in Green Belt of all these sites. Unlike the neighbouring Local Authorities, the Part 2 Green Belt assessment was not undertaken by third party consultants but by the Local Authority itself who notably then did not undertake all the recommended reviews of each site including the land NE of Chesham at Lye Green (SP BP 2). Accordingly, this oversight in the Part 2 Green Belt assessment placed premature focus and fixation on releasing land at Lye Green NE of Chesham from Green Belt designation. The subsequent identification of the Chesham site for release is therefore unjustified. These comments apply equally to proposals effecting the villages in the Green Belt ± policies SP PP1 & DM PP1) The primary aim of Green Belt land (as recited in NPPF 133) is to prevent urban sprawl and to preserve the openness of the area. The Lye Green site (SP BP2) self-evidently performs this function well and has done so for decades. Another aim of Green Belt land stated in NPPF paragraph 134, is to prevent neighbouring towns and settlements from merging into one another.The Green Belt land NE of Chesham performs exceptionally well in maintaining a distinct separate between settlements of Chesham & Lye Green as well as helping to maintain separate identities of other nearby communities at Orchard Leigh, Botley, Whelpley Hill, Ashley Green. It is perverse and inconsistent with national guidance to allocate this land for removal from Green Belt in light of these facts especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if earmarked for development. A further aim of Green Belt designation stated in the NPPF at paragraph 134 (e) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. By allocating Green Belt land NE of Chesham for development, undermines this aim within Chesham. A community lead not for profit organisation called Chesham Renaissance CIC has been striving to create Chesham Masterplan that would not only provide many genuinely affordable homes in more sustainable locations nearer the town centre, but which would also regenerate some of the more deprived wards within Chesham. The Local Authority's
9211 proposals (policy SP EP3) are inconsistent with this local initiative and are therefore also inconsistent with national guidance and are consequently unsound. The Council have asserted that Government planning policy requires local councils to review Green Belt boundaries when considering how to accommodate the development needed in their areas. Just because the Council may be required to look, does not mean the Council should review Green Belt boundaries which as previously stated should only be modified in ªexceptional circumstancesº. National Planning Policy Framework (NPPF) as revised only last year, states in paragraph11 (b) I, directs ªplan makersº to create policies that are required in Local Plans for housing and other uses unless Framework policies (expressly including Green Belt) ªprovides a strong reason for restricting the overall scale type or distribution of development in the plan areaº Accordingly, I submit that given all of the above the land being proposed for release from Green Belt designation around Chesham is unjustified and contrary to national guidance. I am supportive of the Brown Not Green organisation's initiative to have the land listed as an Asset of Community Value and I feel they speak for me in respect of their objections to the draft Local Plan. Accordingly, I request that any representations made by them at any future examination in public regarding the soundness of this Local Plan be considered as an extension of my own comments herein. I feel the land NE of Chesham is an unsustainable location for development, that has been habitually used by the community for improved health & wellbeing for decades and the land performs well against Green Belt aims and objectives. Exceptional circumstances for reviewing Green Belt boundaries at this location, either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by Govt Policy and therefore the plan is unsound. PP Mods - Please specify as I refer to the comments previously submitted but in summary would advocate that; precisely and succinctly as All other options are fully explored including increased density of development of brownfield land and the possible how you would policies emerging from Chesham Masterplan. modify this policy to improve its alignment to this test of Green Belt land should only be considered when all other options are exhausted and in any event the soundness. proposals for developing land NE of Chesham (policy SP BP 2) should be removed as it is an unsustainable location the development of which will cause harm to the wider town including loss of an asset that improves the well-being for the community. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I do not believe that exceptional circumstances exist for redefining green belt boundaries. believe this policy in I contend this draft Local Plan has not demonstrated that all other options have been fully explored and as consistent with the National such this Plan is not justified, sound or in accordance with National Policy and accordingly is not legally Planning Policy Framework compliant. I do not believe that the use of brownfield sites has been fully investigated/utilised. Feb 2019 please explain why There was no prior consultation around the `Green Belt Villages Policy'and I believe that many of the proposals suggested around removing areas of land from the green belt and using them for development will compromise traffic flow/congestion/pollution and is not a sustainable option without undermining the infrastructure of the area. The lack of prior consultation has not allowed for wider nvestigation of options for the local plan and I do not agree that exceptional circumstances exist for the development of green belt land. Areas of outstanding natural beauty are under threat by this plan which is not consistent with other local plans to protect the unique environment in this area. Policy 3a - Please specify as The Plan needs to be modified by; precisely and succinctly as Co-operating with other nearby authorities. Not just Aylesbury. It is simply unsatisfactory to assert this cannot possible how you would be done because they are different Functional Market Areas and that co-operation is not necessary therefore. modify this policy to improve its alignment to this test of Exploring such wider co-operation may result in further housing needs being taken elsewhere. soundness. A more detailed appraisal of brownfield land opportunities MUST be undertaken. Some brownfield opportunities have been ignored or missed. Closer scrutiny of alternative options for housing delivery should be explored (such as Chesham Masterplan by CIC Chesham Renaissance). Green Belt boundary reviews should only be considered AFTER all other reasonable alternatives have been exhausted.
9212 In the face of NPPF guidance and a more thorough appraisal of Green Belt sites being considered, it may then be necessary to conclude that it is not possible to identify poor performing Green Belt sites that can accommodate all the OAN for housing. Consequently it may be necessary to accept that a lower housing provision figure is appropriate. Policy-level file upload - Please attach any supporting evidence
Person ID 1220615 Full Name Mr Robert Smith ID 1962 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as
9213 precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Relating to Policy SP BP 2: not believe this policy to be There is no justification, nor exceptional circumstances, that require the removal of land at lie green from positively prepared please the Green Belt. explain why There is sufficient brownfield land within Chesham to meet the supposed housing need in accordance with the Spatial Policy (SP SP1). The proposed removal of land is entirely inconsistent with the policy to protect wildlife habitats and biodiversity which is also a feature of the plan. Chesham town centre has suffered from retail problems since before the advent of online shopping. The town centre is currently occupied by a large number of charity shops and cafés rather than a diverse selection of retail outlets. Providing space for more shops will do nothing to rejuvenate the town centre unless the whole approach is altered, for example, providing free car parking and making the High Street a more attractive destination. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
9214 Policy 1 - If you do not Alternatives such as use of existing brownfield sites nearer to Chesham do not appear to have been fully believe this policy to be considered. For these refer to the Chesham Renaissance CIC Masterplan. justified please explain why There is no justification for removing land from the Green Belt in this case and to do so, in these circumstances, will set a dangerous precedent for the future. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not It is arguably on lawful for a local plan to accept a CIL funding shortfall of £231 million. believe this policy in The NPPF permits the removal of land from the Green Belt only in exceptional circumstances. The meeting consistent with the National of housing needs does not, of itself, constitute exceptional circumstances and the premise upon which much Planning Policy Framework of the Local Plan is based is therefore inconsistent with the requirements of the NPPF. Feb 2019 please explain why The policy is not consistent with the NPPF which recognises the pre-eminence of the Green Belt in the absence of exceptional circumstances (of which housing need is not one) which do not exist in this case. Policy 3a - Please specify as Remove it in its entirety. precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1220647 Full Name Joseph Walsh ID 2011 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to
9215 relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary
9216 to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do It is my belief that the Draft Local Plan is unsound for the reasons I am outlining below. In addition I believe not believe this policy to be the proposals to release Green Belt land to meet housing targets cannot be justified from the evidence positively prepared please submitted. explain why The Councils have stated that release of some Green Belt is necessary as part of an overall three part strategy. However this policy is unsound because, in my view, not all the available brown-field sites have been identified. In addition, the Council should be looking at higher densities of development on such sites which are generally closer to the town centre because these are more sustainable locations than Green Belt sites. This applies particularly to the Green Belt site north east of Chesham at Lye Green. The development on such Green Belt sites of many hundreds of new homes will generate significantly increased traffic and the suggested highways improvements will be insufficient. I use the station car park regularly and can state as fact that on most weekday mornings the car park is full by 09.30. The Green Belt site NE of Chesham is over 2km away from the train station so there is little doubt that residents would use their cars to get to the station. There is clearly no more capacity for further commuter traffic and the evidence shows that most of the road junctions in Chesham are already operating above capacity. The proposed developments will inevitably lead to increased traffic congestion with further worsening air quality. I would draw the Inspector's attention to the results from the designated Air Quality Management Area on Berkhamstead Road which shows that the air quality here is already considerably worse than EU safe levels. Paragraph 136 of the latest NPPF asserts that Green Belt boundaries should only be modified in ªexceptional circumstancesº. Although the Council did engage third party consultants to undertake the Part 1 Green Belt assessment (which identified numerous sites for ªfurther considerationº where exceptional circumstances ªmightº exist) the third party consultants expressly recommended further review of their assessment of each site against the five purposes of land being in Green Belt. However, the Part 2 Green Belt assessment was not undertaken by third party consultants but by the Local Authority itself which did not undertake the individual reviews of each site as per the consultant's recommendations. The Green Belt site NE of Chesham at Lye Green has not been the subject of a Part 2 Green Belt assessment. In my view this failure of process and the subsequent identification of the Chesham sites for release, and the modification boundaries in Ley Hill and Botley, is therefore not legally compliant. As noted above, Councils seeking to review Green Belt boundaries when considering how to accommodate the development needed in their areas should only modify existing boundaries in ªexceptional circumstancesº. The Council has failed to demonstrate that these ªexceptional circumstancesº exist in relation to the boundaries in Ley Hill and Botley. An important aim of Green Belt designation (as stated in the NPPF at paragraph 134.e) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. Allocating Green Belt land within Chesham and modifying boundaries undermines this aim. The community led not-for-profit organisation ªChesham Renaissance CICº is working to create a Chesham Masterplan that would not only provide genuinely affordable homes in more sustainable locations nearer the town centre (and within walking distance of the station) but which would also regenerate some of the more deprived wards within Chesham. The Local Authority's proposals are inconsistent with this local initiative and are therefore also inconsistent with national guidance.This in my view makes the Council's plan unsound. Paragraph 11(b)i, in the National Planning Policy Framework (NPPF) directs ªplan makersº to create policies in Local Plans for housing and other uses unless framework policies ªprovide a strong reason for restricting the overall scale type or distribution of development in the plan areaº. In this context and in light of my comments above I believe that the land being proposed for release from Green Belt designation around Chesham is unjustified and contrary to national guidance contained. PP Mods - Please specify as To comply with NPFF all other options must fully explored including increased density of development of precisely and succinctly as brownfield land and the policies emerging from Chesham Masterplan. possible how you would Green Belt land should only be considered when all other options are exhausted and in any event the modify this policy to improve proposals for developing land NE of Chesham (policy SP BP 2) and amending the boundaries in Ley Hill its alignment to this test of and Botley should be removed as these unsustainable locations, the development of which will cause harm soundness. to the wider town including loss of an asset that improves the well-being for the community. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
9217 Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not In my view the draft Local Plan is NOT legally compliant because it has not demonstrated sufficient regard believe this policy in to the National Policy and guidance issued by the Secretary of State. consistent with the National The National Planning Policy Framework (NPPF) together with other guidance issued by the Government Planning Policy Framework makes it clear that Local Authorities must demonstrate that they have exhausted all options before considering Feb 2019 please explain why revision of Green Belt boundaries. In my view this draft Local Plan has not demonstrated that all other options have been fully explored and as such this Plan is not justified, unsound and not in accordance with National Policy. Accordingly is not legally compliant. Paragraph 11 b) of the NPPF require Plan Makers to provide for objectively assessed needs for housing and other uses unless the application of Framework policies (including Green Belt) provide a strong reason for restricting the overall scale, type or distribution of development in the plan area. Chiltern District & South Bucks are significantly constrained by development policies such as Green Belt & Areas of Outstanding Natural Beauty (AONB).The Local Plan is therefore inconsistent with National Guidance and as such it is not legally compliant for the Local Authority to claim that housing needs justify a review of these same Green Belt boundaries. The Sustainability Appraisal supporting this Draft Local Plan states that the Plan area is forecast to see carbon emission increase by 21% in the Plan Period. Accordingly, the Plan is inconsistent with Government Policy UK to have net zero carbon emissions by 2050 and therefore not legally compliant. There is a significant infrastructure funding gap of between £179m & £231m. This is acknowledged within the Community Infrastructure Levy evidence that supports this Local Plan, It is a requirement of the NPFF that infrastructure be in place to ensure that development is sustainable. Ignoring the infrastructure funding gap demonstrates the Plan is both unsound and not legally compliant. Policy 3a - Please specify as The Plan needs to be modified by; precisely and succinctly as Co-operating with other nearby authorities. possible how you would modify this policy to improve Exploring opportunities for wider co-operation which may result in further housing needs being taken elsewhere. its alignment to this test of A more detailed appraisal of brownfield land opportunities must be undertaken. Some brownfield opportunities soundness. have been ignored or missed. Considering alternative options for housing delivery (such as Chesham Masterplan by CIC Chesham Renaissance). Green Belt boundary reviews should only be considered after all other reasonable alternatives have been exhausted. Accept that it may be necessary to adopt a lower housing provision figure which is more appropriate. Policy-level file upload - 5493025 Please attach any supporting evidence
Person ID 1220688 Full Name Patricia Miller ID 2093 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details
9218 Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has
9219 met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I would like to make the following points regarding the above proposed plan for another 500 houses, shop not believe this policy to be and 15 traveller pitches on green belt land detailed above and the proposal to remove some of the above positively prepared please local villages from green belt. explain why The road infrastructure of Chesham is already poor with constant traffic issues for the residents. Add this to the potential increased traffic due to arrive with the commencement of the HS2 build and this will result in even greater stress on our roads. As a resident of Chesham I can see that the build of new homes in and around Chesham in the last 2-3 years has already impacted on the traffic problems significantly. There is an acknowledged funding gap from the Community Infrastructure Levy (CIL) for infrastructure of between £179m and £231m ± can this be justified or even legal? Although many of the site allocations (such as Lye Green ± Policy SP BP2) are excluded from CIL and developers will be required to deliver infrastructure directly or make financial contributions to mitigate development impact, I believe these contributions are unquantifiable because much of the costs or related infrastructure is not even specified and is awaiting the preparation of `masterplans' for each site. Is the Spatial Policy (SP SP1) for sustainable development (to promote the recycling of previously developed brownfield land) effective and consistent with the Plan's other proposed uses of green belt land to meet housing needs specifically at Lye Green? Does the plan allow for the protection of wildlife habitats and protection of globally scarce local chalk stream rivers or does the plan undermine those things? PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not Do you consider it effective, justified or in accordance with NPPF to remove land from green belt for housing, believe this policy in especially Policy SP BP 2 which relates to land north east of Chesham at Lye Green? Particularly when this consistent with the National land has been used for many years for informal recreation by locals. Lye Green is good quality agricultural Planning Policy Framework land and separates Lye Green from Chesham. It is 2.5km from the town centre and located up a steep him Feb 2019 please explain why with a school on the same hill. The impact of building a further 500 homes and therefore adding a minimum of 500 vehicles to already congested roads will be significant, not to mention the air pollution this increase in vehicles will create. The Local Plan predicts an increased carbon footprint of +21% which is completely irresponsible. Do you have proof that any mitigation for this increase is planned and/or will be delivered? Are you satisfied that ªexceptional circumstancesº exist for redefining green belt boundaries such as at Lye Green ± Policy SP BP2 ± and that removing numerous villages from green belt or permitting ªinfilling of GB
9220 villagesº as proposed in policies SP PP1 & DM PP 1, (bearing in mind the Courts have held that housing needs alone are NOT ªexceptional circumstancesº) is justified or in accord with National Planning Policy Framework? Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1220661 Full Name Margaret Catchick ID 2050 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness?
9221 Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible
Policy Level - PP - If you do The proposal to release Green Belt land (SP BP 2) to meet housing targets is not justified and I question not believe this policy to be the Council's reasoning to release Green Belt land, and in particular the Green Belt site North East of positively prepared please explain why Chesham at Lye Green.as well as the Council's proposal to remove many local villages from Green Belt such as Botley, Ley Hill and Chartridge (Policy SP BP 2) The primary aim of Green Belt land is to prevent urban sprawl, to protect it from being built on or developed for such purposes and to preserve the openness of the area. With the proposed removal of areas from Green Belt, England will in a very short period of time no longer be a `green and pleasant land' but will become a concrete jungle. I question the soundness of the Council's general policy on releasing Green Belt land for development and whether all brownfield land opportunities have been identified and/or whether
9222 the Council should be looking at higher densities of development on such sites which are generally closer to the town centre and are more sustainable locations than Green Belt sites and in particular the Green Belt site North East of Chesham at Lye Green. The development of such Green Belt sites involving many hundreds of homes will generate increased traffic and although some highways improvements are suggested they are insufficient -as it is the road junctions and infrastructure in and around Chesham is already operating above capacity. Chesham cannot accommodate any significant highways improvements due to the already limited verges and space beside the highway and the topography of the town. Increased traffic will also lead to an increase in the already poor air quality in the area.
Air pollution is a particular concern in Chesham. Adding more homes outside the town on the Green Belt will generate more traffic which in turn will make the air quality even worse. Insofar as it relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable nor justified nor is it in accordance with Government policy. Another aim of Green Belt land is to prevent neighbouring towns from merging into one another and the Green Belt land NE of Chesham performs this function extremely well, maintaining a distinct separation between the settlements of Chesham and Lye Green as well as helping to maintain separate identities of other nearby communities at Orchard Leigh, Botley, Whelpley Hill and Ashley Green. It is inconsistent with national guidance to allocate this land for removal from Green Belt in light of these facts especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if earmarked for development.
I also question why there was no prior consultation on ªGreen Belt Village Policies (SP PP1 & DM PIP 1). Why also are we building more shops mostly on the town car parks (Policy SP EP 3) and why was there no prior consultation on this either - is this justified, effective or even sensible. For those who live in Chesham's outlying villages where bus services are virtually non-existent we will not be able to drive into the town centre to park and do any shopping - it would therefore be pointless to build more shops on these car parks.
As stated, I feel the land NE of Chesham is an unsustainable location for development that has been used by the community for improved health and well being for many years, the land performing well against Green Belt aims and objectives. I also do not believe that the villages of Botley, Ley Hill and Chartridge as well other local villages should be removed from Green Belt as part of this plan. Exceptional circumstances for reviewing Green Belt boundaries at these locations either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by Government Policy and therefore the plan is unjustified. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in
9223 consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5493026 Please attach any supporting evidence
Person ID 1220777 Full Name Alison Sheppard ID 2155 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness?
9224 Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why
9225 Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I believe the draft Local Plan is NOT legally compliant because it has not demonstrated sufficient regard to believe this policy in the National Policy and guidance issued by the Secretary of State. consistent with the National The National Planning Policy Framework (NPPF) together with other guidance issued by the Government Planning Policy Framework is also supported by recent ministerial statements that have made it clear that Local Authorities MUST Feb 2019 please explain why demonstrate they have exhausted all options BEFORE considering revision of Green Belt boundaries. This Local Plan is seeking substantial modifications to Green Belt boundaries including the removal of Green Belt designation of 13 areas within the Districts as well as modifying the Green Belt status of many local villages. I contend this draft Local Plan has not demonstrated that all other options have been fully explored and as such this Plan is not justified, sound or in accordance with National Policy and accordingly is not legally compliant. Furthermore that Paragraph 11 b) of the NPPF (and the footnotes thereto) require Plan Makers to provide for objectively assessed needs for housing and other uses UNLESS the application of Framework policies (including Green Belt) provide a strong reason for restricting the overall scale, type or distribution of development in the plan area Chiltern District & South Bucks are significantly constrained by development policies such as Green Belt & Areas of Outstanding Natural Beauty (AONB). The Local Plan is therefore inconsistent with National Guidance and as such it is not legally compliant for the Local Authority to claim that housing needs justify a review of these same Green Belt boundaries. It is perverse to claim that the combination of housing need and the presence of significant areas of development constraint policy collectively represent ªexceptional circumstancesº (as required in the NPPF) to justify modification of Green Belt boundaries especially given the NPPF states that one of the key features of Green Belts are their permanence. The Government has also recently confirmed its aim for the UK to have net zero carbon emissions by 2050 and it is noted within the Sustainability Appraisal supporting this Draft Local Plan, that the Plan area is forecast to see carbon emission increase by 21% in the Plan Period. Accordingly, the Plan is inconsistent with Government Policy and therefore not legally compliant. There is also a significant infrastructure funding gap acknowledged within the Community Infrastructure Levy evidence that supports this Local Plan, of between £179m & £231m. Given this infrastructure is vital to ensure that development is sustainable (as also required by the NPPF) this further demonstrates the Plan is both unsound and not legally compliant. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5493043 Please attach any supporting evidence
Person ID 1220785 Full Name Katrina Robson ID 2171 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received:
9226 Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance
9227 with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not Local schools are fit to burst, doctor's surgeries are over-full, the roads are already extremely busy and believe this policy to be another 500 houses without any other local infrastructure to compensate for the influx of people and cars justified please explain why would be a disaster. All of this is reason enough however the decision to build on green belt land is disgraceful and not in any way justified. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not Having reviewed the plan online, I am of the opinion that the plan is not positively prepared or in accordance believe this policy in with national guidance. Any new developments should first be considered on brown belt land, not green belt. consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
9228 Policy-level file upload - 5493051 Please attach any supporting evidence
Person ID 1220794 Full Name Alan Robson ID 2173 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications
9229 to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I am opposed to this proposal to build 500 houses and allocate traveller pitches on the green belt land around not believe this policy to be Chesham. As a resident of Ashley Green and having lived in the local area for over 20 years, I feel that this positively prepared please proposal is poorly thought out with little or no consideration for the impact on the surrounding environment. explain why Local schools are all over subscribed, doctor's and dentist's surgeries are in the same predicament. The nearest A&E is either Watford or Stoke Mandeville this is a ridiculous situation. The roads are already ridiculously busy (very poor public transport does not help) and another 500 houses without any other local infrastructure to compensate for the influx of people and cars would be a disaster. As a small example of this, when the new traffic lighting system (by Herts CC) was being installed on Shooters Way last year, the temporary traffic lights caused a tail back from Shooters Way all the way past Ashley Green down to the Ashley Green garage.This meant our school run that normally would take about 8 minutes took over half an hour or more. It goes to show it takes very little to cause mayhem on the local roads at peak times. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not All of this is reason enough, however the decision to build on green belt land is disgraceful and not in any believe this policy to be way justified certainly when there are many areas in Chesham town centre and around the town that appear justified please explain why derelict.These areas should certainly be built on first not only to help with the housing shortage but to improve the look and feel of the town it seems the council have neglected Chesham in favour of the cheaper option
9230 to build on green belt. Looking at some of the information, I have my doubts that it is even legal although as a ley person that is only my opinion. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5493054 Please attach any supporting evidence
9231 Person ID 1220695 Full Name Mr Guy Moultrie ID 2106 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness?
9232 Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The funding gap is enormous not believe this policy to be Government guidance tells plan makers to provide for housing and other uses unless green belt policies positively prepared please provides a strong reason not to. This council appears to be doing otherwise. explain why Green belt release is not consistent with other local plan policies to protect wildlife It does not give enough thought to the consequences of building so many new homes on green belt land so far out of the town centre creating an increased carbon footprint of 21% PP Mods - Please specify as Much more thought on infrastructure needs to be considered before any more new homes are built in or precisely and succinctly as around Chesham. The town centre can barely cope with the flow of traffic as it is. possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not No building of anything on Green belt land can be considered as justifiable believe this policy to be justified please explain why Policy 2a - Please specify as see above precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not This plan has an acknowledged funding gap of between £179 and £231m.This can therefore not be considered believe this policy to be an effective policy. effective please explain why.
9233 PAa - Please specify as Come up with a plan that is within budget to start with. precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I believe that it is not legally compliant to remove land from the Green Belt for housing purposes believe this policy in Government guidance in NPPF tells Plan Makers to provide for housing and other uses UNLESS Green Belt consistent with the National places provide strong reason not to. This council appears to be doing otherwise. Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as Green Belt release must be taken off the agenda before any further consultation is started. This is not precisely and succinctly as consistent with other local plan policies to protect wildlife habitats and biodiversity. possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1220821 Full Name Mr David Hardy ID 2211 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its
9234 legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Chesham station car park is already full most week days. No doubt a good proportion of the proposed not believe this policy to be additional population, should the planned development proceed, would use the Metropolitan Line. The positively prepared please distance from Chesham Station together with the steepness of White Hill and Nashleigh Hill suggests that explain why most would use cars to reach the station. Where will they park? b) The proposed development area is too far for people to walk into Chesham to shop, returning up the steep White Hill or Nashleigh Hill. So where are the additional shopping car parks to be placed?
9235 c) Recent and relatively recent housebuilding on Lycrome Road, Lye Green, has been on sites already in use - a college, a mushroom farm, and dilapidated farm buildings. The new builds have enhanced the area rather than taking away good arable land and a valued amenity available to all. The proposed site is unsustainable by dint of its location, and poor local road and car-parking infrastructure. An earlier demolition of a college (previously a school) for new housing demonstrates very poor forward planning. PP Mods - Please specify as By adopting the NPPF guidance. precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not There are alternative brown field sites and the developing Chesham Masterplan must be properly considered believe this policy to be to regenerate and make better use (with higher density housing) of central Chesham. justified please explain why Policy 2a - Please specify as By adopting NPPF guidance. precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not As previously stated. believe this policy to be effective please explain why. PAa - Please specify as By adopting NPPF guidance. precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not As previously stated. believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as By adopting NPPF guidance. precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1220912 Full Name Mr Jeff Watson ID 2337 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details
9236 Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has
9237 met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The proposals to release Green Belt land to meet housing targets (Generally, Spatial Policy SP SP1 & not believe this policy to be specifically Policy SP BP2 at Lye Green NE of Chesham) are not justified from the evidence submitted by positively prepared please the Councils. explain why The Councils have stated that release of some Green Belt is necessary as part of an overall three part strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. I question the soundness of such a general policy and whether all the brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites and in particular the Green Belt site NE of Chesham at Lye Green. The development of such Green Belt sites involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient and unfunded. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham cannot accommodate any significant highways improvements anyway due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion, with further worsening air quality. Air pollution is a particular concern in Chesham due to the already poor air quality along Bekhampstead Road where there is a designated Air Quality Management Area that already is recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will generate more traffic will make the air quality even worse and insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable nor justified nor is it in accordance with Govt policy. The Green Belt site NE of Chesham (SP BP 2) is not a sustainable location. It is over 2Km away from the train station and slightly further still from the town centre but anyone who cares to walk or cycle this distance also has to negotiate a steep hill too. Such an unsustainable location cannot be made sustainable merely by upgrading a couple of public footpaths within the site into bridleways to facilitate cycling. Neither does adding a bus stop address the geography or topography of the area especially if the promised enhanced bus service (which is already infrequent) either does not materialise or if it subsequently fails to be maintained after a few years. Further doubt is cast upon the ªsoundnessº of this Plan by virtue of there being conflicting policies within it. The Council seem to think that the Green Belt site NE of Chesham is sustainable and provides easy access to public transport including the tube station yet the same Plan promotes a considerable increase in retail development in the town (local draft plan policy SP EP3) , part of which would be built on the very car park that serves the Chesham tube station. This is inconsistent and unsound. For this Plan to be sound it must also be effective, however, there are serious questions about the deliverability of this land. The main landowner is a farmer who has asserted publicly and in a letter to the editor of Your Chesham, that he is not prepared to release all of the land in his ownership for development. The land is also potentially an Asset Of Community Value. The community group (Brown Not Green) have stated their intention is to preserve the land given that many hundreds of local people have habitually used the fields at Lye Green as of right for various informal outdoor recreational purposes. This land also provides an important habitat for wildlife that will be threatened by development of this land and would conflict with the Governments goals as set out in the 25 Year Plan. The primary aim of Green Belt land (as recited in NPPF 133) is to prevent urban sprawl and to preserve the openness of the area. The Lye Green site (SP BP2) self-evidently performs this function well and has done so for decades. Another aim of Green Belt land stated in NPPF paragraph 134, is to prevent neighbouring towns and settlements from merging into one another.The Green Belt land NE of Chesham performs exceptionally well in maintaining a distinct separate between settlements of Chesham & Lye Green as well as helping to maintain separate identities of other nearby communities at Orchard Leigh, Botley, Whelpley Hill, Ashley Green. It is perverse and inconsistent with national guidance to allocate this land for removal from Green Belt in light of these facts especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if earmarked for development. A further aim of Green Belt designation stated in the NPPF at paragraph 134 (e) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. By allocating Green Belt land
9238 NE of Chesham for development, undermines this aim within Chesham. A community lead not for profit organisation called Chesham Renaissance CIC has been striving to create Chesham Masterplan that would not only provide many genuinely affordable homes in more sustainable locations nearer the town centre, but which would also regenerate some of the more deprived wards within Chesham. The Local Authority's proposals (policy SP EP3) are inconsistent with this local initiative and are therefore also inconsistent with national guidance and are consequently unsound. I believe that should the Plan proceed in its current form it will have a significantly detrimental impact on the town of Chesham and its surroundings. The re-designation of land within the town centre for commercial is unnecessary and would further compound issues of parking, congestion, and air quality. PP Mods - Please specify as I refer to the comments previously submitted but in summary would advocate that; precisely and succinctly as All other options are fully explored including increased density of development of brownfield land and the possible how you would policies emerging from Chesham Masterplan. modify this policy to improve its alignment to this test of Commercial development opportunities within the Town centre should be reconsidered on the basis of scale soundness. and access.This should be re-assessed in the context of a masterplan that would deliver a more sustainable and integrated approach. Green Belt land should only be considered when all other options are exhausted and in any event the proposals for developing land NE of Chesham (policy SP BP 2) should be removed as it is an unsustainable location the development of which will cause harm to the wider town including loss of an asset that improves the well-being for the community. Policy 1 - If you do not I refer to comments previously submitted. believe this policy to be justified please explain why Policy 2a - Please specify as I refer to comments previously submitted. precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not I refer to comments previously submitted. believe this policy to be effective please explain why. PAa - Please specify as I refer to comments previously submitted. precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I believe the draft Local Plan is NOT legally compliant because it has not demonstrated sufficient regard to believe this policy in the National Planning Policy Framework (NPPF) and guidance issued by the Secretary of State. consistent with the National Local Authorities MUST demonstrate they have exhausted all options BEFORE considering revision of Green Planning Policy Framework Belt boundaries. This Local Plan is seeking substantial modifications to Green Belt boundaries including the Feb 2019 please explain why removal of Green Belt designation of 13 areas within the Districts as well as modifying the Green Belt status of many local villages. It is perverse to claim that the combination of housing need and the presence of significant areas of development constraint policy collectively represent ªexceptional circumstancesº (as required in the NPPF) to justify modification of Green Belt boundaries especially given the NPPF states that one of the key features of Green Belts are their permanence. `Green Belt' Briefing Paper Number 00934 dated 4th January 2019 highlights that increasing number of residential units that are being built on greenfield sites within the green belt. Whilst this is an alarming trend, the paper noted that: Green belt boundaries may well need to change, but only through careful reviews over wider areas than single local authorities, and where safeguards are put in place to ensure that development is sustainable, affordable and delivered in a timely manner, and without prejudice to the renewal of brownfield land. In addition, the Government recently published a document `A Green Future: Our 25 Year Plan to Improve the Environment' stating: Respecting nature's intrinsic value, and the value of all life, is critical to our mission. For this reason, we safeguard cherished landscapes from economic exploitation¼. We need our planners to address sustainable development opportunities with a more diligent approach; rather than using public resources to attempt to justify unsustainable developments within our green belt. I consider the proposed Local Plan lacks inspiration or creative proposals to facilitate sustainable development or improvements to our local environment. I contend this draft Local Plan has not demonstrated that all other options have been fully explored and as such this Plan is not justified, sound or in accordance with National Policy and accordingly is not legally compliant. The Government has also recently confirmed its aim for the UK to have net zero carbon emissions by 2050 and it is noted within the Sustainability Appraisal supporting this Draft Local Plan, that the Plan area is forecast to see carbon emission increase by 21% in the Plan Period. Accordingly, the Plan is inconsistent with Government Policy and therefore not legally compliant.
9239 There is also a significant infrastructure funding gap acknowledged within the Community Infrastructure Levy evidence that supports this Local Plan, of between £179m & £231m. Given this infrastructure is vital to attempt to achieve development that is sustainable (as also required by the NPPF) this further demonstrates the Plan is both unsound and not legally compliant. Policy 3a - Please specify as The Plan needs to be modified by; precisely and succinctly as Co-operating with other nearby authorities. Not just Aylesbury. It is simply unsatisfactory to assert this cannot possible how you would be done because they are different Functional Market Areas and that co-operation is not necessary therefore. modify this policy to improve its alignment to this test of Exploring such wider co-operation may result in further housing needs being taken elsewhere. soundness. A more detailed appraisal of brownfield land opportunities MUST be undertaken. Some brownfield opportunities have been ignored or missed. Closer scrutiny of alternative options for housing delivery should be explored (such as Chesham Masterplan by CIC Chesham Renaissance). Green Belt boundary reviews should only be considered AFTER all other reasonable alternatives have been exhausted. In the face of NPPF guidance and a more thorough appraisal of Green Belt sites being considered, it may then be necessary to conclude that it is not possible to identify poor performing Green Belt sites that can accommodate all the OAN for housing. Consequently, it may be necessary to accept that a lower housing provision figure is appropriate. Policy-level file upload - 5493127 Please attach any supporting evidence
Person ID 1220922 Full Name Mrs Ann Vincent ID 2347 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this
9240 modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The proposals to release Green Belt land to meet housing targets (Generally, Spatial Policy SP SP1 & not believe this policy to be specifically Policy SP BP2 at Lye Green NE of Chesham) are not justified from the evidence submitted by positively prepared please the Councils. explain why
9241 The Councils have stated that release of some Green Belt is necessary as part of an overall three part strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. I question the soundness of such a general policy and whether all the brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites and in particular the Green Belt site NE of Chesham at Lye Green. The development of such Green Belt sites involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient and unfunded. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham cannot accommodate any significant highways improvements anyway due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion, with further worsening air quality. Air pollution is a particular concern in Chesham due to the already poor air quality along Bekhampstead Road where there is a designated Air Quality Management Area that already is recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will generate more traffic will make the air quality even worse and insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable nor justified nor is it in accordance with Govt policy. The Green Belt site NE of Chesham (SP BP 2) is not a sustainable location. It is over 2Km away from the train station and slightly further still from the town centre but anyone who cares to walk or cycle this distance also has to negotiate a steep hill too. Such an unsustainable location cannot be made sustainable merely by upgrading a couple of public footpaths within the site into bridleways to facilitate cycling. Neither does adding a bus stop address the geography or topography of the area especially if the promised enhanced bus service (which is already infrequent) either does not materialise or if it subsequently fails to be maintained after a few years. Further doubt is cast upon the ªsoundnessº of this Plan by virtue of there being conflicting policies within it. The Council seem to think that the Green Belt site NE of Chesham is sustainable and provides easy access to public transport including the tube station yet the same Plan promotes a considerable increase in retail development in the town (local draft plan policy SP EP3) , part of which would be built on the very car park that serves the Chesham tube station. This is inconsistent and unsound. For this Plan to sound it must also be effective. Unfortunately, further review of the proposal to remove land NE of Chesham at Lye Green from Green Belt designation is not effective as there are serious questions about the deliverability of this land. The main landowner is a farmer who has asserted publicly and in a letter to the editor of Your Chesham, that he is not prepared to release all of the land in his ownership for development. The land is also potentially an Asset Of Community Value and upon confirmation of this designation it would afford a community group the right to bid for the land. The community group (Brown Not Green) have stated their intention is to preserve the land given that many hundreds of local people have habitually used the fields at Lye Green as of right for various informal outdoor recreational purposes. These uses themselves may mean that many local individuals may have acquired easements over and across the land through prescription (20 years uninterrupted use) not least of whom would be the many private residences bordering the fields that have rear garden gates onto the fields at Lye Green. These easements and prescriptive rights may render the land very difficult to develop and make i undeliverable in planning terms. This land also provides an important habitat for wildlife that will be threatened by development of this land. It is perverse that the Local Authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Plan is unsound. The foregoing also points to flawed methodology of Green Belt site selection used by the Local Authority, which is neither effective, justified nor consistent with national policy and as such is unsound. Specifically, the selection of the land NE of Chesham at Lye Green (policy SP BP2) for removal from Green Belt designation is inconsistent with National Planning Policy Framework (NPPF). Paragraph 136 of the latest NPPF asserts that Green Belt boundaries should only be modified in ªexceptional circumstancesº. The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances. The Council engaged third party consultants to undertake the Part 1 Green Belt assessment and they identified numerous sites for ªfurther considerationº where exceptional circumstances ªmightº exist but expressly recommended further review of their assessment of each site against the 5 purposes of land being in Green Belt of all these sites. Unlike the neighbouring Local Authorities, the Part 2 Green Belt assessment was not undertaken by third party consultants but by the Local Authority itself who notably then did not undertake all the recommended reviews of each site including the land NE of Chesham at Lye Green (SP BP 2). Accordingly, this oversight in the Part 2 Green Belt assessment placed premature focus and fixation on releasing land at Lye Green NE of Chesham from Green Belt designation. The subsequent identification of the Chesham site for release is therefore unjustified. These comments apply equally to proposals effecting the villages in the Green Belt ± policies SP PP1 & DM PP1) The primary aim of Green Belt land (as recited in NPPF 133) is to prevent urban sprawl and to preserve the openness of the area. The Lye Green site (SP BP2) self-evidently performs this function well and has done so for decades. Another aim of Green Belt land stated in NPPF paragraph 134, is to prevent neighbouring towns and settlements from merging into one another.The Green Belt land NE of Chesham performs exceptionally well in maintaining a distinct separate between settlements of Chesham & Lye Green as well as helping to maintain separate identities of other nearby communities at Orchard Leigh, Botley, Whelpley Hill, Ashley Green. It is perverse and inconsistent with national guidance to allocate this land for removal from Green Belt in light of
9242 these facts especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if earmarked for development. A further aim of Green Belt designation stated in the NPPF at paragraph 134 (e) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. By allocating Green Belt land NE of Chesham for development, undermines this aim within Chesham. A community lead not for profit organisation called Chesham Renaissance CIC has been striving to create Chesham Masterplan that would not only provide many genuinely affordable homes in more sustainable locations nearer the town centre, but which would also regenerate some of the more deprived wards within Chesham. The Local Authority's proposals (policy SP EP3) are inconsistent with this local initiative and are therefore also inconsistent with national guidance and are consequently unsound. The Council have asserted that Government planning policy requires local councils to review Green Belt boundaries when considering how to accommodate the development needed in their areas. Just because the Council may be required to look, does not mean the Council should review Green Belt boundaries which as previously stated should only be modified in ªexceptional circumstancesº. National Planning Policy Framework (NPPF) as revised only last year, states in paragraph11 (b) I, directs ªplan makersº to create policies that are required in Local Plans for housing and other uses unless Framework policies (expressly including Green Belt) ªprovides a strong reason for restricting the overall scale type or distribution of development in the plan areaº Accordingly, I submit that given all of the above the land being proposed for release from Green Belt designation around Chesham is unjustified and contrary to national guidance. I feel the land NE of Chesham is an unsustainable location for development, that has been habitually used by the community for improved health & wellbeing for decades and the land performs well against Green Belt aims and objectives. Exceptional circumstances for reviewing Green Belt boundaries at this location, either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by Govt Policy and therefore the plan is unsound. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I believe the draft Local Plan is NOT legally compliant because it has not demonstrated sufficient regard to believe this policy in the National Policy and guidance issued by the Secretary of State. consistent with the National The National Planning Policy Framework (NPPF) together with other guidance issued by the Government Planning Policy Framework is also supported by recent ministerial statements that have made it clear that Local Authorities MUST Feb 2019 please explain why demonstrate they have exhausted all options BEFORE considering revision of Green Belt boundaries. This Local Plan is seeking substantial modifications to Green Belt boundaries including the removal of Green Belt designation of 13 areas within the Districts as well as modifying the Green Belt status of many local villages. I contend this draft Local Plan has not demonstrated that all other options have been fully explored and as such this Plan is not justified, sound or in accordance with National Policy and accordingly is not legally compliant. Furthermore that Paragraph 11 b) of the NPPF (and the footnotes thereto) require Plan Makers to provide for objectively assessed needs for housing and other uses UNLESS the application of Framework policies (including Green Belt) provide a strong reason for restricting the overall scale, type or distribution of development in the plan area Chiltern District & South Bucks are significantly constrained by development policies such as Green Belt & Areas of Outstanding Natural Beauty (AONB). The Local Plan is therefore inconsistent with National Guidance and as such it is not legally compliant for the Local Authority to claim that housing needs justify a review of these same Green Belt boundaries. It is perverse to claim that the combination of housing need and the presence of significant areas of development constraint policy collectively represent ªexceptional circumstancesº (as required in the NPPF) to justify modification of Green Belt boundaries especially given the NPPF states that one of the key features of Green Belts are their permanence.
9243 The Government has also recently confirmed its aim for the UK to have net zero carbon emissions by 2050 and it is noted within the Sustainability Appraisal supporting this Draft Local Plan, that the Plan area is forecast to see carbon emission increase by 21% in the Plan Period. Accordingly, the Plan is inconsistent with Government Policy and therefore not legally compliant. There is also a significant infrastructure funding gap acknowledged within the Community Infrastructure Levy evidence that supports this Local Plan, of between £179m & £231m. Given this infrastructure is vital to ensure that development is sustainable (as also required by the NPPF) this further demonstrates the Plan is both unsound and not legally compliant. Policy 3a - Please specify as The Plan needs to be modified by; precisely and succinctly as Co-operating with other nearby authorities. Not just Aylesbury. It is simply unsatisfactory to assert this cannot possible how you would be done because they are different Functional Market Areas and that co-operation is not necessary therefore. modify this policy to improve its alignment to this test of Exploring such wider co-operation may result in further housing needs being taken elsewhere. soundness. A more detailed appraisal of brownfield land opportunities MUST be undertaken. Some brownfield opportunities have been ignored or missed. Closer scrutiny of alternative options for housing delivery should be explored (such as Chesham Masterplan by CIC Chesham Renaissance). Green Belt boundary reviews should only be considered AFTER all other reasonable alternatives have been exhausted. In the face of NPPF guidance and a more thorough appraisal of Green Belt sites being considered, it may then be necessary to conclude that it is not possible to identify poor performing Green Belt sites that can accommodate all the OAN for housing. Consequently it may be necessary to accept that a lower housing provision figure is appropriate. To take account of the the immediate powers given to councils in 2010 by the minister of Housing ;The Rt Hon Greg Clark MP, to ªprevent the destructive practice of garden grabbingº, a practice which had seen the proportion of new homes built on gardens rise from 1 in 10 to 1 in 4 `robbing communities of green breathing space, safe places for children to play, havens for urban wildlife and protection from erosion' This was enshrined in the National Planning Policy Framework (NPPF Policy-level file upload - 5493136 Please attach any supporting evidence
Person ID 1220941 Full Name Mr John Conley ID 2369 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible.
9244 Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the
9245 examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do No additional shops should be built. Chesham has over a dozen charity shops, because there is insufficient not believe this policy to be demand in the town and retailers have increasingly gone out of business. I appreciate that there is a national positively prepared please drive to rejuvenate High Streets, but the aging population is tech. savvy and online retailing will continue to explain why grow, because it is so much more convenient. 500 additional houses will add some hundred extra cars. Having lived here for 35 years and commuted through Chesham for the previous 10, no additional cars should be added to the already congested roads of Chesham. Much of the locality is designated as Area of Outstanding Natural Beauty and attracts visitors, and cyclist, who boost the local economy In filling in such villages as Hawridge and Cholesbury would blight them and make them much less attractive visitors. Chesham commuters, by Tube, have benefitted enormously from the re-introduction of the direct service to Aldgate and this has attracted a considerable number of City workers to move to Chesham. So much so that my wife who commutes daily to the City has had to leave earlier and earlier to get a seat. Additional housing in the area without increasing the number of trains to London will only worsen this situation. Any suggestion of building anything on the town car parks is simply not sensible. I work from home and often mid-week struggle to find a parking space and simply do not try between 09:30 and 5-30 on Saturdays. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not All brown field land, or poor agricultural land in the area should be developed first, rather than build on the believe this policy to be Green Belt. justified please explain why Policy 2a - Please specify as I simply cannot understand why building on the Green Belt was proposed when just a few miles away precisely and succinctly as Bovingdon airfield, a huge brown field site is available. possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1220971 Full Name Mr Andrew Davis ID 2417 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details
9246 Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence
9247 Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I object to this proposed development that would permanently lose good quality agricultural land which is an not believe this policy to be economic asset with considerable community and environmental value and will replace it with a relatively positively prepared please high density of 500 houses, 15 traveller pitches and a shopping arcade..This will generate intolerable pressure explain why on local traffic with possibly 1,000 plus additional cars acerbating existing problems and as many new children over the next 15 years requiring more schools whilst the nearest one is no longer available having already been similarly developed. I am also very concerned about the erosion of our Green Belt and any precedents which are being set for further infilling elsewhere and even endangering our AONB. I am aware that Government is setting some of these overambitious housing targets and where we lack truly independent councilors our democracy is threatened by party pressures on those with political connections. If we are to fulfil some of these housing requirements then better brownfield sites are available elsewhere as already suggested by other groups opposing this plan. This land is obviously attractive to groups of National builders, some of whom have a bad record for quality and imposition of penal leases, but smaller sites could encourage local builders where infrastructure may already exist and the impact of more cars and children less concentrated. Much is often made of ªaffordableº housing in these developments which is misnamed whilst truly affordable are the cheaper, but better built, houses on the local market, some with larger gardens than estate-builds, which can be enhanced by neighbourhood builders as required and keep communities together whilst retaining the economy within them. Such recycling of housing stocks should be encouraged wherever possible. If additional building is kept more within walking distance of Chesham it will stimulate our in-town shopping and reduce some of the needs for cars and parking. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
9248 Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5493165 Please attach any supporting evidence
Person ID 1220910 Full Name Victoria Danaher ID 2332 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You
9249 will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Policy SP BP9 not believe this policy to be
9250 positively prepared please This policy is based on over-inflated government housing need figures. For this reason this policy should be explain why completely deleted from the Local Plan as it is unsound. Analysis has not been carried out to examine the use Brownfield sites first before releasing Green Belt.This makes the policy unjustified. It is also not positively prepared and it is unsustainable and there will be excessive strain on roads and local infrastructure. It is also not effective as the Local Plan is evidently undeliverable, it would not provide any new affordable housing, it would create gridlock with traffic and does not include the infrastructure development that is needed. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not There are no exceptional circumstances for the release of Green Belt. Policy clearly states that housing believe this policy in need, even when based on sound figures (which does not apply here), is not `exceptional circumstances'. consistent with the National Therefore the Local Plan is not legally compliant with the National Planning Policy Framework (NPPF) 2019. Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1220923 Full Name Dr Peter Whitaker ID 2348 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details
9251 Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has
9252 met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The Local Plan has the major defects of having failed to take proper account of alternative local proposals not believe this policy to be (Brown not Green; and the Chesham Masterplan) and of lacking the required funding, and it is thus positively prepared please fundamentally undemocratic, unsound, unreasonable and unfit for purpose. explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not The Plan proposes to sacrifice significant areas of the Green Belt to support planned development; this believe this policy in appears incapable of reconciliation with the National Planning Policy Framework (NPPF) of February 2019, consistent with the National in that no compelling case for ©exceptional circumstances© has been set out to justify the incursion into Planning Policy Framework protected Green Belt land. It is possible that the Plan is in fact unlawful for this reason. (NPPF Sections 8 Feb 2019 please explain why (c) and 20 (d)) The NPPF recognises a number of important functions of Green Belt land, including the protection of biodiversity (habitat protection), and therefore the preservation of the chalk stream ecosystems that characterise this area. It is difficult to escape the conclusion that elected members are uninformed about the urgency of environmentally responsible planning, or alternatively, that they have chosen simply to disregard the issue. (NPPF Part 13, Sections 133-4; 136-7 and 144-5) The 21% increase in carbon footprint (LEPUS Sustainability Appraisal June 2019, page 33) associated with the proposed development underlines the point made above: this Plan is environmentally grossly irresponsible. (NPPF Part 14, Section 150 (b)) Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5493140 Please attach any supporting evidence
Person ID 1220943
9253 Full Name Gwen Ing ID 2370 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness?
9254 Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do We must keep our green belt safe for the beautiful countryside locally, the wildlife and most of all the quality not believe this policy to be of life for the inhabitants of Chesham. positively prepared please I realise that there is a housing shortage and that waiting lists for rented accommodation are long but feel explain why that this plan will not solve the problem locally as these houses are likely to be bought by people outside of the Chiltern area and that those on the renting list will not be able afford them even if some are said to be `affordable'. This will mean a further strain on services such as doctors, police , fire, refuse collections and most of traffic congestion. The people waiting for rental accommodation will just not be catered for. Trying to get in and out of Chesham during the rush hour is already at its upper limit. The parking on local roads during the day by people using the station is horrendous i.e. Chartridge Lane and the road along by the cricket meadow and I am sure many other places.With houses now mostly having two cars I cant imagine what an impact this will have on our town if these plans are fulfilled. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
9255 Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1221013 Full Name Mr Rodney Culverhouse ID 2490 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You
9256 will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Much of the building work could be accommodated nearer the centre of Chesham. What you propose will not believe this policy to be produce one to two vehicles per household and swamp the roads with more and more traffic.Your County
9257 positively prepared please Council have done nothing with this road network for many years and it is already stretched to accommodate explain why the present vehicle density. Why not build nearer the centre within walking/cycling distance of the town. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not Your local plan (regulation 19) is neither legally compliant nor sound. I object to it. believe this policy in You propose to build on green belt (agricultural farmland) against the wishes of the owners. It is an consistent with the National unnecessary disturbance of our lovely green belt. Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1221023 Full Name David Walker ID 2514 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider
9258 the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to
9259 Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The loss of Green Belt in the Ley Green area not believe this policy to be The loss of a unique local village being absorbed into "Greater Chesham". positively prepared please explain why The additional pressure on our already overcrowded roads with people negotiating the 2.5 km and steep hill. The above also creating more pollution and an increase in the carbon footprint by 21% The proposal to remove villages from Green Belt and to permit in filling development within these villages The proposal to build 120,000 sq feet of new retail opportunities on the car parks that currently serve the town centre It does not provide more affordable homes in sustainable locations nearer the town centre PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1221024 Full Name Linda Walker ID 2529 Order 236
9260 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as
9261 precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as I have been impressed with the Chesham Renaissnce CIC Masterplan. It has given careful consideration to precisely and succinctly as utilising brown field sites, to develop affordable housing in the town centre, to reduce the carbon footprint by possible how you would minimising the need to use motorised transport. It also proposes moving industrial activities to a nearby out modify this policy to improve of town location, which frees up more space and will reduce the use of heavy goods vehicles in the town its alignment to this test of centre. Most importantly, it does not destroy more Green Belt. soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not It is not in accordance with the NPPF believe this policy in Specifically, I object to the following in your plan:
9262 consistent with the National The loss of Green Belt in the Ley Green area; Planning Policy Framework The loss of a unique local village being absorbed into "Greater Chesham"; Feb 2019 please explain why The additional pressure on our already overcrowded roads with people negotiating the 2.5 km and steep hill; More pollution and an increase in the carbon footprint by 21%; The proposal to remove villages from Green Belt and to permit infilling development within these villages; The proposal to build 120,000 sq feet of new retail opportunities on the car parks that currently serve the town centre; It does not provide more affordable homes in sustainable locations nearer the town centre; Finally, I am appalled at the lack of publicity given by you regarding the opportunity to give our views. If it were not for the Brown Not Green Chesham Ltd, we would not have been informed about how to and when to respond. We are also indebted to the Your Chesham publication and the articles by Andrew Ketteringham and Phillip Plato. I support their approach wholeheartedly. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1220984 Full Name Mr Martin Prett ID 2440 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested
9263 modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible
9264 Policy Level - PP - If you do This letter is to show my disapproval of your proposal to build on the green belt in Chesham and the not believe this policy to be surrounding areas. As this is just not justified in this setting.The amount of homes proposed should be closer positively prepared please to Chesham in order to rejuvenate Chesham as shown in the Chesham master plan documents. explain why The site selection methodology is not appropriate as lye green is good quality agricultural land that separates lye green from Chesham and is almost 2.5km from the town centre & located up a steep hill, that will only create more traffic congestion and worsen local air quality in Chesham. This is not a sustainable location to build on! Is a local plan that predicts an increase carbon footprint of +21% acceptable and where is the proof that any suggested mitigation will be delivered or will even work? PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not The local plan has an acknowledgment funding gap from the community infrastructure levy of between £179 believe this policy to be & £231 million! How can this be justified, effective or even legal! justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not This is not effective or justified or in accordance with NPPF to allocate green belt land NE of Chesham ( believe this policy in policy sp bp2) for housing when that site has been used for decades for informal recreation by locals and is consistent with the National potentially to be listed as a asset of the community value! Planning Policy Framework The green belt release is not consistent with local plan policies to protect wildlife habitats or biodiversity or Feb 2019 please explain why to protect our globally scare local chalk stream rivers ... I believe this plan undermines them. Government guidance NPPF tells plan makers to provide for housing & other uses unless green belt policies ( for one ) provide a strong reason not to. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1221003 Full Name Mr Sarju Dodhia ID 2480 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body?
9265 Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act
9266 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I do not think this is a viable solution. The site is too far from the town and station for people to walk or not believe this policy to be commute to. The road is too narrow at the lye green end of the site anyway. This will only add to the traffic positively prepared please in chesham. The problem with the town is that it's in a valley and there are only 3 roads in and out. Pollution explain why in the town is already above safe limits without adding to it with extra cars from the proposed site. This is not taking into account HS2 even. The increased carbon footprint is unacceptable too in this day and age of environmental awareness. Building on green belt should be a last resort yet here it seems to have been the only option considered. The Chesham master plan has some much more viable options to build with greater density in the town's brownfield sites that will create genuine affordable housing while helping to regenerate the town and not taking away the green fields that are enjoyed by many As a recreation area. While we all should be reducing car usage this site is just too far from the town to walk to. Steep hills and even light shopping bags do not go well together. PP Mods - Please specify as The Chesham master plan I feel is a more sensible and viable alternative. precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would
9267 modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5493183 Please attach any supporting evidence
Person ID 1221080 Full Name Lionel Barber ID 2611 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as
9268 precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The proposals to release Green Belt land is solely, agreed there is no reason to meet housing targets from not believe this policy to be the evidence submitted. There is a need for better use of the existing properties be they housing, shops, positively prepared please offices, warehousing or factories. explain why The Councils have stated that release of some Green Belt is necessary as part of an overall three part strategy involving: (1) focus on built-up areas to build dwellings on previously developed land. I Ask:- ªWhat does this really meanº (2) an exported proportion of housing need to go to the Aylesbury District. I Ask:- Aylesbury is twenty miles away from Chesham and there are lots of green fields in -between (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt I state:- If you dig it up it won't grow back or If you build on it you will destroy it. Or When it's gone, it's gone I question the soundness and reasoning of adding to the enormous stain experienced by today's population of Chesham at times we already experience traffic journey time dating back to the turn of 1900 when we only had one horse power and you want to add considerable more house power, more Homes, shops requiring delivery vehicles of all sorts onto Chesham limited road network and infrastructure. The sewerage works can't cope at times and when we have thunderstorms the drains overflow. Why take the green belt it's the only area that's available for us all. Why just because you might be rich and able to live in great houses in say, Gerrard's Cross, Chesham Bois, Denham should these areas not be fully
9269 considered for in-fill. One house in these areas has a footprint that if developed might accommodate ten or more houses of the size proposed for Lye Green. These in-fills would allow for no change to the green belt, for are these existing properties classified as brownfield land do they not offer opportunities for the higher densities of development that is being offered to the ª working classesº or the social housing class. Such sites would not require any road infrastructure improvements as the roads are so quite. What is the rush in destroying the green belt or other properties? Why not calculate the council or business rates/tax on a weekly bases and with proper enforcement. Any and all empty or under used properties be they second homes or just empty for any reason should and would face an additional charge by placing a zero on the end of the weekly charge, this charge would apply, until the property is sold, let or demolished for redevelopment. Empty properties and lived in and the authorities would generate additional badly needed income. I.E. a band `D' (just for calculation and demonstration) weekly charge of £52.00 but for an underused property the weekly charge would be £520.00 at £6240.00 per year not many properties would be empty for long. I understand there is a discount formula in operation but no property in today's climate should be empty. Chesham cannot accommodate any significant highways improvements due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion adding to climate change and with further worsening air quality. Who will be asked to pick up the bill for all the required infrastructure changes and alterations? Well surprisingly it's the existing residences the tax payers. As one of these I don't want the green belt dug up and I don't want to subsidise the fat cats of the building industry. Stop selling any more social houses and if ex-social housing is for sale take it back for social housing. That why it was built and paid for out of our taxes in the first place. It's our green legacy to our future children and their children. Chesham is not a sustainable location for this sort of infrastructure development. Chesham might at the end of the Metropolitan line, but it's not London. As anyone who is fit enough to walk or cycle around Chesham will tell you it has some very steep hills but overall there are limited safe roads. They are narrow and with parked cars either-side mostly with one wheel on the pavements the town is getting smaller. One takes one's life in ones hands just to walk down some streets so how merely by upgrading a couple of public footpaths or bridleways is going to facilitate safe cycling. What will 900 additional cars, lorries or busses do for road safety in Chesham. So Chesham might be getting a new, promised enhanced bus service. Heard that one before but the busses were lost on cost grounds. But it will probably never materialise and if it does it won't last. I object to any further green belt being taken for any reason from the people, in this case we that are Chesham residents. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
9270 Policy-level file upload - Please attach any supporting evidence
Person ID 1221331 Full Name Mrs Janice Vose ID 4321 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications
9271 to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I am very concerned about the proposed plan to build 500 houses, plus shop and 15 traveller pitches on not believe this policy to be Green belt land NE of Chesham etc, and the impact it would have on the town of Chesham and surrounding positively prepared please areas. explain why The doctors surgeries are struggling to cope as their patient lists are full, also our dentists and our schools are suffering. Two schools in the past few years were demolished to make room for more housing and now we don't have enough education and sports facilities for the local children. We need more of these facilities to accommodate the increase in the existing population of Chesham. Certainly not more housing to make the problems worse. What, if any, provisions will be made to accommodate the added population in this area if this planning should go ahead. What about the infrastructure needed for this amount of housing. Water supplies, waste disposal, sewerage, roads, pavements, lighting etc., etc. The whole area is already suffering from problems with our Chalk streams drying up, problems with the aquifers in the town and the increase in waste disposal. Our chalk stream is one of only a few left in this country. What provisions would be put in place to alleviate these problems and other problems for a growing population. Another problem that would be exacerbated is the traffic congestion we already suffer from. Especially if there's an accident or problem on either the M25 or the A41. It is becoming a more regular occurrence in the last couple of years. Nashleigh Hill already has a great amount of traffic using it and some traffic is known to cut through side roads from the other side of Chesham to get to Nashleigh Hill, rather than queue. Severalls Avenue has become a `rat run' lately, causing residents to worry about their parked vehicles being damaged or elderly being knocked over when crossing the road.
9272 The thought of an increase of possibly 500+ cars at a minimum, using these roads, and area is a daunting thought to say the least and very dangerous in my humble opinion. I cannot believe it is even an option to consider building on Green Belt land (or Agricultural land), the thought of building homes on brown field land (for factories, businesses etc)is bad enough. Green Belt land was designated for a purpose, as was brown fields. We have Heritage lands and woodlands/forests that need to be looked after. Enough damage is being down by HS2 in this respect with out housing estates being built everywhere. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1221398 Full Name Dr Gordon Keenay ID 3080 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name
9273 Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination
9274 Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The brownfield land opportunities have not been properly identified. Nor does it consider higher not believe this policy to be densities of development on such sites which are likely to be closer to the town centre than the Green Belt positively prepared please sites and in particular the Green Belt site NE of Chesham at Lye Green. explain why The proposed development at Lye Green involving many hundreds of homes will generate substantial increased traffic, and although some highways improvements are suggested, they are insufficient and unfunded. In Chesham the evidence shows that most of the road junctions and infrastructure are operating above capacity. A further concern is that air quality would be further impaired. The Lye Green site NE of Chesham is not a sustainable location. It is over 2Km and a steep hill away from the tube station, so access would not be easy. Hardly anyone would walk or cycle this distance. And it is not credible that a reasonable bus service would be provided and maintained long-term. Most of the residents would use cars. Further doubt is cast upon the soundness of this Plan due to its conflicting claim that there would be easy access to public transport including the tube station at the same time that car parking would be reduced by retail development. This is inconsistent and unsound. PP Mods - Please specify as Please see the comments above. We consider that the use of Green Belt land should only be considered precisely and succinctly as as an absolutely last resort and that the proposals for developing land NE of possible how you would Chesham (policy SP BP 2) should be removed in any event since it is an unsustainable modify this policy to improve its alignment to this test of location and such a development will cause serious harm to the town. soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
9275 Policy-level file upload - Please attach any supporting evidence
Person ID 1221404 Full Name Mr Steve Hedges ID 3147 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications
9276 to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do A serious traffic problem not believe this policy to be Lack of resources and amenities positively prepared please explain why Pollution problems Many areas of outstanding natural beauty Flooding issues which would clearly be much worse with the proposed concrete bases/roads Noise pollution for the surrounding villages e.g 500 mowers, cars etc. 1000 extra cars traveling to and from work and shops gyms etc. at least 3000 vehicle . movements a day ! Lack of jobs locally Sewage issues, can©t cope now with the river pollution/overflowing Overhead electric cables in the villages are unreliable now Walkers using the proposed areas for recreational use dog walking, horse riding etc. Lack of footpaths Narrow lanes leading out of the surrounding areas Wildlife !!! Many many more reasons why these developments cannot happen in these beautiful areas. A development like this is more suited to an industrial area which is run down/derelict near to main roads/motorways Children in juinior schools would be able to see that these plans are flawed, not to mention the added carbon footprint these plans would cause !!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! Please wake up and smell the roses ?????????
9277 PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I have just noticed that Policy SP BP 2 may not be legal ? After all it is an Asset of Community value ! Is this believe this policy in all legally compliant or sound . consistent with the National THIS PROPOSAL IS NOT JUSTIFIED. WILL NOT BE EFFECTIVE AND MAY NOT BE IN ACCORDANCE Planning Policy Framework WITH THE NATIONAL GUIDANCE OF THE NATIONAL POLICY FRAMEWORK (NPPF) Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1221409 Full Name Sharon Morris ID 3162 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant.
9278 Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as
9279 precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I wish to comment on the local proposals to build houses on ©Green Belt © land. I am totally against using not believe this policy to be land classed as Green Belt to be used in this way. My reasons are with regard to traffic congestion, pollution positively prepared please and the complete lack of an infrastructure to accommodate such building in the community. The traffic explain why congestion currently in Chesham is dire and a further influx of vehicles destined to use these roads, would be catastrophic: Business/school rush hour congestion is extremely difficult now and the structure of the town center roads is inadequate to deal with hundreds of extra vehicles. Supporting community facilities, such as Dr©s Surgeries, Schools etc. available at present, would not be able to cope with an arrival of scores of new residents: Parking facilities fall more than short now in the Chesham town center; additional vehicles trying to park would cause even more congestion; not to mention the pollution this would cause. PP Mods - Please specify as Keep the Green Belt land green! precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1221144 Full Name Jamie Walker ID 2642 Order 236
9280 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as
9281 precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The loss of Green Belt in the Ley Green area not believe this policy to be The loss of a unique local village being absorbed into "Greater Chesham". positively prepared please explain why The additional pressure on our already overcrowded roads with people negotiating the 2.5 km and steep hill. The above also creating more pollution and an increase in the carbon footprint by 21%. The proposal to remove villages from Green Belt and to permit in filling development within these villages The proposal to build 120,000 sq feet of new retail opportunities on the car parks that currently serve the town centre It does not provide more affordable homes in sustainable locations nearer the town centre PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would
9282 modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1221179 Full Name Mr Paul Hinkly ID 2282 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible.
9283 Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do There is no justification to remove land NE of Chesham at Lye Green, already an existingly used Asset of not believe this policy to be Community Value, from Green Belt designation when existingly identified sustainable Brownfield land is positively prepared please available Chesham Town Centre. With Brownfield land available clearly exceptional circumstances do not explain why exist for redefining green belt boundaries. live in Lye Green Rd and highways infrastructure is already insufficient to accommodate morning and afternoon traffic peaks causing standstills and resultant air pollution. Add in commonplace winter weather or A41/M25 incident congestion and Chesham / White Hill / Broadway gridlock routinely resulting in days of 1000's of Chesham lost man hours and toxic air quality. Given the acknowledged infrastructure funding gap of the plan and the geography and topology of this area, there is no chance nor opportunity for the kind of levels of investment required to engineer infrastructure sustainability for this plan.
9284 Finally this plan's causation of a 21% increase in the carbon footprint when we have a climate emergency and such increase is in direct conflict with Government Policy, is inconsistent and unsound when compared to Chesham Brownfield building. Consequently this plan is unsound, unsustainable, unjustifiable and illegal to propose house building NE of Chesham at Lye Green PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5493085 Please attach any supporting evidence
Person ID 1221236 Full Name Mr Hans Bierrum ID 2791 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details
9285 Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has
9286 met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I am fully aware of the traffic flow especially around school times and just how grid-locked Lye Green Rd not believe this policy to be and surrounding roads become at peak times. I think that with an increase in the number of vehicles in the positively prepared please area (should the houses etc be built), that traffic will become even more congested. Besides this, I am explain why concerned about the increase in pollution that more vehicles will create coming up hills like White Hill and Eskdale Ave. When I walk up or down these roads during busy periods, I can almost taste the pollution! I feel sorry for the houses situated on these roads which will only be at risk of increased carbon footprint levels. I also believe that the drainage and sewerage systems in this area are already struggling with the amount of houses currently relying upon them. On a number of occasions while I have lived in Manor Way, I have had to have my drains un-blocked. I think that there must be a number of other areas available that would be more suited to having houses built on them. There are a number of brown-field sites around Chesham that would be far more suitable for being built on. Please do look at alternatives to this area as my family has always loved living in this area. We are very proud of the fact that we live in an ©Area of Outstanding Natural Beauty©, which is the Chiltern Hills. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
9287 Person ID 1221246 Full Name Mrs Heather Le Good ID 2817 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness?
9288 Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I am writing to register my dissatisfaction with the draft local plan to build 500 homes plus shop and 15 not believe this policy to be traveller pitches on Green Belt Land North East of Chesham. positively prepared please The Chilterns have always been considered as an Outstanding Area of Natural Beauty. Green Belt land has explain why NEVER been considered as ground for development. In fact, we must be reminded that many years ago Chesham considered a by-pass for their historic town ± to reduce unnecessary incoming traffic. However, such plans were dismissed as a by-pass would have required development of Green Belt Land. Chesham Town Council had no intention of compromising such Green Belt land for such a development. Here we are in 2019 ± and the argument repeats itself. Of course, we need to build affordable housing for those who need it ± but Green Belt land is out of the question. There are plenty of areas of Brown Land around Chesham that should be considered as a priority ± these are in more sustainable locations than the current suggested Green Belt land. I do not believe such Brown Land has even been considered by this draft plan. However, it is all very well to plan the building of so many affordable houses ± but it would seem that the impact on local amenities has not been considered either. Our local GP's are already at capacity ± as are our local schools. In addition, sewage, water supply and traffic congestion also need to be considered. I do not see that the draft plan has effectively considered these issues either. Don't forget that Accident and Emergency services have also been reduced in this area. In addition to these comments already made, we must also note the negative impact of the plans for HS2 in this area. I accept the need for affordable housing but on no account should Green Belt land ever be considered for this purpose. I also totally disagree with such decisions being made by committees who live outside Chesham ± and who will not be impacted by the inappropriate decisions they make. Leave the development of Chesham to those residents who live in the town and understand the implications of decisions made ± as they will have to live with them. Building 500 houses plus shop plus 15 traveller pitches on suggested Green Belt Land risks the removal of many local villages from Green Belt ± Botley,
9289 Ley Hill, Chartridge to name a few. If this plan is approved, it also risks infilling of other Green Belt villages ± such as Whelpley Hill, Ashley Green, Hawridge and Cholesbury. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1221258 Full Name Mr Jan Masat ID 2833 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider
9290 the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to
9291 Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I understand the planners challenge but we either have the Green Belt or we don't.Throughout the document not believe this policy to be they make subjective comments on the impact on the Green Belt e.g. `meets the Green Belt purposes positively prepared please relatively weakly'. explain why I assume that when the exceptional circumstances term was added many years ago it was put there for a reason, because it's human nature to try and negotiate letting out a bit here and a bit there. There is a need for a longer term view, a bit like we now take over the environment. On a daily basis we have been feeling unconcerned about our use of plastics but over the long term we accept we have to change. I've seen figures extracted from "Local authority green belt statistics for England: 2013 to 2014 - GOV.UK". that shows that we lost 2% of the Green Belt in 10 years. That doesn't sound too bad. But over 100 years losing 20% isn't acceptable. I understand what the planners have tried to do. Finding parcels of land with defensible boundaries makes sense. However will they sit down in another 10-20 years and start marking out the next section that is across the road? I think they will. They will be under pressure to do it again. Perhaps they'll build a `ring road' and infill inside it. In the case of Chesham the planners appear to have spotted a large piece of land that can help them locate a significant chunk of the land that they need. The roads around it provide the defensible boundary so they have decided to go all out; 500 houses and the traveller site. The challenge for Chesham is the town centre bottle neck of the road past Lowndes Park. The traffic is increasing and there is no alternative route. The planned development will include commuters so that will lead to more congestion and more air pollution. Similarly there will be rail commuters. At the moment the station car park is full up with little spare capacity (in another planning document I thought I saw that there was a proposal to change the designation of the car park to retail?). So the infrastructure is struggling already and section 106 improvements won't be able to solve the problem. Saying that the problem will be solved by buses is `head in the sand' thinking. Local bus services are not sustainable in such a small town, just the buses that pass through. Have a look at the Red Eagle bus timetable. Water abstraction should also not be ignored. The Chess river is dry through the town. It may recover after last summer but it should be considered. Where is the water going to come from? So the soundness test for me is not me. The exceptional circumstances are not met for Chesham. If they were, there are problems with the development that should not be ignored. As I have said, I understand why the planners have picked the site but they can't turn a blind eye to the problems. Ignoring them or justifying them with unrealistic solutions isn't a sustainable solution. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve
9292 its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1211699 Full Name Mr Alasdair McKay ID 4529 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-02-29 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible.
9293 Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Building on greenbelt should be a last resort and so I find the idea of taking easy profit from these sites to not believe this policy to be be unsound when there are multiple sites within current urban areas.The need for a large area of green land positively prepared please to be built on is a purely a political grand gesture to the electorate to demonstrate that a lack of housing is explain why being addressed. The need to build more family housing is not the correct option when you have an aging population in family homes and a young population wanting to take a step on to the property ladder. PP Mods - Please specify as The plan should be focusing on urban sites and their use, especially considering the ongoing crisis in the precisely and succinctly as high street. There is a need for high density, attractive housing within urban areas that is being demanded possible how you would by both the old and young so as to be close to the amenities. Having a mix of affordable one and two bed modify this policy to improve flats would be both good for society and the high streets economy. I have looked briefly at the proposal from Chesham Renaissance CIC and although it is far from perfect, it is certainly pointing in the correct direction.
9294 its alignment to this test of If this plan is disregarded completely then it makes this consultation a farce and a waste of time. I have two soundness. very young children that are going to be brought up in the area so have very little time to make to this consultation and I find the complicated structure of requesting feedback from residents an utter shambles. It is more likely to put people off and make only the few respond, disgraceful. I hope that the few people and organisations that have the time to reply are listened to and considered. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1211702 Full Name Mr Brian Kilbey ID 3978 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-02-29 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you
9295 consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible.
9296 Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not We wish to comment on the Draft Local Plan (especially pertaining to Chesham Policy SP BP2) which we believe this policy to be conclude is unsound and not justified.We find that your document is very hostile to the non-specialist reader. justified please explain why a) The passing of The Climate Change Act 2008 (2050 Target Amendment) Order 2019 has changed the requirements for future developments. All green land is a carbon sink removing carbon dioxide from the atmosphere, as well as absorbing rain. Any concreting over, for example at the impractical site below Lye Green, prevents carbon capture and contradicts the Act, so must be compensated for elsewhere in the districts. b) Any housing development must not reduce green land e.g. Policies SP LP1, SP BP2, and must be located in or very near town centres. This will reduce or eliminate extra car journeys and traffic queues down the hills into Chesham town centre, giving the additional benefit of reducing air pollution. Paragraph 4.9.2 claims that development will not be allowed without improved public transport, i.e. buses. All the previous housing developments around Chesham started with bus services, but these have withered away to very few per day or none (with the exception of Pond Park Estate, Chesham). Similarly, shops were provided for these housing developments, but all have failed (with the exception of Greenway Parade, Chesham). How will this pattern change in your new developments? No amount of redesigning road junctions will prevent traffic from new developments trying to force its way on to the A416, which is already gridlocked in rush hours. c) Housing standards are bound to be changed very soon to meet The Climate Change Act 2008 (2050 Target Amendment) Order 2019. For example, Policy DM DP5 is certain to be amended to allow for collection of rainwater, use of grey water, soakaways rather than drains, solar panels, etc. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5499132 Please attach any supporting evidence
9297 Person ID 1211802 Full Name Mr Mark Brookes ID 4481 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-03-06 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness?
9298 Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The proposals to release Green Belt land to meet housing targets are not justified on the basis of the evidence not believe this policy to be submitted by the Councils. positively prepared please The Councils have stated that release of some Green Belt is needed as part of an overall three part strategy explain why involving: · focus on built-up areas building dwellings on previously developed land, · an exported proportion of housing need to go to the Aylesbury District, and · through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. The soundness of such a general policy is to be questioned as well as whether all the brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites, particularly the Green Belt site NE of Chesham at Lye Green. The development of such Green Belt sites involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient and, more importantly, unfunded. In Chesham the infrastructure is already insufficient without the addition of large numbers of new housing. In any event, Chesham cannot accommodate any significant highways improvements due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion, with further worsening air quality. This issue is a particular concern in Chesham due to the poor air quality already along Berkhamstead Road where there is a designated Air Quality Management Area that is recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will generate more traffic will make the air quality even worse and insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable. Also it is not in accordance with Government policy. The Green Belt site NE of Chesham is not a sustainable location. It is over 2Km away from the train station and slightly further still from the town centre but anyone who cares to walk or cycle this distance also has to negotiate a steep hill too. Such an unsustainable location cannot be made sustainable merely by upgrading a couple of public footpaths within the site into bridleways to facilitate cycling. Neither does adding a bus
9299 stop address the geography or topography of the area especially if the promised enhanced bus service (which is already infrequent) either does not materialise or if it subsequently fails to be maintained after a few years. Further doubt is cast upon the Plan by contradictory policies within it. The Council believes that the Green Belt site NE of Chesham is sustainable and provides easy access to public transport including the tube station yet the same Plan promotes a considerable increase in retail development in the town, part of which would be built on the very car park that serves the Chesham tube station. Also doubt must be cast upon another element of the plan. For the proposal to remove land NE of Chesham at Lye Green from Green Belt designation to be effective the land has to be deliverable. The main landowner is a farmer who has asserted publicly and in a letter to the editor of Your Chesham that he is not prepared to release all of the land in his ownership for development. The land is also potentially an Asset Of Community Value and upon confirmation of this designation it would afford a community group the right to bid for the land. The community group (Brown Not Green) have stated their intention is to preserve the land given that many hundreds of local people have habitually used the fields at Lye Green as of right for various informal outdoor recreational purposes. These uses themselves may mean that many local individuals may have acquired easements over and across the land through prescription (20 years uninterrupted use) not least of whom would be the many private residences bordering the fields that have rear garden gates onto the fields at Lye Green. These easements and prescriptive rights may render the land very difficult to develop and make it undeliverable in planning terms. This land also provides an important habitat for wildlife that will be threatened by development of this land. It is perverse that the Local Authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Plan is unsound. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not The draft local plan is NOT legally complaint. The National Planning Policy Framework (NPPF) and other believe this policy in government guidance make it clear that Local Authorities must demonstrate all option before considering consistent with the National revision of Green Belt boundaries. Additionally, the NPPF require Plan Makers to provide for objectively Planning Policy Framework assessed needs for housing and other uses unless the application of Framework policies (including Green Feb 2019 please explain why Belt) provide a strong reason for restricting the overall scale, type or distribution of development in the plan area. Chiltern District and South Bucks are significantly constrained by development policies such as Green Belt and Areas of Outstanding Natural Beauty (AONB).The Local Plan is therefore inconsistent with National Guidance and as such it is not legally compliant for the Local Authority to claim that housing needs justify a review of these same Green Belt boundaries. It is not coherent to claim that the combination of housing need and the presence of significant areas of development constraint policy collectively represent ªexceptional circumstancesº (as required in the NPPF) to justify modification of Green Belt boundaries especially given the NPPF states that one of the key features of Green Belts are their permanence. The Sustainability Appraisal supporting this Draft Local Plan is forecast to see carbon emission increase by 21% in the Plan Period. Accordingly, the Plan is inconsistent with recently stated Government Policy to have net zero carbon emission by 2050 and therefore not legally compliant. The proposal fails to address that there is also a significant infrastructure funding gap acknowledged within the Community Infrastructure Levy evidence that supports this Local Plan, of between £179m & £231m. Given this infrastructure is vital to ensure that development is sustainable (as also required by the NPPF) this further demonstrates the Plan is both unsound and not legally compliant. I would also add that during the sixteen years that I have lived here I have noticed that the existing infrastructure has been under considerable strain and appears unfit for purpose.
9300 I contend this draft Local Plan has not demonstrated that all other options have been fully explored and as such this Plan is not justified, sound or in accordance with National Policy and accordingly is not legally compliant. The above also points to flawed methodology of Green Belt site selection used by the Local Authority, which is neither effective, justified nor consistent with national policy and as such is unsound. Specifically, the selection of the land NE of Chesham at Lye Green for removal from Green Belt designation is inconsistent with NPPF.This framework also asserts that Green Belt boundaries should only be modified in ªexceptional circumstancesº. The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances. The Council engaged third party consultants to undertake the Part 1 Green Belt assessment and they identified numerous sites for ªfurther considerationº where exceptional circumstances ªmightº exist but expressly recommended further review of their assessment of each site against the 5 purposes of land being in Green Belt of all these sites. Unlike the neighbouring Local Authorities, the Part 2 Green Belt assessment was not undertaken by third party consultants but by the Local Authority itself who notably then did not undertake all the recommended reviews of each site including the land NE of Chesham at Lye Green. Accordingly, this oversight in the Part 2 Green Belt assessment placed premature focus and fixation on releasing land at Lye Green NE of Chesham from Green Belt designation. The subsequent identification of the Chesham site for release is therefore unjustified. These comments apply equally to proposals affecting the villages in the Green Belt. The primary aim of Green Belt land is to prevent urban sprawl and to preserve the openness of the area. The Lye Green site self-evidently performs this function well and has done so for decades. Another aim of Green Belt land stated in NPPF paragraph 134, is to prevent neighbouring towns and settlements from merging into one another.The Green Belt land NE of Chesham performs exceptionally well in maintaining a distinct separate between settlements of Chesham and Lye Green as well as helping to maintain separate identities of other nearby communities at Orchard Leigh, Botley, Whelpley Hill, Ashley Green. It is perverse and inconsistent with national guidance to allocate this land for removal from Green Belt in light of these facts especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if earmarked for development. I strongly support the Brown Not Green organisation's initiative to have the land listed as an Asset of Community Value and I feel they speak for me in respect of their objections to the draft Local Plan. Accordingly, I request that any representations made by them at any future examination in public regarding the soundness of this Local Plan be considered as an extension of my own comments herein. I feel the land NE of Chesham is an unsustainable location for development, that has been habitually used by the community for improved health and wellbeing for decades and the land performs well against Green Belt aims and objectives. Exceptional circumstances for reviewing Green Belt boundaries at this location either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by Government Policy and therefore the plan is unsound. Policy 3a - Please specify as would suggest the following: precisely and succinctly as · A greater detailed consideration of Brownfield land opportunities as they clearly exist possible how you would modify this policy to improve · Collaboration with other nearby authorities in addition to Aylesbury. The argument that they are different its alignment to this test of Functional Market Areas doesn't hold water in my opinion. Wider consideration might result in additional soundness. housing needs moving to more appropriate site(s) · Alternatives such as the Chesham Masterplan should be considered · Green Belt boundary reviews should only be considered after all other reasonable alternatives have been considered I refer to my previous comments, particularly: · That other options are thoroughly explored, especially brownfield opportunities Development of Green belt land should only happen when other options are exhausted and should be removed altogether for the land in NE Chesham (policy SP BP2) as it is an unsustainable location and an asset for the town in its current form Policy-level file upload - 5501574 Please attach any supporting evidence
Person ID 1212243 Full Name Anne Hyde ID 3711 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Parish Clerk Latimer and Ley Hill Parish Council Consultee Type - Please Parish Council select the type of consultee: Date Received - Date 2016-03-15 Received:
9301 Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance
9302 with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I write in concern to the proposed changes to Ley Hill taking the gardens out of the Green Belt. not believe this policy to be I am not sure why there was no prior consultation on ©Green Belt Village Policies©. positively prepared please explain why In your document - Proposed Changes to the Adopted Policies Maps showing Botley and Ley Hill (page 65) which showing which properties are being removed from Green Belt there is a site which is between 203 and 205 Botley Road which is not a property but a Scout Hall. No one has lived there and has asbestos underground. On the map this is being removed from the Green Belt and I feel strongly that this site should remain in the Green Belt. Twice the owners have tried to get planning permission which has been refused due to access and therefore there is no reason to take this part of the site out of the Green Belt. This site has much wild life including badgers and deer so surely you should be protecting wild life. Also what is currently operating as a Riding Stables (Beechwood, Jasons Hill, Ley Hill) looks as though it is showing as also being taken out of Green Belt. Surely a residing stables should be kept as Green Belt and this site is quite large would mean that Ley Hill could end up with a huge housing estate which will change the village for ever. Are these two site selections methodology appropriate to remove from Green Belt? I moved to Ley Hill as it was a village with lots of places to walk and the wildlife. All I can see is that eventually Ley Hill will no longer a village but an extension to Chesham and that eventually houses with the larger gardens will sell to create more housing. I understand that building has to take place, but Ley Hill should be protected from merging with Chesham and that area such as the Riding Stables and Scout Hall should remain within the Green Belt. I would appreciate a response to this letter as to the reasoning behind these two sites from being removed from the Green Belt. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why.
9303 PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1212353 Full Name Mr Nigel Adderley ID 3171 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-03-13 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its
9304 legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as
9305 possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I believe the Local Plan has not properly considered the infrastructure and environmental issues which it believe this policy in would create and goes against the National Planning Policy Framework. consistent with the National I do not believe the Plan has properly examined potential brown field sites in the area closer to the town Planning Policy Framework centre which would at least ease the transport issues which high-density housing on the out-skirts would Feb 2019 please explain why create. There is also the issue of existing outlying villages being `swallowed up' by development of the green belt which is contrary to the NPPF guidance as is the failure of the Local Plan to attempt to regenerate and/or recycle derelict urban land. The area at Lye Green has now been designated an Asset of Community Value due to the informal recreational opportunities it has offered hundreds for many decades. It is perverse that the same area should be considered for development and I believe the tests applied to the area to take it out of the green belt have been stringent enough or in line with national policy. Policy 3a - Please specify as I support the proposals of the Brown not Green campaign which would maintain the current infrastructure in precisely and succinctly as the area and protect the local environment in line with national guidance. possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5497921 Please attach any supporting evidence
Person ID 1212657 Full Name Mrs J Clegg ID 5320 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-03-12 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details
9306 Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has
9307 met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not The council has released many local villages close to Chesham from the green belt which could create more believe this policy to be opportunities for small developments more suitable to a small town like Chesham. I lived in Ley Hill for over justified please explain why 40 years and am now a Chesham resident. I have used the footpaths over the proposed Lye Green Road site. I'm questioning whether the policy is sound.What provision has been made for access to water sewage? Affinity water have no access to rivers for water so take water from underground. So what is the future for the river chess? Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not The sewage plant is inadequate for current drainage levels so what is the provision for extra facilities? The believe this policy in proposed site on Ley Green Road will mean access to shops, schools; station etc. will need to be by car. consistent with the National What provision has been made to relieve air pollution on the main routes through the town which has already Planning Policy Framework been shown as extremely poor? Feb 2019 please explain why What places have been made for extra medical practices and school places? All of the above make me aware that Chesham should not be the sight of a large development. Perhaps more use of brownfield sites within the town would lessen pollution. I feel that this plan has not been positively prepared, is not justified and is not consistent with nationi0onal planning policy framework in relation to river chess Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1221299 Full Name Mr Brian Gregory
9308 ID 2916 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its
9309 alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Specifically, I object to the following in your plan.... not believe this policy to be The loss of Green Belt in the Ley Green area positively prepared please explain why The loss of a unique local village being absorbed into "Greater Chesham". The additional pressure on our already overcrowded roads with people negotiating the 2.5 km and steep hill. The above also creating more pollution and an increase in the carbon footprint by 21% The proposal to remove villages from Green Belt and to permit in filling development within these villages The proposal to build 120,000 sq feet of new retail opportunities on the car parks that currently serve the town centre. It does not provide more affordable homes in sustainable locations nearer the town centre. PP Mods - Please specify as I have been impressed with the Chesham Renaissnce CIC Masterplan. It has given careful consideration to precisely and succinctly as utilising brown field sites, to develop affordable housing in the town centre, to reduce the carbon footprint by possible how you would minimising the need to use motorised transport. It also proposes moving industrial activities to a nearby out modify this policy to improve of town location, which frees up more space and will reduce the use of heavy goods vehicles in the town its alignment to this test of centre. Most importantly, it does not destroy more Green Belt. soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why.
9310 PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1212868 Full Name Prof Paul Forster ID 3937 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Other select the type of consultee: Date Received - Date 2016-03-13 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its
9311 legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as
9312 possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not Re Ley Hill Village - area to be removed from Green Belt I was a resident of Ley Hill for in excess of 30 years believe this policy to be and remain the owner of a parcel of land with direct road access to the north of Cherry Tree Farm [our former justified please explain why residence] I submit that the plan to only partially remove Ley Hill from the Green Belt is unsound in so far as it proposes that the land to the east of the village road [The Green] is not part of the village. The effect of this is to leave that side of the village in a prejudiced position for planning purposes - being neither removed from Green Belt restrictions or benefiting from the infilling allowed in villages ©washed over© by the Green Belt [DM PP1] This would appear to be contrary to the NPPF guidance in Section 13 Protecting the Green Belt which proposes to allow limited infilling in villages in para 145 [e]. Within the Chiltern and South Bucks Local Plan the partial removal from the Green Belt [SP PP1] is justified on the basis that the land to the east of the village is of a lower density/more open character. While this is true and there are only a limited number of infilling opportunities between the north of Cherry Tree Farm and the corner with Jasons Hill, in all other respects the properties are very much part of the village being in the very centre of village life - opposite the Memorial Hall, Baptist Church and Village School. In addition, there is some local commercial activity adjacent to Crab Tree Farm and the common land/manorial waste in front of the properties is much narrower than across the side of the road to be removed from the Green Belt. It may no longer be relevant but in the last iteration of the Local Plan in 2014 Chiltern District Council proposed to designate the land between the north of Cherry Tree Farm and Jasons Hill as GB4, allowing for the very limited opportunities. I submit a more sound strategy would be to include this area in the overall village removal from the Green Belt, or alternatively, to classify the area as ©washed over© village land. Policy 2a - Please specify as As mentioned above, to reflect the integral part played by the area from Cherry Tree Farm to Jasons Hill by precisely and succinctly as including it within the Ley Hill village boundary as it is seen by all who live in the village, and thus remove it possible how you would from the Green Belt - or to make such provisions that would be equivalent to ©washed over© village land. modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1212868 Full Name Prof Paul Forster ID 3939 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Other select the type of consultee: Date Received - Date 2016-03-13 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body?
9313 Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act
9314 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not The division of Ley Hill village in to two sections, only one of which is to be removed from the Green Belt, is believe this policy to be based on an arbitrary and subjective assessment of the two sides which does not bear any relationship with justified please explain why the reality and role of the east side of The Green, which plays an integral role in the life of the village. It is also well within the overall village envelope so does not extend or impact on the Green Belt around the village. Policy 2a - Please specify as As outlined before, amend the village boundary proposal to reflect the integral nature of the area to the east precisely and succinctly as of The Green to village life and practice, thus removing it from the Green Belt. possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
9315 Person ID 1213358 Full Name Donald Barber ID 3713 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consulting Engineer Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-03-14 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness?
9316 Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Services. not believe this policy to be Construction of 500 houses will effectively create a small town. The proposed development will require all positively prepared please the essential services. explain why The distance from the town centre services, and the three steep hills between the proposed site and the town, effectively means vehicular transport will be the only effective means of travel. Roads. The proposed location of the houses will require unrestricted road access into the existing highways anticipated to be Lye Green Road/ Eskdale avenue/ White Hill, and Nashleigh Hill. These roads then feed into Berkhamsted Road, Broad Street and St Mary©s Way. All of these roads are heavily congested at peak times, causing traffic hold ups and unacceptable levels of atmospheric pollution. Sewage. The disposal of sewage from the development area will require a large new sewer that will have to cross Chesham, terminating at the sewage works on Latimer Road.The capital cost of constructing this new sewer will be considerable. The time required to plan and construct this sewer will have to be carefully considered. The possible requirement for additional capacity at the sewage works will also need to be assessed. All of these issues will take a considerable time to be designed, approved, and constructed, even if they can be shown to be viable and the required finance is available? Water supply 500 houses will require a new water main from the nearest aquifer pumping station. The current situation in Chesham is at times critical due to over abstraction of water from the underground sources. Most of the chalk streams and springs are currently dry. Constructing 500 houses could result in water shortages, and emergency situations, in the future.This potential situation alone raises serious questions on the proposed development. Surface water. Provision will be required for the disposal of the surface water generated by 500 houses. As the proposed site is on one of the highest parts of Chesham it can be concluded that this surface water will finally find its
9317 way down into the lower parts of the town.These areas are already subject to flooding at times of high rainfall. Any additional surface water will exacerbate this situation. Gas and electricity The plan does not show the ability of the gas, and electricity, utilities to provide the necessary services to 500 houses.The distribution networks would require reinforcing.This can only be undertaken at considerable cost, and inevitably result in disruption of the communities during construction. Air Quality. Air quality is a most significant controlling factor, which should alone justify refusal of the proposed plan. The construction of 500 houses at Lye Green would seriously affect air quality in the lower parts of Chesham. The cause if this predicted problem is the additional traffic on the roads surrounding the development. Air quality measurements reported by the District Council already show high levels of nitrogen dioxide along Berkhamsted Road, Broad Street, and St Mary©s Way. The Council©s 2019 air quality annual status report indicates concentrations of nitrogen dioxide well in excess of the European requirements. Other pollutants such as carbon monoxide, hydrocarbons, and particulates are not included. The dispersion of pollutants into the atmosphere is also dependent on the topography of an area, and the ambient conditions such as temperature, humidity, and wind speed and direction. Details of these conditions should have been included in the Council©s report. Details of these conditions should have been included in the Council©s report. These details should include reference to the times when the lower areas of Chesham are subject to atmospheric inversion. The diffusion tubes used by the District Council only give indicative monthly mean levels of NO2 in the atmosphere.The accuracy of the diffusion tube method is only plus or minus 25 percent.The District Council report does not indicate any continuous monitoring instrumentation required to measure accurately the 1-hour peak concentration of NO2. The values reported in the Council©s 2019 Air Quality Annual Status report are therefore potentially inaccurate by up to 25%, even after correction factors are applied. The Council report shows that the diffusion tube sampling points are located 1.5m above the pavement level, which represents the aspiration height of a standing adult. Nitrogen dioxide, which is heavier than air gas, is discharged from vehicle exhausts at a typical height less than 0.5m. The maximum concentration of nitrogen dioxide, and other pollutants, in the atmosphere will be at ground level, not at 1.5m. There are three children©s nurseries in Berkhamsted Road and Broad Street. The air quality measurements should be made, adjacent to these nurseries, at a lower level, suggested at 0.5m. A current report from Asthma UK shows a very high mortality rate in children, due to atmospheric pollution. The current level of pollutants in the critical areas of Chesham constitute an "Air Quality Emergency". Air quality alone is therefore considered sufficient justification for denying the development of the 500 houses at Lye Green. PP Mods - Please specify as Alternative development sites. precisely and succinctly as There are a number of potentially alternative development sites in the Chesham area, which would not intrude possible how you would on the Green Belt. These include: modify this policy to improve its alignment to this test of - A redundant industrial unit opposite the post office in Waterside. soundness. - A redundant industrial unit close to the railway bridge in Waterside. - The site of the former Chesham Cottage Hospital, together with the area between the hospital and Chesham underground station. - The Lords Mill site in Waterside. - The former station coal yard. - The sites of former industrial premises in Ash ridge Road - The buildings formerly occupied by two banks, in the High Street. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National
9318 Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1213364 Full Name Mrs Eleanor Watts ID 4936 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-03-14 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you
9319 consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The proposals to release Green Belt land to meet housing targets (Spatial Policy SP SP1 & specifically Policy not believe this policy to be SP BP2 at Lye Green NE of Chesham) are not justified based on the evidence submitted. positively prepared please It is stated that release of some Green Belt is necessary as part of a 3 part strategy involving (1) focus on explain why built-up areas, to build dwellings on previously developed land, (2) an exported proportion of housing need accounted for by Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. I do not believe it has been demonstrated that all brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites and in particular the Green Belt site NE of Chesham at Lye Green. The development of such Green Belt sites involving many hundreds of homes will generate increased traffic. The corresponding highways improvements suggested are insufficient. In Chesham it is apparent that most of the roads / infrastructure is already operating above capacity.
9320 It would be difficult to instigate any significant highways improvements in Chesham due to the limited verges and space available. This combined with a steep hill to / from the town centre means that people will resort to vehicles via road use leading to further traffic congestion and an impact on air quality. Air pollution is already a concern in Chesham due to the poor air quality along Berkhampstead Road where there is a designated Air Quality Management Area already recording air quality that is considerably worse than EU safe levels. Additional homes outside the town on the Green Belt site at Lye Green NE of Chesham will generate more traffic and make the air quality worse ± thus making the plan unsound. The Green Belt site NE of Chesham (SP BP 2) is not a sustainable location. It is over 2km away from the train station and slightly further still from the town centre via a steep hill. Further doubt is cast upon the ªsoundnessº of this Plan by virtue of there being conflicting policies within it. It is proposed that the Green Belt site NE of Chesham is sustainable and provides easy access to public transport including the tube station yet the same Plan promotes a considerable increase in retail development in the town (local draft plan policy SP EP3). The land has also recently been specified as an Asset Of Community Value and due to this designation it now permits a community group the right to bid for the land. The community group (Brown Not Green) have stated their intention is to preserve the land given that many hundreds of local people have habitually used the fields at Lye Green as of right for various informal outdoor recreational purposes. It is unclear why the Local Authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. This makes the Plan unsound. This land also provides an important habitat for wildlife that will be threatened by development of this land. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not For this Plan to be sound it must also be effective. Unfortunately, further review of the proposal to remove believe this policy to be land NE of Chesham at Lye Green from Green Belt designation is not effective as there are serious questions effective please explain why. about the deliverability of this land. The main landowner is a farmer who has asserted publicly and in a letter to the editor of Your Chesham that he is not prepared to release all of the land in his ownership for development. PAa - Please specify as I refer to my previous comments but would suggest that all other options are investigated, including the precisely and succinctly as development of existing brownfield land and consideration given to the contents of the Chesham Masterplan. possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I believe the draft Local Plan is not legally compliant because it has not demonstrated adequate consideration believe this policy in of the National Policy and guidance issued. consistent with the National The National Planning Policy Framework (NPPF) issued by the Government states that Local Authorities Planning Policy Framework must demonstrate they have exhausted all options before considering revision of Green Belt boundaries. Feb 2019 please explain why This Local Plan proposes considerable modifications to Green Belt boundaries including the removal of Green Belt designation of 13 areas within the Districts as well as modifying the Green Belt status of many local villages. I believe this draft Local Plan has not demonstrated that all other options have been fully explored and as such this Plan is not justified, sound or in accordance with National Policy and thus not legally compliant. I believe that it is not sufficient to claim that the combination of housing need and the presence of significant areas of development collectively represent ªexceptional circumstancesº (as required in the NPPF) to justify modification of Green Belt boundaries. Also, the Plan area is forecast to see a carbon emission increase by 21% in the plan period ± this is inconsistent with Government Policy to achieve net zero carbon emissions by 2050 and therefore not legally compliant. There is also a significant infrastructure funding gap acknowledged within the Community Infrastructure Levy evidence that supports this Local Plan, of between £179m & £231m. Without infrastructure, this development will not be sustainable ± which further makes this plan unsound. This also points to flawed methodology of Green Belt site selection used by the Local Authority, which is neither effective, justified nor consistent with national policy and as such is unsound. Specifically, the selection of the land NE of Chesham at Lye Green (policy SP BP2) for removal from Green Belt designation is inconsistent with National Planning Policy Framework (NPPF).
9321 The primary aim of Green Belt land is to prevent urban sprawl and to preserve the openness of the area. The Lye Green site satisfies this requirement well. Another aim of Green Belt land stated in NPPF paragraph 134, is to prevent neighbouring towns and settlements from merging into one another.The Green Belt land NE of Chesham maintains a distinct separate between settlements of Chesham & Lye Green as well as helping to maintain separate identities of other nearby communities at Orchard Leigh, Botley, Whelpley Hill and Ashley Green. It is inconsistent with national guidance to allocate this land for removal from Green Belt especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if earmarked for development. A further aim of Green Belt designation stated in the NPPF at paragraph 134 (e) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land.The allocation of Green Belt land NE of Chesham for development undermines this aim within Chesham. A community lead not for profit organisation called Chesham Renaissance CIC has been striving to create a Chesham Masterplan that would not only provide many genuinely affordable homes in more sustainable locations nearer the town centre, but which would also regenerate some of the more deprived wards within Chesham. The Plan is inconsistent / takes no regard of this local initiative and is therefore also inconsistent with national guidance and thus unsound. I feel the land NE of Chesham is an unsustainable location for development, that has been used by the community for improved health & wellbeing for decades ± demonstrated by the recent assignation of an Asset of Community Value. Exceptional circumstances for reviewing Green Belt boundaries at this location do not exist or are insufficient to warrant the removal of this land from Green Belt designation ± thus the plan is unsound. Policy 3a - Please specify as The Plan needs to be modified by; precisely and succinctly as Considering the complete housing requirement with other nearby authorities, not just Aylesbury. It is possible how you would unsatisfactory to infer this cannot be undertaken because they are different areas. modify this policy to improve its alignment to this test of Exploring co-operation with other nearby authorities may result in further housing needs being catered for soundness. elsewhere. A more thorough investigation and identification of potential brownfield land opportunities must be undertaken. Consideration of alternative options available for meeting the requirements should be explored - such as the Chesham Masterplan by CIC Chesham Renaissance. Green Belt boundary reviews should only be considered after all other reasonable alternatives have been exhausted. Policy-level file upload - 5503115 Please attach any supporting evidence
Person ID 1221353 Full Name Mrs Joanne Bathurst ID 3059 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to
9322 relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary
9323 to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported not believe this policy to be proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where positively prepared please sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity explain why of the Green Belt. I question the soundness of such a general policy and whether all the brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites and in particular the Green Belt site NE of Chesham at Lye Green. The development of such Green Belt sites involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient and unfunded. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham cannot accommodate any significant highways improvements anyway due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion, with further worsening air quality. Air pollution is a particular concern in Chesham due to the already poor air quality along Bekhampstead Road where there is a designated Air Quality Management Area that already is recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will generate more traffic will make the air quality even worse and insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable nor justified nor is it in accordance with Govt policy. The Green Belt site NE of Chesham (SP BP 2) is not a sustainable location. It is over 2Km away from the train station and slightly further still from the town centre but anyone who cares to walk or cycle this distance also has to negotiate a steep hill too. Such an unsustainable location cannot be made sustainable merely by upgrading a couple of public footpaths within the site into bridleways to facilitate cycling. Neither does adding a bus stop address the geography or topography of the area especially if the promised enhanced bus service (which is already infrequent) either does not materialise or if it subsequently fails to be maintained after a few years. Further doubt is cast upon the ªsoundnessº of this Plan by virtue of there being conflicting policies within it. The Council seem to think that the Green Belt site NE of Chesham is sustainable and provides easy access to public transport including the tube station yet the same Plan promotes a considerable increase in retail development in the town (local draft plan policy SP EP3) , part of which would be built on the very car park that serves the Chesham tube station. This is inconsistent and unsound. The land is also potentially an Asset Of Community Value and upon confirmation of this designation it would afford a community group the right to bid for the land. The community group (Brown Not Green) have stated their intention is to preserve the land given that many hundreds of local people have habitually used the fields at Lye Green as of right for various informal outdoor recreational purposes. These uses themselves may mean that many local individuals may have acquired easements over and across the land through prescription (20 years uninterrupted use) not least of whom would be the many private residences bordering the fields that have rear garden gates onto the fields at Lye Green. These easements and prescriptive rights may render the land very difficult to develop and make i undeliverable in planning terms. This land also provides an important habitat for wildlife that will be threatened by development of this land. It is perverse that the Local Authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Plan is unsound. PP Mods - Please specify as All other options are fully explored including increased density of development of brownfield land and the precisely and succinctly as policies emerging from Chesham Masterplan. possible how you would Green Belt land should only be considered when all other options are exhausted and in any event the modify this policy to improve proposals for developing land NE of Chesham (policy SP BP 2) should be removed as it is an unsustainable its alignment to this test of location the development of which will cause harm to the wider town including loss of an asset that improves soundness. the well-being for the community. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not For this Plan to sound it must also be effective. Unfortunately, further review of the proposal to remove land believe this policy to be NE of Chesham at Lye Green from Green Belt designation is not effective as there are serious questions effective please explain why. about the deliverability of this land. The main landowner is a farmer who has asserted publicly and in a letter to the editor of Your Chesham, that he is not prepared to release all of the land in his ownership for development.
9324 PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not The foregoing also points to flawed methodology of Green Belt site selection used by the Local Authority, believe this policy in which is neither effective, justified nor consistent with national policy and as such is unsound. Specifically, consistent with the National the selection of the land NE of Chesham at Lye Green (policy SP BP2) for removal from Green Belt designation Planning Policy Framework is inconsistent with National Planning Policy Framework (NPPF). Feb 2019 please explain why Paragraph 136 of the latest NPPF asserts that Green Belt boundaries should only be modified in ªexceptional circumstancesº. The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances. The Council engaged third party consultants to undertake the Part 1 Green Belt assessment and they identified numerous sites for ªfurther considerationº where exceptional circumstances ªmightº exist but expressly recommended further review of their assessment of each site against the 5 purposes of land being in Green Belt of all these sites. Unlike the neighbouring Local Authorities, the Part 2 Green Belt assessment was not undertaken by third party consultants but by the Local Authority itself who notably then did not undertake all the recommended reviews of each site including the land NE of Chesham at Lye Green (SP BP 2). Accordingly, this oversight in the Part 2 Green Belt assessment placed premature focus and fixation on releasing land at Lye Green NE of Chesham from Green Belt designation. The subsequent identification of the Chesham site for release is therefore unjustified. The primary aim of Green Belt land (as recited in NPPF 133) is to prevent urban sprawl and to preserve the openness of the area. The Lye Green site (SP BP2) self-evidently performs this function well and has done so for decades. Another aim of Green Belt land stated in NPPF paragraph 134, is to prevent neighbouring towns and settlements from merging into one another.The Green Belt land NE of Chesham performs exceptionally well in maintaining a distinct separate between settlements of Chesham & Lye Green as well as helping to maintain separate identities of other nearby communities at Orchard Leigh, Botley, Whelpley Hill, Ashley Green. It is perverse and inconsistent with national guidance to allocate this land for removal from Green Belt in light of these facts especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if earmarked for development. A further aim of Green Belt designation stated in the NPPF at paragraph 134 (e) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. By allocating Green Belt land NE of Chesham for development, undermines this aim within Chesham. A community lead not for profit organisation called Chesham Renaissance CIC has been striving to create Chesham Masterplan that would not only provide many genuinely affordable homes in more sustainable locations nearer the town centre, but which would also regenerate some of the more deprived wards within Chesham. The Local Authority's proposals (policy SP EP3) are inconsistent with this local initiative and are therefore also inconsistent with national guidance and are consequently unsound. The Council have asserted that Government planning policy requires local councils to review Green Belt boundaries when considering how to accommodate the development needed in their areas. Just because the Council may be required to look, does not mean the Council should review Green Belt boundaries which as previously stated should only be modified in ªexceptional circumstancesº. National Planning Policy Framework (NPPF) as revised only last year, states in paragraph11 (b) I, directs ªplan makersº to create policies that are required in Local Plans for housing and other uses unless Framework policies (expressly including Green Belt) ªprovides a strong reason for restricting the overall scale type or distribution of development in the plan areaº Accordingly, I submit that given all of the above the land being proposed for release from Green Belt designation around Chesham is unjustified and contrary to national guidance. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1221367 Full Name Colin Le Good ID 3041 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee:
9325 Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider
9326 the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not There is much that is unacceptable, and I outline some of this below. believe this policy in In the NPPF document Paragraph 182 requires the plan must be prepared in accordance for examination consistent with the National which it considers is ªSoundº: namely that it is - Planning Policy Framework Feb 2019 please explain why · Positively prepared · Justified ± the plan should be the most appropriate strategy, when considered against the reasonable alternatives, · Effective ± deliverable over its period · Consistent ± with the national policy ± the plan should enable the delivery of sustainable development in accordance with the policies in the framework.
9327 · With regard to Positive preparation there have been, and still are, very significant shortcomings: ªEarly and meaningful engagement and collaboration with neighbourhoods, local organisations and businesses is essential. A wide section of the community should be proactively engaged, so that Local Plans, as far as possible, reflect a collective vision and a set of agreed priorities for the sustainable development of the area, including those contained in any neighbourhood plans that have been madeº ± NPPF In no way does this plan reflect a `collective vision.'There has been none of the engagement that there should have been which is outlined in this paragraph of NPPF. With regard to whether the plan is Justified. It is clear that the plan does not take into account the NPPF requirements for Green Belt: Protecting Green Belt land 79. The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence. 80. Green Belt serves five purposes: to check the unrestricted sprawl of large built-up areas; to prevent neighbouring towns merging into one another; to assist in safeguarding the countryside from encroachment; to preserve the setting and special character of historic towns; and to assist in urban regeneration, by encouraging the recycling of derelict and other urban land. Once established, Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan. At that time, authorities should consider the Green Belt boundaries having regard to their intended permanence in the long term, so that they should be capable of enduring beyond the plan period. A local planning authority should regard the construction of new buildings as inappropriate in Green Belt. Exceptions to this are: buildings for agriculture and forestry; provision of appropriate facilities for outdoor sport, outdoor recreation and for cemeteries, as long as it preserves the openness of the Green Belt and does not conflict with the purposes of including land within it; the extension or alteration of a building provided that it does not result in disproportionate additions over and above the size of the original building; the replacement of a building, provided the new building is in the same use and not materially larger than the one it replaces; limited infilling in villages, and limited affordable housing for local community needs under policies set out in the Local Plan; or limited infilling or the partial or complete redevelopment of previously developed sites (brownfield land), whether redundant or in continuing use (excluding temporary buildings), which would not have a greater impact on the openness of the Green Belt and the purpose of including land within it than the existing development. The courts have held that housing needs alone are not ªExceptional circumstancesº for the demoting of Green belt land. It is clear that the local plan does not fulfil the requirements of the NPPF in this respect.There are alternative possibilities and these are outlined in the Schemes which have been put forward by Chesham Renaissance and others. The use of Brownfield sites is eminently feasible and far more sympathetic to the needs of the area. Brownfield development will also support housing for a more reasonable number of families than that proposed in the present disparate local plan. With respect to the requirement that it should be Effective, there are several threads which indicate that if implemented this plan will not be effective at all: · The period in which the plan is concerned will increase the carbon footprint by 21%. · There is a funding gap of between £170million and £231 million from the Community Infrastructure Levy. · It will increase demand on local resources, waste-disposal, health, schooling, energy supply, communications, without any significant increase in those resources. · The traffic in Chesham is a serious problem right now. To add 500 homes on a major route immediately adjacent to the town will increase traffic flow to a level that is unacceptable. It will also add further pollution in an area which is already significantly stressed, and become almost certainly illegal. · There are several further aspects ± the proposal to build new shops in Chesham is one which indicates the individuals who contrived this plan are insufficiently aware of the large number of long-term vacant business premises in the town right now. · The plan does not reflect the needs of Chesham. It fails to take into account the needs of the town and those who live in it. From all that has been outlined above, it is clear this plan is not Consistent, either within the context of the needs of those who wish to be housed, the town of Chesham and its present residents, or with the NPPF. It is not sustainable. If it is implemented it will generate a negative impact throughout every aspect of life in the town. It is not acceptable and does not fall within the requirements of the NPPF in so many respects that it is probably, in some respects, not even legal.
9328 I believe it is vital that the town is sympathetically rejuvenated. Brownfield sites should be at the centre of this development. Green-belt land should not be used for housing. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5497648 Please attach any supporting evidence
Person ID 1213963 Full Name Mr John Docwra ID 4742 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Chairman Sunnymede Avenue Residents Association Consultee Type - Please Local Interest Group/Amenity Society select the type of consultee: Date Received - Date 2016-03-14 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness?
9329 Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not My objections to the Draft Local Plan is based upon my belief it to be unsound and unsustainable; even believe this policy to be perverse through being inconsistent with National Guidance, therefore unjustified. justified please explain why
9330 In Chesham we are privileged to have the support of Chesham CiC who have developed the Chesham Masterplan.You are aware of their findings which have been to demonstrate the potential for new residential housing sites - within the town itself. Please accept we are all of equal mind in seeking to find space for much needed housing but for the Councils to totally ignore CiC findings is to contradict the Government©s ruling to investigate brown field sites first in order to minimise incursion onto our own Green Belt Land. It is astonishing to discover that our own Green Belt land NE of Chesham has been chosen for development while ignoring the alternative of Brown Field sites found by the CiC. The more sensible approach is surely to fully recognise the CiC proposals and allow their work to assist the Councils to find sites for development, and reduce pressure on our Green Belt land. Please also have in mind the ©water-sourced protection zone© we believe exists within the same NE Chesham Area that the Councils are concentrating upon. By permitting new development and associated ground upheaval, our concern of course is the real danger you risk of polluting the River Chess along with our drinking water supplies. This process of interfering with nature could even become irreversible. Finally, I fully accept the task the Councils face is far from easy. In particular to overcome our very real infrastructure problems that already exist due to successive authorities failing to correct an ever worsening situation. For example, we have a dangerous health issue with high air contamination on the Berkhamsted Road due to heavy traffic concentration, mornings and evenings. The location has an AQMA register and includes the Newtown Infants© School while the National Papers have carried news of a child fatality resulting from this set of conditions. More houses mean more cars in this area. Chesham is built on acquirers and suffers from poor drainage. The High Street will have to be majorly disturbed within 10 years to increase flood handling capacity. More houses will result in even greater flood risks. Our Chalk River Chess is being threatened by too much water abstraction on a continuous basis and often runs dry as is the case today. It is also occasionally poisoned by raw sewage exuding from the Sewage Treatment Works as a result of input of flood water that it cannot handle. More housing will make matters worse. The difficulties we face in Chesham are due in no small measure to a physical phenomenon known as the topography. Each of these infrastructure issues are assisted by the lie of the land whereby all valleys slope into Chesham and there is only one outfall - via Waterside, the Sewage Treatment Works and River Chess. The topography cannot be altered at which point we must then seriously question whether the Town can even take any more houses. I now understand that the Councils have chosen not to entertain opening dialogue with adjoining local authorities with a view to sharing out the need for houses elsewhere, yet this is an allowable procedure. I am thinking of Slough, Dacorum, Milton Keynes and Aylesbury, for example. Since we in Chesham can be shown to have real insurmountable difficulties, yet despite all, have volunteered to find as much space as possible by the establishment and findings of the Chesham CiC, surely a strong case exists for special consideration for help? Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1213989 Full Name Mrs Brenda Collins
9331 ID 3659 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Hivings Hill Residents Association Consultee Type - Please Local Interest Group/Amenity Society select the type of consultee: Date Received - Date 2016-06-21 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its
9332 alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do There is a consequence that many sites will either become unviable or will be delivered without the appropriate not believe this policy to be infrastructure in place. Any additional building on the Green Belt land surrounding Chesham will only increase positively prepared please the traffic coming into an already congested town centre. explain why Building on such Green Belt land will also increase the need for new schools, doctor surgeries, dentists, social facilities and shopping areas. PP Mods - Please specify as The council should work in conjunction with the Chesham Renaissance CIC Master plan and Brown Not precisely and succinctly as Green Chesham Ltd in order to create a more appropriate planning program which will meet requirements possible how you would but, a the same time, protect the Green Belt and Villages within the Green Belt. modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not Whilst we fully accept the obligation placed upon the Council to increase the housing stock within its boundaries believe this policy to be there is no justification for building on the Green Belt land as proposed. The suggested site allocations are justified please explain why effectively out of town and developers will therefore be required to deliver infrastructure directly or make financial contributions to mitigate development impact. These contributions cannot be quantified because the costs and related infrastructure are not even specified. The policy is to place 500 houses on Green Belt land north east of Chesham and this, as mentioned above, will increase the need for more school places. How can this type of development be justified when you have allowed residential buildings on educational sites such as in the Greenway and the College Campus at the junction of Lyecrome Road and Nashleigh Hill? It was indeed a great mistake to allow residential property building on educational sites. Redefining Green Belt boundaries cannot be justified within existing policies and the local plans suggesting such action should be completely destroyed. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
9333 Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not There are no exceptional circumstances in existence for the purpose of redefining Green Belt boundaries believe this policy in such as at Lye Green or removing numerous villages from Green Belt. consistent with the National It is questionable as to whether these policies are justified or in accordance with NPPF as it has been accepted Planning Policy Framework by the Court that exceptional circumstances cannot be on the grounds of housing need only. Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1221399 Full Name Mr David Whiscombe ID 3081 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You
9334 will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be
9335 positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I am writing to comment on the Draft Local Plan (ªDLPº). Principally I am objecting that it is ªunsoundº by believe this policy in reference to para 35 of the National Planning Policy Framework (ªNPPFº) of February 2019. To the extent consistent with the National that it does not have proper regard to the NPPF I consider that it is also not ªlegally compliantº, as failing to Planning Policy Framework satisfy the requirements of s19 of the Planning and Compulsory Purchase Act 2004. I am looking in particular Feb 2019 please explain why at that part of the Draft Local Plan described as Policy SP B2, relating to land to the north-east of Chesham, though many of the criticisms relate equally to the plan as a whole. Although four tests of soundness are identified in para 35, they do to some extent overlap. For example, a plan that fails (as I consider the DLP to fail) to take into account the reasonable alternatives based on proportionate evidence, is not ªjustifiedº: but neither is it likely to be consistent with policies expressed in the NPPF. I question whether the plan is ªan appropriate strategy, taking in account the reasonable alternatives, and based on proportionate evidenceº. The NPPF encourages the use of ªbrownfieldº land in preference to previously undeveloped land (see eg. Para 117 and 137). I have noted the ªChesham Masterplanº that has been promoted by a Community Interest Company called Chesham Renaissance CIC makes realistic proposals for providing sustainable homes much nearer the centre of Chesham. According to the most recently filed accounts of the company nearly 1,150 individual comments were made on various aspects of the Masterplan with nearly 75% of respondents in favour of the key themes. It is not apparent to me that the Draft Local Plan has taken proper account of the alternatives to building on Green Belt land, which alternatives would appear to deliver significant advantages in regard to sustainability. For example, the development envisaged by SP B2 is not within walking or cycling distance of facilities in Chesham (and any access to Chesham is via steep hills). At best, the development would increase movement by public transport and much more likely would significant increase car use. This is likely to lead to an number of adverse results including: · Further degradation of air quality in areas where existing air quality is already poor (e.g. Berkhamstead Road) · Further traffic congestion on local roads · Increased pressure on car parking in Chesham: I note policy SP EP3 envisages building over the Star Yard and Station Car Parks in Chesham with no detail of the ªreprovisioningº of the existing car parks. Further, one express purpose of Green belt (NPPF para 134) is to ªencourage the recycling of derelict and other urban landº. The failure of the DLP properly to identify and favour brownfield over greenfield sites thus contradicts NPPF and renders the DLP unsound. NPPF para 136 asserts that Green Belt boundaries should only be altered where ªexceptional circumstances are fully evidenced and justifiedº. Although Arup were engaged to undertake the ªPart 1 Green Belt Assessmentº which identified a number of sites for further consideration, all further assessment seems to have been undertaken by the Council itself who seem to have been judge and jury in assessing whether ªexceptional circumstancesº exist. The Council's ªPart 2 Green Belt Assessmentº has the flavour of starting from the presumption that to meet housing needs it will be necessary to release some Green Belt land; the only question for determination is which bits should be released. That seems to be inconsistent with the NPPF.The question should be, in relation to each parcel of Green Belt land ± are there exceptional circumstances to justify removal? Housing need is not of itself an exceptional circumstance. Accordingly I do not think that the DLP is consistent with NPPF and is therefore unsound. Para 155 of the NPPF discourages development in areas at risk of flooding. I note that the area to the north-east of Chesham proposed to be released from the Green Belt appears to includes ªAreas of Critical Drainageº as identified on the Council's Strategic Flood Assessment, which does not appear to have been given weight in the DLP.
9336 Finally, the development of the land in question would represent clear ªurban sprawlº of Chesham and would encroach on the countryside, contradicting two of the five purposes of Green Belt land (see NPPF para 134). Overall, the proposed development is not sustainable; it is not justified; in a number of areas it contradicts government policy expressed in the NPPF. There are better alternatives that better consist with government policy and for that reason the DLP is ªunsoundº. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1221401 Full Name Mrs Sara Rhiannon Brown ID 3093 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible.
9337 Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do There is a Strategic Objective (SO5) on Buckinghamshire's Environment that incorporates the conservation not believe this policy to be and enhancement of the natural environment and landscape character. Although the council have put forward positively prepared please Policies 17-26 which address Strategic Objective (SO5) I do not consider these appropriate to the area in explain why that the areas being proposed to be removed from the Green Belt have sites for traditional Chiltern Brick creation which are a character of the area which will be lost once these areas have been developed for housing. Waste management is considered in Policy 10 but the fact the local council has started charging residents in excess of council tax requirements for using the local recycling centre has not been considered at all in this policy, the local council cannot control the current waste management requirements so with additional requirements there is no apparent evidence they will be able to meet this.
9338 The council has not considered, or evidenced their consideration, of the Chesham Renaissance CIC Masterplan or the Brown not Green campaign, and this contradicts part 33A (1) of the Duty to Co-operate, Section 110 of the Localism Act 2011 in that it has not evidenced adhereing to consulting part 1(c) ©a body, or other person, that is prescribed or of a prescribed description,© which the local groups would conform to. PP Mods - Please specify as I feel that the parts unanswered or considered not applicable on the ©Soundness and NPPF compliance precisely and succinctly as self-assessment checklist© completed in May 2018 needs to be re-addressed for developments of the council possible how you would in 2019 and if this is a checklist to consider the soundness of a project surely no parts should be not applicable, modify this policy to improve for example, Ensuring the Viability of Town Centres, I feel is applicable to have a plan to incorporate the its alignment to this test of whole town, I feel not applicable is inappropriate. soundness. There is a need for housing, as objectively identified. Brownfield sites should be utilised in the first instance. Green Belt land has been awarded the honour of Green Belt for many factors and should not be used until all other options are exhausted. Policy 1 - If you do not As above, there is ample Brownfield sites which could be used to meet the requirements as outlined in the believe this policy to be Local Plan, this would fulfil both the need to build housing without the loss of agricultural and recreational justified please explain why land. This would also mean development in smaller numbers at varying locations which would ease the burden on the local infrastructure. Policy 2a - Please specify as As above precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not The Local Plan already has an acknowledged funding gap from the Community Infrastructure Levy (CIL believe this policy to be Funding Gap Analysis June 2019).There is no evidence that there is the financial resource available to meet effective please explain why. the Local Plan. PAa - Please specify as Build more frequently in smaller areas, existing sites of Brownfield land, and also consider the redevelopment precisely and succinctly as of areas of the town to improve infrastructure. possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not The policy is not consistent with NPPF as exceptional circumstances do not exist for redefining Green Belt believe this policy in boundaries such as Lye Green (Policy SP BP 2) and removing numerous villages from Green Belt or permitting consistent with the National ©infilling of Green Belt Villages© as proposed in SP PP1 & DM PP 1. Exceptional circumstances in accordance Planning Policy Framework with English Law do not arising from the need for housing alone. The sites have been used for decades as Feb 2019 please explain why recreation areas for locals and is potentially to be listed as an Asset of Community Value. I consider the Local Plan to not be legally compliant on the basis the lack of evidence with respect to evidence of exceptional circumstances for redefining Green Belt boundaries such as at Lye Green (Policy SP BP 2) and removing numerous villages, including Ley Hill, from the Green Belt as proposed in policies SP PP1 & DM PP 1. Housing needs alone are not considered exceptional circumstances. These areas are areas of recreation and have been for a significant number of years. In the village of Ley Hill for example, there is a golf course, it is an area of AONB, and has a history since early 1900 of growing trees and plants for the golf course and an area of recreation. This is common land with numerous people daily travelling to by car as there is such little recreation area elsewhere. In addition, the small village boasts a National Lottery Funded recreation and preservation area which was designed and built with the local school. Further to this, the agricultural benefits of the land are immense, with much of the area being old allotments (circa 1850-1920) and attract much wildlife. Horse riders are frequent in the area which they are able to utilise due to the lack of congestion approximately 2.5km outside of the Chesham Town Centre. I do not consider the removal of the surrounding areas of Chesham from the Green Belt sustainable due to increased congestion and the increase in the carbon footprint of the town. This week alone the neighbouring council (Hertfordshire) has declared a state of emergency in relation to its carbon footprint. The Hertfordshire boundary is within 4km of the sites being proposed to be removed from the Green Belt for building. The further considerations is the funding gap and infrastructure. I do not believe it is legal or justified to proceed with a Local Plan with an acknowledged funding gap of between £179-£231million, as developers will be required to deliver infrastructure directly or make financial contributions to mitigate development impact. Outsourcing to private developers and what their contribution will be cannot be quantified due to the lack of specification and the simple lack of formal plan (masterplans) for each of these sites. There is a high risk that these villages will be released from the Green Belt, developers passing through the procurement process and then the project be undeliverable or unsustainable and the appropriate infrastructure not be available. Chesham infrastructure needs to be sufficiently robust to not only serve the needs of the residents but a significant amount of traffic and commuters use Chesham as a through route from the A41 to Amersham/Beaconsfield and surrounding areas. The A41 is a critical route between Watford and Aylesbury (the latter seeing a significant amount of homes developed at lower housing values than in Chesham) and as such there is a significant amount more of people commuting to the area. Policy 3a - Please specify as The council should be considering more effective alternatives such as higher densities of housing development precisely and succinctly as on Brownfield sites which are generally closer to the town centre and in more sustainable locations. Not only possible how you would would this restrict destroying Green Belt land and an AONB but it could assist in rejuvenation of the local modify this policy to improve town in accordance with the Chesham Renaissance CIC Master Plan. This is made by the community for its alignment to this test of the community and acknowledges the need for extra housing and sustainable alternatives. soundness.
9339 Policy-level file upload - Please attach any supporting evidence
Person ID 1221412 Full Name Mr Chee Toh ID 3095 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications
9340 to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not I believe the Draft Local Plan is unsound. believe this policy to be The proposals to release Green Belt land to meet housing targets are not justified from the evidence submitted. justified please explain why I question the soundness of such a general policy and whether all the brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites and in particularly the Green Belt site North East of Chesham at Lye Green. The development of such Green Belt sites involving many hundreds of homes will generate increased traffic and although some highways improvements are suggested they are insufficient. For example, in Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham cannot accommodate any significant highways improvements due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion with further worsening air quality.
9341 Air pollution is a particular concern in Chesham due to the already poor air quality along Berkhamstead Road where there is a designated Air Quality Management Area that already is recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will generate more traffic which in turn will make the air quality even worse. Insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable nor justified nor is it in accordance with Government policy. The Green Belt site NE of Chesham is not a sustainable location. It is over 2km away from the train station and slightly further still from the town centre but anyone who cares to walk or cycle this distance also has to negotiate a very steep hill in either White Hill or Nashleigh Hill. Such an unsustainable location cannot be made sustainable merely by upgrading a couple of public footpaths within the site into bridleways to facilitate cycling. Neither does adding a bus stop address the geography or topography of the area especially if the promised enhanced bus service (which is already infrequent) either does not materialise or if it subsequently fails to be maintained after a few years. Further doubt is cast upon the ªsoundnessº of this Plan by virtue of there being conflicting policies within it. The Council seem to think that the Green Belt site NE of Chesham is sustainable and provides easy access to public transport including the tube station yet the same Plan promotes a considerable increase in retail development in the town (local draft plan policy SP EP3), part of which would be built on the very car park that serves the Chesham tube station. This is inconsistent and unsound. For this Plan to be sound it must also be effective. Unfortunately, further review of the proposal to remove land NE of Chesham at Lye Green from Green Belt designation is not effective as there are serious questions about the deliverability of this land. The main landowner is a farmer who has asserted publicly and in a letter to the editor of Your Chesham magazine that he is not prepared to release all of the land in his ownership for development. The land is also potentially an Asset of Community Value and upon confirmation of this designation it would afford a community group the right to bid for the land. The community group (Brown Not Green) have stated their intention is to preserve the land given that many hundreds of local people have habitually used the fields at Lye Green as of right for various informal outdoor recreational purposes. These uses themselves may mean that many local individuals may have acquired easements over and across the land through prescription (20 years uninterrupted use) not least of whom would be the many private residences bordering the fields that have rear garden gates onto the fields at Lye Green. These easements and prescriptive rights may render the land very difficult to develop and make it undeliverable in planning terms. It is perverse that the Local Authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Plan is unsound. The foregoing also points to flawed methodology of Green Belt site selection used by the Local Authority which is neither effective, justified nor consistent with national policy and as such is unsound. Specifically, the selection of the land NE of Chesham at Lye Green for removal from Green Belt designation is inconsistent with National Planning Policy Framework (NPPF). Paragraph 136 of the latest NPPF asserts that Green Belt boundaries should only be modified in ªexceptional circumstancesº. The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances. The Council engaged third party consultants to undertake the Part 1 Green Belt assessment and they identified numerous sites for ªfurther considerationº where exceptional circumstances ªmightº exist but expressly recommended further review of their assessment of each site against the 5 purposes of land being in Green Belt of all these sites. Unlike the neighbouring Local Authorities, the Part 2 Green Belt assessment was not undertaken by third party consultants but by the Local Authority itself who notably then did not undertake all the recommended reviews of each site including the land NE of Chesham at Lye Green. Accordingly, this oversight in the Part 2 Green Belt assessment placed premature focus and fixation on releasing land at Lye Green NE of Chesham from Green Belt designation. The subsequent identification of the Chesham site for release is therefore unjustified. The primary aim of Green Belt land (as recited in NPPF 133) is to prevent urban sprawl and to preserve the openness of the area. The Lye Green site self-evidently performs this function well and has done so for decades. Another aim of Green Belt land stated in NPPF paragraph 134 is to prevent neighbouring towns and settlements from merging into one another. The Green Belt land NE of Chesham performs exceptionally well in maintaining a distinct separate between settlements of Chesham and Lye Green as well as helping to maintain separate identities of other nearby communities at Orchard Leigh, Botley, Whelpley Hill and Ashley Green. It is perverse and inconsistent with national guidance to allocate this land for removal from Green Belt in light of these facts especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if earmarked for development. A further aim of Green Belt designation as stated in the NPPF at paragraph 134 (e) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. By allocating Green Belt land NE of Chesham for development, undermines this aim within Chesham. A community lead not-for-profit organisation called Chesham Renaissance CIC has been striving to create a Chesham Masterplan that would not only provide many genuinely affordable homes in more sustainable locations nearer the town centre but which would also regenerate some of the more deprived wards within Chesham.The Local Authority's proposals are inconsistent with this local initiative and are therefore also inconsistent with national guidance and are consequently unsound. The Council have asserted that Government planning policy requires local councils to review Green Belt boundaries when considering how to accommodate the development needed in their areas. Just because the Council may be required to look does not mean the Council should review Green Belt boundaries which as previously stated should only be modified in ªexceptional circumstancesº. National Planning Policy Framework (NPPF) as revised only last year, states in paragraph 11(b)i, directs ªplan makersº to create policies that are required in Local Plans for housing and other uses unless Framework policies (expressly including Green Belt) ªprovides a strong reason for restricting the overall scale type or distribution of development in the plan areaº Accordingly, I submit that given all of the above the land being proposed for release from Green Belt designation around Chesham is unjustified and contrary to national guidance. I am supportive of the Brown Not Green organisation's initiative to have the land listed as an Asset of Community Value and I feel they speak for me in respect of their objections to the draft Local Plan. Accordingly,
9342 I request that any representations made by them at any future examination in public regarding the soundness of this Local Plan be considered as an extension of my own comments herein. I feel the land NE of Chesham is an unsustainable location for development, that has been habitually used by the community for improved health & wellbeing for decades and the land performs well against Green Belt aims and objectives. Exceptional circumstances for reviewing Green Belt boundaries at this location either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by Government Policy and therefore the plan is unsound. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5497913 Please attach any supporting evidence
Person ID 1221413 Full Name Dr Sophie Grabczynska ID 3101 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant,
9343 including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s),
9344 do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not The proposals to release Green Belt land to meet housing targets are not justified from the evidence submitted. believe this policy to be I question the soundness of such a general policy and whether all the brownfield land opportunities have justified please explain why been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites and in particularly the Green Belt site North East of Chesham at Lye Green. The development of such Green Belt sites involving many hundreds of homes will generate increased traffic and although some highways improvements are suggested they are insufficient. For example, in Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham cannot accommodate any significant highways improvements due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion with further worsening air quality. Air pollution is a particular concern in Chesham due to the already poor air quality along Berkhamstead Road where there is a designated Air Quality Management Area that already is recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will generate more traffic which in turn will make the air quality even worse. Insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable nor justified nor is it in accordance with Government policy. The Green Belt site NE of Chesham is not a sustainable location. It is over 2km away from the train station and slightly further still from the town centre but anyone who cares to walk or cycle this distance also has to negotiate a very steep hill in either White Hill or Nashleigh Hill. Such an unsustainable location cannot be made sustainable merely by upgrading a couple of public footpaths within the site into bridleways to facilitate cycling. Neither does adding a bus stop address the geography or topography of the area especially if the promised enhanced bus service (which is already infrequent) either does not materialise or if it subsequently fails to be maintained after a few years. Further doubt is cast upon the ªsoundnessº of this Plan by virtue of there being conflicting policies within it. The Council seem to think that the Green Belt site NE of Chesham is sustainable and provides easy access to public transport including the tube station yet the same Plan promotes a considerable increase in retail development in the town (local draft plan policy SP EP3), part of which would be built on the very car park that serves the Chesham tube station. This is inconsistent and unsound. For this Plan to be sound it must also be effective. Unfortunately, further review of the proposal to remove land NE of Chesham at Lye Green from Green Belt designation is not effective as there are serious questions about the deliverability of this land. The main landowner is a farmer who has asserted publicly and in a letter to the editor of Your Chesham magazine that he is not prepared to release all of the land in his ownership for development. The land is also potentially an Asset of Community Value and upon confirmation of this designation it would afford a community group the right to bid for the land. The community group (Brown Not Green) have stated their intention is to preserve the land given that many hundreds of local people have habitually used the fields at Lye Green as of right for various informal outdoor recreational purposes. These uses themselves may mean that many local individuals may have acquired easements over and across the land through prescription (20 years uninterrupted use) not least of whom would be the many private residences bordering the fields that have rear garden gates onto the fields at Lye Green. These easements and prescriptive rights may render the land very difficult to develop and make it undeliverable in planning terms. It is perverse that the Local Authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Plan is unsound. The foregoing also points to flawed methodology of Green Belt site selection used by the Local Authority which is neither effective, justified nor consistent with national policy and as such is unsound. Specifically, the selection of the land NE of Chesham at Lye Green for removal from Green Belt designation is inconsistent with National Planning Policy Framework (NPPF). Paragraph 136 of the latest NPPF asserts that Green Belt boundaries should only be modified in ªexceptional circumstancesº. The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances. The Council engaged third party consultants to undertake the Part 1 Green Belt assessment and they identified numerous sites for ªfurther considerationº where exceptional circumstances ªmightº exist but expressly recommended further review of their assessment of each site against the 5 purposes of land being in Green Belt of all these sites. Unlike the neighbouring Local Authorities, the Part 2
9345 Green Belt assessment was not undertaken by third party consultants but by the Local Authority itself who notably then did not undertake all the recommended reviews of each site including the land NE of Chesham at Lye Green. Accordingly, this oversight in the Part 2 Green Belt assessment placed premature focus and fixation on releasing land at Lye Green NE of Chesham from Green Belt designation. The subsequent identification of the Chesham site for release is therefore unjustified. The primary aim of Green Belt land (as recited in NPPF 133) is to prevent urban sprawl and to preserve the openness of the area. The Lye Green site self-evidently performs this function well and has done so for decades. Another aim of Green Belt land stated in NPPF paragraph 134 is to prevent neighbouring towns and settlements from merging into one another. The Green Belt land NE of Chesham performs exceptionally well in maintaining a distinct separate between settlements of Chesham and Lye Green as well as helping to maintain separate identities of other nearby communities at Orchard Leigh, Botley, Whelpley Hill and Ashley Green. It is perverse and inconsistent with national guidance to allocate this land for removal from Green Belt in light of these facts especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if earmarked for development. A further aim of Green Belt designation as stated in the NPPF at paragraph 134 (e) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. By allocating Green Belt land NE of Chesham for development, undermines this aim within Chesham. A community lead not-for-profit organisation called Chesham Renaissance CIC has been striving to create a Chesham Masterplan that would not only provide many genuinely affordable homes in more sustainable locations nearer the town centre but which would also regenerate some of the more deprived wards within Chesham.The Local Authority's proposals are inconsistent with this local initiative and are therefore also inconsistent with national guidance and are consequently unsound. The Council have asserted that Government planning policy requires local councils to review Green Belt boundaries when considering how to accommodate the development needed in their areas. Just because the Council may be required to look does not mean the Council should review Green Belt boundaries which as previously stated should only be modified in ªexceptional circumstancesº. National Planning Policy Framework (NPPF) as revised only last year, states in paragraph 11(b)i, directs ªplan makersº to create policies that are required in Local Plans for housing and other uses unless Framework policies (expressly including Green Belt) ªprovides a strong reason for restricting the overall scale type or distribution of development in the plan areaº Accordingly, I submit that given all of the above the land being proposed for release from Green Belt designation around Chesham is unjustified and contrary to national guidance. I am supportive of the Brown Not Green organisation's initiative to have the land listed as an Asset of Community Value and I feel they speak for me in respect of their objections to the draft Local Plan. Accordingly, I request that any representations made by them at any future examination in public regarding the soundness of this Local Plan be considered as an extension of my own comments herein. I feel the land NE of Chesham is an unsustainable location for development, that has been habitually used by the community for improved health & wellbeing for decades and the land performs well against Green Belt aims and objectives. Exceptional circumstances for reviewing Green Belt boundaries at this location either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by Government Policy and therefore the plan is unsound. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5497917 Please attach any supporting evidence
Person ID 1221618 Full Name Miss Georgina Minter-Brown
9346 ID 2589 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its
9347 alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I believe the draft Local Plan is NOT legally compliant, as it is not justified or in accordance with the not believe this policy to be National Planning Policy Framework (NPPF)to remove land from Green Belt for housing and no positively prepared please explain why further options have been fully explored. The Plan's Spatial Policy for sustainable development by claiming to promote the recycling of previous developed (brownfield) land is ineffective and also inconsistent with the Plan's proposed uses of Green Belt to meet housing needs generally and specifically at Lye Green. It is perverse to claim that the combination of housing need and the presence of significant areas of development constraint policy collectively represent ªexceptional circumstancesº (as required in the NPPF) to justify modification of Green Belt boundaries especially given the NPPF states that one of the key features of Green Belts are their permanence. There is also a significant infrastructure funding gap acknowledged within the Community Infrastructure Levy evidence that supports this Local Plan, of between £179m & £231m. Given this infrastructure is vital to ensure that development is sustainable (as also required by the NPPF) this further demonstrates the Plan is both unsound and not legally compliant. Many of the site allocations (such as at Lye Green. Policy SP BP2) are excluded from the Community Infrastructure Levy and developers will therefore be required to deliver infrastructure directly or make financial contributions to mitigate the development's impact. However, these contributions cannot be quantified even in the broadest of terms because much of the costs or related infrastructure is not specified and is awaiting the preparation of (as yet unpublished) ªmasterplansº for each site allocation. The fear is that many sites will either be undeliverable / unviable or worse; delivered without the appropriate infrastructure necessary to avoid adverse impacts on the wider area. The Government has also recently confirmed its aim for the UK to have net zero carbon emissions by 2050 and it is noted within the Sustainability Appraisal supporting this Draft Local Plan, that the Plan area is forecast to see carbon emission increase by 21% in the Plan Period. Accordingly, the Plan is inconsistent with Government Policy and therefore not legally compliant.
9348 PP Mods - Please specify as The Plan needs to be modified by; precisely and succinctly as Consulting with nearby authorities such as Green Belt Villages Policies possible how you would modify this policy to improve The Council should be looking at more effective alternatives such as higher densities of housing its alignment to this test of development on brownfield sites which are generally closer to the town centre that are therefore in soundness. more sustainable locations than Green Belt sites and which will also rejuvenate Chesham, as advocated by an alternative community led scheme. Green Belt boundary reviews should only be considered AFTER all other reasonable alternatives have been exhausted, and not as the first port of call. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5511830 Please attach any supporting evidence
Person ID 1214139 Full Name Mrs Claire Ellerton ID 4443 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Learning Support Assistant Egerton Rothesay School Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-12-11 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details
9349 Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has
9350 met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do With reference to Policy SP BP2: We live in a stressful world where mental health, physical wellbeing and not believe this policy to be the importance of community are increasingly important issues. Over the seven years that I have lived positively prepared please opposite the Lye Green greenfield site, I have observed many locals regularly using the fields to walk alone, explain why with friends and family, or with dogs, to jog, to get into or out of town on foot and generally to enjoy the peace and space provided there. Although I am no expert, other locals I have spoken to have observed important and rare wildlife and plants in the fields. A neighbour who lives in a house that backs right onto the field on Lye Green Road reminded me of a large clump of clover growing on the field and the fact that we need to protect these wild plant species for pollination. I have noticed the abundance of different butterflies over the past months too. In seeking to remove the Lye Green fields from greenbelt status, the Local Plan flies in the face of its own policies to protect biodiversity and wildlife habitats. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1214227 Full Name Mr John Chambers ID 3847
9351 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-12-07 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as
9352 precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Firstly, concerning the housing development which is the extension to the hilltop estate in Chesham, I was not believe this policy to be wondering how the traffic was going to access the main road. I don't know if you are aware, but with the positively prepared please schools in hilltop, there is considerable congestion twice a day on Cameron Road.This congestion is twofold: explain why firstly there is a big tailback of (engine idling) cars in Cameron Road wanting to get onto the main Berkhamsted Road, and secondly, and more importantly, cars wanting to turn into Cameron Road coming from the town centre, i.e. turning right and needing to wait for a gap in the traffic, do cause a considerable snarl up for the free flowing of traffic on Berkhamsted Road. If you are intending for all the new traffic to come through the hilltop, you are going to have a big problem on your hands. On the other hand, if there is a way for the school traffic to go some other route with this development, you will have a knock-on beneficial effects to the traffic flow on Berkhamsted Road. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not Secondly, and I don't know if this has been addressed by anyone, but the South East of England is quite a believe this policy to be dry part of the world: we actually don't have that much rainfall. So I am concerned about the long-term justified please explain why sustainability of the water supply, and especially its resilience to drought situations in hot spells, which we are told are likely to become more numerous as climate change happens. If Victorian engineers were able to transport water long distances from the Lake District to Manchester, and from Wales to Birmingham, clearly long distance water transfer is do-able, then I would suggest that some kind of strategic water supply network needs to be constructed to take water from the wet north-west to the dry south-east, if this kind of development in the south-east is to be sustained. It would be disappointing for the government to only address this after it becomes a problem, but entirely typical of the British way. I suspect that the fragmentation of the water supply industry doesn't help with this kind of long-term planning, and the availability of information. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
9353 Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1214423 Full Name Miss Christine Lee ID 3592 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-11-06 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You
9354 will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I believe that time and money would be better spent addressing the issue of overpopulation. not believe this policy to be
9355 positively prepared please Taking away some of the beautiful, peaceful countryside around us and replacing it iwth areas marked for explain why building does nothing to help. Anxiety and sadness that one day it will all be gone, along with thew wildlife that lives there. And then there is the inevitable reduction in value of our properties, a worrying fact that will impact our futures. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I do not believe that this plan is legally complaint, or sound. believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1214481 Full Name Mr Christopher Collier ID 4247 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-12-12 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details
9356 Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has
9357 met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do There seems to be an unnecessary focus on releasing green-belt land for development. Chesham is the not believe this policy to be best example, where houses could be better placed elsewhere - ie. closer to existing amenities positively prepared please One of the arguments put forward [previously] for releasing green-belt, was that plots could be offered to explain why individuals. I now see that this will only be for sites of over 100 homes - this is very disappointing. The local plan makes reference for retaining woodland.The Chesham proposal includes releasing woodland from the green-belt and then including a strip of this in the area to be built upon. I believe this to be wrong. Releasing large areas of green-belt should be a last resort. The proposal for Chesham is poorly sited, not very sustainable and will be to the detriment of both Chesham and Lye Green. There should be more space provided between any new development and the existing homes, to provide a buffer. PP Mods - Please specify as There should be a provision for all sites to accommodate plots for individuals to have the opportunity to build precisely and succinctly as their own homes. possible how you would The Chesham site is re-sited to a more ©sustainable© local, ie. closer to the existing town centre and amenities modify this policy to improve its alignment to this test of The areas of established woodland not be included in the area to be built on, eg. Chesham as currently soundness. stands. Re-site the proposed houses closer to the centre of Chesham. If any are to be built on the current site, reduce the number and increase the amount of open/ green space retained. Policy 1 - If you do not Whatever the benefits of providing 500 homes, etc. are, there seems to be a distinct lack of reasoning as to believe this policy to be why this particular site has been chosen. There are areas of green space which are much more suited to justified please explain why sustainable development. Policy 2a - Please specify as Remove the 500 homes proposal for Chesham in its entirety and find an alternative site closer to the existing precisely and succinctly as town centre. possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not Too many homes for Chesham, sited in the wrong location. Could be much better placed and done in such believe this policy to be a way as the existing green-belt boundary to the town is totally ignored. effective please explain why. PAa - Please specify as Scrap the current proposal for the Lye Green side of Chesham and find an alternative location, closer to the precisely and succinctly as town centre. possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1214496 Full Name Mrs Caroline Biddle
9358 ID 7267 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-12-10 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its
9359 alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not The proposals to release Green Belt land to meet housing targets (Generally, Spatial Policy SP SP1 and believe this policy to be specifically Policy SP BP2 at Lye Green NE of Chesham) are not justified from the evidence submitted by justified please explain why the Councils. The Councils have stated that release of some Green Belt is necessary as part of an overall three part strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. I question the soundness of such a general policy and whether all the brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites and in particular the Green Belt site NE of Chesham at Lye Green. The development of such Green Belt sites involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient and unfunded. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham cannot accommodate any significant highways improvements anyway due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion, with further worsening air quality. Air pollution is a particular concern in Chesham due to the already poor air quality along Berkhamstead Road where there is a designated Air Quality Management Area that already is recording air quality that is
9360 considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will generate more traffic will make the air quality even worse and insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable nor justified nor is it in accordance with Government policy. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1211187 Full Name Ms Georgina Lomnitz ID 3977 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-01-31 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be
9361 as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public?
9362 Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not We wish to comment on the Draft Local Plan (especially pertaining to Chesham Policy SP BP2) which we believe this policy to be conclude is unsound and not justified.We find that your document is very hostile to the non-specialist reader. justified please explain why a) The passing of The Climate Change Act 2008 (2050 Target Amendment) Order 2019 has changed the requirements for future developments. All green land is a carbon sink removing carbon dioxide from the atmosphere, as well as absorbing rain. Any concreting over, for example at the impractical site below Lye Green, prevents carbon capture and contradicts the Act, so must be compensated for elsewhere in the districts. b) Any housing development must not reduce green land e.g. Policies SP LP1, SP BP2, and must be located in or very near town centres. This will reduce or eliminate extra car journeys and traffic queues down the hills into Chesham town centre, giving the additional benefit of reducing air pollution. Paragraph 4.9.2 claims that development will not be allowed without improved public transport, i.e. buses. All the previous housing developments around Chesham started with bus services, but these have withered away to very few per day or none (with the exception of Pond Park Estate, Chesham). Similarly, shops were provided for these housing developments, but all have failed (with the exception of Greenway Parade, Chesham). How will this pattern change in your new developments? No amount of redesigning road junctions will prevent traffic from new developments trying to force its way on to the A416, which is already gridlocked in rush hours. c) Housing standards are bound to be changed very soon to meet The Climate Change Act 2008 (2050 Target Amendment) Order 2019. For example, Policy DM DP5 is certain to be amended to allow for collection of rainwater, use of grey water, soakaways rather than drains, solar panels, etc. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5499132 Please attach any supporting evidence
Person ID 1211187 Full Name Ms Georgina Lomnitz ID 3993 Order 236
9363 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-01-31 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as
9364 precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do a) The National Planning Policy Framework requires a water supply for new housing and there is no spare not believe this policy to be water for licensing in either the Colne or the Thames catchment areas.Where will the new housing in Chesham positively prepared please get their water from? explain why b) Paragraph 3.1.2 ªSupport residents to reduce waste and increase recyclingº. Extra houses will mean that the recycling centre in Chesham will need to be open every day, in order to discourage fly-tipping. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
9365 Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1214625 Full Name Mr Gary Bartlett ID 3409 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-12-05 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness?
9366 Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Policy SP BP2 ± Chesham - 500 new homes and associated facilities. not believe this policy to be 1. The Council should plan for many kinds of transportation for the residents of the new homes, which could positively prepared please number over 1,000, namely walking, cycling, public transport and private vehicles. explain why The plateau location of the site means it located at the top of a steep hill with access by road and footpath via Nashleigh Hill (A416) / Lycrome Road; Eskdale Avenue / Lye Green Road (B4505) and White Hill (to the B4505). According to Google Maps, Lye Green is 2.1 miles from Chesham town centre and its bus terminus and Underground railway station (TFL Metropolitan line). Given the geography how likely is that residents of the new homes will cycle or walk to these destinations? The bus services closest to Lye Green (to Berkhamsted and Hemel Hempstead) are sporadic at best. This leaves private transport with the problem of exacerbating existing problems of congestion and air pollution.You only have to see the traffic jams that result from a single set of traffic lights because of road
9367 works anywhere along the A416 as it runs along the valley bottom. It is common at rush hour / school opening and closing times for resulting queues on the A416 to go back to Ashley Green to the north and Chesham Bois to the south. Surely it makes greater sense to develop brownfield land on level ground within the built up area that is closer to bus and rail transport hubs and which is therefore within walking and cycling distance. The decision by TFL to run through trains to Chesham on the `Met' line (replacing the shuttle service to Chalfont & Latimer) has significantly increased the attractiveness of Chesham to commuters heading to London to work. The surface car park at the station is already full early in the morning `rush hour'. If the new housing is allowed thereby further increasing demand of the rail service, it is essential that the developers contribute towards the decking of the station car park. An example of this has taken place at Rickmansworth Underground station and the Inspector is asked to seek details of how this was financed. Policy SP BP2 gives no details of the `adequate mitigation' needed to address the impact that another 500+ private vehicles will have on the existing situation (paras 11.3.3 & 11.3.4). The Plan therefore FAILS on this criterion. 2. Paragraph 11.3.5 states that there is an AQMA along the A416 (Berkhampstead Road and Broad Street). The Inspector should be aware that there is a Medical Centre (Chess); a primary school (Newtown) and two pre-school nurseries/day care fronting onto the A416 within the AQMA. The elderly, children and parents that do not drive to these facilities (see previous paragraph), walk through the AQMA to get to them. The Inspectors attention is drawn to the Air Quality section on page 30 of the Joint Chiltern and South Bucks Authorities' Monitoring Report 2017/18 and footnote 18 - 2018 Air Quality Annual Status Report for Chiltern District. How will junction modelling improve the situation when the physical geography of Chesham means there is only one road running through the town. All side roads north and south of the town have to eventually join the A416 at some point. Traffic lights, mini roundabouts etc on the A416 will not prevent this. How can the developers who develop the allocated site with housing and the local highway authority realistically demonstrate that the new residents will not increase existing levels of pollution in the valley bottom in the AQMA. Policy SP BP2 does not demonstrate or give guidance on how this might be achieved. The Plan therefore FAILS on this criterion. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5498120 Please attach any supporting evidence
Person ID 1211575
9368 Full Name Miss Nicola Bland ID 3720 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-03-10 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness?
9369 Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Changing the purpose of the land so that it solves a short-term issue such as the housing problem in the not believe this policy to be district would mean that the long-term implications are immense. When the land has been reclassified there positively prepared please will be no going back. The council will have to deal with the decision of building out of town, so Chesham explain why residents will have to drive to the town. Though the council are going to show how the increased pressure on bus services, such as transport and sewage is going to be solved. The residents of Chesham will be suspicious and angry at the council. One of the main reasons the Green Belt site NE of Chesham is not a sustainable location. It is over 2km away from the train station and slightly further still from the town center but anyone who cares to walk or cycle this distance also has to negotiate a very steep hill in either White Hill or Nashleigh Hill. Such an unsustainable location cannot be made sustainable merely by upgrading a couple of footpaths within the site into bridleways to facilitate cycling. Neither does adding a bus stop address the geography or topography of the area especially if the promised enhanced bus service (which is already infrequent) either does not materialise or if it subsequently fails to be maintained after a few years. The residents only method for the disabled or elderly will be to use their vehicles.There are many problems with this as I have already mentioned. Further doubt is cast upon the logic of this plan by virtue of there being conflicting policies within it. The council seem to think that the Green Belt site NE of Chesham is sustainable and provides easy access to public transport including the tube station yet the same plan promotes a considerable increase in retail development in the town (SP EP3), part of which would be built on the very car park that serves Chesham tube station. This shows that the council is not considering what the impact of building out of town will be. If you build out of town where the bus service is infrequent and unless you are physically fit and don©t mind the lung bursting walk up White Hill, then as previously stated. The only method of transport is the car. The land north east of Chesham in Lye Green which is currently used as agricultural land. This means that this business employs local people and provides numerous paths and bridleways. The farmer who owns the land is also not prepared to sell all the land. Though I believe once the council starts building in the area, it will be easier for them to try to pass subsequent plans to build on the land later. The land has now been recognised as an Asset of Community Value as such it would afford a community group the right to bid for the land. The community group (Brown Not Green) have stated their intention is to
9370 preserve the land given that many hundreds of local people have habitually used the fields at Lye Green as of right for various informal outdoor recreational purposes. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not That facts that the land in the Lye Green area, are unsuitable for building 500 houses, but also will be believe this policy to be unsustainable. The council would be better to look at brown fill areas, and areas nearer the town center and justified please explain why the impact of building nearer the center will be less than trying to build in an area where it looks good on the map. The council has failed to explain their decisions at every turn. The development of such Green Belt sites involving many hundreds of homes will generate increased traffic and although some highways improvements are suggested they are insufficient. In Chesham the evidence shows that most of the road junctions and framework is already operating above capacity. Any minor disruption in the already heavy traffic flow as seen recently, causes elongated tailbacks.The valley which Chesham sits in is a natural trap. Both for water and pollution. The long term effects of air pollution on the younger members of Chesham will only be realised when it is too late. The Councils in London areas are already trying to implement plans to decrease air pollution.What are the Council going to do about letting the children at the Newtown primary school play in a school playground which will not comply with EU air quality standards? Again, the Council have not explained. Adding more homes outside the town on the Green Belt will generate more traffic which in turn will make the air quality even worse. Insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable nor justified nor is it in accordance with Government policy. Especially with the announcement to the country that Britain will reach net zero carbon emissions by 2050. So clearly the council have again looked for the short-term fix for what is a long-term problem. It is perverse that the Local Authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the plan is not feasible. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not The foregoing also points to flawed methodology of Green Belt site selection used by the Local Authority, believe this policy in which is neither effective, justified not consistent with national policy and as such is unsound. Specifically, consistent with the National the selection of the land NE of Chesham at Lye Green for removal from Green Belt designation is inconsistent Planning Policy Framework with National Planning Policy Framework (NPPF). The council cannot pick which bits of legislation they will Feb 2019 please explain why abide by. The need for more housing is an ongoing problem all over the country but if we in the south east do. To protect the Green Belt with on the upcoming projects such as Heathrow 3rd runway and HS2. Clearly the need for open space is even more important.This need does not fit the criteria of exceptional circumstance. The subsequent identification of the Chesham site for release is therefore unjustified as the Local Authority itself who notably then did not undertake all the recommended reviews of each site. Thus, showing the unsuitability of the Lye Green Site. The primary aim of Green Belt land is to prevent urban and to preserve the openness of the area. The Lye Green site self-evidently performs this function well and has done so for decades. Another aim of Green Belt land stated in NPPF paragraph 134 is to prevent neighboring towns and settlements from merging into one another.The Green Belt land NE of Chesham performs exceptionally well in maintaining a distinct separate between settlements of Chesham and Lye Green as well as helping to maintain separate identities of other nearby communities at Orchard Leigh, Botley, Whelpley Hill and Ashley Green. It is perverse and inconsistent with national guidance to allocate this land for removal from the Green Belt considering these facts especially when the land also represents good quality agricultural land and an enviroment for many species of wildlife that will be lost if earmarked for development. The Council have asserted that Government policy requires local councils to review Green Belt boundaries when considering how to accommodate the development needed in their areas. Just because the Council may be required to look does not mean the Council should review Green Belt boundaries which as previously stated should only be modified in "exceptional circumstances". Accordingly, I submit that given all of the above the land being proposed for release from Green Belt designation around Chesham is unjustified and contrary to national guidance. I feel the land NE of Chesham is an unsustainable location for development, that has been habitually used by the community for improved health and well being for decades and the land performs well against Green Belt aims and objectives. Exceptional circumstances for reviewing Green Belt boundaries at this location either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by Govt Policy and therefore the plan is unsound.
9371 Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1211702 Full Name Mr Brian Kilbey ID 3991 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-02-29 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant
9372 legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do a) The National Planning Policy Framework requires a water supply for new housing and there is no spare not believe this policy to be water for licensing in either the Colne or the Thames catchment areas.Where will the new housing in Chesham positively prepared please get their water from? explain why b) Paragraph 3.1.2 ªSupport residents to reduce waste and increase recyclingº. Extra houses will mean that the recycling centre in Chesham will need to be open every day, in order to discourage fly-tipping. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would
9373 modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1211862 Full Name Mr Fred Wilson ID 3357 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-03-06 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance?
9374 Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible
9375 Policy Level - PP - If you do See comments above. not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not We appreciate the need for a Local Plan for Chiltern and South Bucks Districts. That is not the issue. believe this policy in However, as is often the case when there are nationally issued regulations and guidelines, common sense consistent with the National needs to be applied in instances where simply following said regulations and guidelines leads to the wrong Planning Policy Framework outcome. Feb 2019 please explain why This is the case as regards Chesham and specifically the proposal to release land from the Green belt on the NE edge of the town. From the outset, the community of Chesham has been broadly supportive of building more homes in Chesham. We know they are needed. In fact, the community went so far as to set up a Community Interest Company which has drawn up a Master Plan for Chesham based on the actual needs of the community. Unfortunately, this Master Plan does not appear to fit well with the nationally issued regulations and guidelines, at least as interpreted by the councils. The Local Plan differs from the Chesham Master Plan in particular by proposing that the bulk of new homes are built on the outskirts of Chesham. This is the wrong solution for Chesham. It is also contrary to the recent Climate Emergency resolution passed by the Council after this consultation started (see note below). Chesham does not need more 4-5 bedroom homes on the outskirts of Chesham, some 2 miles away from the centre of town. We need affordable homes, starter homes for young families and homes for the elderly who wish to down-size. All these homes should be in or near the centre of Chesham both for the benefit of those living in the new homes and for the community at large e.g. fewer cars and car journeys = less pollution. We ask that the Inspector, in this instance, please apply the common sense which apparently the regulations and guidelines do not permit the District Councils to apply in the case of Chesham. It is interesting to note that the many issues which make the development of the Green Belt site on the border of Chesham so problematic, are fully recognised by the District Councils. For example, there are no real solutions in the foreseeable future for two of these issues: - The County Council objected on the grounds that the road infrastructure cannot cope as it is and there is no practical method of alleviating that to cope with significant additional traffic. - The air pollution along the road into Chesham town centre is already a major concern and could not tolerate the additional traffic. In fact, the issues are such that at one stage the Councils proposed to take the land out of the Green Belt but not to develop it. Rather, it would be ªsafeguardedº for development some time in the future beyond the Local Plan period. This is an admission that development of this site is not in fact deliverable within the Local Plan period. The solution to this is the Chesham Master Plan produced by the Chesham Renaissance Community Interest Company in conjunction with Chesham Town Council and several local community groups. Note: On 23 July 2019 Chiltern District Council declared a Climate Emergency, with an aspiration to be carbon neutral by 2030, well within the timeframe of the Local Plan. In particular, officers were charged to ensure that specific consideration is given to how policies affect our contribution to climate change, and to take action as appropriate. Clearly the Local Plan now needs to be reviewed and action taken regarding proposals that would significantly contribute to climate change. There is no doubt in our minds that the proposal to build hundreds of houses on the outskirts of Chesham would contribute significantly to harmful emissions. Therefore, in accordance with the Council's own Climate
9376 Emergency declaration, action should now be taken. The solution is offered by the Chesham Master Plan. There is, therefore, no need to remove a large piece of land, which contributes positively towards carbon neutrality, from the Green Belt. Note: Subsequent to the start of the consultation, it has been recognised that the land north-east of Chesham that the Local Plan is proposing to remove from the Green Belt, in fact meets the criteria of the Localism Act 2011 to allow it to be listed as an Asset of Community Value. Surely this, together with the other considerations mentioned above, clearly demonstrates that this land should remain in the Green Belt and be preserved for use by the community. Policy 3a - Please specify as Yes, regarding Chesham: precisely and succinctly as - Do not take any land out of the Green Belt possible how you would modify this policy to improve - Instead implement the Chesham Master Plan, which would deliver at least as many if not more homes, of its alignment to this test of the right type and in the right place. soundness. Having studied the Local Plan consultation documentation including the Evidence Base on the Chiltern District Council website, and attended meetings on the Local Plan at Chesham Town Council, the Chesham Society and the Chiltern Chamber of Trade & Commerce, we believe the following modifications should be made: - The Local Plan should aim to deliver a greater proportion of flats, family starter homes, and smaller homes for older people wishing to downsize from family homes too large for them. Evidence includes feedback from local estate agents to the effect that such properties are often sold off-plan before even being built or, where older properties come on the market, are often sold without appearing in the local press property pages. - It is clear from the overwhelming response at the Chesham Town meetings and from talking to friends and neighbours, that such properties mentioned in the bullet above should be in or as near as possible to the Town centre with easy access on foot to local shops, public transport, schools, GP and other services. - We fully support the idea of building such homes including flats up to four or five storeys in height where appropriate, in and around the Town Centre. The best places to build these are on parts of the current car parks in the Town Centre and near the London Underground station. - Chesham has abundant parking spaces in and near the Town Centre. However, they represent a highly inefficient use of space. They are all on one level and take up around half of the Town Centre area. Two of these car parks, the one next to the London Underground station and the main Waitrose car park, could be replaced by multi-storey car parks, providing much of the parking space needed both by commuters, people working in the Town Centre, shoppers and visitors. This would enable, for example, large scale development providing homes and retail facilities in the town centre, together with the requisite infrastructure. - Chesham Town already suffers from significant urban sprawl due to its position in a narrow valley. Housing development on the North and West edges of the Town would be so far from the Town centre as to require people to use what little public transport there is or, much more likely given current experience, cars to access Chesham town centre. This would increase the amount of traffic congestion and air pollution, both of which are already major issues in the town. The Green Belt: On the face of it, there does not appear to be any need to encroach into existing Green Belt land on the edge of Chesham, if we accept higher density housing development in Chesham town centre and release under-utilised employment land. Policy-level file upload - Please attach any supporting evidence
Person ID 1214755 Full Name Mrs Janet Lansdowne ID 5255 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-12-09 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details
9377 Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has
9378 met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The Council's plan to release Green Belt (SP SP1 & SP BP2 at Lye Green NE of Chesham) as part of a not believe this policy to be strategy to meet housing needs targets are not justified from the evidence submitted. positively prepared please The potential to build on Brownfield land has not been fully explored and neither has the potential to build explain why higher densities closer to the town centre. With particular reference to the land to the NE of Chesham (Policy SB BP2) this is not a sustainable site. It is located 2.5k from the town centre at the top of a steep hill making walking or cycling into the town centre difficult for most people who would choose to drive, which would increase traffic congestion and have an adverse effect on local air quality. Building 100's of homes on the Lye Green site, due to the location inevitably will generate an increase in traffic and congestion in Chesham, evidence shows that most junctions are already operating well above capacity. There is limited potential to improve the road network due to the topography and the countryside location. Proposed infrastructure improvements to roads are insufficient and underfunded. Increased traffic will also have a detrimental effect on air quality & pollution in the town which is already in an Air Quality Management Area that has recorded levels that far worse than EU safe levels. Air Quality is a hot topic at National Government level and to build houses on a site which will adversely impact air quality is unsustainable, unjustified and goes against Government policy. This land has also recently been listed as `An Asset of Community Value' under The Localism Act 2011, demonstrating its' significance as an open area where people have enjoyed informal recreation for decades. Many local individuals have acquired easements on the land through prescription of 20 years uninterrupted use. Additionally, many houses have rear garden gates which open on to the fields which gives them prescriptive rights. For the local Authority to allow development on this land undermines the objectives of the Localism Act. How can this land now be considered suitable for housing development? Releasing this area of Green Belt is not consistent with draft Local Plan policies to protect Wildlife habitats, biodiversity and globally scarce chalk stream rivers. It is also valuable agricultural land. Policy SP EP3 proposes to build more retail shops mostly on the town car parks. This is totally unjustified and unsound when there are already a large number of retail units vacant in Chesham. Additionally, it doesn't make sense to take away car parking space when additional capacity will be required to accommodate an increase in the number of commuters needing car parking at the train Station as a result of an out of town housing development. The deliverability of this land is in question as the Landowner has stated in an open letter in `Your Chesham' that he not prepared to release all of his land for development. The Council has said that Government planning policy required them to review Green Belt boundaries when trying to meet housing targets, however this was an option rather than a directive and the NPPF went on to say that boundaries should only be modified in exceptional circumstances. The NPPF paragraph 11b, which was revised only last year, directs `Plan makers' to create policies that are required in Local Plans for housing and other uses unless Framework policies (including Green Belt) provides a strong reason for restricting the overall scale type or distribution of development in the plan area. Consequently, I believe that the above statement proposing to release the Green Belt around Chesham is contrary to National Guidance and therefore unjustified. I am supportive of The Brown Not Green Organisation's initiative to have the land listed as an Asset of Community Value and I feel they speak for me in respect of their objections to the Draft Local Plan. Accordingly, I request that any representations made by them at any future examination in public regarding the soundness of this Local Plan be considered as an extension of my own comments herein. I believe that the land NE of Chesham is unsustainable for development, it has been habitually used by the community for improvement of health & wellbeing for many years and the land performs well against Green Belt aims and Objectives. Exceptional circumstances to remove this land from Green Belt have not been proved as required by government Policy and therefore the plan is unsound. PP Mods - Please specify as I refer to comments previously submitted but in summary would suggest that; precisely and succinctly as All other options are fully explored including increased density of development of Brownfield land and all the possible how you would policies of Chesham Masterplan. modify this policy to improve
9379 its alignment to this test of Green Belt land should ONLY be considered when all other policies have been exhausted and in any event soundness. the proposals for developing land NE of Chesham (Policy SB BP2) should be removed as it is an unsustainable location and development here will cause harm to the whole town and also includes a loss of an asset That improves the wellbeing of a community. Policy 1 - If you do not I refer to my comments previously submitted. believe this policy to be justified please explain why Policy 2a - Please specify as I refer to my comments previously submitted. precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not I refer to my comments previously submitted. believe this policy to be effective please explain why. PAa - Please specify as I refer to my comments previously submitted. precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I do not consider the draft Local Plan legally compliant because it does not follow the guidelines set out in believe this policy in the National Planning Policy Framework (NPPF) issued by the Secretary od State. This policy clearly states consistent with the National that Local Authorities must demonstrate that they have exhausted all other options before removing Green Planning Policy Framework Belt for the purposes of housing development. Feb 2019 please explain why The NPPF also promotes the use of land effectively for meeting housing needs whilst safeguarding and improving the environment. The draft Local plan proposal to remove the Green Belt designation of 13 Areas and remove several villages from Green Belt protection (Policy SP PP1 & DM PP1) does not follow the NPPF guidelines as it has not investigated thoroughly the use of brownfield land or given sufficient consideration to alternative options such the Chesham Masterplan. The draft Local plan is not meeting housing needs effectively or safeguarding and improving the environment. The Local Authority has not given enough consideration or fully explored all other options before removing the Green Belt status and allocating it for housing. The Courts have ruled that Green Belt should only be used for housing in `exceptional circumstances' and housing need alone does not constitute exceptional circumstances. I do not believe that the Local Authority have proved that exceptional circumstances exist in the draft Local plan. With particular reference to the land to the NE of Chesham (Policy SB BP2) this is not a sustainable site and I question the site selection methodology! The NPPF (133) states that the purpose of Green Belt is to prevent urban sprawl and neighbouring towns and villages merging, the Lye Green site clearly performs this function well by separating Chesham from Lye Green. The sustainability Appraisal supporting the draft Local Plan forecasts carbon emissions to increase by 21% during the plan period which goes directly against The Government's target for the UK to have net zero carbon emissions by 2050 and therefore inconsistent with Government Policy and not legally compliant. For this site to be sustainable there would need to be significant investment in infrastructure which the draft Local Plan acknowledges there is a funding gap of between £179m to £231m. There is no justification to go ahead and build houses when there is such a question mark over the provision of the necessary infrastructure to support it! Policy 3a - Please specify as Green Belt should only be considered after ALL other options have been thoroughly explored as stated in precisely and succinctly as the NPPF. possible how you would The Local Authority should look again at all Brownfield site opportunities to identify any that have been missed modify this policy to improve off the Brownfield register. its alignment to this test of soundness. Consider higher density housing on Brownfield sites near or in town centre locations which are more sustainable. They would be more affordable, convenient for public transport reducing the need to use a car (reducing the impact on air quality) and would rejuvenate the town centre. Further consideration to be given to alternative housing development plans as put forward Chesham Masterplan by CIC Chesham Renaissance which proposes to provide more affordable housing in or close to the town centre with the added benefit of regenerating the town centre. Further co-operation with neighbouring Authorities (as was done with Aylesbury) e.g. Dacorum, Slough. People living in Chiltern District travel to these areas for work, shopping recreation purposes therefore they are not in a different functional Market area. Policy-level file upload - 5511424 Please attach any supporting evidence
Person ID 1214892 Full Name Ms Kim Tyrrell
9380 ID 3533 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-12-05 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its
9381 alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Misuse of land currently designated as green belt. not believe this policy to be No existing sustainable infrastructure to support the plan nor any viable infrastructure proposed or budgeted positively prepared please for. explain why (Unsound) PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
9382 Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1214892 Full Name Ms Kim Tyrrell ID 3535 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-12-05 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness?
9383 Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Extension of consultation period due to non compliance issues. (not met) not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why
9384 Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1215017 Full Name Mr Ian Jarvis ID 4176 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-12-04 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to
9385 make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this
9386 to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I do not consider the plan sound for a number of reasons, some of which have been detailed in the previous not believe this policy to be sections. However, there are further reasons for me taking this position. positively prepared please The plan makes some provision for infrastructure, but nowhere near enough. Plans for tackling issues such explain why as traffic, access to the site, parking in town, drainage, flooding risk, school places, doctors and employment opportunities are just some areas which have very little explanation. Although some highways improvements are suggested, they are insufficient and unfunded. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham cannot accommodate any significant highways improvements anyway due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion, with further worsening air quality. Regarding the homes being built, there is no mention of which form these will take, where they will be placed on the land or how tall they will be. These factors could have major implications for residents in the adjoining and surrounding areas. In the plan, 114,000 square feet of retail space is suggested for the town centre. This is a town centre where many shops are already shut or may be shutting soon. This shows an incredible lack of understanding of Chesham's town centre and the issues it faces. Not only will the viability of these retail spaces be under huge pressure, but there will also be the extra factors such as parking for shoppers and access for delivery vehicles. If the plan believes there is room for this level of retail space, can this not be considered for town centre housing instead? It is in the Chesham Masterplan. I also have deep concerns for how this plan was approved at a recent public meeting. Councillors spoke of serious reservations about the plan, but even after this only 2 voted against and I believe these councillors have now been suspended. I can only conclude the councillors were voting under a three-line whip. Some of the reasons then given for their approval (despite these serious reservations) were that only 2.7% of green belt would be lost (setting a bad precedent), Central Government would only write one for us if we reject this one and that this is the least worst option. Hardly ringing endorsements and it suggests the councillors are taking the path of least resistance. We need to remember that this plan will change our town and the surrounding villages forever and any negative impact will affect future generations very badly. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I believe the draft Local Plan is NOT legally compliant in regard to the National Policy and guidance issued believe this policy in by the Secretary of State. consistent with the National The National Planning Policy Framework (NPPF) makes it clear that Local Authorities MUST demonstrate Planning Policy Framework they have exhausted all options BEFORE considering revisions of Green Belt boundaries. I don't believe Feb 2019 please explain why the draft Local Plan has demonstrated that all other options have been fully explored and as such this Plan is not justified, sound or in accordance with National Policy and accordingly is not legally compliant. There are entire sections of the NPPF to which this draft plan falls critically short. Chapter 7 - Ensuring the vitality of town centres. Building homes at the top of a steep hill, at least 2km outside of the town centre, will do little to enhance the vitality of the town centre in Chesham. With the development including some (admittedly limited) retail units, residents are likely to use this rather than travel into the town centre. Chapter 8 - Promoting healthy and safe communities and Chapter 9 - Promoting sustainable transport. Chesham already has some severe air quality issues, not helped by congested roads. Building homes on top of the hill will mean the majority of residents will use cars when they do come into the town centre or to access the train station. Independent surveys predict the traffic congestion will increase by 400% under this plan. The Government has also recently confirmed its aim for the UK to have net zero carbon emissions by
9387 2050 and it is noted within the Sustainability Appraisal supporting this Draft Local Plan, that the Plan area is forecast to see carbon emission increase by 21% in the Plan Period. Accordingly, the Plan is inconsistent with Government Policy and therefore not legally compliant. Chapter 13 ± Protecting Green Belt land. I do not believe the ªexceptional circumstancesº required to remove Green Belt protection has been met by this plan. There are a number of alternative Brown Field Sites and plans (such as Chesham Masterplan by CIC Chesham Renaissance) which will enable the housing needs to be met and the Green Belt to be protected. Chapter 14 - Meeting the challenge of climate change, flooding and coastal change. Flooding and drainage is already an issue in many parts of Chesham. Building on Green Belt land (which will absorb vast quantities of water, with increase flooding risk. With the development being sited at the top of a hill there is also only one way for this water to flow. Chapter 15 - Conserving and enhancing the natural environment. The area highlighted for development is rich in countless species of wildlife and home to threatened bird species. Areas like these are vital for maintaining biodiversity. There is also a significant infrastructure funding gap acknowledged within the Community Infrastructure Levy evidence that supports this Local Plan, of between £179m & £231m. Given this infrastructure is vital to ensure that development is sustainable (as also required by the NPPF) this further demonstrates the Plan is both unsound and not legally compliant. Policy 3a - Please specify as I believe the plan needs to be modified by in a number of ways. precisely and succinctly as Alternative options for housing development should be explored in much greater detail, in particular The possible how you would Chesham Masterplan by CIC Chesham Renaissance. This plan resolves almost all of the issues I have modify this policy to improve mentioned in the previous section and takes greater steps to reduce the impact of those it cannot completely its alignment to this test of resolve. It also has the backing of at least 70% of Chesham residents. soundness. It is a more visionary plan, but one which has the potential to reinvigorate Chesham from the centre out and may even become an historic turning point in how suburban development addresses sustainability. A more detailed appraisal of Brown Field land opportunities MUST be undertaken with far greater scrutiny Some Brown Field opportunities have been ignored or missed. Green Belt boundary reviews should only be considered AFTER all other reasonable alternatives have been exhausted. Policy-level file upload - 5500689 Please attach any supporting evidence
Person ID 1212207 Full Name Mrs Jenny Walker ID 4855 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-03-13 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be
9388 as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public?
9389 Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do THE LOCAL PLAN IS NOT DELIVERABLE not believe this policy to be This local plan has an acknowledged funding gap from the Community Infrastructure Levy (CIL) of between positively prepared please £179m - £231m. Many of the proposed sites (including SP BP2 Chesham) are excluded from the CIL so that explain why developers will be required to deliver infrastructure directly or make financial contributions to mitigate the impact of development. These impacts are as yet unquantified and the costs unspecified so there is a considerable risk that the necessary required infrastructure would not be delivered. In particular, Chesham Town Council have raised concerns that the Chesham Sewage Treatment Works (CSTW) will be unable to cope with the increased capacity for the duration of the local plan. The main landowner of the site NE of Chesham has also asserted publicly (in an open letter to Your Chesham magazine) that he is not prepared to release all the land in his ownership for development. This farmland has been in his family for several generations. THE LOCAL PLAN IS NOT SUSTAINABLE The CSA's appraisal matrix of the site SP BP2 Chesham shows that there would be a negative impact both pre and post mitigation particularly with regard to landscape, climate change adaptation, natural resources, pollution, waste, transport and accessibility, health and economy. In fact, the only positive score (+++) for the Chesham site is the ability for it to accommodate 500 houses due to the large area of land being removed from the Green belt! The site North East of Chesham (SP BP2) thoroughly fulfills all 5 purposes of Green belt and NPPF para 143 states that, ªInappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances.º Provision of housing need alone does not constitute special circumstances. Many pages could easily be provided here detailing how this plan is unsustainable at every level. The more I discover, the more inconceivable it seems to me that the local plan is. For the sake of brevity, in the following pages, I will highlight just some of the serious concerns raised in the local plan with regard to sustainability. Again my knowledge mainly refers to the site at Chesham but may well apply to other Green belt locations. The Sustainability Appraisal of the Chiltern and South Bucks local plan appears to me to contradict national guidance in the National Planning Policy Framework at every turn. Location The Green belt site at Chesham is not a sustainable location. Local Plan 7.0.1 ªSustainability can be achieved through creating an environment where the activities important to the quality of day-to-day life are within easily accessible locations and which minimise the need to travel.º Local plan 7.0.2 ªWhen planning for movement, there should be a hierarchy of preference of walking, cycling and then public transport, before reliance on the use of a private car.º The Green belt site North East of Chesham is over 2km (1.33 miles) from the train station and further still from the town centre. (This is the shortest route measured from the median of the site to Chesham station.) There are two routes, both involve steep hills (White Hill or Nashleigh Hill).The road up White Hill is particularly narrow as is the pavement. No one would want to walk or cycle up it after a day at work! Especially after they had not got a seat on the crowded train. Bucks County Council Highways Development Management Guidance 2018 states that: ªDevelopments must meet their own transport needs. Development should be located to support sustainable transport choices and minimise negative impacts on existing transport networksº. The current bus service is hourly and does not operate late at night. If a developer funds an improved bus service, what happens when the service fails to be maintained? 500 houses on this site, shops and traveller pitches potentially means up to 1000 more cars in Chesham. Road junctions and infrastructure are already operating above capacity. Currently, all it takes is a delivery lorry in Broad Street or a badly parked car along Berkhamsted Road and the main (only!) thoroughfare in Chesham becomes gridlocked in an instant. This in turn will make the air quality even worse which already considerably exceeds safe EU levels along Berkhamsted Road where there is a designated Air Quality Management Area. I find the Draft Local Plan to be neither well prepared, justified, effective nor in accord with the National Planning Policy PP Mods - Please specify as Solutions precisely and succinctly as Chesham Renaissance Community Interest Company have an integrated plan for residential and commercial possible how you would development (the Chesham Masterplan) which seeks to provide the number of dwellings to meet the growing modify this policy to improve population and at the same time make infrastructure and environmental changes to improve the town. The its alignment to this test of basis of this plan is to increase the population density within the town but to protect the Green belt surrounding soundness. it. In 2018, the results of a consultation on the Chesham Masterplan showed that 70% of respondents supported a plan which would build new dwellings within the town centre and replace the existing car parks with multi storey car parking. Kitewood Estates Ltd, the preferred partner of Chesham Renaissance CIC will soon be making their first planning application. Chesham CIC is also working with Paradigm housing to deliver social and affordable housing. (Chesham Masterplan press release 19/06/19).
9390 This is a plan made by local people for local people for the benefit of the community of Chesham and yes! It does include plans to build plenty of houses! Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not However the site SP BP2 Chesham abundantly fulfils all 5 purposes of Green belt in the NPPF. It is also believe this policy in prime agricultural land (Grade 3a, possibly some of it Grade 2) and therefore classed as best and most consistent with the National versatile. It is grazing and arable land, containing diverse populations of birds, mammals, amphibians, and Planning Policy Framework insects, including the flora to support them. Feb 2019 please explain why It has recently been designated an Asset of Community Value by virtue of it being enjoyed and used for decades by local residents for informal recreational use. Natural Environment The Council Sustainability Appraisal (CSA) N56 states: ªA significant potential issue to be considered for Green belt locations is the fragmentation of habitats following development, reducing the connectivity of habitats.º N86 ªdevelopment is likely to result in a direct loss of habitat links.º NPPF 2.8c) ªan environmental objective ± to contribute to protecting and enhancing our natural environment; including helping to improve biodiversity.º NPPF 171 ªplans should: safeguard components of local wildlife-rich habitats.º The site North East of Chesham at Lye Green (SP BP2) lies adjacent to the AONB along one border and only one field away on another, and contains much of the same features as designations on either side, it is clear that the importance of this land goes well beyond that of simple undesignated arable land. That it should not just border a protected landscape, but several non-statutory Local Wildlife Sites, points to a land of rich connectivity whose value is being overlooked. A full assessment of its ecological value, including its role as green corridor and AONB buffer zone, is essential. This site (SP BP2) is of intrinsic value to wildlife, particularly due to the diversity of habitats contained within it. It is rich in birdlife and annually, around 55 different bird species are recorded there annually. (Buckinghamshire and Milton Keynes Environmental Records database) including at least 22 species which are on the Birds of Conservation Concern Red and Amber lists. Farmland birds make up many of the species recorded on the Chesham Green belt site and it is these birds whose populations are in the most severe decline (eg skylarks and meadow pipits) both of which are regularly seen on the Chesham site (SP BP2). If this site is lost, the birds will not simply go elsewhere, they will not breed and the local populations will be lost. 3 species of bats have been recorded at the site, (brown long-eared, common pipistrelle and soprano pipistrelle). This site also supports badgers, hedgehogs, rabbits, foxes and muntjac deer. An extended phase 1 habitat survey which was carried out on part of the site in 2016 concluded that the site could be of value to protected species such as badgers, bats, breeding birds, reptiles and great crested newts.To adhere to relevant wildlife legislation, several formal assessments and surveys were recommended. In so far as can be ascertained, none of these works have been carried out or are contained in the Council's Evidence base. Soil The Regulation 19 CSA states: N59 ªSoil within the districts is a highly valuable and non-renewable resource. Many of the potential Green Belt locations are largely located on previously undeveloped land, which is undesirable due to potential for soil contamination, soil loss and erosion, loss of carbon sink and water filtering capabilities¼many (sites) would require development of Grade 3 agricultural land. Development would therefore be likely to result in the loss of some of the district's most versatile and productive soils.º The land at the site Chesham 1 is certainly Grade 3 and possibly some even Grade 2 (Agricultural Land Classification map London and the South East ALC007). Its current use is partly arable and partly grazing (for a prize winning herd of Limousin cattle!) And in CSA N91. ªA significant quantity of development is proposed by the Local Plan, a large proportion on greenfield sites where it is expected that new buildings will result in the direct loss of the soil resource.
9391 The loss to BMV land would reduce the quantity of the most productive and flexible agricultural land that can best deliver food and non-food crops for future generations. Soil provides essential services to the local area, that include nutrient cycling, abating flood risk, filtering water and carbon storage. Direct loss to soil through construction will reduce these essential ecosystem services.º The NPPF 170 states: ºPlanning policies and decisions should contribute to and enhance the natural and local environment by: a) protecting and enhancing¼..soilsº Water According to the CSA N60: ªNone of the potential Green Belt removal locations are anticipated to have a positive effect on water quality due to the significant increase in demand on water demand and treatment facilities....Water pollution may also be of concern..º N92 ªThe Local Plan is likely to have negative impacts upon water. Inputs into the watercourse may cause significant harm to the quality of water. Development proposed within the Local Plan is likely to increase total water consumption.º N87 ªDevelopment in the plan area¼ may exacerbate flood risk.º The NPPF 170 e) says: ªDevelopment should, wherever possible, help to improve local environmental conditions such as... water quality.º and NPPF 155. ªInappropriate development in areas at risk of flooding should be avoided.º Chesham Town Council believe that the development of the Green belt area at Lye Green would potentially lead to flooding. Brushwood Road and The Spinney, nearby already have a history of flooding issues. The capacity of Chesham Sewage Treatment works is already exceeded during periods of high rainfall. Thames Water confirmed that a further 20 waste storage tanks costing £20m would be needed to protect our chalk stream and natural environment but no additional capacity is planned. Local abstraction for the public water supply is already near the licensed limits. Multi-agency investigations have identified that the current level of abstraction from the local aquifer is having a detrimental impact on the River Chess. The Chess, which is an internationally rare chalk stream environment now runs dry for extended periods of time over a significant portion of its Chesham stretch. Air quality The CSA makes reference to increases in air pollution (N58, N87). N98 table N4 ªThe Local Plan is anticipated to lead to a reduction in local air quality with implications for human health.º NPPF 181. ªPlanning policies and decisions should sustain and contribute towards compliance with relevant limit values or national objectives for pollutants, taking into account the presence of Air Quality Management Areas.º Berkhamsted Road and Broad Street in Chesham (both close to the proposed development site in Chesham and Berkhamsted Road being the main thoroughfare through the town), are already designated an Air Quality Management Area and it is incumbent on all authorities under national law, to actively promote measures that will decrease rather than increase pollution. Climate change CSA N87. ªProposed development within Local Plan is likely to increase the Plan area's carbon emissions by 21%º. NPPF 148. ªThe planning system should support the transition to a low carbon future in a changing climate. It should help to: shape places in ways that contribute to radical reductions in greenhouse gas emissions.º Using Green belt land for development NPPF 96. ªAccess to a network of high quality open spaces and opportunities for sport and physical activity is important for the health and well-being of communities.º NPPF 180 b) ºPlanning policies should...identify and protect tranquil areas which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason;º The Green belt land at Lye Green, Chesham (SP BP2) has recently been designated an Asset of Community Value by virtue of the fact that it `improves the wellbeing of the community'. Lack of consultation and transparency The Council's approach to consulting the public and gathering comments regarding the Local plan has been woeful. The Chiltern and South Bucks Local Plan states that ªThese areas were selected because they least met the purposes of including land in the Green beltº (Draft Chitern and South Bucks Local Plan 10.1.5). THE LOCAL PLAN IS NOT SOUND The NPPF 136 states that Green belt boundaries should only be modified in ªexceptional circumstancesº. The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances. NPPF 137 a) ªBefore changing Green belt boundaries, authorities should make as much use as possible of suitable brownfield sites and underutilised land.º I am not convinced that the councils have considered all the local brownfield land opportunities nor have they explored the possibility of higher densities of housing in the town centre, as proposed by the Chesham Renaissance Community Interest Company and supported by Chesham Town Council. The removal of the land North East of Chesham from Green belt protection subsequent to its recent designation as an Asset of Community Value would undermine the NPPF (96 and 180 b) which seeks to ªidentify and protect tranquil areas which¼ are prized for their recreational valueº. The site at Chesham is exactly this; a species rich area of Green belt land, abutting an AONB and used by generations of local people for jogging, dog walking, rambling, and a short cut to Brushwood school and Chesham Grammar School avoiding a much longer route with busy roads and no pavement.
9392 The Councillors who voted for the draft local plan also do not believe it is sound! I attended a Chiltern District Council Meeting on 15/5/19 where several of the Councillors said they were voting for the Chiltern and South Bucks Local Plan because it was ªthe least worst option.º Another Councillor, Fred Wilson, stated in a letter to me (16/5/19) ªIf we had voted against proceeding with this stage of the Local Plan, the deal that we negotiated with Aylesbury Vale to build 6,000 homes on their land could go out the window¼.We had no choice but to proceed....because the alternatives are a lot worseº. So is this what it comes to? We end up following a plan until 2036 which is fundamentally unsound and nobody wants, simply because it means that Aylesbury Vale will take some of our housing allocation and Councillors think it is the least worst option! Can't we just have a better plan?!! The plan area at Chesham (SP BP2) is 22.9 hectares but table B.2.1 of the Sustainability appraisal shows the total site release from Green belt as 55.58 hectares. Why the discrepancy? Once it has been removed from the Green belt will the rest of the area just become a free for all for the developers? Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5503026 Please attach any supporting evidence
Person ID 1212353 Full Name Mr Nigel Adderley ID 3172 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-03-13 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally
9393 compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The green belt site NE of Chesham is an impractical location for such a development due to its position not believe this policy to be 1.5miles from the town centre and the tube station. The infrequent bus service and steep hill would help positively prepared please create even more traffic congestion in what it already a very busy area and the increasing lack of parking explain why options in the town centre means there will be nowhere for cars to go ± the large car park at the tube station has been earmarked for development by the Local Plan !
9394 The Lye Green area within the green belt has recently been made an Asset of Community Value due to the informal recreational opportunities it has offered residents for decades. Many locals may have gained easements and prescriptive rights to use the land due to access gates from their gardens to the fields which were established 20+ years ago.This would not appear to make it straightforward for any type of development and seems a clear conflict. The green belt helps to preserve the identity of many outlying villages which is consistent with national policy. The Council have not exhausted all other options in line with national guidelines. It appears they have gone for a `quick-fix' which may not be sustainable on a number of levels. PP Mods - Please specify as You will need to say why this modification(s) will make the Local Plan sound/strengthen its soundness. It will precisely and succinctly as be helpful If you are able to put forward your suggested revised wording of any policy or text and include all possible how you would information and evidence necessary to support/justify your suggested change. modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1212387 Full Name Mr Neville Slade ID 5171 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-03-13 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID
9395 Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination
9396 Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do This Green Belt site NE of Chesham is clearly not a sustainable location, being over 2km away from the train not believe this policy to be station and further still from the town (both being accessed by a long and steep hill). Such an unsustainable positively prepared please location cannot be made sustainable simply by adding a bus stop; the current bus service is infrequent. explain why Chesham cannot accommodate any significant highways improvements due to the already limited verges and space beside the highways; combined with the topography of the town this means that there will be increased traffic congestion leading inevitably to a worsening of air quality. The development of this Green Belt site involving many hundreds of homes will generate increased traffic; in Chesham the evidence shows that most of the road junctions and infrastructure are already operating at above reasonable capacity. Traffic congestion during the morning and evening rush hour periods is already unacceptable. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not For this Plan to be considered sound, it must also be effective. The effectiveness of proposal to build on this believe this policy to be Green Belt site is seriously questionable as there are issues with the deliverability of this land. The main effective please explain why. landowner is a farmer who has asserted publicly and in a letter to the editor of Your Chesham magazine that he is not prepared to release all of the land in his ownership for development. Further, the land is designated an Asset of Community Value and therefore cannot be released without first being offered for purchase to the local community. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not We note that paragraph 136 of the latest National Policy Planning Framework asserts that Green Belt believe this policy in boundaries should only be modified in ªexceptional circumstancesº. The courts have held that unmet local consistent with the National housing needs of an area are themselves not exceptional circumstances. We do not believe that such Planning Policy Framework exceptional circumstances exist in respect of the above-mentioned site and strongly question whether the Feb 2019 please explain why Council has exhausted Brownfield land opportunities within the town, which are of course generally closer to the town centre and are in more sustainable locations. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
9397 Policy-level file upload - 5499134 Please attach any supporting evidence
Person ID 1215248 Full Name Mrs Samantha Davis ID 3642 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-12-11 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications
9398 to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I believe the site selection methodology of using the Green Belt land at Lye Green to be flawed. Building 500 not believe this policy to be houses 2.5 miles from the town centre atop a very steep hill, will result in the widespread use of cars by positively prepared please residents to reach amenities in the town centre and tube station. These short journeys by car will only add explain why to the already high levels of pollution present in parts of Chesham. Indeed, Berkhamsted Road has a designated Air Quality Management Area that is already recording air quality that exceeds EU safe levels considerably. Lye Green is not a suitable location to build hundreds of homes.The congestion caused by residents needing to commute through the town, reach the tube station or schools, particularly down White Hill or Eskdale Avenue, will only add to the gridlock that drivers already experience on Berkhamsted Road during rush hour traffic, further worsening air quality. Some highway improvements have been suggested but they are insufficient. Evidence shows that most of the road junctions and infrastructure in Chesham are already operating above capacity. Limited verges and space beside the highway mean Chesham cannot accommodate any significant highways improvements. The Councils plan contains conflicting policies that states that the Green Belt site NE of Chesham provides easy access to public transport, including the tube station, yet the very same plan also promotes the building of shops on the car park that serves the tube station. I believe this to be inconsistent and unsound. Chesham already had two large supermarkets, a butcher and two bakeries. There are empty shops in the high street as well as along Berkhamsted Road. Chesham has many independent cafes and restaurants within its town centre. These, along with the existing shops, library, park and theatre, would be much better served if housing was built within easy walking distance of them. As well as providing recreational use over decades for local people, the land is good quality agricultural land. As such it soaks up rainfall which would otherwise run off the fields as floodwater into Chesham, adding to the problem of flooding on the Berkhamsted Road. As well as being inconvenient for pedestrians and traffic it also leads to the polluting of the River Chess, a fragile ecosystem and globally rare habitat.
9399 Brushwood Junior school, with its current 278 pupils, is located on the boundary of the said Green Belt land. In an age where cars are being discouraged or banned from idling or parking near schools, it is irresponsible and enviromentally unsustainable to build 500 homes, which will in turn bring a minimum of 500 cars so close to the school. This will have a detrimental effect on the health of the children and staff of the school. The Green Belt land at Lye Green supports rich biodiversity and provides crucial habitat for many species of birds, insects and mammals, most of which will be driven out if such a development goes ahead. Surely with all we now know and understand about the need to protect the environment, increase tree planting and reduce CO2 emissions, the idea of removing this land from the Green Belt and developing it for housing is completely unjustified, short sighted and irresponsible. PP Mods - Please specify as When Chesham residents were asked by community interest company Chesham Renaissance what was precisely and succinctly as most important to them about where they lived, the overwhelming majority said the AONB status. Increasing possible how you would the population density within the town boundary can protect the Green Belt that surrounds the town. This modify this policy to improve can be achieved by building on existing brownfield sites closer to the town centre where all the facilities and its alignment to this test of amenities are. soundness. Policy 1 - If you do not The proposals to release Green Belt land to meet housing targets are not justified from the evidence submitted. believe this policy to be I question the soundness of such a general policy and whether all Brownfield land that offers a more justified please explain why sustainable location for development have been identified. The plan itself estimates an increase in the districts carbon footprint of 21%.This points to the current proposal as being unsound. Therefore, the development of the Lye Green site NE of Chesham cannot be sustainable, nor justified, nor in accordance with government policy. National planning guidance requires the local authority to consider viable alternatives such as the Chesham Renaissance C/C Masterplan, devised by local people for local people, or to recycle brownfield land for housing. The divegence of the plan from these viable alternatives is inconsistent with local initiative and further suggests the plan is inconsistent with national guidance, ineffective and unjustified. The council employed third party consultants to undertake the part 1 Green Belt assessment, in doing this they identified numerous sites for "further consideration" where exceptional circumstances might exist, but firmly recommended further review of their assessment of each site against the 5 purposes of land being in Green Belt of all these sites. However, contrary to neighbouring local authorities, the Local Authority chose to undertake the part 2 Green Belt assessment itself and in doing so did not undertake all the recommended views of each site, including the land NE of Chesham at Lye Green.This oversight by the local Local Authority drew sole, excessive focus on releasing the said land from Green Belt designation.Therefore, the identification of the land for release from the Green Belt is unjustified. Policy 2a - Please specify as The Chesham Renaissance C/C Masterplan, a community led scheme, suggests more effective alternatives precisely and succinctly as such as higher densities of housing development on brownfield sites closer to the town centre. This would possible how you would be a more sustainable and enviromentally friendly alternative such as higher densities of housing development modify this policy to improve on brownfield sites closer to the town centre. This would be a more sustainable and environmentally friendly its alignment to this test of alternative, keeping development to land that has been previously built on and which is within the town soundness. boundary. This alternative plan would bring investment to Chesham by building the number and types of housing we need in areas where they will benefit and rejuvenate the town and the more deprived parts of Chesham. Policy 2 - If you do not The removal of the land NE of Chesham at Lye Green from Green Belt is not effective as there are serious believe this policy to be questions around the deliverability of this land. The main landowner has said publicly, including in a letter to effective please explain why. the editor of Your Chesham, that he is not prepared to release all the land for development. The land has also been granted status as an asset of community value, giving a community group the right to bid for the land. It is not effective, justified or in accord with the National Planning policy (policy SP BP2), that Green Belt land designated as an asset of Community Value be developed and undermines the objectives of the Localism Act 2011. This renders this aspect of the plan unsound. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not Selection of the land NE of Chesham at Lye Green for removal from Green Belt designation is inconsistent believe this policy in with the National Planning Policy Framework. Paragraph 136 of the latest NPPF states that Green Belt consistent with the National boundaries should only be modified in "exceptional circumstances".The courts have held that "unmet housing Planning Policy Framework needs of an area are themselves not exceptional circumstances. Feb 2019 please explain why The proposed development of this Green Belt land will destroy the distinctiveness of Chesham and promote urban sprawl into the neighbouring historical hamlet of Lye Green. This would contradict the primary aim of Green Belt land being to "prevent urban sprawl and preserve the openness of the area (NPPF133). The plan also proposes the removal of many neighbouring local villages from Green Belt which could lead to the infilling of others. It is incomprehensible that areas of ANOB could be negatively changed forever in this way. The NPPF paragraph 134 states that another aim of Green Belt is to "prevent neighbouring towns and settlements from merging into one another". The land has been used by the community for improved health and well being for decades and performs well against Green Belt aims and objectives. Exceptional circumstances for reviewing Green Belt boundaries at this location either do not exist or are insufficient to warrant the removal from the Green Belt designation as required by Government policy and therefore the plan is unsound. Policy 3a - Please specify as precisely and succinctly as
9400 possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1215315 Full Name Mr Toby Friedner ID 5285 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-11-28 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as
9401 precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I am writing in response to the consultation on the draft local plan which I do not think is a sound proposal. not believe this policy to be Firstly, the Draft Local Plan does not consider the Chesham Masterplan, as set out by Chesham Renaissance positively prepared please CiC, ignoring a key stakeholder in the future of the town. explain why This alternative plan takes a more global view of the town and its future. It puts the new homes in the town centre, thus reducing the need for cars and creating a regenerated and vibrant local economy. It provides the right kind of housing for the people who, as their evidence shows, actually need it and improves the safety of St Mary's Way by making it a single carriageway road. Building 500 homes on an area of green belt land within the Chilterns AONB ruins the local countryside, increases traffic and offers little in terms of town centre rejuvenation. The fields that are proposed for development are used widely by dog walkers, runners, ramblers and many others. There is no suggestion of how this lost amenity will be replaced. The Draft Local Plan destroys the identity of the nearby hamlet of Lye Green and consumes an area that helps give Chesham its rural feel. I am aware of the need for new homes but I believe building them in the green belt is wrong and due consideration should be given to the alternative Chesham Masterplan. PP Mods - Please specify as precisely and succinctly as possible how you would
9402 modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5511428 Please attach any supporting evidence
Person ID 1212697 Full Name Mr & Mrs David Lansdowne ID 5265 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-03-11 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant,
9403 including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s),
9404 do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do This land has also recently been listed as `An Asset of Community Value' under The Localism Act 2011, not believe this policy to be demonstrating its' significance as an open area where people have enjoyed informal recreation for decades. positively prepared please Many local individuals have acquired easements on the land through prescription of 20 years uninterrupted explain why use. Additionally, many houses have rear garden gates which open on to the fields which gives them prescriptive rights. For the local Authority to allow development on this land undermines the objectives of the Localism Act. How can this land now be considered suitable for housing development? The deliverability of this land is in question as the Landowner has stated in an open letter in `Your Chesham' that he not prepared to release all of his land for development. The Council's plan to release Green Belt (SP SP1 & SP BP2 at Lye Green NE of Chesham) as part of a strategy to meet housing needs targets are not justified from the evidence submitted. The potential to build on Brownfield land has not been fully explored and neither has the potential to build higher densities closer to the town centre. With particular reference to the land to the NE of Chesham (Policy SB BP2) this is not a sustainable site. It is located 2.5k from the town centre at the top of a steep hill making walking or cycling into the town centre difficult for most people who would choose to drive, which would increase traffic congestion and have an adverse effect on local air quality. Building 100's of homes on the Lye Green site, due to the location inevitably will generate an increase in traffic and congestion in Chesham, evidence shows that most junctions are already operating well above capacity. There is limited potential to improve the road network due to the topography and the countryside location. Proposed infrastructure improvements to roads are insufficient and underfunded. Increased traffic will also have a detrimental effect on air quality & pollution in the town which is already in an Air Quality Management Area that has recorded levels that far worse than EU safe levels. Air Quality is a hot topic at National Government level and to build houses on a site which will adversely impact air quality is unsustainable, unjustified and goes against Government policy. Releasing this area of Green Belt is not consistent with draft Local Plan policies to protect Wildlife habitats, biodiversity and globally scarce chalk stream rivers. It is also valuable agricultural land. Policy SP EP3 proposes to build more retail shops mostly on the town car parks. This is totally unjustified and unsound when there are already many retail units vacant in Chesham. Additionally, it doesn't make sense to take away car parking space when additional capacity will be required to accommodate an increase in the number of commuters needing car parking at the train Station as a result of an out of town housing development. The Council has said that Government planning policy required them to review Green Belt boundaries when trying to meet housing targets, however this was an option rather than a directive and the NPPF went on to say that boundaries should only be modified in exceptional circumstances. The NPPF paragraph 11b, which was revised only last year, directs `Plan makers' to create policies that are required in Local Plans for housing and other uses unless Framework policies (including Green Belt) provides a strong reason for restricting the overall scale type or distribution of development in the plan area. Consequently, I believe that the above statement proposing to release the Green Belt around Chesham is contrary to National Guidance and therefore unjustified. I am supportive of The Brown Not Green Organisation's initiative to have the land listed as an Asset of Community Value and I feel they speak for me in respect of their objections to the Draft Local Plan. Accordingly, I request that any representations made by them at any future examination in public regarding the soundness of this Local Plan be considered as an extension of my own comments. I believe that the land NE of Chesham is unsustainable for development, it has been habitually used by the community for improvement of health & wellbeing for many years and the land performs well against Green Belt aims and Objectives. Exceptional circumstances to remove this land from Green Belt have not been proved as required by government Policy and therefore the plan is unsound. PP Mods - Please specify as I refer to comments previously submitted but in summary would suggest that; precisely and succinctly as All other options are fully explored including increased density of development of Brownfield land and all the possible how you would policies of Chesham Masterplan. modify this policy to improve its alignment to this test of Green Belt land should ONLY be considered when all other policies have been exhausted and in any event soundness. the proposals for developing land NE of Chesham (Policy SB BP2) should be removed as it is an unsustainable location and development here will cause harm to the whole town and also includes a loss of an asset That improves the wellbeing of a community. Policy 1 - If you do not believe this policy to be justified please explain why
9405 Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not The Local Plan is not legally compliant because it does not follow the guidelines set out in the NPPF issued believe this policy in by the Secretary of State. This policy clearly states that Local Authorities must demonstrate that they have consistent with the National exhausted all other options before removing Green Belt for the purposes of housing development. Planning Policy Framework The Local Plan has not demonstrated that all other options have been fully explored and is therefore not Feb 2019 please explain why justified, sound or in accordance with National Policy and is therefore not legally compliant. The draft Local plan proposal to remove the Green Belt designation of 13 Areas and remove several villages from Green Belt protection (Policy SP PP1 & DM PP1) does not follow the NPPF guidelines as it has not investigated thoroughly the use of brownfield land or given sufficient consideration to alternative options such the Chesham Masterplan. The draft Local plan is not meeting housing needs effectively or safeguarding and improving the environment. The Local Authority has not fully explored all other options before removing the Green Belt status and allocating it for housing.The Courts have ruled that Green Belt should only be used for housing in `exceptional circumstances' and housing need alone does not constitute exceptional circumstances. I do not believe that the Local Authority have proved that `exceptional circumstances' exist in the draft Local plan. With reference to the land to the NE of Chesham (Policy SB BP2) this is not a sustainable site and I question the site selection methodology! The NPPF states that the purpose of Green Belt is to prevent urban sprawl and neighbouring towns and villages merging, the Lye Green site clearly performs this function well by separating Chesham from Lye Green. The sustainability Appraisal supporting the draft Local Plan forecasts carbon emissions, if it goes ahead, to increase by 21% - this has recently been bizarrely changed to 17% - which certainly proves a lack of planning expertise in drafting the plan. Even at 17% this goes directly against The Government's target for the UK to have net zero carbon emissions by 2050 and therefore inconsistent with Government Policy and not legally compliant. For this site to be sustainable there would need to be significant investment in infrastructure which the draft Local Plan acknowledges there is a funding gap of between £179m to £231m. There is no justification to go ahead and build houses when there is such a question mark over the provision of the necessary infrastructure to support it! Policy 3a - Please specify as Consider higher density housing on Brownfield sites near or in town centre locations which are more precisely and succinctly as sustainable. They would be more affordable, convenient for public transport reducing the need to use a car possible how you would (reducing the impact on air quality) and would rejuvenate the town centre. modify this policy to improve Further consideration to be given to alternative housing development plans as put forward Chesham its alignment to this test of Masterplan by CIC Chesham Renaissance which proposes to provide more affordable housing in or close soundness. to the town centre with the added benefit of regenerating the town centre. Green Belt should only be considered after ALL other options have been thoroughly explored as stated in the NPPF. The Local Authority should look again at all Brownfield site opportunities to identify any that have been missed off the Brownfield register. Further co-operation with neighbouring Authorities (as was done with Aylesbury) e.g. Dacorum, Slough. People living in Chiltern District travel to these areas for work, shopping recreation purposes therefore they are not in a different functional Market area. Policy-level file upload - 5511283 Please attach any supporting evidence
Person ID 1212868 Full Name Prof Paul Forster ID 3938 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details
9406 Consultee Type - Please Other select the type of consultee: Date Received - Date 2016-03-13 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence
9407 Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I submit the boundary division of Ley Hill village as proposed is not consistent with actual village life or not believe this policy to be perceptions, and would leave the area between the north of Cherry Tree Farm and Jasons Hill in a unfairly positively prepared please prejudiced position relative to ©washed over© Green Belt villages. explain why PP Mods - Please specify as Either include the land east of The Green between Cherry Tree Farm and Jasons Hill within the Ley Hill precisely and succinctly as village envelope to be removed from the Green Belt, or classify the land as a ©washed over© village area. possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would
9408 modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
9409 Person ID 1212868 Full Name Prof Paul Forster ID 3940 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Other select the type of consultee: Date Received - Date 2016-03-13 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness?
9410 Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve
9411 its alignment to this test of soundness. Policy 3 - If you do not As outlined before, amend the village boundary proposal to reflect the integral nature of the area to the east believe this policy in of The Green to village life and practice, thus removing it from the Green Belt. consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as Modify Ley Hill village boundary to include the land to the east of The Green Belt between the North of Cherry precisely and succinctly as Tree Farm and Jasons Hill. possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1213097 Full Name Mrs Gillian Russell ID 5250 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-03-14 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible.
9412 Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible
Policy Level - PP - If you do I am writing to express my concerns about the recently published Local Plan for Chiltern and South Bucks not believe this policy to be and to submit my comments to the Independent Planning Inspector. positively prepared please I have come to the conclusion that the Local Plan as it stands is unsound for the following explain why reasons: The developments proposed in the Local Plan will result in an increase in the carbon footprint of the Chiltern/South Bucks area of 21% or more ( Sustainability Appraisal of the Chiltern and South Bucks Local Plan, Table N4, p. xxxiii ). This is unacceptable. Chapter 3 - Sustainable Places, para. 3.1.2 states that `the Councils will strive to conserve
9413 the environment whilst also promoting sustainable economic growth' and will `conserve the Green Belt through the planning process, whilst balancing the need for housing'. The Local Plan proposes to remove 60 hectares of Green Belt land at Lye Green on the outskirts of Chesham for housing (Policy SP BP 2) . This site is 2.5 km from the town centre and at the top of a steep hill, not within practicable walking or cycling distance, so any future residents travelling into Chesham would have to drive into the town. Clearly this development, if built, would substantially increase the present rush hour traffic congestion in the town, and add to air pollution, which is already at dangerous levels. For example, Berkhampstead Road is a designated Air Quality Management Area where the air quality is already above EU safe levels. Building on this site would also destroy an area which has recently been officially listed as an Asset of Community Value and thus plays a vital role in the health and well-being of the local population. As I understand it, that there have to be `exceptional circumstances' in order for land to be removed from the Green Belt and that housing needs alone are not considered by the courts to be `exceptional circumstances'.Therefore I consider that this policy is unsustainable and therefore unsound. I would suggest that brownfield sites in the area should be looked at first. Obviously these are more difficult and less attractive to developers but I don't think that we should destroy the Green Belt for their convenience. However should these housing plans go ahead, there are two opportunities that I think have been missed. One is to make the new housing carbon neutral. There is a `low carbon' statement in the report which refers to a measly 20% reduction which will scarcely make a dent in the extra carbon created. Why not insist on complete sustainability? There is an opportunity here for Chesham and Buckinghamshire to lead the way in sustainable development and to create something amazing. Which is why I think the plan should also specify that the land should be either self- build or given to small developers so it has a mixture of styles and aesthetics just as an organically grown area has. I also understand that the Local Plan has an infrastructure funding gap of between £179m and £231m ( CIL Funding Gap Analysis June 2019 ). This is another indication that the Local Plan has not been thought through and is therefore unsound. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1213167
9414 Full Name Mrs Audrey Walker ID 3770 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-03-14 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness?
9415 Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do As for the plan to remove Green Belt restrictions on some areas I did not think this was legal! Let the local not believe this policy to be children enjoy the fields as our four children did and said recently to me what a lovely free childhood they positively prepared please had. explain why As for plans to build new shops in Chesham - another mad ideas when so many have closed for lack of trade and also building on a car park so there will be nowhere to park cars if they choose to shop here! Yes of course choosing "brown sites" is the way to go! Please do not turn our fields into housing sites, find these brown sites to use and continue to use the files for their true purpose. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why.
9416 PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1213221 Full Name Dr Marie Prendergast ID 5160 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-03-14 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its
9417 legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The proposals to release Green Belt land to meet housing targets (Generally, Spatial Policy SP SP1 & not believe this policy to be specifically Policy SP BP2 at Lye Green NE of Chesham) are not justified from the evidence submitted by positively prepared please the Councils. explain why The Councils have stated that release of some Green Belt is necessary as part of an overall three part strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where
9418 sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. I question the soundness of such a general policy and whether all the brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites and in particular the Green Belt site NE of Chesham at Lye Green. The development of such Green Belt sites involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient and unfunded. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham cannot accommodate any significant highways improvements anyway due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion, with further worsening air quality. Air pollution is a particular concern in Chesham due to the already poor air quality along Bekhampstead Road where there is a designated Air Quality Management Area that already is recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will generate more traffic will make the air quality even worse and insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable nor justified nor is it in accordance with Govt policy. The Green Belt site NE of Chesham (SP BP 2) is not a sustainable location. It is over 2Km away from the train station and slightly further still from the town centre but anyone who cares to walk or cycle this distance also has to negotiate a steep hill too. Such an unsustainable location cannot be made sustainable merely by upgrading a couple of public footpaths within the site into bridleways to facilitate cycling. Neither does adding a bus stop address the geography or topography of the area especially if the promised enhanced bus service (which is already infrequent) either does not materialise or if it subsequently fails to be maintained after a few years. Further doubt is cast upon the ªsoundnessº of this Plan by virtue of there being conflicting policies within it. The Council seem to think that the Green Belt site NE of Chesham is sustainable and provides easy access to public transport including the tube station yet the same Plan promotes a considerable increase in retail development in the town (local draft plan policy SP EP3) , part of which would be built on the very car park that serves the Chesham tube station. This is inconsistent and unsound. The land is also potentially an Asset Of Community Value and upon confirmation of this designation it would afford a community group the right to bid for the land. The community group (Brown Not Green) have stated their intention is to preserve the land given that many hundreds of local people have habitually used the fields at Lye Green as of right for various informal outdoor recreational purposes. These uses themselves may mean that many local individuals may have acquired easements over and across the land through prescription (20 years uninterrupted use) not least of whom would be the many private residences bordering the fields that have rear garden gates onto the fields at Lye Green. These easements and prescriptive rights may render the land very difficult to develop and make i undeliverable in planning terms. This land also provides an important habitat for wildlife that will be threatened by development of this land. It is perverse that the Local Authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Plan is unsound. PP Mods - Please specify as I refer to the comments previously submitted but in summary would advocate that; precisely and succinctly as All other options are fully explored including increased density of development of brownfield land and the possible how you would policies emerging from Chesham Masterplan. modify this policy to improve its alignment to this test of Green Belt land should never be considered and the proposals for developing land NE of Chesham (policy soundness. SP BP 2) should be removed as it is an unsustainable location. The development of this site will cause harm to the wider town including irreversible loss of the charming character of the area, loss of an asset that improves the well-being for the community and the creation of significant congestion and air pollution. Policy 1 - If you do not I refer to comments previously submitted. believe this policy to be justified please explain why Policy 2a - Please specify as I refer to comments previously submitted. precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not For this Plan to sound it must also be effective. Unfortunately, further review of the proposal to remove land believe this policy to be NE of Chesham at Lye Green from Green Belt designation is not effective as there are serious questions effective please explain why. about the deliverability of this land. The main landowner is a farmer who has asserted publicly and in a letter to the editor of Your Chesham, that he is not prepared to release all of the land in his ownership for development. PAa - Please specify as I refer to comments previously submitted. precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I believe the draft Local Plan is NOT legally compliant because it has not demonstrated sufficient regard to believe this policy in the National Policy and guidance issued by the Secretary of State. consistent with the National
9419 Planning Policy Framework The National Planning Policy Framework (NPPF) together with other guidance issued by the Government Feb 2019 please explain why is also supported by recent ministerial statements that have made it clear that Local Authorities MUST demonstrate they have exhausted all options BEFORE considering revision of Green Belt boundaries. This Local Plan is seeking substantial modifications to Green Belt boundaries including the removal of Green Belt designation of 13 areas within the Districts as well as modifying the Green Belt status of many local villages. I contend this draft Local Plan has not demonstrated that all other options have been fully explored and as such this Plan is not justified, sound or in accordance with National Policy and accordingly is not legally compliant. Furthermore that Paragraph 11 b) of the NPPF (and the footnotes thereto) require Plan Makers to provide for objectively assessed needs for housing and other uses UNLESS the application of Framework policies (including Green Belt) provide a strong reason for restricting the overall scale, type or distribution of development in the plan area Chiltern District & South Bucks are significantly constrained by development policies such as Green Belt & Areas of Outstanding Natural Beauty (AONB). The Local Plan is therefore inconsistent with National Guidance and as such it is not legally compliant for the Local Authority to claim that housing needs justify a review of these same Green Belt boundaries. It is perverse to claim that the combination of housing need and the presence of significant areas of development constraint policy collectively represent ªexceptional circumstancesº (as required in the NPPF) to justify modification of Green Belt boundaries especially given the NPPF states that one of the key features of Green Belts are their permanence. The Government has also recently confirmed its aim for the UK to have net zero carbon emissions by 2050 and it is noted within the Sustainability Appraisal supporting this Draft Local Plan, that the Plan area is forecast to see carbon emission increase by 21% in the Plan Period. Accordingly, the Plan is inconsistent with Government Policy and therefore not legally compliant. There is also a significant infrastructure funding gap acknowledged within the Community Infrastructure Levy evidence that supports this Local Plan, of between £179m & £231m. Given this infrastructure is vital to ensure that development is sustainable (as also required by the NPPF) this further demonstrates the Plan is both unsound and not legally compliant. The primary aim of Green Belt land (as recited in NPPF 133) is to prevent urban sprawl and to preserve the openness of the area. The Lye Green site (SP BP2) self-evidently performs this function well and has done so for decades. Another aim of Green Belt land stated in NPPF paragraph 134, is to prevent neighbouring towns and settlements from merging into one another.The Green Belt land NE of Chesham performs exceptionally well in maintaining a distinct separate between settlements of Chesham & Lye Green as well as helping to maintain separate identities of other nearby communities at Orchard Leigh, Botley, Whelpley Hill, Ashley Green. It is perverse and inconsistent with national guidance to allocate this land for removal from Green Belt in light of these facts especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if earmarked for development. A further aim of Green Belt designation stated in the NPPF at paragraph 134 (e) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. By allocating Green Belt land NE of Chesham for development, undermines this aim within Chesham. A community lead not for profit organisation called Chesham Renaissance CIC has been striving to create Chesham Masterplan that would not only provide many genuinely affordable homes in more sustainable locations nearer the town centre, but which would also regenerate some of the more deprived wards within Chesham. The Local Authority's proposals (policy SP EP3) are inconsistent with this local initiative and are therefore also inconsistent with national guidance and are consequently unsound. The Council have asserted that Government planning policy requires local councils to review Green Belt boundaries when considering how to accommodate the development needed in their areas. Just because the Council may be required to look, does not mean the Council should review Green Belt boundaries which as previously stated should only be modified in ªexceptional circumstancesº. National Planning Policy Framework (NPPF) as revised only last year, states in paragraph11 (b) I, directs ªplan makersº to create policies that are required in Local Plans for housing and other uses unless Framework policies (expressly including Green Belt) ªprovides a strong reason for restricting the overall scale type or distribution of development in the plan areaº Accordingly, I submit that given all of the above the land being proposed for release from Green Belt designation around Chesham is unjustified and contrary to national guidance. I feel the land NE of Chesham is an unsustainable location for development, that has been habitually used by the community for improved health & wellbeing for decades and the land performs well against Green Belt aims and objectives. Exceptional circumstances for reviewing Green Belt boundaries at this location, either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by Govt Policy and therefore the plan is unsound Paragraph 136 of the latest NPPF asserts that Green Belt boundaries should only be modified in ªexceptional circumstancesº. The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances. The Council engaged third party consultants to undertake the Part 1 Green Belt assessment and they identified numerous sites for ªfurther considerationº where exceptional circumstances ªmightº exist but expressly recommended further review of their assessment of each site against the 5 purposes of land being in Green Belt of all these sites. Unlike the neighbouring Local Authorities, the Part 2 Green Belt assessment was not undertaken by third party consultants but by the Local Authority itself who notably then did not undertake all the recommended reviews of each site including the land NE of Chesham at Lye Green (SP BP 2). Accordingly, this oversight in the Part 2 Green Belt assessment placed premature focus and fixation on releasing land at Lye Green NE of Chesham from Green Belt designation. The subsequent identification of the Chesham site for release is therefore unjustified. Policy 3a - Please specify as The Plan needs to be modified by; precisely and succinctly as
9420 possible how you would Co-operating with other nearby authorities. Not just Aylesbury. It is simply unsatisfactory to assert this cannot modify this policy to improve be done because they are different Functional Market Areas and that co-operation is not necessary therefore. its alignment to this test of Exploring such wider co-operation may result in further housing needs being taken elsewhere. soundness. A more detailed appraisal of brownfield land opportunities MUST be undertaken. Some brownfield opportunities have been ignored or missed. Closer scrutiny of alternative options for housing delivery should be explored (such as Chesham Masterplan by CIC Chesham Renaissance). Green Belt boundary reviews should never be considered as Green Belt should be protected for current and future generations to enjoy. In the face of NPPF guidance and a more thorough appraisal of Green Belt sites being considered, it may then be necessary to conclude that it is not possible to identify poor performing Green Belt sites that can accommodate all the OAN for housing. Consequently it may be necessary to accept that a lower housing provision figure is appropriate. The foregoing also points to flawed methodology of Green Belt site selection used by the Local Authority, which is neither effective, justified nor consistent with national policy and as such is unsound. Specifically, the selection of the land NE of Chesham at Lye Green (policy SP BP2) for removal from Green Belt designation is inconsistent with National Planning Policy Framework (NPPF). Policy-level file upload - 5511299 Please attach any supporting evidence
Person ID 1221156 Full Name Marian Tomkins ID 2676 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally
9421 compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The loss of precious Green Belt in the Ley Green area not believe this policy to be The loss of local villages being absorbed into Greater Chesham. positively prepared please explain why The additional pressure on our already overcrowded roads. The above also creating more pollution.
9422 The proposal to remove villages from Green Belt and to permit infilling development with these villages. It does not provide more affordable homes in sustainable locations nearer the town centre. Finally I am disappointed at the lack of publicity given by you regarding the opportunity to give our views. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1213359 Full Name Mr Neil Watts ID 4937 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-03-14 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider
9423 the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to
9424 Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The proposals to release Green Belt land to meet housing targets (Spatial Policy SP SP1 & specifically Policy not believe this policy to be SP BP2 at Lye Green NE of Chesham) are not justified based on the evidence submitted. positively prepared please It is stated that release of some Green Belt is necessary as part of a 3 part strategy involving (1) focus on explain why built-up areas, to build dwellings on previously developed land, (2) an exported proportion of housing need accounted for by Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. I do not believe it has been demonstrated that all brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites and in particular the Green Belt site NE of Chesham at Lye Green. The development of such Green Belt sites involving many hundreds of homes will generate increased traffic. The corresponding highways improvements suggested are insufficient. In Chesham it is apparent that most of the roads / infrastructure is already operating above capacity. It would be difficult to instigate any significant highways improvements in Chesham due to the limited verges and space available. This combined with a steep hill to / from the town centre means that people will resort to vehicles via road use leading to further traffic congestion and an impact on air quality. Air pollution is already a concern in Chesham due to the poor air quality along Berkhampstead Road where there is a designated Air Quality Management Area already recording air quality that is considerably worse than EU safe levels. Additional homes outside the town on the Green Belt site at Lye Green NE of Chesham will generate more traffic and make the air quality worse ± thus making the plan unsound. The Green Belt site NE of Chesham (SP BP 2) is not a sustainable location. It is over 2km away from the train station and slightly further still from the town centre via a steep hill. Further doubt is cast upon the ªsoundnessº of this Plan by virtue of there being conflicting policies within it. It is proposed that the Green Belt site NE of Chesham is sustainable and provides easy access to public transport including the tube station yet the same Plan promotes a considerable increase in retail development in the town (local draft plan policy SP EP3). The land has also recently been specified as an Asset Of Community Value and due to this designation it now permits a community group the right to bid for the land. The community group (Brown Not Green) have stated their intention is to preserve the land given that many hundreds of local people have habitually used the fields at Lye Green as of right for various informal outdoor recreational purposes. It is unclear why the Local Authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. This makes the Plan unsound. This land also provides an important habitat for wildlife that will be threatened by development of this land. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not For this Plan to be sound it must also be effective. Unfortunately, further review of the proposal to remove believe this policy to be land NE of Chesham at Lye Green from Green Belt designation is not effective as there are serious questions effective please explain why. about the deliverability of this land. The main landowner is a farmer who has asserted publicly and in a letter to the editor of Your Chesham that he is not prepared to release all of the land in his ownership for development.
9425 PAa - Please specify as I refer to my previous comments but would suggest that all other options are investigated, including the precisely and succinctly as development of existing brownfield land and consideration given to the contents of the Chesham Masterplan. possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I believe the draft Local Plan is not legally compliant because it has not demonstrated adequate consideration believe this policy in of the National Policy and guidance issued. consistent with the National The National Planning Policy Framework (NPPF) issued by the Government states that Local Authorities Planning Policy Framework must demonstrate they have exhausted all options before considering revision of Green Belt boundaries. Feb 2019 please explain why This Local Plan proposes considerable modifications to Green Belt boundaries including the removal of Green Belt designation of 13 areas within the Districts as well as modifying the Green Belt status of many local villages. I believe this draft Local Plan has not demonstrated that all other options have been fully explored and as such this Plan is not justified, sound or in accordance with National Policy and thus not legally compliant. I believe that it is not sufficient to claim that the combination of housing need and the presence of significant areas of development collectively represent ªexceptional circumstancesº (as required in the NPPF) to justify modification of Green Belt boundaries. Also, the Plan area is forecast to see a carbon emission increase by 21% in the plan period ± this is inconsistent with Government Policy to achieve net zero carbon emissions by 2050 and therefore not legally compliant. There is also a significant infrastructure funding gap acknowledged within the Community Infrastructure Levy evidence that supports this Local Plan, of between £179m & £231m. Without infrastructure, this development will not be sustainable ± which further makes this plan unsound. This also points to flawed methodology of Green Belt site selection used by the Local Authority, which is neither effective, justified nor consistent with national policy and as such is unsound. Specifically, the selection of the land NE of Chesham at Lye Green (policy SP BP2) for removal from Green Belt designation is inconsistent with National Planning Policy Framework (NPPF). The primary aim of Green Belt land is to prevent urban sprawl and to preserve the openness of the area. The Lye Green site satisfies this requirement well. Another aim of Green Belt land stated in NPPF paragraph 134, is to prevent neighbouring towns and settlements from merging into one another.The Green Belt land NE of Chesham maintains a distinct separate between settlements of Chesham & Lye Green as well as helping to maintain separate identities of other nearby communities at Orchard Leigh, Botley, Whelpley Hill and Ashley Green. It is inconsistent with national guidance to allocate this land for removal from Green Belt especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if earmarked for development. A further aim of Green Belt designation stated in the NPPF at paragraph 134 (e) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land.The allocation of Green Belt land NE of Chesham for development undermines this aim within Chesham. A community lead not for profit organisation called Chesham Renaissance CIC has been striving to create a Chesham Masterplan that would not only provide many genuinely affordable homes in more sustainable locations nearer the town centre, but which would also regenerate some of the more deprived wards within Chesham. The Plan is inconsistent / takes no regard of this local initiative and is therefore also inconsistent with national guidance and thus unsound. I feel the land NE of Chesham is an unsustainable location for development, that has been used by the community for improved health & wellbeing for decades ± demonstrated by the recent assignation of an Asset of Community Value. Exceptional circumstances for reviewing Green Belt boundaries at this location do not exist or are insufficient to warrant the removal of this land from Green Belt designation ± thus the plan is unsound. Policy 3a - Please specify as The Plan needs to be modified by; precisely and succinctly as Considering the complete housing requirement with other nearby authorities, not just Aylesbury. It is possible how you would unsatisfactory to infer this cannot be undertaken because they are different areas. modify this policy to improve its alignment to this test of Exploring co-operation with other nearby authorities may result in further housing needs being catered for soundness. elsewhere. A more thorough investigation and identification of potential brownfield land opportunities must be undertaken. Consideration of alternative options available for meeting the requirements should be explored - such as the Chesham Masterplan by CIC Chesham Renaissance. Green Belt boundary reviews should only be considered after all other reasonable alternatives have been exhausted. Policy-level file upload - 5503122 Please attach any supporting evidence
Person ID 1214139 Full Name Mrs Claire Ellerton ID 4440 Order 236
9426 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Learning Support Assistant Egerton Rothesay School Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-12-11 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as
9427 precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I would like to express my concerns that the Regulation 19 Local Plan to build 500 houses on Green Belt not believe this policy to be land northeast of Chesham is neither legally compliant nor sound, for the following reasons: positively prepared please Through the Brown not Green campaign, which I fully support, I have learnt that the Local Plan has an explain why acknowledged funding gap of between £179m-£231m from the CIL for infrastructure. This fact is of huge concern to myself as a resident of Chesham since 2010, and owner of a house on Lye Green Road opposite the greenfield site since 2012. The infrastructure of the town is already under stress and in need of reinforcement/expansion, so the idea of increasing the number of houses by 500 (with the increasing population that will come to live in those homes) is a massive problem in terms of catering for sick inhabitants who need to see a doctor, young families trying to get their children into local schools, heavy traffic on the roads (and the increased carbon footprint ± air pollution that will result), sewage systems that are already under strain and inadequate water supplies. I recently needed to see a doctor urgently and was told by the surgery's receptionist, when I rang to make an appointment, that she was under instructions not to give out any more appointments that day as the doctors were too busy (I called shortly after 8am in the morning). I had to plead in order to be seen that day. This was not an isolated incident and I have previously tried to make appointments and been told that the doctor is booked up for the next two weeks.You cannot provide 500 new homes without committing to the added infrastructure that the new residents will require. In summary, the Lye Green greenfield land is unsustainable because it lacks the necessary infrastructure to support it, is located too far from the town centre to be accessed on foot ± so the increased carbon footprint that will result from extra traffic to and from the site will increase traffic congestion and further pollute the air quality, which is already a concern. Building on the Lye Green land will destroy existing wildlife habitats and biodiversity, and also threaten the health of our precious and increasingly rare chalk streams. Furthermore, it will deprive the local population of a much-valued community asset, where for years people have sought relaxation and exercise. Extra housing should be built on existing brownfield sites in and nearer to the town centre. If this is done and there is still demand for further homes, it would be better to look beyond the outskirts of Chesham to the Bovingdon airfield site, where there would be space for a self-sustaining community with homes, a new school, a doctors' surgery and a road that could better accommodate the traffic. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve
9428 its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5501513 Please attach any supporting evidence
Person ID 1214496 Full Name Mrs Caroline Biddle ID 4385 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-12-10 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to
9429 relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary
9430 to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The proposals to release Green Belt land to meet housing targets (Generally, Spatial Policy SP SP1 and not believe this policy to be specifically Policy SP BP2 at Lye Green NE of Chesham) are not justified from the evidence submitted by positively prepared please the Councils. explain why The Councils have stated that release of some Green Belt is necessary as part of an overall three part strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. I question the soundness of such a general policy and whether all the brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites and in particular the Green Belt site NE of Chesham at Lye Green. The development of such Green Belt sites involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient and unfunded. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham cannot accommodate any significant highways improvements anyway due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion, with further worsening air quality. Air pollution is a particular concern in Chesham due to the already poor air quality along Berkhamstead Road where there is a designated Air Quality Management Area that already is recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will generate more traffic will make the air quality even worse and insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable nor justified nor is it in accordance with Government policy. The Green Belt site NE of Chesham (SP BP 2) is not a sustainable location. It is over 2Km away from the train station and slightly further still from the town centre but anyone who cares to walk or cycle this distance also has to negotiate a steep hill too. Such an unsustainable location cannot be made sustainable merely by upgrading a couple of public footpaths within the site into bridleways to facilitate cycling. Neither does adding a bus stop address the geography or topography of the area especially if the promised enhanced bus service (which is already infrequent) either does not materialise or if it subsequently fails to be maintained after a few years. The land is also potentially an Asset Of Community Value and upon confirmation of this designation it would afford a community group the right to bid for the land. The community group (Brown Not Green) have stated their intention is to preserve the land given that many hundreds of local people have habitually used the fields at Lye Green as of right for various informal outdoor recreational purposes. These uses themselves may mean that many local individuals may have acquired easements over and across the land through prescription (20 years uninterrupted use) not least of whom would be the many private residences bordering the fields that have rear garden gates onto the fields at Lye Green. These easements and prescriptive rights may render the land very difficult to develop and make it undeliverable in planning terms. This land also provides an important habitat for wildlife that will be threatened by development of this land. It is perverse that the Local Authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Plan is unsound. The foregoing also points to flawed methodology of Green Belt site selection used by the Local Authority, which is neither effective, justified nor consistent with national policy and as such is unsound. Specifically, the selection of the land NE of Chesham at Lye Green (policy SP BP2) for removal from Green Belt designation is inconsistent with National Planning Policy Framework (NPPF). PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
9431 Policy 2 - If you do not For this Plan to sound it must also be effective. Unfortunately, further review of the proposal to remove land believe this policy to be NE of Chesham at Lye Green from Green Belt designation is not effective as there are serious questions effective please explain why. about the deliverability of this land. The main landowner is a farmer who has asserted publicly and in a letter to the editor of Your Chesham that he is not prepared to release all of the land in his ownership for development. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I believe the draft Local Plan is NOT legally compliant because it is not in line with the National Policy and believe this policy in guidance issued by the Secretary of State. consistent with the National The National Planning Policy Framework (NPPF) states that Local Authorities should demonstrate they have Planning Policy Framework exhausted all options before considering revision of Green Belt boundaries. This Local Plan is seeking Feb 2019 please explain why substantial modifications to Green Belt boundaries including the removal of Green Belt designation of 13 areas within the Districts as well as modifying the Green Belt status of many local villages. I contend this draft Local Plan has not demonstrated that all other options have been fully explored and as such this Plan is not justified, sound or in accordance with National Policy and accordingly is not legally compliant. The NPPF states that one of the key features of Green Belts are their permanence, and there are no `exceptional circumstances' to justify modifying the current green belt boundaries, certainly `housing need' cannot constitute an exceptional circumstance. The Government has also recently confirmed its aim for the UK to have net zero carbon emissions by 2050 and it is noted within the Sustainability Appraisal supporting this Draft Local Plan, that the Plan area is forecast to see carbon emission increase by 21% in the Plan Period. Accordingly, the Plan is inconsistent with Government Policy and therefore not legally compliant. The infrastructure is not there to support building in this area. The distance from the tube station is over 1 mile by foot and involves a steep hill with a very narrow pavement, there are no cycle lanes and so anyone wishing to cycle home up the hill would have to push their bike up the pavement, encroaching on pedestrian's space. Given this infrastructure is vital to ensure that development is sustainable (as also required by the NPPF) this further demonstrates the Plan is both unsound and not legally compliant. Paragraph 136 of the latest NPPF asserts that Green Belt boundaries should only be modified in ªexceptional circumstancesº. The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances. The Council engaged third party consultants to undertake the Part 1 Green Belt assessment and they identified numerous sites for ªfurther considerationº where exceptional circumstances ªmightº exist but expressly recommended further review of their assessment of each site against the 5 purposes of land being in Green Belt of all these sites. Unlike the neighbouring Local Authorities, the Part 2 Green Belt assessment was not undertaken by third party consultants but by the Local Authority itself who notably then did not undertake all the recommended reviews of each site including the land NE of Chesham at Lye Green (SP BP 2). Accordingly, this oversight in the Part 2 Green Belt assessment placed premature focus and fixation on releasing land at Lye Green NE of Chesham from Green Belt designation. The subsequent identification of the Chesham site for release is therefore unjustified. The primary aim of Green Belt land (as recited in NPPF 133) is to prevent urban sprawl and to preserve the openness of the area. The Lye Green site (SP BP2) self-evidently performs this function well and has done so for decades. Another aim of Green Belt land stated in NPPF paragraph 134 is to prevent neighbouring towns and settlements from merging into one another.The Green Belt land NE of Chesham performs exceptionally well in maintaining a distinct separate between settlements of Chesham & Lye Green as well as helping to maintain separate identities of other nearby communities at Orchard Leigh, Botley, Whelpley Hill, Ashley Green. It is perverse and inconsistent with national guidance to allocate this land for removal from Green Belt in light of these facts especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if earmarked for development. A further aim of Green Belt designation stated in the NPPF at paragraph 134 (e) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. By allocating Green Belt land NE of Chesham for development, undermines this aim within Chesham. A community lead not for profit organisation called Chesham Renaissance CIC has been striving to create Chesham Masterplan that would not only provide many genuinely affordable homes in more sustainable locations nearer the town centre, but which would also regenerate some of the more deprived wards within Chesham. The Local Authority's proposals (policy SP EP3) are inconsistent with this local initiative and are therefore also inconsistent with national guidance and are consequently unsound. Policy 3a - Please specify as The Plan needs to be modified by; precisely and succinctly as Exploring co-operating with other local authorities in the region to see if there are sites that have been missed, possible how you would particularly brownfield sites. modify this policy to improve its alignment to this test of The Chesham Masterplan should be fully considered. soundness. Modifications: I refer to the comments previously submitted but in summary would advocate that; All other options are fully explored including increased density of development of brownfield land and the policies emerging from Chesham Masterplan. Green Belt land should only be considered when all other options are exhausted and in any event the proposals for developing land NE of Chesham (policy SP BP 2) should be removed as it is an unsustainable
9432 location the development of which will cause harm to the wider town including loss of an asset that improves the well-being for the community. Policy-level file upload - 5511379 Please attach any supporting evidence
Person ID 1221253 Full Name Mr Bob Ing ID 2808 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible.
9433 Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Why are we even thinking of encroaching on green belt land when there are many brown sites available? not believe this policy to be Why are builders sitting on land banks to make a huge killing. positively prepared please explain why New houses in Chesham will not be occupied by local people but by out of area people. The infrastructure can't cope now, parking, doctor's surgeries, schools, pot holes, traffic congestion, police and hospitals. We have a lovely old town and surrounding countryside why spoil this more houses onº GREEN BELT LANDº. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve
9434 its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1214577 Full Name Mr Dominic Cherry ID 4662 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-12-11 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance?
9435 Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible
9436 Policy Level - PP - If you do In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above not believe this policy to be capacity. Chesham cannot accommodate any significant highways improvements due to the already limited positively prepared please verges and footway space beside the highway. I have worked on highways transport schemes for many explain why years. A frequent limitation to improving traffic flow, pedestrian or cycle improvements are that Highway Authority boundaries are not sufficient in area in order to accommodate additional traffic lanes/wider pavements/cycle lanes.The only way to widen the roundabouts and add traffic lanes is by reducing pavement width (not acceptable and will discourage sustainable modes of transport such as walking and cycling) or compulsory purchase order of front drives/housing (prohibitively expensive and time consuming). The increases in vehicular traffic which will directly be spurred by the proposed Local Plan may mean several of the roundabouts would require signalisation, increasing traffic queues exponentially and causing higher levels of NOx, CO2 and particulate pollution (PM10/PM2.5). Thus the Local Plan appears to contravene the following national, international and supranational policies/protocols of which the UK is a signatory: - The Kyoto Protocol (1997) stemming from the 1992 United Nations Framework Convention on Climate Change (UNFCCC) - The Paris Agreement on Climate Change (2016) within the (UNFCCC), - The following EU air quality directives namely 2008/50/EC Directive on Ambient Air Quality and Cleaner Air for Europe & 2004/107/EC Directive on heavy metals and polycyclic aromatic hydrocarbons in ambient air. - The Climate Change Act 2008 (c 27) - Forthcoming UK legislation for a neutral carbon economy for 2050 as an amendment to the 2008 Climate Change Act. The Local Plan 2036 will increase the traffic saturation at the roundabouts causing traffic queues to build. Additional traffic will be generated from the development of Lye Green (or indeed anywhere on the Green Belt periphery of Chesham). These increases in traffic will make Chesham a less attractive location for business (and residents) and will put off investment which will instead flow to Amersham, Berkhamsted, Hemel Hempstead and High Wycombe. Hence it is imperative that the additional housing demand in Chesham is catered for by increasing residential density on brownfield sites in the town centre. Instead of 2 or 3 car households you are far more likely to have car free or 1 car households. The thinking in the draft Local Plan 2036 appears muddled and contradictory. It states in Section 4.5.4 (page 20) that development ªbe low-car or car-free with the primary modes of travel being by foot, bicycle and public transport.º The edge of town locations outlined in the plan are diametrically opposed to Section 4.5.4 in the draft Local Plan. Please note the developments such as on the edge of Beaconsfield and around Lye Green would require a restriction of 1 car per dwelling in order to meet 4.5.4. I fail to see how this development would work for residents to access retail or employment markets and also recreational or educational facilities with such a parking restriction. Locating additional housing in town centres has many beneficial effects: 1. It is more environmentally sustainable (less car driving, less CO2, NOx and particulate emissions 2. It encourages people to walk around more and shop locally. This will benefit retail on the High Street (supports NPPF paragraph 23 ± vitality of town centres) 3. It will preserve traffic capacity on the crucial through road along St. Mary's Way 4. As per the Chesham Renaissance Masterplan it will enable the Council to reverse the historic negative impact of the demolition of Blucher Street by redeveloping Star Yard in a sympathetic manner and improving pedestrian links to Scottowes' Pond and Lowndes' Park. Another concern I have about the draft Local Plan is on Air Quality. Chesham has a fairly rare topography and exhibits `frost hollow' characteristics (Mayes 2013: Royal Meteorological Society, Box 1, page 61). This means that in high pressure anticyclonic conditions which frequently occur during winter months air from the top of the ridges (e.g Chartridge / Hilltop / Ashridge / White Hill / Nashleigh Hill) `sinks' into the valleys, trapping pollutants within radiation fog (p188, Goudie). These temperature inversions can cause rapidly worsening air quality, especially along transport corridors such as Berkhamsted Road, where many people live and there is a Primary School (Newtown Infant School), the Chesham Health Centre and two Nurseries. Berkhamsted Road is already designated as one of Chiltern and South Bucks's three Air Quality Management Areas which already records air quality in excess of EU safe levels. Adding more homes outside town on the Green Belt will 4 generate more traffic which in turn will make the air quality even worse. Insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable nor justified nor is it in accordance with Government policy or EU Directives 2008/50/EC & 2004/107/EC. Please see below relief map illustrating Chesham's topography ± bluer areas are lower, red areas higher. Communities within Berkhamsted Road and Chesham town centre / Waterside are most at risk to amplified air pollution due to local topography. In short, approving the Local Plan is unconscionable and prejudicial towards the health of the pupils and teachers of Newtown School. I believe approving these plans (or any release of Green Belt land around Chesham) would also be highly prejudicial towards the residents of Berkhamsted Road as they will suffer the impacts of the extra vehicular traffic and pollution. Hence I have copied in the relevant Local Councillors.
9437 PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I don't believe the proposals to release Green Belt land to meet housing targets are justified from the evidence believe this policy in submitted. I question the soundness of such a general policy and whether all the brownfield land opportunities consistent with the National with higher public transport accessibility have been identified (National Planning Policy Guidance Feb 2019, Planning Policy Framework page 41, Section 137 a & b) Feb 2019 please explain why I am dismayed that the Council haven't robustly considered higher densities of development on brownfield sites which are closer or within the town centre. These would be far more sustainable locations than any Green Belt sites, including the Green Belt site North East of Chesham at Lye Green. The development of such Green Belt sites involving many hundreds of homes will generate increased traffic and although some highways improvements are suggested they are insufficient. Another 900 houses will put the following roundabouts under severe pressure: - Nashleigh Hill / Berkhamsted Road - St. Mary's Way / Chartridge Lane / Blucher Street - St Mary's Way / Red Lion Street - Amersham Hill / Red Lion Street I believe the Local Plan is in contravention of National Planning Policy Guidance Feb 2019, page 41, Section 138 as there is: - no additional housing planned for Amersham-on-the-Hill in the Local Plan - the housing that is planned in the Amersham area is for Old Amersham (which has far inferior public transport accessibility) - the additional housing for Chesham is outside the town centre on Green Belt land with terrible public transport accessibility Furthermore, in the Amersham area there are ideal sites to develop housing, including the area between Chiltern Avenue and Sycamore Road, which includes East Building Supplies, the St. Michael's Church and Sorbon Estate's land holdings on Sycamore Corner. With careful medium term planning this large site could easily accommodate a net increase of 100 dwellings, improve pedestrian connectivity between the new Leisure Centre and the High Street plus lend an opportunity towards creating a new town square and a new Church. Also, the Royal Mail sorting office on Hill Avenue is an underutilised site which could accommodate 20 apartments and some modern retail in the town centre. If these two, highly sustainable sites were redeveloped it would take some of the pressure off the house building target for Chesham. Rebalancing some residential development towards Amersham Town Centre, intensifying residential development within Chesham Town Centre would negate the `need' to release Green Belt land at Lye Green (or any other green belt land in Chesham and Amersham) and would be in concordance with National Planning Policy Guidance Feb 2019, page 41, Section 138. For this Plan to sound it must also be effective. Unfortunately, further review of the proposal to remove land NE of Chesham at Lye Green from Green Belt designation is not effective as there are serious questions about the deliverability of this land. The main landowner is a farmer who has asserted publicly and in a letter to the editor of Your Chesham magazine that he is not prepared to release all of the land in his ownership for development. The land is also an Asset of Community Value and upon confirmation of this designation it would afford a community group the right to bid for the land. The community group (Brown Not Green) have stated their intention is to preserve the land given that many hundreds of local people have habitually used the fields at Lye Green as of right for various informal outdoor recreational purposes. These uses themselves may mean that many local individuals may have acquired easements over and across the land through prescription (20 years uninterrupted use) not least of whom
9438 would be the many private residences bordering the fields that have rear garden gates onto the fields at Lye Green. These easements and prescriptive rights may render the land very difficult to develop and make it undeliverable in planning terms. It is perverse that the Local Authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Plan is unsound. The primary aim of Green Belt land (as recited in NPPF 133) is to prevent urban sprawl and to preserve the openness of the area. The Lye Green site self evidently performs this function well and has done so for decades. Another aim of Green Belt land stated in NPPF paragraph 134 is to prevent neighbouring towns and settlements from merging into one another.The Green Belt land NE of Chesham performs exceptionally well in maintaining a distinct separate between settlements of Chesham and Lye Green as well as helping to maintain separate identities of other nearby communities at Orchard Leigh, Botley, Whelpley Hill and Ashley Green. It is perverse and inconsistent with national guidance to allocate this land for removal from Green Belt in light of these facts especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if earmarked for development. A further aim of Green Belt designation as stated in the NPPF at paragraph 134 (e) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. By allocating Green Belt land NE of Chesham for development, undermines this aim within Chesham. A community lead not-for-profit organisation called Chesham Renaissance CIC has been striving to create a Chesham Masterplan that would not only provide many genuinely affordable homes in more sustainable locations nearer the town centre but which would also regenerate some of the more deprived wards within Chesham. The Local Authority's proposals are inconsistent with this local initiative and are therefore also inconsistent with national guidance and are consequently unsound. I would urge the Council to incorporate the Chesham Renaissance suggestions in a heavily revised Local Plan. The Council have asserted that Government planning policy requires local councils to review Green Belt boundaries when considering how to accommodate the development needed in their areas. Just because the Council may be required to look does not mean the Council should review Green Belt boundaries which as previously stated should only be modified in ªexceptional circumstancesº. National Planning Policy Framework (NPPF) as revised only last year, states in paragraph 11(b)i, directs ªplan makersº to create policies that are required in Local Plans for housing and other uses unless Framework policies (expressly including Green Belt) ªprovides a strong reason for restricting the overall scale type or distribution of development in the plan areaº. Accordingly, I submit that given all of the above the land being proposed for release from Green Belt designation around Chesham is unjustified and contrary to national guidance. I am supportive of the Brown Not Green organisation's initiative to have the land listed as an Asset of Community Value and support in respect of their objections to the draft Local Plan. Accordingly, I request that any representations made by them at any future examination in public regarding the soundness of this Local Plan be considered as an extension of my own comments herein. Additionally, I feel the land NE of Chesham, or indeed, any Green Belt Land surrounding Chesham (listed below) are fundamentally unsustainable locations for development, that has been habitually used by the community for improved health & wellbeing for decades and these areas of land performs well against Green Belt aims and objectives. This would include Greenbelt and AONB land in other areas such as: - Ashridge Vale - Pednor Vale - Ashley Green - Chartridge - Waterside - Latimer Exceptional circumstances for reviewing Green Belt boundaries at Lye Green, or indeed, any of these locations either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by Government Policy and therefore the plan is unsound. As a final point I would like to register my concern about the Local Plan and the detrimental impact it will likely have upon rare chalk stream habitats in Chiltern District. There are only circa 200 chalk streams worldwide, with two of them in Chiltern; the River Chess and Misbourne. They are both frequently dried out due to over water abstraction (please see photo). I believe the additional houses planned for Chesham will negatively impact upon the Chess as more water will be abstracted for residential use, depriving the local aquifers of water to recharge the Chess (WWF 2014, The State of England's Chalk Streams) Two SSSIs associated with the River Chess will be negatively impacted ± Frogmore Meadows (Chiltern District/Three Rivers District Council/Dacorum Borough Council and Sarratt Bottom (Three Rivers District Council /Hertfordshire). I do not believe the draft Local Plan has appropriate mitigation for the increases in water abstraction and believe this should be included in full Environmental Impact Assessment (EIA) to accompany a revised Plan. This may require the building of new reservoirs with neighbouring Councils and mandating any new development in the town centre to incorporate rainwater and greywater recycling. The threshold for an EIA is a development in excess of 150 homes. The agglomerated impact of 5,200 extra houses in Chiltern and South Bucks would therefore require a robust EIA unless every single commercial development was 149 homes or less. Hence I believe the draft Local Plan is also in contravention the Wildlife
9439 and Countryside Act (1981) Section F226 F28H and European Union Directive (85/337/EEC) on Environmental Impact Assessments. I deduce Chiltern District Council is a Section 28G Statutory Undertaker and is required to notify Natural England before ªcarrying out, in the exercise of its functions, operations likely to damage any of the flora, fauna or geological or physiographical features by reason of which a site of special scientific interest is of special interest.º Policy 3a - Please specify as Please do not misinterpret my letter. I am pro-development and very happy for additional housing to be precisely and succinctly as located within Chesham. It just needs to be accomplished in a strategic, lawful and sustainable way. The possible how you would extra residential units should primarily be accommodated within the town centre to: modify this policy to improve 1. Retain all of our precious green belt and green spaces in Chesham its alignment to this test of soundness. 2. Revitalise Chesham's town centre with ~1,000 extra residents 3. The CIL/s106 payments from the 900 new houses in the town centre can contribute towards a custom 4-car S-stock train for the Chesham to Chalfont & Latimer service. The bay platforms at Chesham and Chalfont could then be reopened. This could increase the frequency between 50-100% (from 2 to 3 or 4 trains an hour). So a train to Chalfont every 15 or 20 minutes instead of 30. This would increase Chesham's desirability as a residential/retail/business location plus encourage less people to drive to Berkhamsted, Amersham and Chalfont for their commute so a win-win. 4. Suggested locations are, Star Yard Car Park (100 residential units) Watermeadow Car Park (100 residential units) the Wickes retail centre 80 units) Chesham Youth Centre (10 residential units), the Old coal yard by Chesham Station (20 units), Waitrose and the Council Car Parks in front of the Whitehill Centre (150 units), Sainsbury's car park and Chesham Library redevelopment/improvement (100 units). These residential dwellings could be combined with the retail development as outlined in your plan but with higher density (page 75, 6.2.11) Chiltern District Council should also liaise and work with Paradigm Housing to review their assets and help redevelop their housing stock with increased residential density in Chesham and Amersham. Finally a revised plan should rebalance a quantum of the additional proposed housing demand from Chesham to Amersham-on-the-Hill which has superior public transport. I'm sure the all the additional housing units could be catered for if the above locations were reviewed and injected with a mixture of private and public sector capital. Hence I urge the Council to revise the Local Plan. I'm happy to help out with any suggestions and there are lots of people in Chesham with skills who may be happy to lend a hand in order to ensure that we seize this remarkable opportunity to rejuvenate and revitalise Chesham for the future. Policy-level file upload - Please attach any supporting evidence
Person ID 1221258 Full Name Mr Jan Masat ID 2830 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is
9440 not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is
9441 proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do In my view it is non-compliant but I am a layman without the knowledge of all the planning laws and regulations. not believe this policy to be Some of the statements presented in Green Belt Exceptional Circumstances Report May 2019: positively prepared please explain why `Our evidence concludes that the LHN for housing in Chiltern and South Bucks is 15,260 dwellings or 763 homes per year over the period 2016-2036' `This analysis concludes that only using previously developed land would not provide us with enough land to meet our LHN. The allocation of Green Belt sites enable us to contribute to some of these requirements' `The Green Belt Review concludes that the sites allocated can be released from the Green Belt without significantly harming Green Belt purposes'. `Maintenance of strong defensible Green Belt boundaries' `Exceptional circumstances therefore exist for the release of this site from the Green Belt.' So in my simple terms the planners have a problem. The Local Housing Need (LHN) has determined that we must build 763 houses a year. The planners have concluded that we do not have enough non Green Belt land available to achieve this target. From the original purposes of the Green Belt that would be the end of the discussion. We would accept that this area could not achieve the target. As we know, exceptional circumstances are required to build on the Green belt so the planners are now looking for a new definition of exceptional circumstances. My understanding was that these had to be of regional or national significance, for example the expansion of Pinewood Studios protected the British film industry's future. In their report they have listed this statement under exceptional circumstances: `The acuteness/intensity of the need for new homes, employment and retail provision'. That is not a national or regional need. It's just the perceived challenge of the LHN. I live in Chesham and I don't see or feel this need. Is there really an acute need for more retail in Chesham? Have the residents been surveyed? There are empty shops in Chesham and they have to stand and be successful on their own. Many come and go. We don't need more retail. Similarly for employment. This is a commuter area hence the high peak traffic demands. What percentage of residents work in Chesham? It will be small. Where is the acute need for employment? Just on these two factors the statement is not true or not backed up by survey evidence. For me, an acute need would be confirmed by 70-80% of residents and it hasn't been. Interestingly, I didn't see LHN defined. I think this is a very significant term. Is the `need' really `local' when the plan covers such a large area. I moved to Chesham 12 years ago and live on a small infill development. It's interesting to note where the people who first bought the houses came from. They were not local. About 60% moved here from London Boroughs because the equivalent houses are cheaper, the traffic is better, air is cleaner etc. I'm sure that will be similar for other new house development. I don't think there really is an acute local `need'. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
9442 Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5495912 Please attach any supporting evidence
Person ID 1214678 Full Name Mrs Heather Baker ID 4320 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-12-10 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness?
9443 Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I question whether all the brownfield land opportunities have been identified and also whether development not believe this policy to be should not be closer to the town centre and on sites that are more sustainable than Green Belt sites particularly positively prepared please the Green Belt site North east of Chesham at Lye Green. explain why Development of hundreds of homes on Green Belt sires will generate increased traffic and evidence from Chesham already shows most road junctions and infrastructure is operating above capacity. Increased traffic congestion will further worsen air quality and with Berkhamsted Road already designated as an Air Quality Management Area with air quality worse than EU safe levels, building more homes on the Green Belt site NE of Chesham will only exacerbate the problem. This cannot be sustainable or in accordance with Government Policy. The Green Belt site NE of Chesham is not a sustainable location being over 2km away from the train station and town centre. There are conflicting policies within the plan promoting easy access to public transport including the tube but also proposing retail development on the current station car park. This is inconsistent
9444 and unsound. Furthermore the station car park is often full and during rush hours of 7-9am and 5-7pm the tubes are full with standing room only. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not The land NE of Chesham at Lye Green is potentially an Asset of Community Value. If this designation is believe this policy to be confirmed, a community group would have the right to bid for the land.This land is currently used by hundreds justified please explain why of local people year round for outdoor recreational purposes such as dog walking, running, Duke of Edinburgh Award Scheme expedition trails, kite flying. The land is also rich in many species of wildlife which will be threatened by development.The community group (Brown Not Green) have stated their intention is to preserve the land for the local people and wildlife. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not For the plan to be sound it must also be effective. The proposal remove land NE of Chesham at Lye Green believe this policy to be from Green Belt designation is not effective as there are doubts over the deliverability of this land. The main effective please explain why. landowner is a local farmer whose family have lived in the area for many years and he has been vocal in expressing his views publicly that he is not prepared to release all of the land in his ownership for development. The land is good quality agricultural land utilised for both crops and livestock. The aim of Green Belt land is to prevent urban sprawl and to preserve openness of the area. Another aim of Green Belt landed stated in NPPF is to prevent neighbouring towns and settlements merging into one another. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not This local plan includes removal of Green Belt designation of 13 areas within the districts as well as altering believe this policy in Green Belt status of many local villages. consistent with the National This contravenes the National Planning Policy Framework (NPPF) which advises that Local Authorities must Planning Policy Framework demonstrate that all other options have been fully explored and is therefore not justified, sound or in agreement Feb 2019 please explain why with the National Policy and as a result is not legally compliant. The NPPF states that one of the key features of Green Belts are their permanence and that only in exceptional circumstances should their boundaries by modified. As above, I do not feel all options for alternative housing sires have been explored so to suggest that these are exceptional circumstances and that Green Belt land should be developed is not justified. The plan is inconsistent with Government Policy in the UK to aim for net zero carbon emissions by 2050 as within the sustainability appraisal supporting the Draft Local Plan, the forecast for the plan area is for carbon emission to increase by 21%. In this respect the plan is not legally compliant. Furthermore to ensure the development is sustainable, adequate funding for infrastructure is essential. Evidence in the community infrastructure levy which supports this Local Plan indicates an infrastructure funding gap of between £179million and £231million which again indicated the Plan is unsound and not legally compliant. The foregoing also points to flawed methodology if Green belt site selection used by the Local Authority, which is neither effective, justified not consistent with national policy and as such is unsound. Specifically, the selection of the land NE of Chesham at Lye Green (policy SP BP2) for removal from Green Belt designation is inconsistent with National Planning Policy Framework (NPPF). Paragraph 136 of the latest NPPF asserts that Green Belt boundaries should only be modified in "exceptional circumstances". The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances. The council engaged third party consultants to undertake the Part 1 Green Belt assessment and they identified numerous sites for "further consideration" where exceptional circumstances "might" exist but expressly recommended further review of their assessment of each site against the 5 purposes of land being in Green Belt of all these sires Unlike the neighbouring Local Authorities, the Part 2 Green Belt assessment was not undertaken by third party consultants but by the Local Authority itself who notably then did not undertake all the recommended reviews of each site including the land NE of Chesham at Lye Green (SP BP 2), Accordingly, this oversight in the Part 2 Green Belt assessment placed premature focus and fixation on releasing land at Lye Green NE of Chesham from Green Belt designation. The subsequent identification of the Chesham site for release is therefore unjustified. A further aim of Green Belt designation stated in the NPPF at paragraph 134 (e) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. By allocating Green Belt land NE of Chesham for development, undermines this aim within Chesham. A community lead not for profit organisation called Chesham Renaissance CIC has been striving to create Chesham Master plan that would not only provide many genuinely affordable homes in more sustainable locations near the town centre.
9445 Policy 3a - Please specify as -Exploring in more detail brownfield land for development. precisely and succinctly as -Considering other options for housing such as Chesham Master plan by CIC Chesham Renaissance. possible how you would modify this policy to improve -Green Belt Land should only be considered after all other possible alternatives have been explored thoroughly. its alignment to this test of -Spreading the need for housing in several areas. soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1214798 Full Name Mr John Mayne ID 4189 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-12-11 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant
9446 legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve
9447 its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not 1. It seeks to use Green Belt land at Lye Green instead of potential land closer to Chesham which would believe this policy in make the plan more sustainable. There is a presumption that plans should favour sustainable development. consistent with the National The plan is not justified in taking this land out of Green Belt when there is more suitable land available. The Planning Policy Framework selection process has therefore been flawed. Housing need in the area does not justify the poor choice. Feb 2019 please explain why There is more space available in the north of the county for housing.The plan is inconsistent with the National Planning Policy Framework (NPPF). 2. The plan is not sound as it will undermine sustainability by encouraging motor car usage. Transport modelling indicates a 300% increase in local journey times. Furthermore, air quality will suffer.The particular topography of the Chess Valley makes Chesham residents particularly vulnerable in this respect. 3. The plan will add to `urban sprawl' and coalescence of settlements. A problem will arise with associated drainage problems and flooding connected to building on the existing soak-a-way available on the agricultural land. Chesham is already particularly exposed to flooding problems. At the same time extra demand on the water supply will threaten the (chalk stream) River Chess already running dry and will adversely impact local ecology. 4. The policy for infilling within the currently washed over villages in the Green Belt such as Ashley Green will adversely impact a conservation area that includes a number of listed buildings such as Nashleigh Farm, Ashley Hall Farm, Ashley Cottage and Old Oak Farm and assets of community value, namely the Golden Eagle public house and the Village Green. 5. The plan takes agricultural land out of agricultural production. This is now a national strategic concern made more serious by Brexit. Agricultural policy will almost certainly need to be re-balanced away from livestock to more sustainable and healthier production. More land will be required for agricultural output in order to increase UK self-sufficiency and food security to strategically reduce dependence on imports. 6. I am generally more supportive of the Brown-Not-Green campaign alternative plan rather than the proposed Local plan. I also consider the Chesham Masterplan as a credible alternative. 7. As a resident of Ashley Green for over 35 years I have significant local knowledge gained both as a member of and past chairman of the Ashley Green Community Association (AGCA) I would like to request the opportunity to make a submission to the enquiry under Regulation 19. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5500472 Please attach any supporting evidence
Person ID 1214892 Full Name Ms Kim Tyrrell ID 3534 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-12-05 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID
9448 Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination
9449 Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Removing areas from green belt is not currently legal (non-compliant) not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1221280 Full Name Mr Steve Carter ID 2899 Order 236 Number 11.3
9450 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible.
9451 Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The Green Belt site NE of Chesham is not a sustainable location. It is over 2km away from the train station not believe this policy to be and slightly further still from the town centre but anyone who cares to walk or cycle this distance also has to positively prepared please negotiate a very steep hill in either White Hill or Nashleigh Hill. Such an unsustainable location cannot be explain why made sustainable merely by upgrading a couple of public footpaths within the site into bridleways to facilitate cycling. Neither does adding a bus stop address the geography or topography of the area especially if the promised enhanced bus service (which is already infrequent) either does not materialise or if it subsequently fails to be maintained after a few years. PP Mods - Please specify as There are other possibilities available. Could the council not look to develop brownfield sites which are often precisely and succinctly as closer to the town centre and are in more sustainable locations? possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
9452 Policy 3 - If you do not The courts have stated that building on green belt land may only happen in `exceptional circumstances' and believe this policy in that the desire for more housing does not constitute an `exceptional circumstance'. I, therefore, must conclude consistent with the National that the current draft plans must be altered or dismissed. Planning Policy Framework The current plans seem to be at odds with other policies that the council has in regards to protecting local Feb 2019 please explain why wildlife habitats. The local wildlife is a source of pride and enjoyment for many of us residents and would hate to see it disappear for the sake of a new housing development. I feel I must also raise the Consultation Form that is provided by Chiltern and South Bucks. Having attempted to complete the form on numerous occasions I felt stumped by the wording of the document and the size of it. Is the council honestly asking me, a local citizen, to provide references to legislation, regulation and/or policies (P.2)? Or to provide modifications to make the proposal more legally compliant (P.4)? These are just 2 examples of the issues with the form. I found it difficult to put my thoughts across using it and felt that the form was there to dissuade me from completing it. Surely the council is able to provide their residents with an easier way of stating their case. If the council wishes to point out prior consultations, I would respond by saying that no prior consultations were given. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1214931 Full Name Mrs Lorraine Boyd ID 4285 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-12-04 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this
9453 modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Not legally compliant not believe this policy to be I believe that the Local Pan is not legally compliant because: positively prepared please explain why
9454 Green Belt boundary reviews should only take place AFTER every other possibility has been examined. In this case, alternative local Brown Field sites have been ignored. Detailed examination of alternative options for housing delivery should be explored (such as Chesham Masterplan by CIC Chesham Renaissance). There are entire sections of the NPPF to which have not been complied with. Vitality of Town Centres The building of houses at the top of a very steep hill over a mile away from the town centre will not enhance the vitality of the town centre in Chesham. In fact, it will only result in an increase in motor traffic through Chesham. Promoting healthy and safe communities and Promoting sustainable transport. Chesham lies at the bottom of a valley. There is just one already congested road into and out of the town. The proposed building on top of the hill will mean the majority of residents will use cars when they visit the town centre or to access the train station. Independent surveys predict the traffic congestion will increase by 400% under this plan. The Government has also recently confirmed its aim for the UK to have net zero carbon emissions by 2050 and it is noted within the Sustainability Appraisal supporting this Draft Local Plan, that the Plan area is forecast to see carbon emission increase by 21% in the Plan Period. Accordingly, the Plan is inconsistent with Government Policy and therefore not legally compliant. Meeting the challenge of climate change, flooding and coastal change. Flooding and drainage is already an issue in many parts of Chesham. Building on Green Belt land (which absorbs vast quantities of water) will increase flooding risk. With the development being sited at the top of a hill there is also only one way for this water to flow, down into the town. Conserving and enhancing the natural environment.The area highlighted for development is rich in countless species of wildlife and home to threatened bird species. Areas like these are vital for maintaining biodiversity. There is also a significant infrastructure funding gap acknowledged within the Community Infrastructure Levy evidence that supports this Local Plan, of between £179m & £231m. Given this infrastructure is vital to ensure that development is sustainable (as also required by the NPPF) this further demonstrates the Plan is both unsound and not legally compliant. Unsound The Plan is unsound for a number of reasons. The plan makes no provision for tackling issues such as traffic, access to the site, parking in town, drainage, flooding risk, school places, doctors and employment opportunities are just some areas which have very little explanation. Although some highways improvements are suggested, they are insufficient and unfunded. Chesham cannot accommodate any significant highways improvements due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion, with further worsening air quality. Regarding the homes being built, there is no mention of which form these will take, where they will be placed on the land or how tall they will be. These factors could have major implications for residents in the adjoining and surrounding areas. The way in which the Plan was passed by the Town Council is of concern. Councillors spoke of serious reservations about the plan, and yet only two voted against.These councillors were subsequently suspended. I can only conclude the councillors were voting under a three-line whip. Some of the reasons then given for their approval (despite these serious reservations) were that only 2.7% of green belt would be lost (setting a bad precedent). Central Government would only write one for us if we reject this one and that this is the least worst option. Hardly ringing endorsements and it suggests the councillors are taking the path of least resistance. We need to remember that this plan will change our town and the surrounding villages forever and any negative impact will affect future generations very badly. I am supportive of the Brown Not Green organisation's initiative to have the land listed as an Asset of Community Value and I feel they speak for me in respect of their objections to the draft Local Plan. Accordingly, I request that any representations made by them at any future examination in public regarding the soundness of this Local Plan be considered as an extension of my own comments herein. PP Mods - Please specify as Not legally compliant modifications precisely and succinctly as I list below the modifications I feel are essential. possible how you would modify this policy to improve The Chesham Masterplan by CIC Chesham Renaissance should be looked at with serious intent. This plan its alignment to this test of resolves almost all of the issues I have mentioned in the previous section and takes greater steps to reduce soundness. the impact of those it cannot completely resolve. It also has the backing of at least 70% of Chesham residents. It is a visionary plan, but one which has the potential to reinvigorate Chesham from the centre out and may even become an historic turning point in how suburban development addresses sustainability. A more detailed appraisal of Brown Field land opportunities MUST be undertaken. Unsound modifications Modifications I refer to the comments previously submitted but in summary would advocate that; All other options are fully explored including increased density of development of Brown Field land and the policies emerging from Chesham Masterplan. Green Belt land should only be considered when all other options are exhausted and in any event the proposals for developing land NE of Chesham (policy SP BP 2) should be removed as it is an unsustainable
9455 location the development of which will cause harm to the wider town including loss of an asset that improves the well-being for the community. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5501069 Please attach any supporting evidence
Person ID 1221281 Full Name Sarah Gaughran ID 2903 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to
9456 relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary
9457 to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do In Chesham the evidence shows that most of the road junctions and infrastructures are already operating not believe this policy to be above capacity. The development of such Green Belt sites involving many hundreds of homes will generate positively prepared please increased traffic and although some highways improvements are suggested they appear to be insufficient. explain why I understand that due to the already limited verges and space beside the highway combined with the topography of the town any significant highways improvements cannot be accommodated. The outcome therefor will be increased traffic congestion and further worsening of air quality. Air pollution is a particular concern in Chesham due to the already poor air quality along Bekhamstead Road where there is a designated Air Quality Management Area that already is recording air quality that is considerably worse than EU safe levels. Worsening of air quality cannot be sustainable nor justifiable as is it not in accordance with Government policy. The Green Belt site North East of Chesham is over 2km away from the train station and slightly further still from the town centre anyone walking or cycling these distances will have to negotiate a very steep hill (either White Hill or Nashleigh Hill).This cannot be made sustainable by simply upgrading a couple of public footpaths to allow cycling.The the idea of adding a bus stop with a general promise of an enhanced service is a fanciful solution to the transportation needs of an increase in population of the size proposed. I think that there should also be attention paid to the inconstant and conflicting policies within the plan. The Council indicates that they believe that the Green Belt site North East of Chesham is sustainable and provides easy access to public transport including the Tube station yet the same Plan (local draft plan policy SP EP3) promotes a considerable increase in retail development in the town part of which would be built on the car park that serves the very same station that will need to support additional customers.. Serious questions about the deliverability of the land North East of Chesham at Lye Green are present. The main landowner is a farmer who has asserted publicly and in a letter to the editor of Your Chesham magazine that he is not prepared to release all of the land in his ownership for development. There is also the matter of the land being considered as a potential Asset of Community Value and upon confirmation of this designation it would afford a community group the right to bid for the land. The community group (Brown Not Green) have stated their intention is to preserve the land. Easements and prescriptive rights may render the land very difficult to develop and make it undeliverable in planning terms. It is perverse that the Local Authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. I would suggest that these points indicate that the methodology used by the Local Authority is neither effective, justified nor consistent with national policy and as such is unsound. PP Mods - Please specify as A community lead not-for-profit organisation called Chesham Renaissance CIC has been striving to create precisely and succinctly as a Chesham Masterplan that would not only provide many genuinely affordable homes in more sustainable possible how you would locations nearer the town centre but which would also regenerate some of the more deprived wards within modify this policy to improve Chesham. The Local Authority's proposals are inconsistent with this local initiative and are therefore also its alignment to this test of inconsistent with national guidance.The Council seem intent on ignoring the NPPF paragraph 134 (e) stating soundness. that Green Belt policy "is to assist in urban regeneration by encouraging the recycling of derelict and other urban land". By allocating Green Belt land North East of Chesham for development this aim is , undermined and consequently unsound. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not The primary aim of Green Belt land (as recited in NPPF 133) is to prevent urban sprawl and to preserve the believe this policy in openness of the area.The Lye Green site self clearly performs this function well and has done so for decades. consistent with the National Another aim of Green Belt land stated in NPPF paragraph 134 is to prevent neighbouring towns and Planning Policy Framework settlements from merging into one another.The Green Belt land North East of Chesham performs more than Feb 2019 please explain why adequately in maintaining a distinct separate between Chesham and Lye Green as well as preserving the identities of other nearby communities ie Orchard Leigh, Botley, Whelpley Hill and Ashley Green. It is
9458 inconsistent with national guidance to allocate this land for removal from Green Belt especially when considering that the land represents agricultural land of good quality and an environment for many species of wildlife that will be lost if earmarked for development. The identification of the Chesham site for release can also be considered unjustified on the basis that Paragraph 136 of the latest NPPF where it is stated that Green Belt boundaries should only be modified in ªexceptional circumstancesº.The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances. The fact that the Part 2 Green Belt assessment was undertaken by the Local Authority itself who notably then did not undertake all the reviews of each site recommended in the third party Part 1 assessment suggests that the identification of these sites are unsound.. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1215219 Full Name Mrs Sharon Cookes ID 4337 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-11-23 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be
9459 as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do 1.0 THIS PLAN IS NOT POSTIVELY PREPARED not believe this policy to be It is my interpretation that Positively Prepared means that Councils are obliged to consider the well-being of positively prepared please the environment and the communities that they have been elected to represent when preparing plans for explain why change. This principle has been wilfully ignored in this case. 1.1 Chiltern District Council Meeting ± 15 May, 2019 I sat in the public gallery to listen to the Chiltern District Councillors give their reasons for their support of the local plan. Member after member stood up and publicly admitted that they knew that the Plan would be
9460 opposed by a significant majority of their constituents, that the Plan would not benefit the communities that they were supposed to be representing and that, in some cases they themselves had serious reservations about the impact of this Plan upon their communities. No councillor made any reference to the potentially negative environmental impacts of the Plan.This may have been due to the fact that those voting had probably not had the time to read the documents produced in support of the Local Plan. These had been released within a time frame of three days to 48 hours before the meeting and exceeded 800 pages of typed information. Disturbingly, this means that the Councillors almost certainly, voted for their Local Plan without reading all of the information pertaining to the proposals contained within the plan. Their uniform justification for voting for the Plan was two-fold: That if they did not vote for the Plan, central government would impose their own plan and it would be ªeven worseº, and that, if the Council did not have a fixed Plan, housing developments would descend into some kind of chaotic free for all planning nightmare± a faintly embarrassing excuse as it was plainly obvious to all in the public gallery that this was simply fictitious scare-mongering as all planning applications still have to be submitted to the Council and their planning professionals for approval. 1.2 Lack of Consultation The Councils' strategy, when consulting the public, appears to discourage any form of dissent by either making the process of objecting as difficult as possible or keeping publicity of the Plan to a minimum in order to avoid dissent altogether. Evidence of this approach can be found in the fact that many people who live in the local villages were completely unaware that their Council had proposed the removal of green belt protection from their village or had freed it up for in-filling - a process I had to explain as many did not understand what that meant (I have spent many hours distributing leaflets to the local villages and have spoken with many of them about the Plan). The process of filing a Regulation 19 response seemed to be made as awkward as possible: the options available were to try and complete a highly technical, complicated online Objective Portal or fill in a ªRepresentation to the Public Examination of the Local Planº form online. Neither option allowed for the public to download the forms and I have heard many residents complain that they were timed out and all of their work lost. No mention was made on the website at that time of the fact that letters and emails were perfectly acceptable until this was challenged. One resident of Chalfont St. Peter told me that the Head of the Chiltern District Council informed a public meeting that letters and emails responses ªwere not allowedº. 1.3 Increased Pollution and Traffic Congestion The development of the proposed Green Belt sites involving many hundreds of homes will inevitably increase the volume of traffic and although some highways improvements are suggested, they are insufficient. For example, in Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. It is not unusual for a four mile journey to Amersham during the morning rush hour to take over 30 minutes due to existing traffic congestion. Chesham cannot accommodate any significant highways improvements due to the already limited verges and space beside the highway and, combined with the topography of the town, this means that there will be significantly increased traffic congestion and further worsening air quality. Existing levels of air pollution is a concern in Chesham due to the already poor air quality along Berkhamstead Road where there is a designated Air Quality Management Area that is currently recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will generate more traffic which in turn will make the air quality even worse. In fact the Councils' own Sustainability Appraisal states that the Plan will increase Chesham's carbon footprint by 21%. 1.4 Green Spaces As the 21st most populated country in the world, England needs to preserve its remaining green spaces. Last year, the Chairman of the London Green Belt Council, Richard Knox-Johnston, stated "The Green Belt is a vital green lung for people in London and the wider South East. By protecting green spaces, it is making a hugely important contribution to people©s health and well-being as well as maintaining essential eco-systems and providing wildlife corridors. "Green spaces help to mitigate climate change because carbon is absorbed by vegetation and held long-term in soils emissions. They also help us adapt to climate change by absorbing rainwater and cooling our towns and cities. The more green space we lose, the more we are at risk from flooding and rising temperatures, two of the predicted effects of climate change. District and borough councils are absolutely right to recognise the seriousness of climate change and to acknowledge the role that local government can play in tackling the climate crisis, but if they do not also pledge to defend the Green Belt and countryside from development then they are failing in their duty to protect our communities and environment." Many of the people who live in Chesham love and respect the countryside that surrounds the town. The land at Lye Green North East of Chesham has recently become an Asset of Community Value in recognition of its importance to the local community who use it for walking, nature watching or simply teaching their children to enjoy their countryside. Removing this valued resource can hardly be viewed as a positive outcome for the community. 1.5 Wildlife Habitat The green belt land at Lye Green, North East of Chesham is of intrinsic value to wildlife, particularly due to the diversity of habitats contained within it. It is Best & Most Versatile agricultural land (BMV) and comprises grazing and arable land, whilst accommodating hedgerow, woodland, scrub as well as a large wildlife pond directly on its border. For this reason, a large diversity of bird, mammal, amphibian, and insect populations are present, including the flora to support them. The current state of nature in the UK is in serious trouble and the rapid decline of British wildlife is mirrored locally: in the last 40 years, eleven bird species have become extinct in this area, a further five species critically endangered and another twelve species in serious decline. It should be noted that the bird species most seriously affected are farmland birds. Of the bird species of the highest conservation concern (red list), eleven species have been recorded at the Lye Green, North East of Chesham site together with a further eleven bird species on the Amber List (second most serious cause for concern). This are:
9461 Red list: Cuckoo, Skylark, Starling, Fieldfare, Song thrush, Redwing, Mistle Thrush, House Sparrow, Grey wagtail, Linnet, Yellowhammer Amber list: Tawny Owl, Stock dove, Kestrel, House Martin, Black-headed Gull, Mallard, Dunnock, Bullfinch, Reed Bunting, Lesser Black-backed Gull and Meadow Pipit. Many of the above species also breed at this site. This year, Green woodpecker, House sparrow, Kestrel and Tawny Owl, amongst others, definitely bred successfully. If this site is lost, the birds will not simply go elsewhere, they will not breed, and the local populations will be lost. Further fauna occupying the land include three species of bats, badgers, hedgehogs, rabbits, foxes and muntjac deer are frequently seen.The large pond bordering the site is ideal for amphibians and reptiles such as grass snakes. Given the current national concern about the decline of British wildlife and threat of widespread extinction, good quality agricultural land able to support good bio-diversity should not be surrendered to developers. 1.6 The River Chess There are only around 210 chalk stream rivers that have been identified in the world and 85% of them are located in England. The serious plight of our chalk stream rivers was debated in Parliament last month. Our nation's neglect and abuse of this rare, global resource is an international disgrace and the condition of the River Chess is testament to that fact. Brown trout, king fishers and critically endangered water voles depend on the river, but its high mineral content also creates an abundance of other flora, fauna and insects upon which other wildlife depends. The river periodically runs dry due to over abstraction by the local water company (a cheaper option than building adequate water conservation facilities such as reservoirs) coupled with highly variable weather events and on occasion, raw sewerage is discharged into the river as the rate of infilling development and population expansion has pushed the system beyond its maximum capacity. The impact on fish and aquatic invertebrates is disastrous and adding yet more housing and increasing water consumption without adequate water conservation measures may damage this rare and precious habitat beyond repair . ural Beauty, of which chalk streams are 1.7 Soil and Water The Councils' own Sustainability Appraisal admits that using green belt land for housing development is ªis undesirable due to potential for soil contamination, soil loss and erosion, loss of carbon sink and water filtering capabilitiesº. It accepts that ªDevelopment would therefore be likely to result in the loss of some of the district's most versatile and productive soils.º That will result in ªThe loss to BMV land would reduce the quantity of the most productive and flexible agricultural land that can best deliver food and non-food crops for future generations.º The negative impact of this plan on water quality is also spelt out. ªNone of the potential Green Belt removal locations are anticipated to have a positive effect on water quality due to the significant increase in demand on water demand and treatment facilities. Water pollution may also be of concern.º Given the negative impact on the community, local wildlife and the environment in general, this draft Local Plan is anything but positively prepared. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not 1.0 THIS PLAN IS NOT JUSTIFIED believe this policy to be 1.1 Selecting Greenbelt for Housing Development justified please explain why There is currently enough brownfield land in England to accommodate more than 1 million homes, with almost three quarters of this land in counties with Green Belt land https://tinyurl.com/y2lokml7 . Government data shows that greenfield land is still being lost to housing development at an unnecessary and alarming rate. The Campaign to Protect Rural England (CPRE) has calculated that the amount of farmland, forest, gardens and greenfield land lost to housing development each year has increased by 58% over the past four years according to an analysis by the CPRE Ref: https://tinyurl.com/y5y4pxlt . Chesham Renaissance is a community interest company that has spent four years developing a Master Plan for Chesham which incorporates creative ideas for affordable housing in sustainable locations close to the town centre, whilst preserving the green belt surrounding the town. This Masterplan was developed in consultation with the public and was widely publicised locally to give residents the opportunity to feed back on the Master Plan (unlike the Local Plan). This endeavour has been completely ignored by the Council who have failed to adequately consider all of the local brownfield land opportunities, nor explored the possibilities of higher densities of development on such sites. Greenbelt exists for a number of reasons: Its primary aim is to prevent urban sprawl and to help maintain the identities and character of rural settlements in danger of being swallowed up by the ever-extending boundaries of their local towns and cities. The land at Lye Green, North East of Chesham, together with the greenbelt land surrounding the local villages such as Botley, Ley Hill and Ashley Green performs this function very well. Central government are beginning to recognise the scale of the problem (and local resistance to these unrealistic and damaging housing targets) and now assert that greenbelt protection should only be lost in exceptional circumstances and even specifies that ªunmet local housing needs of an area are themselves not exceptional circumstancesº.Yet still the Chiltern and South Bucks Councils have selected beautiful, valued, prime agricultural greenbelt to offer up to developers to build houses upon. This decision is not justifiable. 1.2 Building Unwanted Retail Businesses
9462 Despite relentless infilling developments and the consequential detriment to the quality of life for residents living in Chesham (traffic, parking, GP services, school places, etc), the town is still just managing to retain a strong sense of community and the feel of a rural, county town. Like many other High Streets all over the United Kingdom, shops are failing to compete with digital markets and have been replaced with coffee bars and charity shops. However, one of the main attractions of shopping in Chesham is the wide range of independent, family run shops, e.g. bakers, hardware, health products, jewellers, stationers, electrical goods etc., offering a friendly personalised service which is often superior to that of the larger branded retail chains and is highly valued by many residents who make the effort to patronise local businesses. These shops are supplemented by an excellent market twice a week. Those who wish to visit the larger shopping malls are spoiled for choice: Watford, High Wycombe, Hemel Hempstead and Aylesbury all have large retail malls and parks and, of course, Chesham has a direct route into central London via its tube station. Given the above circumstances, the Local Plan's proposal to dispense with a fully utilised station carpark to create a retail development SP EP3 will not only damage the prospects of small independent retailers by setting up unwanted competition but make shopping in Chesham altogether unattractive due to lack of parking facilities. This cannot be justified. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not 1.0 THIS PLAN IS NOT EFFECTIVE believe this policy to be 1.1 The Proposed Development Site is Too Far from the Town Centre effective please explain why. The green belt land selected for housing development at Lye Green, N. E. Chesham is at least 2km from the town centre - which is situated at the bottom of a very steep hill. Creating cycle paths into the town centre to encourage cycling will not work as only the fittest will attempt a return journey by bike as it will be up-hill for most of the way. Adding another bus stop on the promise of a vaguely outlined, enhanced future bus service is simply risible and cannot be guaranteed anyway. In the current reality, people will use motor vehicles to get around and to plan town developments by pretending otherwise is irresponsible and lazy. 1.2 This Site may not be Deliverable The main landowner of the green belt land at Lye Green, N. E. Chesham is a farmer who has openly expressed his opposition by writing in the local free magazine, Your Chesham, that he is not prepared to release all the land in his ownership for development. 1.3 Funding Deficit This Local Plan has an acknowledged funding gap from the Community Infrastructure Levy (CIL) of between £179m ± £231m. That alone is sufficient reason to deem this Plan ineffective - it is not affordable. 1.4 Infrastructural Issues have not been Addressed Many of the site allocations (including Lye Green - Policy SP BP2) are excluded from CIL and developers (with no mandate to serve the wider needs of the community) will be required to deliver infrastructure directly or make financial contributions to mitigate development impact. However, in their eagerness to meet government housing targets by handing over prime green belt land to developers, the Councils' have neglected to develop ªMasterplansº for each site preferring to green light large developments without giving full consideration to the consequential infrastructural requirements and associated costs. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not 1.0 THIS PLAN DOES NOT COMPLY WITH NATIONAL GUIDELINES believe this policy in I have read the Chiltern and South Bucks Councils' Local Plan and the number of instances where this Plan consistent with the National ignores or even contradicts the National Planning Policy Framework (NPPF) are so numerous I have tabled Planning Policy Framework those I found below to demonstrate just how far this Plan has strayed from Government guidelines. Feb 2019 please explain why SELECTION OF GREEN BELT LAND FOR URBAN DEVELOPMENT NPPF 133: The primary aim of Green Belt land is to prevent urban sprawl and to preserve the openness of the area. Local Plan Proposals/Appraisals: Infill the area between Chesham and Lye Green and pave the way for further urban sprawl by removing the villages of Botley, Ley Hill and Chartridge from green belt protection NPPF paragraph 134: to prevent neighbouring towns and settlements from merging. Local Plan Proposals/Appraisals: Merge Lye Green with Chesham NPPF Paragraph 136: Green Belt boundaries should only be modified in ªexceptional circumstancesº. (Meeting local housing targets do not constitute ªexceptional circumstancesº). Local Plan Proposals/Appraisals: The Councils have not produced evidence of exceptional circumstances to justify the removal of this land from green belt other than to threaten if they don't do it the Government will do something worse. NPPF 96. ªAccess to a network of high-quality open spaces and opportunities for sport and physical activity is important for the health and well-being of communitiesº. Local Plan Proposals/Appraisals: Propose the urban development of green belt land so well used by its local residents it has been designated an Asset of Community Value
9463 NPPF 180 b)º identify and protect tranquil areas which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason;º Local Plan Proposals/Appraisals: Remove greenbelt protection from the rural and tranquil areas around Chesham and its surrounding villages in order to maximise urban development opportunities at the expense of local residents and their environment NPPF 143 states that, ªInappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances.º Local Plan Proposals/Appraisals: Propose housing on wildlife rich, good agricultural green belt land. EXPLORING ALTERNATIVE OPTIONS TO GREEN BELT DEVELOPMENT NPPF 137 a) ªBefore changing Green belt boundaries, authorities should make as much use as possible of suitable brownfield sites and underutilised land;º Local Plan Proposals/Appraisals Ignore the Master Plan drawn up by Chesham Renaissance in consultation with local residents ± a plan which makes as much use as possible of suitable brownfield sites NPPF at paragraph 134 (e) is to assist urban regeneration by encouraging the recycling of derelict and other urban land. Local Plan Proposals/Appraisals The Councils have not produced sufficient evidence to demonstrate that they have given careful consideration to derelict and brownfield sites POLLUTION NPPF 148. ªThe planning system should support the transition to a low carbon future in a changing climate. It should help to: shape places in ways that contribute to radical reductions in greenhouse gas emissions.º Local Plan Proposals/Appraisals: CSA N87. ªProposed development within Local Plan is likely to increase the Plan area's carbon emissions by 21%º. NPPF 170 e) says: ªDevelopment should, wherever possible, help to improve local environmental conditions such as... water quality.º Local Plan Proposals/Appraisals: CSA N60: ªNone of the potential Green Belt removal locations are anticipated to have a positive effect on water quality due to the significant increase in demand on water demand and treatment facilities. Water pollution may also be of concern.º NPPF 181. ªPlanning policies and decisions should sustain and contribute towards compliance with relevant limit values or national objectives for pollutants, taking into account the presence of Air Quality Management Areas.º Local Plan Proposals/Appraisals: Councils Sustainability Plan N58, N87). N98 table N4 ªThe Local Plan is anticipated to lead to a reduction in local air quality with implications for human health.º Please note that Chesham has an Air Quality Management area. ENVIRONMENT AND BIO-DIVERSITY NPPF 171 ªplans should: safeguard components of local wildlife-rich habitats.º Local Plan Proposals/Appraisals: CSA N86: ªdevelopment is likely to result in a direct loss of habitat links.º NPPF 2.8c) ªan environmental objective ± to contribute to protecting and enhancing our natural environment; including helping to improve biodiversity NPPF 174 a ªPlans should protect and enhance biodiversityº Local Plan Proposals/Appraisals: CSA N56: ªA significant potential issue to be considered for Green belt locations is the fragmentation of habitats following development, reducing the connectivity of habitats.º Earlier objections citing the wide range of bio-diversity in the area (including areas of Biological Note) and the red listed species spotted there were ignored. NPPF 170: ªPlanning policies and decisions should contribute to and enhance the natural and local environment by: a) protecting and enhancing¼.. soilsº Local Plan Proposals/Appraisals: CSA N91 ªA significant quantity of development is proposed by the Local Plan, a large proportion on greenfield sites where it is expected that new buildings will result in the direct loss of the soil resource. The loss to BMV land would reduce the quantity of the most productive and flexible agricultural land that can best deliver food and non-food crops for future generations.º Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5501071 Please attach any supporting evidence
Person ID 1221299 Full Name Mr Brian Gregory ID 2953 Order 236 Number 11.3 Title Policy SP BP2 - Chesham
9464 Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible.
9465 Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The loss of Green Belt in the Ley Green area not believe this policy to be The loss of a unique local village being absorbed into "Greater Chesham". positively prepared please explain why The additional pressure on our already overcrowded roads with people negotiating the 2.5 km and steep hill. The above also creating more pollution and an increase in the carbon footprint by 21% The proposal to remove villages from Green Belt and to permit in filling development within these villages The proposal to build 120,000 sq feet of new retail opportunities on the car parks that currently serve the town centre It does not provide more affordable homes in sustainable locations nearer the town centre PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
9466 Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1221308 Full Name Donna Joce ID 2943 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness?
9467 Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I am writing as I am against the proposal which the Council are recommending regarding a development of not believe this policy to be many houses on green belt land in an area which has...... A serious traffic problem positively prepared please Lack of resources and amenities explain why Pollution problems Many areas of outstanding natural beauty Flooding issues which would clearly be much worse with the proposed concrete bases/roads Noise pollution for the surrounding villages e.g 500 mowers, cars etc. 1000 extra cars traveling to and from work and shops gyms etc. at least 3000 vehicle . movements a day ! Lack of jobs locally Sewage issues, can©t cope now with the river pollution/overflowing Overhead electric cables in the villages are unreliable now
9468 Walkers using the proposed areas for recreational use dog walking, horse riding etc. Lack of footpaths Narrow lanes leading out of the surrounding areas Wildlife !!! Many many more reasons why these developments cannot happen in these beautiful areas. A development like this is more suited to an industrial area which is run down/derelict near to main roads/motorways I have just noticed that Policy SP BP 2 may not be legal ? After all it is an Asset of Community value ! Is this all legally compliant or sound . PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1215329 Full Name Mr Trevor Brawn ID 5181 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-12-12 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of:
9469 Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is
9470 incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I do not consider the Local Plan to be legally compliant because of proposal SP BP2 which is a 500+ housing not believe this policy to be development on the outskirts of Chesham, within the Green Belt, and in an unsustainable location, positively prepared please approximately 2km from the town Centre and at the top of a very steep hill. explain why The Government's National Planning Guidance Framework has been ignored numerous times as indicated in more detail later in my response. The Government's Planning Policy Guidance states that a local authority may not choose to develop Green Belt land simply to meet its housing allocation needs, without first exploring all other options. There is no indication that all other options have been appropriate explored. There are new measures introduced in the Local Plan which have not been consulted on previously. For example the development of a significant amount of new retail area with what appears to be a reduced town centre car parking area The Council do not appear to have consulted all of the neighbouring local authorities with regard to the housing allocation. The Sustainability Appraisal details the adverse impacts of SP BP2 but does not identify ways to make this proposal `sustainable'. Furthermore, it indicates that the carbon footprint would rise to 21% (I understand this has been subsequently revised down to 17%) Before SP BP2 could be approved by the Inspector, the Council would have to indicate where they would provide additional green open space in close proximity to the existing area, to adequately compensate local residents for that lost if the development went ahead. I do not think the Council has addressed this issue. SP BP2 is now also within an `Area of Community Value' and it seems likely this would have a significant bearing on whether the site is deliverable, even though that safeguard may only last for 5 years. The Sustainability Appraisal indicates that SP BP2 is not sustainable. The Government's appointed Planning Inspector has the power to reject this proposal because the Plan should be ensuring a more sustainable approach is found for our Community. The Government's own target for carbon emissions by 2050 is zero, yet this 20 year plan proposes taking our community to 2036 with emissions at 17% (previously 21%), leaving a reduction to zero within a period of a further 14 years. It is not clear that this is even remotely possible, unless this plan takes a far more sustainable approach to development at this stage. Eco houses can now be constructed to give zero carbon emissions and the plan should reflect this necessary criteria. Extinction Rebellion is calling for a reduction of carbon emissions to zero by 2025, only 6 years away, and there is a growing number of people and organisations who recognise our government is not responding appropriately to their declared climate emergency. We must do far better within the new local plan. It is not fair for our local council to inflict on our community such a poorly thought through housing proposal for the Chesham area. Even if SP BP2 did not involve removal from the Green Belt, which I and many others oppose, the site would still be equally unsustainable. I do not believe that SP BP2 meets our community's needs and it is clearly inconsistent with achieving sustainable development. The Sustainability Appraisal indicates that SP BP2 will increase the Town's carbon footprint by 21%, or 17% depending which assessment is accurately prepared. This would be a tragedy for our caring community when, with a more strategic approach with development in and close to the town centre, as outlined by CRCIC and BNG we have a chance of reducing our carbon footprint with quality building designs. This
9471 strategy received 70% support by those who responded when the local community was consulted by CRCIC about their proposals. I do not regard SP BP2 as well located in a Green Belt area at the top of a steep hill, on the edge of Chesham, approximately 2km from the town centre. It is not a sustainable development as the Sustainability Assessment indicates a carbon footprint increase of 21% (or possibly 17%) from this development. The Council has not worked with the support of the Community to meet housing needs in a sustainable way. SP BP2 is in an existing open space which is clearly valued and well used by the local community, as detailed in the BNG submission. It cannot therefore be regarded as surplus to requirements. Creating a 500 house development will release substantial amounts of carbon into the atmosphere which is currently locked up in the soils on the site. The existing open space has now been officially designated an Asset of Community Value. Because of the location of the SP BP2, very high up above the Town Centre, it is likely that only a very few trips into the Town centre from such a development would be made on foot, or by bicycle. Even if the bus timetable was significantly improved, it seems likely that only a small % of people from the proposed development would use the bus in preference to using their own vehicle. The full impact of this has not been adequately addressed within the Local Plan. There is no indication of any environmental gains as a result of this development and it clearly will not contribute to making a high quality Chesham. Having the new houses in and around the town centre actively promotes sustainable transport systems and reduces the town's carbon footprint. I do not think SP BP2 is focussed in a location which can be made sustainable, and there is very limited scope for any alternatives to travelling by car because it is at the top of a significant hill and 2km from the town centre. Focussing the development needs closer to the town centre significantly increases opportunities for a genuine choice of sustainable transport connectivity. I do not accept that the Local Plan contains policies to optimise the use of land to meet as much of the housing need as possible in other parts of the Town Centre. The Government guidance clearly states that planning applications should be refused for failing to take account the Policies in this framework and it appears our District Council is actively encouraging the provision of an area of land which fails to meet all of the elements of the guidance in this section. The Council must consider opportunities like those presented in detail by CRCIC in order to meet our housing needs in a sustainable way. I do not regard the Plan as doing anything to promote outstanding or innovative design promoting high levels of sustainability. Our community want a more sustainable housing policy to be delivered by the Council. We have this opportunity now to make a big difference and we have to take it. I do not believe the plan to be positively prepared as the selected site at Lye Green is unsustainable. The Sustainabilty Appraisal reaches the same conclusion and does not offer any justification for the choice of this site. Moving the additional housing needs to the Town Centre and close to the Town centre can be the only sustainable option. Moving the new housing units within and close to the Town Centre would meet the requirements providing the design criteria included the latest technology for reducing the carbon footprint, included higher rise units and encouraged non- car ownership. This plan must retain at least the same amount of car parking close to the High Street or provide free transport from a new community transport hub. I do not expect SP BP2 to be deliverable because of constraints to development of the land, including the recent decision to designate the land as an Area of Community Use. My view is that the Council has not taken account of our communities' needs in Chesham, has not presented development proposals that will improve the quality of our lives and has not protected our valued environment. I understand the need to have an approved local plan as it will dictate what happens in our area until 2036, but we have to ensure that it is sustainable and sets an excellent example to other authorities by having sustainability at its core, reducing our carbon footprint, valuing green open spaces and making Chesham an even better place to live. We need to make Chesham a walking and Cycling town, not a stationary queue of traffic. Valuing Nature Wilding by Isabelle Tree is a book which highlights the `value of nature'. In pages 291 to 302, Isabella eloquently details the adverse impacts of developments like SP BP2 on green space and, in this case, Green Belt land set up to maintain the openness of such an area. Green Belt areas, such as the SP BP2 provide a sense of peace and tranquillity and play an important part in helping to relieve emotional stresses. They also soak up pollution and reduce climate change by locking carbon within the soil. Community Infrastructure Levy (CIL) There appears to be a major funding gap between what the Council needs in order to provide new infrastructure and to improve existing infrastructure. However the gap is also shown with huge possible variations. It is perhaps not surprising that the gap is unsustainably large if the Council does not have an effective way of collecting the appropriate CIL from developers. SP BP2 would be subject to a S106 agreement but the plan does not indicate in any detail what the developer would need to provide for off-site contributions. In times of high groundwater, our failing sewers pass more flow to the sewage treatment works in Chesham. It does not have the capacity to cope, so much of the sewage ends up being discharged into the River Chess.
9472 We need our Utilities together with money from the CIL and S106 agreements to find ways of ensuring this cannot happen by improving our sewers to stop groundwater infiltration. Sustainable Transport matters Air Quality management area. The existing monitored area in Chesham is set to gather readings at a high level and failing to measure the levels at push chair level where young children are at their most vulnerable. Reducing Reliance on the private motor car is essential. Policy DM DP9. CRCIC can do this SP BP2 cant. The concerns of the potential increased traffic in Chesham resulting from SP BP2 and the increased pollution resulting in an even further worsening of air quality in and close to the Town Centre, particularly along the Berkhampstead Road are highlighted within the Sustainabilty Appraisal (SA). There are no proposals put forward to demonstrate that this matter is being addressed. SP BP2 would be in close proximity to an existing school and would clearly therefore increase risks to all of the children, and particularly those that have breathing difficulties already, including asthma, which is on the increase. Our local plan, and all local plans, should include positive messages promoting the `switching off' vehicle engines when they are stationary in a queue of traffic for even less than the legal limit of 2 minutes (Highway Code). The queueing of cars towards Chesham Town Centre is a daily occurrence. There is a scheme being trialled in part of London where members of the public take a photo/video of a vehicle where the drivers fails to turn off the engine when stationary. They submit this evidence and repeat offenders will be fined. This should be rolled out across the country as soon as possible. The plan lacks any safeguards to conserve the aquifer to get our River Chess flowing again. Focussing development in and around the town centre is crucial for sustainable development. Redeveloping the Town Centre with well designed higher rise blocks and at a denser rate on Brownfield sites as a priority, should ensure more residents do not own cars and that car sharing schemes and alternative forms of more sustainable transport can be utilised. Emissions from stationary vehicles have been shown to be twice that of moving vehicles. Climate Change and flood risk The evidence for climate change as a consequence of increasing carbon emissions is growing all the time. It cannot be coincidence that the 10 warmest years on record have occurred in the last 16 years. Glaciers are melting at an unprecedented level, sea levels are rising, flooding is become more severe, droughts are becoming more prolonged. The evidence is on the news nearly every day. Our River Chess, a precious Chalk stream is dry through the town the vast majority of the time. Groundwater levels are at a record low again now due to abstraction. So we need a plan that encourages people to use less water and publicity campaigns to ensure it happens. 30 years ago Mrs Margaret Thatcher gave a speech to United Nations calling for them to unite to stop climate change but little heed was taken. However there is a groundswell that now believe we must force the Government's hand to take more action by appropriate people power. Extinction Rebellion are doing a good job raising awareness. We have our own Chesham branch which are looking at how they can achieve changes from the bottom up. The Inter-governmental conference on climate change agreed we should become carbon neutral by 2030. Extinction Rebellion say 2025. The Government which recently declared a climate emergency is still saying 2050. We need a plan to reduce our carbon emissions as quickly as possible, ceasing every opportunity. Expansion of Heathrow to facilitate more flying indicates the Government concern is business led, not climate change led. One of the Town's greatest assets is The River Chess, a prized chalk stream habitat. Due to a combination of over abstraction and climate change our river has been dry in Chesham for 27 of the last 32 months. No doubt more detailed evidence will be supplied by the River Chess Association. Recently the plight over our Chalk streams has been discussed in Parliament and a document entitled `Chalk streams in crisis' has been produced. These chalk streams have a special status which means they are protected. It can reasonably argued that a chalk stream is not a chalk stream unless it has flowing water from the chalk aquifer. Our ground water levels are very close to the lowest they have ever been, yet the Council is prepared to promote a further 500 homes in an unsustainable location without including very special measures to reduce the amount of abstraction from the aquifer. It is possible to substantially reduce the domestic water usage in existing homes and implement much better systems in new housing units to harness rain water for grey water uses. This should be a planning requirement of new building. PP Mods - Please specify as If we are required to have 500+ new homes in the Chesham area, the plan needs to be modified to include precisely and succinctly as the potential development of up to 500 new homes in Chesham Town Centre, or very near to the Town possible how you would Centre (within a 750 metre radius say), over the 20 year plan. modify this policy to improve This is the only sustainable solution that provides an opportunity for substantially reducing the town's carbon its alignment to this test of footprint. soundness. It would also have the huge benefit of reducing car movements as public transport would then be readily available to many other local towns and into London. More people would be able to avoid owning their own vehicle, reducing congestion and ensuring that the already dangerously high vehicle emissions in and close to Chesham Town Centre are not further increased by development away from the town centre which will inevitably lead to more use of cars travelling into the Town Centre, more congestion and more consequent pollution. The Council should also be promoting other simple measures such as the creation of more dual cycleway and footways on quieter routes through the town creating a safer and healthier environment, and further reducing car movements on the main roads through Chesham.
9473 A detailed proposal has already been prepared by Chesham Renaissance Community Interest Company (CRCIC) and is also reflected in the submissions by BrownNotGreen (BNG). Both of these groups have qualified planners as part of their team. They know Chesham and know what a large proportion of the town's residents have already said they want for our Town. I support the broad aims of these two groups to include the housing allocation in and close to the Town Centre. It seems likely that the planners who prepared the Local Plan were not local residents and did not therefore know enough about our local community to make appropriate judgements about what is reasonable and likely to be acceptable. Re-development of our town centre on brown field sites must include housing units built to higher rise and greater density, incorporating the latest ecological advances to reduce our overall carbon footprint. This should be clearly stated in the plan. I am sure a similar, but more detailed strategy will be presented by our local interest groups CRCIC and BNG. This alternative strategy is also broadly supported by the Chilterns Green Party. A proposal based on this alternative strategy could make the plan legally compliant. This outlines almost exactly the strategy which I believe should be applied to Chesham to meet its housing allocation. This guidance is reflected in the CRCIC plan and what BNB have been saying. It appears our District Council has just ignored this guidance and should be asked to re-think their proposals for Chesham. Re-developing Chesham town centre can provide the greater proportion of the housing needs and could boost the attraction of Chesham by making it eco- friendly, incorporating all of the latest technology for reducing our carbon footprint, including establishing green roofs. Policy 1 - If you do not I believe the Council's plan to site SP BP2 in the Green Belt is totally unjustified when it has been shown to believe this policy to be the District Council already that CRCIC plans have widespread local support and can achieve most of the justified please explain why additional housing required within the plan period. I believe the Local Plan is fundamental flawed in selecting SP BP2 for a major housing development. The Council has failed to show that it has examined fully all other reasonable options for meeting the identified need for its housing allocation. It has failed to show that the Plan makes as much use as possible of suitable brownfield sites and underutilised land and optimises the density of development in line with the policies in chapter 11 of this Framework, including whether policies promote a significant uplift in minimum density standards in town and city centres and other locations well served by public. The Council has not demonstrated any other considerations which could justify their choice of SP BP2. I do not think the proposals are justified as there aren't any detailed alternative proposals put forward by the District Council, so it lacks the proportionate evidence to support the Council's proposal. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not There is no evidence to show that all of the surrounding planning councils have been consulted to see if they believe this policy to be may take some of our housing allocation. Cross-boundary agreements should be the first option for our effective please explain why. District Council. There are reservations about whether SP BP2 can be delivered. I understand that the site may be owned by an off-shore company that might at best be hard to trace. If the land owner is not prepared to release the land necessary, the proposal seems unlikely to be deliverable. BNG have done extensive research and it is quite clear that the whole area of the proposed development, not just the public footpaths, has been used by local residents extensively for many years and possibly in some cases over the 20 year threshold. I am pleased they have now succeeded in winning their case to have the land declared an `Asset of Community Value' which clearly it is. As I understand it, this provides an opportunity for the land to be bought by a local consortium if necessary, within the next 5 years to protect it from an enormous unsustainable residential development. I support the fundamental principles of BNG to ensure there is no development in the Green Belt at SP BP2. I hope this will add to the justification as to why the site should not be removed from the Green Belt and increase the possibility that the site is not deliverable. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not No. I do not believe the Local Plan is consistent with national policy nor do I believe it enables the delivery believe this policy in of sustainable development. I do not therefore believe this plan meets the tests of soundness. consistent with the National There are a considerable number of sections within the NPPF that steer SPBP2 away from the chosen Planning Policy Framework location in the Green Belt Feb 2019 please explain why The following paragraphs have been copied to demonstrate the lack of regard which the plan has for NPPG. Whilst it may only be guidance, the Government clearly expects it to be followed unless there is very got reason not to. I do not believe any such justification has been provided for such a wholesale ignoring of the guidance.
9474 The plan does not: i) respect the Green Belt ii) seek to protect and enhance our local environment iii) improve biodiversity iv) include mitigation and adaption to climate change, including moving to a low carbon economy. I do not think that the Local Plan consultation has acceptably met the `Duty to Co-operate' with local residents because it has included the following: a) removing a large area of land in the Green Belt for a mixed development near Chesham and around the various villages local to Chesham b) Large shopping complexes in the Town Centre two of which appear to be on existing car parks serving the town centre. c) A reduction in Town Centre Car Parking cannot be justified when all of the Town's car parks are very full at busy times. These proposals were not presented in the previous consultation phase. It is therefore appropriate to say that the current consultation version has not met the Duty to Co-operate. It seems that the comments of individuals and local interest organisations have been disregarded in favour of removing land from the Green Belt to allow an unsustainable housing development right on the northern edge of the town at Lye Green. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1215469 Full Name Mr Giles Ellerton ID 4442 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Regional Partnership Director BT Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2017-11-07 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible.
9475 Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the
9476 examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I would like to express my concerns that the Regulation 19 Local Plan to build 500 houses on Green Belt not believe this policy to be land northeast of Chesham is neither legally compliant nor sound, for the following reasons: positively prepared please The Local Plan has an acknowledged funding gap of between £179m- £231m from the CIL for infrastructure. explain why This fact is of huge concern to myself as a resident of Chesham since 2010, and owner of a house on Lye Green Road opposite the greenfield site since 2012. The infrastructure of the town is already under stress and in need of reinforcement/expansion, so the idea of increasing the number of houses by 500 at this site (with the increasing population that will come to live in those homes) is a massive problem in terms of catering for health needs for local GP surgeries, local school places, heavy traffic on the roads (and the increased carbon footprint ± air pollution that will result), sewage systems that are already under strain and inadequate water supplies. With reference to Policy SP BP2: We live in a stressful world where mental health, physical wellbeing and the importance of community are increasingly important issues. Over the seven years that I have lived opposite the Lye Green greenfield site, I have observed many locals regularly using the fields to walk alone, with friends and family, or with dogs, to jog, to get into or out of town on foot and generally to enjoy the peace and space provided there. Important and rare wildlife and plants have been observed in the fields. A neighbour who lives in a house that backs onto the field on Lye Green Road reminded me of a large clump of clover growing on the field and the fact that we need to protect these wild plant species for pollination. I have noticed an abundance of different butterflies over the past months too. In seeking to remove the Lye Green fields from greenbelt status, the Local Plan flies in the face of its own policies to protect biodiversity and wildlife habitats. The site has recently been awarded the status of Asset of Community Value. It is evidence that the community has used the area, unfettered from land owners, planners or developers to enjoy. I would question whether therefore it is therefore justified or in accord with NPPF to allocate the land NE of Chesham for housing when for decades prior to its award, the land has been used for recreation, and the enjoyment of local residents. The environmental impact on this green belt area would mean that all this biodiversity would be lost. The added impact of traffic build up into Chesham means that pollution from cars and houses would be channelled down White Hill into the town centre. Many students currently walk up White Hill to Chesham Grammar School located at the top of White Hill, and are already subjected to car pollution. There are no plans to mitigate the inevitable traffic build up from such a site located outside Chesham, and too far for most to consider walking into town for an onward journey. The Local Plan currently predicts that the carbon footprint would be increased by at least 21%, and there is little or no evidence that mitigating such an increase will be delivered or will be effective. Far from creating a bigger footprint, our communities should be aiming to reduce carbon footprint through low / no use of fossil fuels, and making use of green energy. It is clear that situating a community of 500 homes with little / no public transport planning, and an overuse on private vehicles runs in the face of planning policy to minimise carbon footprints. In summary, the Lye Green greenfield land is unsustainable because it lacks the necessary infrastructure to support it, is located too far from the town centre to be accessed on foot ± so the increased carbon footprint that will result from extra traffic to and from the site will increase traffic congestion and further pollute the air quality, which is already a concern. Building on the Lye Green land will destroy existing wildlife habitats and biodiversity, and also threaten the health of our precious and increasingly rare chalk streams. Furthermore, it will deprive the local population of a much-valued community asset, where for years people have sought relaxation and exercise. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
9477 Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5501557 Please attach any supporting evidence
Person ID 1221351 Full Name Mr Adrian Bathurst ID 3054 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness?
9478 Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The Councils have stated that release of some Green Belt is necessary as part of an overall three part not believe this policy to be strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported positively prepared please proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where explain why sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. I question the soundness of such a general policy and whether all the brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites and in particular the Green Belt site NE of Chesham at Lye Green. The development of such Green Belt sites involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient and unfunded. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity.
9479 Chesham cannot accommodate any significant highways improvements anyway due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion, with further worsening air quality. Air pollution is a particular concern in Chesham due to the already poor air quality along Bekhampstead Road where there is a designated Air Quality Management Area that already is recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will generate more traffic will make the air quality even worse and insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable nor justified nor is it in accordance with Govt policy. The Green Belt site NE of Chesham (SP BP 2) is not a sustainable location. It is over 2Km away from the train station and slightly further still from the town centre but anyone who cares to walk or cycle this distance also has to negotiate a steep hill too. Such an unsustainable location cannot be made sustainable merely by upgrading a couple of public footpaths within the site into bridleways to facilitate cycling. Neither does adding a bus stop address the geography or topography of the area especially if the promised enhanced bus service (which is already infrequent) either does not materialise or if it subsequently fails to be maintained after a few years. Further doubt is cast upon the ªsoundnessº of this Plan by virtue of there being conflicting policies within it. The Council seem to think that the Green Belt site NE of Chesham is sustainable and provides easy access to public transport including the tube station yet the same Plan promotes a considerable increase in retail development in the town (local draft plan policy SP EP3) , part of which would be built on the very car park that serves the Chesham tube station. This is inconsistent and unsound. The land is also potentially an Asset Of Community Value and upon confirmation of this designation it would afford a community group the right to bid for the land. The community group (Brown Not Green) have stated their intention is to preserve the land given that many hundreds of local people have habitually used the fields at Lye Green as of right for various informal outdoor recreational purposes. These uses themselves may mean that many local individuals may have acquired easements over and across the land through prescription (20 years uninterrupted use) not least of whom would be the many private residences bordering the fields that have rear garden gates onto the fields at Lye Green. These easements and prescriptive rights may render the land very difficult to develop and make i undeliverable in planning terms. This land also provides an important habitat for wildlife that will be threatened by development of this land. It is perverse that the Local Authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Plan is unsound. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not For this Plan to sound it must also be effective. Unfortunately, further review of the proposal to remove land believe this policy to be NE of Chesham at Lye Green from Green Belt designation is not effective as there are serious questions effective please explain why. about the deliverability of this land. The main landowner is a farmer who has asserted publicly and in a letter to the editor of Your Chesham, that he is not prepared to release all of the land in his ownership for development. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not The foregoing also points to flawed methodology of Green Belt site selection used by the Local Authority, believe this policy in which is neither effective, justified nor consistent with national policy and as such is unsound. Specifically, consistent with the National the selection of the land NE of Chesham at Lye Green (policy SP BP2) for removal from Green Belt designation Planning Policy Framework is inconsistent with National Planning Policy Framework (NPPF). Feb 2019 please explain why Paragraph 136 of the latest NPPF asserts that Green Belt boundaries should only be modified in ªexceptional circumstancesº. The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances. The Council engaged third party consultants to undertake the Part 1 Green Belt assessment and they identified numerous sites for ªfurther considerationº where exceptional circumstances ªmightº exist but expressly recommended further review of their assessment of each site against the 5 purposes of land being in Green Belt of all these sites. Unlike the neighbouring Local Authorities, the Part 2 Green Belt assessment was not undertaken by third party consultants but by the Local Authority itself who notably then did not undertake all the recommended reviews of each site including the land NE of Chesham at Lye Green (SP BP 2). Accordingly, this oversight in the Part 2 Green Belt assessment placed premature
9480 focus and fixation on releasing land at Lye Green NE of Chesham from Green Belt designation. The subsequent identification of the Chesham site for release is therefore unjustified. The primary aim of Green Belt land (as recited in NPPF 133) is to prevent urban sprawl and to preserve the openness of the area. The Lye Green site (SP BP2) self-evidently performs this function well and has done so for decades. Another aim of Green Belt land stated in NPPF paragraph 134, is to prevent neighbouring towns and settlements from merging into one another.The Green Belt land NE of Chesham performs exceptionally well in maintaining a distinct separate between settlements of Chesham & Lye Green as well as helping to maintain separate identities of other nearby communities at Orchard Leigh, Botley, Whelpley Hill, Ashley Green. It is perverse and inconsistent with national guidance to allocate this land for removal from Green Belt in light of these facts especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if earmarked for development. A further aim of Green Belt designation stated in the NPPF at paragraph 134 (e) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. By allocating Green Belt land NE of Chesham for development, undermines this aim within Chesham. A community lead not for profit organisation called Chesham Renaissance CIC has been striving to create Chesham Masterplan that would not only provide many genuinely affordable homes in more sustainable locations nearer the town centre, but which would also regenerate some of the more deprived wards within Chesham. The Local Authority's proposals (policy SP EP3) are inconsistent with this local initiative and are therefore also inconsistent with national guidance and are consequently unsound. The Council have asserted that Government planning policy requires local councils to review Green Belt boundaries when considering how to accommodate the development needed in their areas. Just because the Council may be required to look, does not mean the Council should review Green Belt boundaries which as previously stated should only be modified in ªexceptional circumstancesº. National Planning Policy Framework (NPPF) as revised only last year, states in paragraph11 (b) I, directs ªplan makersº to create policies that are required in Local Plans for housing and other uses unless Framework policies (expressly including Green Belt) ªprovides a strong reason for restricting the overall scale type or distribution of development in the plan areaº Accordingly, I submit that given all of the above the land being proposed for release from Green Belt designation around Chesham is unjustified and contrary to national guidance. I am supportive of the Brown Not Green organisation's initiative to have the Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1216603 Full Name Chris Padley ID 4891 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Environment Agency Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant.
9481 Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as
9482 precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do We believe that this policy has been positively prepared. not believe this policy to be positively prepared please explain why PP Mods - Please specify as NA precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not NA believe this policy to be justified please explain why Policy 2a - Please specify as NA precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not Please note that this site is partially within a Source protection zone (SPZ) 3 for groundwater protection and believe this policy to be is adjacent to historic landfill sites. Appropriate groundwater protection measures will need to be incorporated effective please explain why. into the design and construction of any development. Please be aware that additional investigations will be required at the planning stage. Remediation may also be required in certain cases if sites are shown to be causing pollution. Historic landfills can also have issues with land stability and gassing which should be taken into account when undertaking risk assessments and in this case allocating sites. PAa - Please specify as We would like to see the below amendment to point j in the policy: precisely and succinctly as `j. a comprehensive Landscaping Scheme to include: possible how you would modify this policy to improve i. the retention of characteristic views across the site; its alignment to this test of ii. the conservation of the existing woodland blocks, trees and hedgerows; soundness. iii. mitigation and enhancement to provide biodiversity net gain, including orchard planting, native woodland planting and a strong planted edge adjacent to the open fields' Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1221398 Full Name Dr Gordon Keenay ID 3078 Order 236 Number 11.3 Title Policy SP BP2 - Chesham
9483 Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible.
9484 Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
Policy 1 - If you do not Please note that we are supportive of the Brown Not Green organisation's representations in relation to this believe this policy to be Local Plan. They have made a much more detailed and professional study of the relevant statutes, case justified please explain why law, compliance failures and lack of soundness of this plan and their representations contain all of the necessary references. Please take the whole of our response as being in agreement with their response and incorporating the detailed references that they have provided. Our response here gives emphasis to particular areas of concern. Local Authorities are supposed to demonstrate that they have exhausted all other options before considering the revision of Green Belt boundaries. This Local Plan is seeking substantial modifications to Green Belt boundaries including the reckless removal of Green Belt designation of many areas within the Districts and modifying the Green Belt status of local villages without any comprehensive or convincing demonstration that all other options have been explored. We therefore consider that the Plan is not justified, sound or in accordance with National Policy and as a result not legally compliant. Policy 2a - Please specify as The Plan should be modified by wider co-operation with other nearby authorities which may precisely and succinctly as result in further housing needs being taken elsewhere. possible how you would modify this policy to improve A more detailed and genuine appraisal of brownfield land opportunities should be undertaken and other its alignment to this test of options for housing delivery explored (such as Chesham Masterplan by CIC Chesham Renaissance). soundness. This would much reduce or even eliminate the need to de-classify precious Green Belt land. Policy 2 - If you do not believe this policy to be effective please explain why.
9485 PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5511826 Please attach any supporting evidence
Person ID 1221538 Full Name Mrs Margaret Hildreth ID 3372 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its
9486 legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as The Plan needs to be modified by; precisely and succinctly as
9487 possible how you would Co-operating with other nearby authorities. Not just Aylesbury. It is simply unsatisfactory to assert this cannot modify this policy to improve be done because they are different Functional Market Areas and that co-operation is not necessary therefore. its alignment to this test of Exploring such wider co-operation may result in further housing needs being taken elsewhere. soundness. A more detailed appraisal of brownfield land opportunities MUST be undertaken. Some brownfield opportunities have been ignored or missed. Closer scrutiny of alternative options for housing delivery should be explored (such as Chesham Masterplan by CIC Chesham Renaissance). Green Belt boundary reviews should only be considered AFTER all other reasonable alternatives have been exhausted. In the face of NPPF guidance and a more thorough appraisal of Green Belt sites being considered, it may then be necessary to conclude that it is not possible to identify poor performing Green Belt sites that can accommodate all the OANB for housing. Consequently it may be necessary to accept that a lower housing provision figure is appropriate. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5497994 Please attach any supporting evidence
Person ID 1221625 Full Name Margaret Barber ID 2613 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name
9488 Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination
9489 Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The proposals to release Green Belt land is solely, agreed there is no reason to meet housing targets from not believe this policy to be the evidence submitted. There is a need for better use of the existing properties be they housing, shops, positively prepared please offices, warehousing or factories. explain why The Councils have stated that release of some Green Belt is necessary as part of an overall three part strategy involving: (1) focus on built-up areas to build dwellings on previously developed land. I Ask:- ªWhat does this really meanº (2) an exported proportion of housing need to go to the Aylesbury District. I Ask:- Aylesbury is twenty miles away from Chesham and there are lots of green fields in -between (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt I state:- If you dig it up it won't grow back or If you build on it you will destroy it. Or When it's gone, it's gone I question the soundness and reasoning of adding to the enormous stain experienced by today's population of Chesham at times we already experience traffic journey time dating back to the turn of 1900 when we only had one horse power and you want to add considerable more house power, more Homes, shops requiring delivery vehicles of all sorts onto Chesham limited road network and infrastructure. The sewerage works can't cope at times and when we have thunderstorms the drains overflow. Why take the green belt it's the only area that's available for us all. Why just because you might be rich and able to live in great houses in say, Gerrard's Cross, Chesham Bois, Denham should these areas not be fully considered for in-fill. One house in these areas has a footprint that if developed might accommodate ten or more houses of the size proposed for Lye Green. These in-fills would allow for no change to the green belt, for are these existing properties classified as brownfield land do they not offer opportunities for the higher densities of development that is being offered to the ª working classesº or the social housing class. Such sites would not require any road infrastructure improvements as the roads are so quite. What is the rush in destroying the green belt or other properties? Why not calculate the council or business rates/tax on a weekly bases and with proper enforcement. Any and all empty or under used properties be they second homes or just empty for any reason should and would face an additional charge by placing a zero on the end of the weekly charge, this charge would apply, until the property is sold, let or demolished for redevelopment. Empty properties and lived in and the authorities would generate additional badly needed income. I.E. a band `D' (just for calculation and demonstration) weekly charge of £52.00 but for an underused property the weekly charge would be £520.00 at £6240.00 per year not many properties would be empty for long. I understand there is a discount formula in operation but no property in today's climate should be empty. Chesham cannot accommodate any significant highways improvements due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion adding to climate change and with further worsening air quality. Who will be asked to pick up the bill for all the required infrastructure changes and alterations? Well surprisingly it's the existing residences the tax payers. As one of these I don't want the green belt dug up and I don't want to subsidise the fat cats of the building industry. Stop selling any more social houses and if ex-social housing is for sale take it back for social housing. That why it was built and paid for out of our taxes in the first place. It's our green legacy to our future children and their children. Chesham is not a sustainable location for this sort of infrastructure development. Chesham might at the end of the Metropolitan line, but it's not London. As anyone who is fit enough to walk or cycle around Chesham will tell you it has some very steep hills but overall there are limited safe roads. They are narrow and with parked cars either-side mostly with one wheel on the pavements the town is getting smaller. One takes one's life in ones hands just to walk down some streets so how merely by upgrading a couple of public footpaths or bridleways is going to facilitate safe cycling. What will 900 additional cars, lorries or busses do for road safety in Chesham. So Chesham might be getting a new, promised enhanced bus service. Heard that one before but the busses were lost on cost grounds. But it will probably never materialise and if it does it won't last.
9490 I object to any further green belt being taken for any reason from the people, in this case we that are Chesham residents. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1221751 Full Name Ann Cox ID 3376 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider
9491 the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to
9492 Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible
Policy Level - PP - If you do Suggestions that to develop green belt is rediculous, chesham is a small market town and not geared for not believe this policy to be over more 500 houses. We have asmall train station which couldnt cope with all new residents wishing to positively prepared please explain why go to London etc., also where would they be able to park as most people these days have at least two cars. The bus service we have is inadquate and the roads around will hardley be able to accmodate to say nothing about schools, doctors etc.,congestion and plollution. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1219284 Full Name Mr Bertan Duducu ID 3453 Order 236 Number 11.3
9493 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible.
9494 Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Following careful consideration of the above, I am forced to conclude that the council©s Local Plan will cause not believe this policy to be harm to the wider town of Chesham and is unsound. Specific areas of concern include: positively prepared please - loss of Green Belt around Chesham with all of the environmental implications explain why - more traffic congestion and worsening air quality in Chesham - Loss of land with Community Value in Chesham which supports wildlife and recreation - Outward sprawl of the town which will result in Lye Green becoming part of ©Greater Cehsham© - Failure to recognise an opportunity for urban development and regeneration PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not I am concerned that the many hundreds of proposed homes will generate increased traffic and its attendant believe this policy to be air pollution, already at alarming levels in the Chesham area. The designated Air Quality Management Area justified please explain why along Berkhamstead Road is already recording air quality that is considerably worse than EU safe levels. The council©s proposals are inconsistent with Local Plan Policy DM DP5 relating to ©climate responsive development© and policy DM DP9 ©reducing reliance on private cars© and DM DP15 ©BLue Green infrastructure©. The council©s wilful failure to take these into account will only make things worse and cannot be justified under recent national government policy.These considerations alone should be sufficient grounds to reconsider the entire draft local plan which is unsound in this matter. there are suggestions of mitigating the air quality but where is the proof these measures will be delivered or that they will work? The Green Belt site NE of Chesham is over two kilometres from the underground station and Chesham town centre and is therefore an unsustainable location. The council seems to think that the Lye Green site is sustianble and provides easy access to public transport including the underground station , yet the same local plan promotes a considerable increase in retail development in the town (draft local plan policy SP EP3 which I also feel is unsound), part of which would be built on the very car park that serves the Chesham underground station, thus undermining the use of public transport and resulting in the greater use of private cars, which, in turn will lead to more traffic congestion. This is inconsistent and unsound. The flawed methodology used by the Local Authority to select the Green Belt site was not effective, justified or consistent with the national planning policy framework (NPPF) and has resulted in their choice of Lye Green which is unsound.
9495 Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not It appears that the council has decided to take the easy option and develop Green Belt land (specifically believe this policy in 13GB sites in Chiltern and South Bucks), which is unjustified, ineffective and inconsistent with national policy. consistent with the National This view is supported by the fact that the councils policy for Green Belt release is part of an overall strategic Planning Policy Framework objective that promotes sustainable development as reflected in Local Plan Policy SP SP1. Such sites are Feb 2019 please explain why generally not sustainable, and to designate them as such is unsound. In additional, there are insufficient ©exceptional circumstances© generally to justify Green Belt release and specifically at Lye Green in this instance. Paragraph 136 of the latest National Planning Policy Framework (NPPF) asserts that Green Belt boundaries should be modified only in ©exceptional circumstances©. The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances and Lye Green is not a sustainable location being too far from the town centre with a steep hill to negotiate too. Quite simply, Green Belt land should not be the first choice for development when other, less damaging options exist nearer the Chesham town centre and the underground station. I question the soundness of the local plan which fails to identify the brownfield land opportunities that have been identified by other such as the Chesham Renaissance CIC Masterplan.The council should be looking at higher densities of development on such sites as are generally closer to the town centre. In short, i believe that the council has used flawed methodology for identifying sites to meet local housing needs and that Lye Green is an unsustainable location and, therefore, its release from the Green Belt is unjustified. The selection of the land at Lye Green as suitable for removal from Green Belt is inconsistent with National Planning Policy Framework (NPPF) not only for the reasons so far stated, but also for the fact that the land supports wildlife and is an important recreational site for nearby communities. Most Green Belt areas do not have widespread public access making this land Lye Green unusual and a rare feature that improves community well being and to allocate such an important sit for development is unjustified. Lye Green is a potential Asset of Community Value and confirmation of this designation will afford a community group the right to bid for the land in order to preserve it for the hundreds of local people who have long used it for recreation purposes. It is perverse that the local authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Local Plan is unsound. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open. This is government policy as set out in paragraph 133 of NPPF 2018. The Lye Green site self-evidently does this well and has done so for decades. A further aim of Green Belt land (stated in NPPF paragraph 134) is to prevent neighbouring towns and settlements from merging into one another. The preservation of Lye Green as Green Belt Land is vital in maintaining a distinct separation from as well as helping to maintain the separate identities of other nearby communities. In view of these facts, it is perverse and inconsistent with national guidance to allocate this land for removal from green belt, especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if the land is developed. Given the above the land being proposed for release form Green Belt designation around Chesham is unjustified and contrary to national guidance. A further aim of Green Belt designation (as stated in the NPPF at paragraph 134(e)) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. Allocating Green Belt land at Lye Green as an area for development completely undermines this aim by failing to recognize the opportunities that exist within Chesham. A community led not-for-profit organisation called Chesham Renaissance CIC has developed the Chesham Masterplan that would not only provide more sustainable locations nearer the town centre, but which would also regenerate some of the more deprived wards within Chesham. While the local plan promotes a considerable increase in retail development alone is not required. A simple stroll down Chesham High Street would reveal at least 10 empty shops. The problem is not insufficient retail spaces but a lack of thoughtful redevelopment that promotes and supports existing retail premises. Indeed the proposals to build shops on the car parks actively undermines the Chesham Renaissance CIC Masterplan. The local authority©s proposals are inconsistent with the local initiative and are therefore also inconsistent with national guidance and are consequently unsound. Everyone in Chesham, not just Lye Green, will be impacted by the addition of 500 homes on this area of Green Belt. I am supportive of the Brown not Green organisation©s initiative to have the land listed as an Asset of Community Value, and I feel they speak for me in respect of their objections to the draft local plan. Accordingly, I request that any representations made by them at any future examination in public regarding the soundness of this local plan be considered as an extension of my own comments herein.
9496 I feel the land NE of Chesham at Lye Green is an unsustainable location for development, that has been habitually used by the community for improved health and wellbeing for decades and that the land performs well against Green Belt aims and objectives. Exceptional Circumstances for reviewing Green Belt boundaries at this location either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by government policy, and therefore, the local plan is unsound. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1219299 Full Name Karoline Skoric ID 3465 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness?
9497 Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The proposals to release Green Belt land to meet housing targets are not justified from the evidence submitted not believe this policy to be by the Councils. positively prepared please The Councils have stated that release of some Green Belt is necessary as part of an overall three part explain why strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. I question the soundness of such a general policy and whether all the brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites and in particular the Green Belt site NE of Chesham at Lye Green.
9498 The development of such Green Belt sites involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient. For example, In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham cannot accommodate any significant highways improvements anyway due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion, with further worsening air quality. Air pollution is a particular concern in Chesham due to the already poor air quality along Bekhampstead Road where there is a designated Air Quality Management Area that already is recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will generate more traffic will make the air quality even worse. Insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable nor justified nor is it in accordance with Govt policy. The Green Belt site NE of Chesham is not a sustainable location. It is over 2Km away from the train station and slightly further still from the town centre but anyone who cares to walk or cycle this distance also has to negotiate a steep hill too. Such an unsustainable location cannot be made sustainable merely by upgrading a couple of public footpaths within the site into bridleways to facilitate cycling. Neither does adding a bus stop address the geography or topography of the area especially if the promised enhanced bus service (which is already infrequent) either does not materialise or if it subsequently fails to be maintained after a few years. Further doubt is cast upon the ªsoundnessº of this Plan by virtue of there being conflicting policies within it. The Council seem to think that the Green Belt site NE of Chesham is sustainable and provides easy access to public transport including the tube station yet the same Plan promotes a considerable increase in retail development in the town (local draft plan policy SP EP3), part of which would be built on the very car park that serves the Chesham tube station. This is inconsistent and unsound. For this Plan to be sound it must also be effective, however, there are serious questions about the deliverability of this land. The main landowner is a farmer who has asserted publicly and in a letter to the editor of Your Chesham, that he is not prepared to release all of the land in his ownership for development. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not The land is also potentially an Asset Of Community Value. The community group (Brown Not Green) have believe this policy in stated their intention is to preserve the land given that many hundreds of local people have habitually used consistent with the National the fields at Lye Green as of right for various informal outdoor recreational purposes.These uses themselves Planning Policy Framework may mean that local individuals have acquired easements over and across the land through prescription (20 Feb 2019 please explain why years uninterrupted use) not least of whom would be the many private residences bordering the fields that have rear garden fences onto the field of Lye Green. These easements and prescriptive rights may render the land very difficult to develop and make it deliverable in planning terms. It is perverse that the Local Authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the plan in unsound. The foregoing also points to flawed methodology of Green Belt site selection used by the Local Authority which is neither effective, justified, nor consistent with national policy and as such is unsound. Specifically the selection of the land NE of Chesham at Lye Green for removal from Green Belt designation is inconsistent with the National Planning Policy Framework(NPPF). Paragraph 136 of the latest NPPF asserts that Green Belt boundaries should only be modified in ªexceptional circumstancesº. The courts have held that unmet local housing needs of an area themselves are not exceptional circumstances. The council engaged third party consultants to undertake the Part 1 Green Belt assessment and they identified numerous sites for ªfurther considerationº where exceptional circumstances ªmightº exist but expressly recommend further review of their assessment of each site against the 5 purposes of land being in Green Belt of all these sites. Unlike the neighbouring local authorities, the part 2 assessment
9499 was not undertaken by third party consultants but by the local authority itself who notably then did not undertake all the recommended reviews of each site including the land NE of Chesham at Lye Green. Accordingly, this oversight in the Part 2 Green Belt assessment placed premature focus and fixation on releasing land at Lye Green NE of Chesham from Green Belt designation. The subsequent identification of the Chesham site for release is therefore unjustified. The primary aim of Green Belt land (as recited in NPPF 133) is to prevent urban sprawl and to preserve the openness of the area. The Lye Green site (SP BP2) self-evidently performs this function well and has done so for decades. Another aim of Green Belt land stated in NPPF paragraph 134, is to prevent neighbouring towns and settlements from merging into one another.The Green Belt land NE of Chesham performs exceptionally well in maintaining a distinct separate between settlements of Chesham & Lye Green as well as helping to maintain separate identities of other nearby communities at Orchard Leigh, Botley, Whelpley Hill, Ashley Green. It is perverse and inconsistent with national guidance to allocate this land for removal from Green Belt in light of these facts especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if earmarked for development. A further aim of Green Belt designation stated in the NPPF at paragraph 134 (e) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. By allocating Green Belt land NE of Chesham for development, undermines this aim within Chesham. A community lead not for profit organisation called Chesham Renaissance CIC has been striving to create Chesham Masterplan that would not only provide many genuinely affordable homes in more sustainable locations nearer the town centre, but which would also regenerate some of the more deprived wards within Chesham. The Local Authority's proposals (policy SP EP3) are inconsistent with this local initiative and are therefore also inconsistent with national guidance and are consequently unsound. The Council has asserted that Government planning policy requires local councils to review Green Belt boundaries when considering how to accommodate the development needs in their areas. Just because the council may be required to look does not mean the Council should review Green Belt boundaries which as previously stated should only be modified in ªexceptional circumstancesº. The National Planning Policy Framework (NPPF) as revised only last year in paragraph 11(b)I, directs ªplan makersº to create policies that are required in Local Plans for housing and other uses unless Framework policies (expressly including Green Belt) ªprovides a strong reason for restricting the overall scale type or distribution of development in the plan areaº. Accordingly, I submit that given all of the above land being proposed for release from Green Belt designation around Chesham is unjustified and contrary to the national guidance. I feel the land NE of Chesham is an unsustainable location for development, which has been habitually used by the community to improve health & wellbeing for decades and the land performs well against Green Belt aims and objectives. Exceptional Circumstances for reviewing Green Belt boundaries at this location either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by Govt policy and therefore this plan is unsound. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1219302 Full Name Mr Ian Walter ID 3477 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name
9500 Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination
9501 Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The proposals to release Green Belt land to meet housing targets are not justified from the evidence submitted. not believe this policy to be In our view Green Belt is sacrosanct and must not be released for development. We need countryside in positively prepared please one of the most densely populated areas of one of the planet's most densely populated countries! explain why The Councils have stated that release of some Green Belt is necessary as part of an overall three part strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. I question the soundness of such a general policy and whether all the brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites and in particular the Green Belt site NE of Chesham at Lye Green. Has this detailed exercise been carried out? The development of such Green Belt sites involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient and unfunded. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham cannot accommodate any significant highways improvements anyway due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion, with further deterioration of air quality that is worse than it should be. Air pollution is a particular concern in Chesham due to the already poor air quality along Bekhampstead Road where there is a designated Air Quality Management Area that already is recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will generate more traffic, moving slower than ever, will make the air quality even worse as engines idle. Insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable nor justified nor is it in accordance with Government policy. I am intrigued that the Lye Green proposals include 15 traveller sites. Where does this figure come from? If 500 homes are to be built, 15 represents a not significant 3%. I am aware of a proposal elsewhere for 5000 homes that also includes 15 traveller sites (0.3%). This seems to be considerably more proportionate than the 15 proposed in Lye Green which is significantly disproportionate. So at most I would expect to see 1 or 2 in the proposal not 15. The Green Belt site NE of Chesham is not a sustainable location. It is over 2Km away from the train station and slightly further still from the town centre but anyone who cares to walk or cycle this distance also has to negotiate a steep hill in either White Hill or Nashleigh Hill. Marketing such properties as being within walking distance of the London Tube Network is frankly outrageous. Such an unsustainable location cannot be made sustainable merely by upgrading a couple of public footpaths within the site into bridleways to facilitate cycling. Neither does adding a bus stop address the geography or topography of the area especially if the promised enhanced bus service (which is already infrequent) either does not materialise or it subsequently fails to be maintained after a few years. Further doubt is cast upon the ªsoundnessº of this Plan by virtue of there being conflicting policies within it. The Council seem to think that the Green Belt site NE of Chesham is sustainable and provides easy access to public transport including the tube station yet the same Plan promotes a considerable increase in retail development in the town (local draft plan policy SP EP3) , part of which would be built on the very car park that serves the Chesham tube station. This is inconsistent and unsound. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
9502 Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not For this Plan to sound it must also be effective. Unfortunately, further review of the proposal to remove land believe this policy in NE of Chesham at Lye Green from Green Belt designation is not effective as there are serious questions consistent with the National about the deliverability of this land. The main landowner is a farmer who has asserted publicly and in a letter Planning Policy Framework to the editor of Your Chesham, that he is not prepared to release all of the land in his ownership for Feb 2019 please explain why development. The land is also potentially an Asset Of Community Value and upon confirmation of this designation it would afford a community group the right to bid for the land. The community group (Brown Not Green) have stated their intention is to preserve the land given that many hundreds of local people have habitually used the fields at Lye Green as of right for various informal outdoor recreational purposes. These uses themselves may mean that many local individuals may have acquired easements over and across the land through prescription (20 years uninterrupted use) not least of whom would be the many private residences bordering the fields that have rear garden gates onto the fields at Lye Green. These easements and prescriptive rights may render the land very difficult to develop and make i undeliverable in planning terms. This land also provides an important habitat for wildlife that will be threatened by development of this land. It is perverse that the Local Authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Plan is unsound. The foregoing also points to flawed methodology of Green Belt site selection used by the Local Authority, which is neither effective, justified nor consistent with national policy and as such is unsound. Specifically, the selection of the land NE of Chesham at Lye Green for removal from Green Belt designation is inconsistent with National Planning Policy Framework (NPPF). Paragraph 136 of the latest NPPF asserts that Green Belt boundaries should only be modified in ªexceptional circumstancesº. The courts have held that unmet local housing needs of an area themselves are not exceptional circumstances. The council engaged third party consultants to undertake the Part 1 Green Belt assessment and they identified numerous sites for ªfurther considerationº where exceptional circumstances ªmightº exist but expressly recommend further review of their assessment of each site against the 5 purposes of land being in Green Belt of all these sites. Unlike the neighbouring local authorities, the part 2 assessment was not undertaken by third party consultants but by the local authority itself who notably then did not undertake all the recommended reviews of each site including the land NE of Chesham at Lye Green.Accordingly, this oversight in the Part 2 Green Belt assessment placed premature focus and fixation on releasing land at Lye Green NE of Chesham from Green Belt designation. The subsequent identification of the Chesham site for release is therefore unjustified. The primary aim of Green Belt land (as recited in NPPF 133) is to prevent urban sprawl and to preserve the openness of the area. The Lye Green site self-evidently performs this function well and has done so for decades. Another aim of Green Belt land stated in NPPF paragraph 134, is to prevent neighbouring towns and settlements from merging into one another.The Green Belt land NE of Chesham performs exceptionally well in maintaining a distinct separate between settlements of Chesham & Lye Green as well as helping to maintain separate identities of other nearby communities at Orchard Leigh, Botley, Whelpley Hill, Ashley Green. It is perverse and inconsistent with national guidance to allocate this land for removal from Green Belt in light of these facts especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if earmarked for development. A further aim of Green Belt designation stated in the NPPF at paragraph 134 (e) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. By allocating Green Belt land NE of Chesham for development, undermines this aim within Chesham. A community lead not for profit organisation called Chesham Renaissance CIC has been striving to create Chesham Masterplan that would not only provide many genuinely affordable homes in more sustainable locations nearer the town centre, but which would also regenerate some of the more deprived wards within Chesham. The Local Authority's proposals (policy SP EP3) are inconsistent with this local initiative and are therefore also inconsistent with national guidance and are consequently unsound. The Council have asserted that Government planning policy requires local councils to review Green Belt boundaries when considering how to accommodate the development needed in their areas. Just because the Council may be required to look, does not mean the Council should review Green Belt boundaries which as previously stated should only be modified in ªexceptional circumstancesº. National Planning Policy Framework (NPPF) as revised only last year, states in paragraph11 (b) I, directs ªplan makersº to create policies that are required in Local Plans for housing and other uses unless Framework policies (expressly including Green Belt) ªprovides a strong reason for restricting the overall scale type or
9503 distribution of development in the plan areaº Accordingly, I submit that given all of the above the land being proposed for release from Green Belt designation around Chesham is unjustified and contrary to national guidance. I believe the land NE of Chesham is an unsustainable location for development, which has been habitually used by the community to improve health & wellbeing for decades and the land performs well against Green Belt aims and objectives. Exceptional Circumstances for reviewing Green Belt boundaries at this location either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by Govt policy and therefore this plan is unsound. I am also very concerned about the last minute proposals that have almost slipped under the radar to remove many local villages, including my own in Ley Hill, from Green Belt, as well as permitting `infilling' development within them. The prospect of villages being gradually being ,merged into ever-increasing towns is totally unacceptable. We need countryside and we are in danger of turning Chesham into another Aylesbury, High Wycombe or Bedford which would be a tragedy in a prime location in the Chilterns. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1219455 Full Name Mrs Janet Rose ID 3600 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the
9504 Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I do not feel that Chesham could cope with an influx of people - what about extra schools, DR©s surgeries not believe this policy to be which are already stretched to the limit? positively prepared please We do not have enough car parks in the town to cope with the present amount of traffic and I think that if explain why this plan goes ahead it will be chaotic.
9505 PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1219462 Full Name Marion and Neville Thorneycroft ID 3602 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant.
9506 Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as
9507 precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Apart from ruining the landscape and local recreational facilities, there appears to be no provision for what not believe this policy to be would be much needed infrastructure such as a medical centre and school plus the inevitable traffic congestion. positively prepared please Apart from other complaints the Local Plan is neither sound or possibly legally compliant. explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
9508 Person ID 1219469 Full Name Mrs Roz Stockman ID 3455 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness?
9509 Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Following careful consideration of the above, I am forced to conclude that the council©s Local Plan will cause not believe this policy to be harm to the wider town of Chesham and is unsound. Specific areas of concern include: positively prepared please - loss of Green Belt around Chesham with all of the environmental implications explain why - more traffic congestion and worsening air quality in Chesham - Loss of land with Community Value in Chesham which supports wildlife and recreation - Outward sprawl of the town which will result in Lye Green becoming part of ©Greater Cehsham© - Failure to recognise an opportunity for urban development and regeneration PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not I am concerned that the many hundreds of proposed homes will generate increased traffic and its attendant believe this policy to be air pollution, already at alarming levels in the Chesham area. The designated Air Quality Management Area justified please explain why along Berkhamstead Road is already recording air quality that is considerably worse than EU safe levels. The council©s proposals are inconsistent with Local Plan Policy DM DP5 relating to ©climate responsive development© and policy DM DP9 ©reducing reliance on private cars© and DM DP15 ©BLue Green infrastructure©. The council©s wilful failure to take these into account will only make things worse and cannot be justified under recent national government policy.These considerations alone should be sufficient grounds to reconsider the entire draft local plan which is unsound in this matter. there are suggestions of mitigating the air quality but where is the proof these measures will be delivered or that they will work? The Green Belt site NE of Chesham is over two kilometres from the underground station and Chesham town centre and is therefore an unsustainable location. The council seems to think that the Lye Green site is sustianble and provides easy access to public transport including the underground station , yet the same local plan promotes a considerable increase in retail development in the town (draft local plan policy SP EP3
9510 which I also feel is unsound), part of which would be built on the very car park that serves the Chesham underground station, thus undermining the use of public transport and resulting in the greater use of private cars, which, in turn will lead to more traffic congestion. This is inconsistent and unsound. The flawed methodology used by the Local Authority to select the Green Belt site was not effective, justified or consistent with the national planning policy framework (NPPF) and has resulted in their choice of Lye Green which is unsound. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not It appears that the council has decided to take the easy option and develop Green Belt land (specifically believe this policy in 13GB sites in Chiltern and South Bucks), which is unjustified, ineffective and inconsistent with national policy. consistent with the National This view is supported by the fact that the councils policy for Green Belt release is part of an overall strategic Planning Policy Framework objective that promotes sustainable development as reflected in Local Plan Policy SP SP1. Such sites are Feb 2019 please explain why generally not sustainable, and to designate them as such is unsound. In additional, there are insufficient ©exceptional circumstances© generally to justify Green Belt release and specifically at Lye Green in this instance. Paragraph 136 of the latest National Planning Policy Framework (NPPF) asserts that Green Belt boundaries should be modified only in ©exceptional circumstances©. The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances and Lye Green is not a sustainable location being too far from the town centre with a steep hill to negotiate too. Quite simply, Green Belt land should not be the first choice for development when other, less damaging options exist nearer the Chesham town centre and the underground station. I question the soundness of the local plan which fails to identify the brownfield land opportunities that have been identified by other such as the Chesham Renaissance CIC Masterplan.The council should be looking at higher densities of development on such sites as are generally closer to the town centre. In short, i believe that the council has used flawed methodology for identifying sites to meet local housing needs and that Lye Green is an unsustainable location and, therefore, its release from the Green Belt is unjustified. The selection of the land at Lye Green as suitable for removal from Green Belt is inconsistent with National Planning Policy Framework (NPPF) not only for the reasons so far stated, but also for the fact that the land supports wildlife and is an important recreational site for nearby communities. Most Green Belt areas do not have widespread public access making this land Lye Green unusual and a rare feature that improves community well being and to allocate such an important sit for development is unjustified. Lye Green is a potential Asset of Community Value and confirmation of this designation will afford a community group the right to bid for the land in order to preserve it for the hundreds of local people who have long used it for recreation purposes. It is perverse that the local authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Local Plan is unsound. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open. This is government policy as set out in paragraph 133 of NPPF 2018. The Lye Green site self-evidently does this well and has done so for decades. A further aim of Green Belt land (stated in NPPF paragraph 134) is to prevent neighbouring towns and settlements from merging into one another. The preservation of Lye Green as Green Belt Land is vital in maintaining a distinct separation from as well as helping to maintain the separate identities of other nearby communities. In view of these facts, it is perverse and inconsistent with national guidance to allocate this land for removal from green belt, especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if the land is developed. Given the above the land being proposed for release form Green Belt designation around Chesham is unjustified and contrary to national guidance. A further aim of Green Belt designation (as stated in the NPPF at paragraph 134(e)) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. Allocating Green Belt land at Lye Green as an area for development completely undermines this aim by failing to recognize the opportunities that exist within Chesham. A community led not-for-profit organisation called Chesham Renaissance CIC has developed the Chesham Masterplan that would not only provide more sustainable locations nearer the town centre, but which would also regenerate some of the more deprived wards within Chesham. While the local plan promotes a considerable increase in retail development alone is not required. A simple stroll down Chesham High Street would reveal at least 10 empty shops. The problem is not insufficient retail spaces but a lack of thoughtful redevelopment that promotes and supports existing retail premises. Indeed the proposals to build shops on the car parks actively undermines the Chesham Renaissance CIC Masterplan.
9511 The local authority©s proposals are inconsistent with the local initiative and are therefore also inconsistent with national guidance and are consequently unsound. Everyone in Chesham, not just Lye Green, will be impacted by the addition of 500 homes on this area of Green Belt. I am supportive of the Brown not Green organisation©s initiative to have the land listed as an Asset of Community Value, and I feel they speak for me in respect of their objections to the draft local plan. Accordingly, I request that any representations made by them at any future examination in public regarding the soundness of this local plan be considered as an extension of my own comments herein. I feel the land NE of Chesham at Lye Green is an unsustainable location for development, that has been habitually used by the community for improved health and wellbeing for decades and that the land performs well against Green Belt aims and objectives. Exceptional Circumstances for reviewing Green Belt boundaries at this location either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by government policy, and therefore, the local plan is unsound. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1221970 Full Name Susan Wilmot ID 3452 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally
9512 compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Contravening Green Belt policies, without strong reason is not justified or effective. not believe this policy to be It is far more effective and justified to develop brown field sites. positively prepared please explain why Where is the proportionate evidence that the green belt should be destroyed? We haven©t seen it! How have residents currently living in or near threatened green belt locations been satisfied that there is unmet need from neighbouring areas with no other alternatives?
9513 Where is the evidence that alternative solutions, e.g. as proposed by the CIC master plan, have been fully studied? PP Mods - Please specify as Provide information to local resident why the green belt is being built on, with more time for consultation. precisely and succinctly as Do not expect residents to fill in 34 page forms in the summer holiday period when many people are away possible how you would and will miss the 19 July deadline! modify this policy to improve its alignment to this test of Give due consideration to the proposals of the Chesham renaissance CIC master plan thereby improving soundness. Chesham town centre and making use of land for more effectively sustainably and economically. Policy 1 - If you do not When and how was information provided to residents explaining in clear simple terms why all other alternatives believe this policy to be to building on Green belt have been dismissed justified please explain why This information should be delivered to households since most residents are unable to attend the occasional meeting that have been held. How is a plan with a substantial funding gap justified? It is simply not realistic that most of the affected residents will complete a 34 page consultation form many locals here have strong feelings but are overwhelmed by the length and complexity of the form. Policy 2a - Please specify as Re-plan by providing higher density housing on existing brown field sites. Reduce the funding gap by precisely and succinctly as developing brown field sites. possible how you would Improve the sustainability by redeveloping Chesham town centre. modify this policy to improve its alignment to this test of Give due consideration to the proposals of the Chesham renaissance CIC master plan to develop more soundness. sustainability. Policy 2 - If you do not Has the statement of common ground clearly and comprehensively explained why building on Green belt believe this policy to be land is the only solution? effective please explain why. Has it explained why the proposals of the Chesham renaissance CIC master plan have been discounted? Has it explained how an acknowledged funding gap is effective? PAa - Please specify as The policy would be more effective if it took into consideration the proposals of the community led Chesham precisely and succinctly as renaissance CIC master plan. possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not There is a funding gap from the CIL, Is this really legal? believe this policy in Information has not been delivered to residents explain why remaining land from the green belt is the only consistent with the National solution to providing enough housing Planning Policy Framework Feb 2019 please explain why The dismissal of the proposals of the Chesham renaissance CIC master plan has not been explained to residents. I am not satisfied that the exceptional circumstances for redefining the boundaries of the green belt have been met. Policy 3a - Please specify as Develop brown field sites precisely and succinctly as Continue allowing developers to build housing on properties with large gardens when they come into the possible how you would market. For example, as is already happening on Chartridge Lane, Chesham provided that the buildings are modify this policy to improve in harmony with existing properties. This is far more effective than encroaching on Green Belt locations and its alignment to this test of destroying the biodiversity. It is also far more cost effective to develop brown field sites. soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1221974 Full Name Janet Archer ID 3437 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body?
9514 Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act
9515 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The proposed development, houses, businesses, no doubt schools, shopping areas, makes no sense - it not believe this policy to be will mean extra public transport in this area, extra local jobs here? When local industries here are already positively prepared please diminishing - or is everyone expected to commute to London? In which case extra metropolitan line trains, explain why already are crowded at rush hours. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1219474
9516 Full Name Mr Robin Rance ID 3678 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness?
9517 Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do As is obvious to all we are in the Chiltern Hills and out topography is unique. Our town floods when it rains not believe this policy to be and is in drought from over abstraction at other times. positively prepared please The Lye Green Road/Lycrome Road greenbelt site is not sustainable option. It is just over 2 kms from the explain why underground station and town centre. I see the planners believe it is perfectly reasonable to walk this distance, if only we were all fit and well! There is an hourly bus service running until 8.15pm but it is expensive and cycling is not possible (unless you belong to a cycling club). Both Nashleigh hill and White hill are narrow roads, congested at peak times and are subject to gridlock when just one incident occurs anywhere on the A416. Although some road modifications have been suggested they are inadequate and who is going to pay for them? We appear to be hundreds of millions short on funding. PP Mods - Please specify as 70% of Chesham residents support the Chesham Renaissance plan. Brown not Green also have much precisely and succinctly as support with their strongly held views on keeping the Greenbelt. I would ask the inspector to closely inspect possible how you would their proposal as being a far better proposal to that from CDC. modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not Air pollution is, as recorded, dreadful on the A416 it is considerably worse than EU safe levels. Developing believe this policy to be this site and expanding the villages is not sustainable or justified nor is it in accordance with Government justified please explain why Policy. I always understood that you could not exacerbate a current AQMA. Releasing village development will bring even more traffic along the AQMA. Building in the affected area has been carried out over recent years, against the advice of BCC due to congestion and air pollution concerns. The land is in excellent quality and will not only deprive the mash family of some of their livelihood but agricultural production will duffer as well. This area is currently being considered as amenity land, it is not just full of footpaths for dog walking it is much more sociable area with gated access from many homes directly onto the land. An unmet housing need is not a reason to release Greenbelt- a recent court judgement has adjudicated. Our greenbelt is precious, there are other alternatives and I am disappointed that the planners chose to ignore
9518 Chesham renaissance who, having accepted development must take place, produced a plan providing homes exactly where we need them whilst upgrading the town centre at the time. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222005 Full Name Celia Strange ID 3446 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible.
9519 Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the
9520 examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Already the HS2 is having an adverse effect, so with addition to the new plans, it will be a disaster for the not believe this policy to be whole area. positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222012 Full Name Pavel Sims ID 3483 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID
9521 Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination
9522 Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not Should this project be allowed it will fundamentally breach a law that has protected green belt land for many believe this policy in generations. consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222015 Full Name B W Hawkes ID 3485 Order 236 Number 11.3
9523 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible.
9524 Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not Should this project be allowed it will fundamentally breach a law that has protected green belt land for many believe this policy in generations. consistent with the National Planning Policy Framework Feb 2019 please explain why
9525 Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222017 Full Name Kathy Wood ID 3487 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant
9526 legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve
9527 its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not Should this project be allowed it will fundamentally breach a law that has protected green belt land for many believe this policy in generations. consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222020 Full Name M Asres ID 3489 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance?
9528 Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible
9529 Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not Should this project be allowed it will fundamentally breach a law that has protected green belt land for many believe this policy in generations. consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222022 Full Name G Thomas ID 3491 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details
9530 Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has
9531 met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not Should this project be allowed it will fundamentally breach a law that has protected green belt land for many believe this policy in generations. consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222024 Full Name Mrs M Westley ID 3493 Order 236 Number 11.3 Title Policy SP BP2 - Chesham
9532 Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible.
9533 Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not Should this project be allowed it will fundamentally breach a law that has protected green belt land for many believe this policy in generations. consistent with the National Planning Policy Framework Feb 2019 please explain why
9534 Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1219985 Full Name Rodney Hill ID 3724 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant
9535 legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I would, however ask what considerations are being taken into the local infrastructure regarding the proposal. not believe this policy to be For example the roads. W have one main road the A416 (I live in Bois Moor Road and when the main road positively prepared please is blocked from Amersham to Chesham the only alternative is down through my road. We need a bold plan explain why by passing Amersham and Chesham and linking into the A41 M) PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not The metropolitan is single track from Chalfont to Chesham and with headway times, twice an hour seems believe this policy to be all that is possible. The alternative is the suburban service to Euston from Berkhamsted, Tring or Hemel with justified please explain why also attendant problems with parking. In addition what considerations are given to council services, schools, medical services, water, sewerage etc, etc. Policy 2a - Please specify as precisely and succinctly as possible how you would
9536 modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222158 Full Name Mr Ovid Leonard ID 3502 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance?
9537 Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible
9538 Policy Level - PP - If you do The Green Belt site NE of Chesham (SP BP2) is not a sustainable location. It is over 2km away from the not believe this policy to be train station and the town centre. The development of this site will generate substantially increased traffic, positively prepared please and suggested highways improvements are insufficient and unfunded. In Chesham most of the road junction explain why and infrastructure is already operating above capacity. Chesham©s topography limits options to increase traffic flow. Air pollution above EU safe levels is already a problem in parts of the town. An additional 500 houses on the edge of the town will introduce a further 1000 motor vehicles into an already over-stretched system. The plan is therefore unsound. The proposal for retail development on the Chesham Town Car Park, at a time when the town has empty shops and a shortage of Car Park Spaces, is unsound. It is so divorced from reality that it brings into question the efficacy of the whole plan. There are a number of factors which mean the land NE of Chesham, may not actually be available for housing development. Much of the land is owned by a local farmer of long standing who has asserted he is not prepared to release all of his land for development. The fact that the land at Lye Green (SP BP2) is listed as an asset of Community Value underlines its formal recreational value and as such this listing supports the contention that this Green Belt site, at least, has been incorrectly bought forward for allocation for development. This land also provides an important habitat for many species of wildlife that will be threatened by development. Destruction of such habitat can never be rectified. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not In my opinion the proposals to release Green Belt land to meet housing targets are not justified from the believe this policy to be evidence submitted. I question the soundness of the proposals and whether all the brownfield land opportunities justified please explain why have been identified and/or whether the council should be looking at higher densities of development on sites which are more sustainable locations than Green Belt sites and in particular the Green Belt site NE of Chesham at Lye Green. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I believe the draft local plan is not legally compliant because the local authority has not demonstrated they believe this policy in have exhausted all options before considering revision of Green Belt boundaries. consistent with the National This Local Plan is seeking substantial modifications to Green Belt boundaries including removal of Green Planning Policy Framework Belt designation of 13 areas within the districts as well as modifying the Green Belt status of many local Feb 2019 please explain why villages. Failure to exhaust all options and to properly engage with and understand the needs and wants of the community means that what is proposed is not justified or sound or even relevant. The sustainability appraisal supporting this plan, suggests that the plan area is forecast to see carbon emission increase by 21% in the plan period. This despite the fact that certain areas already experience levels of pollution considerably above EU safe levels. Accordingly, the plan is inconsistent with Government policy and therefore not legally compliant. Local infrastructure is already inadequate and under-funded in many areas. Evidence that supports this local plan acknowledges a funding gap of up to £231m. That significant infrastructure investment is essential is self-evident. To propose this plan without identifying adequate and secure infrastructure funding is irresponsible and demonstrates the plan is unsound and not legally compliant. I am advised that promoting such a valued community asset for development undermines the objective of the Localism Act 2011 making this aspect of the plan unsound. The land NE of Chesham is an unsustainable location for development, that has been habitually used by the community for improved health and well being for decades and the land performs well against Green Belt aims and objectives. Exceptional circumstances for reviewing Green Belt boundaries at this location, either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by govt policy and therefore the plan is unsound. Policy 3a - Please specify as In the case of Chesham, a complete reappraisal of the wants and needs of the community must be undertaken. precisely and succinctly as The plan, as presented, demonstrates a total lack of understanding of and interest in, the wants and needs possible how you would of Chesham Town and its community. modify this policy to improve
9539 its alignment to this test of Chesham Town has empty shops and a shortage of car park space.That the plan should propose a substantial soundness. retail development on the Town station car park is an indication of the extent to which planners have failed to understand, or respond to, local circumstances. Much good work has been undertaken and very professionally recorded by CIC Chesham Renaissance and Brown Not Green. These local organisations have presented coherent and well thought out proposals which have engendered a deal of support from the community. Local planners have failed to engage with these organisations in a manner which can only be considered as irresponsible and unprofessional. Local Planners must take guidance from the work done by these organisations and work closely with these valuable resources in future. A more detailed appraisal of brownfield land opportunities and closer scrutiny of alternative options for housing must be undertaken. Useful input on this issue is available from Chesham Renaissance and Brown Not Green. Green Belt boundary reviews must be a last resort. Policy-level file upload - Please attach any supporting evidence
Person ID 1222160 Full Name Mr Paul Castaldini ID 3719 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible.
9540 Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I believe that the draft Local Plan is not legally compliant as it has not demonstrated any regard to the National not believe this policy to be Policy issued by the Secretary of State. positively prepared please The National Planning Policy considering makes it clear that Local Authorities must demonstrate that they explain why have exhausted all options before considering a revision of the boundary of any Green Belt. I feel that this draft local plan has not demonstrated that all other options have not been fully explored thus making this draft plan not legally compliant nor is it sound. Furthermore it can be seen that there is a forecast increase in the carbon emission of 21% as indicated in the Sustainability Appraisal supporting the Draft Local Plan, this is at odds with the Government aim to reduce Carbon Emission to net zero by 2050, making this Draft Local plan at odds with Government Policy and therefore not legally compliant.
9541 There is a further demonstration of the Local Draft Plan being both unsound and not legally compliant, in that there is a significant infrastructure funding gap that is acknowledged within the community Infrastructure levy evidence, of between £179m and £231m. PP Mods - Please specify as The plan needs to be revised in the following areas: precisely and succinctly as By co-operating with all local authorities, including Aylesbury District and other Local Authorities possible how you would modify this policy to improve By co-operating with Chesham Renaissance who©s Masterplan is far more in touch with the specific needs its alignment to this test of to the Chesham area. soundness. Fully explore the proper use of brown fields sites for the development of housing needs within the area. The redefinition of Green Belt should only be considered after all other options have been fully evaluated and ruled out. Without Green Belt the towns become uncontained sprawling urbanisation that in themselves impose higher levels of unsustainable services and resources. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222165 Full Name Stephen Davis ID 3640 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details
9542 Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has
9543 met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I believe the site selection methodology of using the Green Belt land at Lye Green to be flawed. Building 500 not believe this policy to be houses 2.5 miles from the town centre atop a very steep hill, will result in the widespread use of cars by positively prepared please residents to reach amenities in the town centre and tube station. These short journeys by car will only add explain why to the already high levels of pollution present in parts of Chesham. Indeed, Berkhamsted Road has a designated Air Quality Management Area that is already recording air quality that exceeds EU safe levels considerably. Lye Green is not a suitable location to build hundreds of homes.The congestion caused by residents needing to commute through the town, reach the tube station or schools, particularly down White Hill or Eskdale Avenue, will only add to the gridlock that drivers already experience on Berkhamsted Road during rush hour traffic, further worsening air quality. Some highway improvements have been suggested but they are insufficient. Evidence shows that most of the road junctions and infrastructure in Chesham are already operating above capacity. Limited verges and space beside the highway mean Chesham cannot accommodate any significant highways improvements. The Councils plan contains conflicting policies that states that the Green Belt site NE of Chesham provides easy access to public transport, including the tube station, yet the very same plan also promotes the building of shops on the car park that serves the tube station. I believe this to be inconsistent and unsound. Chesham already had two large supermarkets, a butcher and two bakeries. There are empty shops in the high street as well as along Berkhamsted Road. Chesham has many independent cafes and restaurants within its town centre. These, along with the existing shops, library, park and theatre, would be much better served if housing was built within easy walking distance of them. As well as providing recreational use over decades for local people, the land is good quality agricultural land. As such it soaks up rainfall which would otherwise run off the fields as floodwater into Chesham, adding to the problem of flooding on the Berkhamsted Road. As well as being inconvenient for pedestrians and traffic it also leads to the polluting of the River Chess, a fragile ecosystem and globally rare habitat. Brushwood Junior school, with its current 278 pupils, is located on the boundary of the said Green Belt land. In an age where cars are being discouraged or banned from idling or parking near schools, it is irresponsible and enviromentally unsustainable to build 500 homes, which will in turn bring a minimum of 500 cars so close to the school. This will have a detrimental effect on the health of the children and staff of the school. The Green Belt land at Lye Green supports rich biodiversity and provides crucial habitat for many species of birds, insects and mammals, most of which will be driven out if such a development goes ahead. Surely with all we now know and understand about the need to protect the environment, increase tree planting and reduce CO2 emissions, the idea of removing this land from the Green Belt and developing it for housing is completely unjustified, short sighted and irresponsible. PP Mods - Please specify as When Chesham residents were asked by community interest company Chesham Renaissance what was precisely and succinctly as most important to them about where they lived, the overwhelming majority said the AONB status. Increasing possible how you would the population density within the town boundary can protect the Green Belt that surrounds the town. This modify this policy to improve can be achieved by building on existing brownfield sites closer to the town centre where all the facilities and its alignment to this test of amenities are. soundness. Policy 1 - If you do not The proposals to release Green Belt land to meet housing targets are not justified from the evidence submitted. believe this policy to be I question the soundness of such a general policy and whether all Brownfield land that offers a more justified please explain why sustainable location for development have been identified. The plan itself estimates an increase in the districts carbon footprint of 21%.This points to the current proposal as being unsound. Therefore, the development of the Lye Green site NE of Chesham cannot be sustainable, nor justified, nor in accordance with government policy. National planning guidance requires the local authority to consider viable alternatives such as the Chesham Renaissance C/C Masterplan, devised by local people for local people, or to recycle brownfield land for housing. The divegence of the plan from these viable alternatives is inconsistent with local initiative and further suggests the plan is inconsistent with national guidance, ineffective and unjustified. The council employed third party consultants to undertake the part 1 Green Belt assessment, in doing this they identified numerous sites for "further consideration" where exceptional circumstances might exist, but firmly recommended further review of their assessment of each site against the 5 purposes of land being in Green Belt of all these sites. However, contrary to neighbouring local authorities, the Local Authority chose
9544 to undertake the part 2 Green Belt assessment itself and in doing so did not undertake all the recommended views of each site, including the land NE of Chesham at Lye Green.This oversight by the local Local Authority drew sole, excessive focus on releasing the said land from Green Belt designation.Therefore, the identification of the land for release from the Green Belt is unjustified. Policy 2a - Please specify as The Chesham Renaissance C/C Masterplan, a community led scheme, suggests more effective alternatives precisely and succinctly as such as higher densities of housing development on brownfield sites closer to the town centre. This would possible how you would be a more sustainable and enviromentally friendly alternative such as higher densities of housing development modify this policy to improve on brownfield sites closer to the town centre. This would be a more sustainable and environmentally friendly its alignment to this test of alternative, keeping development to land that has been previously built on and which is within the town soundness. boundary. This alternative plan would bring investment to Chesham by building the number and types of housing we need in areas where they will benefit and rejuvenate the town and the more deprived parts of Chesham. Policy 2 - If you do not The removal of the land NE of Chesham at Lye Green from Green Belt is not effective as there are serious believe this policy to be questions around the deliverability of this land. The main landowner has said publicly, including in a letter to effective please explain why. the editor of Your Chesham, that he is not prepared to release all the land for development. The land has also been granted status as an asset of community value, giving a community group the right to bid for the land. It is not effective, justified or in accord with the National Planning policy (policy SP BP2), that Green Belt land designated as an asset of Community Value be developed and undermines the objectives of the Localism Act 2011. This renders this aspect of the plan unsound. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not Selection of the land NE of Chesham at Lye Green for removal from Green Belt designation is inconsistent believe this policy in with the National Planning Policy Framework. Paragraph 136 of the latest NPPF states that Green Belt consistent with the National boundaries should only be modified in "exceptional circumstances".The courts have held that "unmet housing Planning Policy Framework needs of an area are themselves not exceptional circumstances. Feb 2019 please explain why The proposed development of this Green Belt land will destroy the distinctiveness of Chesham and promote urban sprawl into the neighbouring historical hamlet of Lye Green. This would contradict the primary aim of Green Belt land being to "prevent urban sprawl and preserve the openness of the area (NPPF133). The plan also proposes the removal of many neighbouring local villages from Green Belt which could lead to the infilling of others. It is incomprehensible that areas of ANOB could be negatively changed forever in this way. The NPPF paragraph 134 states that another aim of Green Belt is to "prevent neighbouring towns and settlements from merging into one another". The land has been used by the community for improved health and well being for decades and performs well against Green Belt aims and objectives. Exceptional circumstances for reviewing Green Belt boundaries at this location either do not exist or are insufficient to warrant the removal from the Green Belt designation as required by Government policy and therefore the plan is unsound. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222183 Full Name Isobel Tellez ID 3644 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of:
9545 Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is
9546 incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do - As our district council you should promote clean air for the wellbeing of all who breathe on these hills - now not believe this policy to be and for future generations. Building on land held in trust for cultivating oxygen reverses this aim. Once built positively prepared please on, it can never return to its original usefulness and beauty. explain why - The drains on Lye Green Road are continually flooding because the bore of the pipes is too narrow for the effluent from recent infill houses. How will the infrastructure cope with 500 plus more households on this hill? The valley, where it end up, and therefore the town centre, will not cope either. PP Mods - Please specify as I support the Brown not Green campaign suggestions, and The Chesham Renaissance Master plan. They precisely and succinctly as have both made very viable suggestions for brown sites and town sites to be developed rather than destroy possible how you would the Green belt. There is no justification for ignoring their proposals. It is also a crime against our health to modify this policy to improve increase the carbon footprint in the Chilterns. its alignment to this test of soundness. Policy 1 - If you do not - There is ample land around Chesham - on the way to Ashley Green and Bovingdon further onto the plateau believe this policy to be - where traffic congestion could be shared with Hemel and Berkhamsted and drains could be more justified please explain why self-contained. -Your plans, if implemented, will change the character of Chesham irreversibly for the worse in every respect: aesthetics, health, infrastructure and the overall wellbeing of us, its townspeople. Chesham prides itself as a Fair Trade town and welcomes leisure-seekers from London. We must keep it as a sustainable tourist destination and market town. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not Destroying this amenity land is contrary to national and international aims to reduce exhaust fumes and believe this policy in carbon mon/di-oxide; you will be adding to them. consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
9547 Policy-level file upload - Please attach any supporting evidence
Person ID 1222195 Full Name Gillian Clark ID 3732 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications
9548 to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Surely we must consider Chesham©s infrastructure is already struggling and I am very concerned about so not believe this policy to be many properties being built on fields near Brushwood school, how will out poor town cope with so many positively prepared please more cars and vehicles. How will the surgeries cope? Where will the children go to school? Will the sewage explain why system be adequate? So if we need to expand these amenities will that mean using even more green belt? PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not My understanding of Greenbelt is that it was to protect area©s just outside of London otherwise these small believe this policy to be town and villages would become part of Greater London. This programme to keep building properties in justified please explain why these areas will eventually lead to this happening . Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why.
9549 PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222197 Full Name Neil Cooper ID 3764 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its
9550 legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I remain extremely concerned that this project did not have prior consultation on ©Green Belt Village Policies.© not believe this policy to be This is a large project housing large numbers of people that our community will struggle to cope with (including positively prepared please medical provision). explain why PP Mods - Please specify as precisely and succinctly as
9551 possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1220471 Full Name Cristian Ley ID 4356 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is
9552 not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is
9553 proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The land at Lye Green, in relation to which a considerable housebuilding project is contemplated, is a habitat not believe this policy to be for wildlife and provides a counter co2 effect by virtue of its many trees and plants. positively prepared please The council should have the foresight to recognize that the increasing availability of land that is already built explain why upon means that many new homes can be developed upon such land - without, for the most part, the loss of scarce green land and natural habitat for wildlife. I genuinely believe that there is a sustainability and biodiversity issue in surrendering scarce green space for the erection of shops that will one day be lost to the tidal overtake of online retail. Chesham does not currently possess a bypass. traffic towards Berkhamstead (A416) from Amersham is appalling for large parts each day. The addition of 500 homes at Lye Green will ass anywhere between 200 and 1000 motor vehicles. Such motor vehicles will be a huge strain on the already over-burdened traffic system in Chesham. On the basis that few will be single occupancy, there is a prospect of 1000 or more new residents to Chesham. If, as the local plan contemplates, 500 homes are added at Lye Green, there will be a combined loss of Co2 countering trees, plants and shrubbery and an addition of many hundreds of polluting vehicles. PP Mods - Please specify as I would propose a development of just 50 homes on the part of land at Lye Green. precisely and succinctly as To do so would fulfill a number of aims as follows: possible how you would modify this policy to improve 1) Some housing needs would be met. its alignment to this test of 2) While some green land would be lost, only a few hectares are needed to build 50 homes. soundness. 3) The addition of 50-220 motor vehicles to the roads at Chesham is just about sustainable.. 4) The pressure on infrastructure and resources created by 50-200 new residents is just about sustainable. Policy 1 - If you do not When physical retail fails further, creating plenty of built land near to Chesham Town Centre and Chesham believe this policy to be train station upon which to develop residential dwellings, the Chilterns area would have benefited from justified please explain why "foresight" and the keeping of vital green space. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as The plan does not adhere to Paragraph 22 of the Strategic policies Section of the NPPF document. If the precisely and succinctly as council were to look beyond the 15 years, as required, it would realize that the retail sector will move almost possible how you would completely online, thereby making vast amounts of urban land available for residential development. modify this policy to improve The plan does not adhere to Paragraph 103 of the NPPF in the sustainable transport section as patterns of its alignment to this test of growth will not be managed and air quality will worsen. Further, a bypass at Chesham would need to be built soundness. for traffic through its centre to be managed. Policy 3 - If you do not Restrict heavily the size and scope of any development at Lye Green. believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5493012 Please attach any supporting evidence
Person ID 1220603 Full Name Jane Birchenough ID 3109
9554 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as
9555 precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not Is the spatial policy (SP SP1) for sustainable development effective and consistent with the plan©s other believe this policy to be proposed uses of Green Belt land to meet housing needs specifically at Lye Green? effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not There is an acknowledged funding gap form the Community Infrastructure Levy(CIL) for infrastructure of believe this policy in between £179m and £231m - Can this be justified or even legal?
9556 consistent with the National these contributions are unquantifiable because much of the costs related infrastructure is not even specified Planning Policy Framework and is awaiting the preparations of ©masterplans© for each site. Feb 2019 please explain why Do you consider it in accordance with the NPPF to remove land from the Green Belt for housing, especially policy SP BP 2 which relates to land North East of Chesham at Lye Green? The local plan predicts an increased carbon footprint of +21% which is completely irresponsible. Finally, are you satisfied that "Exceptional Circumstances" exist for redefining green belt boundaries such as Lye Green - Policy SP BP2 - and removing numerous villages from green belt or permitting "infilling of GB villagfes" as proposed in policies SP PP1 and DM PP1(bearing in mind the courts have held that housing needs alone are NOT "exceptional circumstances") are in accord with the National Planning Policy Framework. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222197 Full Name Neil Cooper ID 3769 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be
9557 as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would
9558 modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not I do not feel this site is effective in this sense the huge number of people settling here will choke our local believe this policy to be community (GP surgeries, shops, roads, sewerage system) where is the extra provision? effective please explain why. PAa - Please specify as Further studies and consultation with community leaders (including the doctors!) To understand how we precisely and succinctly as could all manage this larger increase in population. possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222201 Full Name Saskia Reed ID 3619 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant,
9559 including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s),
9560 do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not No infrastructure is in place at Lye Green for the introduction of so many houses.Yes, more housing is believe this policy to be needed - especially social housing but the amenities to accommodate this amount of housing are not in justified please explain why place. Lycrome road and Lye green road are not suitable fort he amount of extra traffic it would generate. The school at the end of Lycrome road has been demolished and replaced with a large number of houses. Why not use brownfield sites where the infrastructure is in place? Lye green is a small hamlet in a quiet location which has been used for farming and recreational activities for years. The idea of introducing the Green belt was to separate town from countryside and prevent urban sprawl.The footpaths are in constant use by dog walkers and people come to enjoy the countryside for many activities. There is an abundance of wildlife in the area. Their habitat would be destroyed. At the moment, the combination of Chesham, a small but busy market town and the surrounding countryside seems ideal. Why would you relax the planning laws on Green Belt policy when it has worked well to protect the villages surrounding Chesham,. Gradually the land would be built on leaving no protected green belt. Surely councils should be responsible for providing a good mixed community for benefit of everyone. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222202 Full Name Christine Stone ID 3580 Order 236 Number 11.3
9561 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible.
9562 Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not The whole area of the proposed planning is farmed green belt land and has not been fallow all the time we believe this policy to be have lived here. The fields are divided by fencing or hedges and footpaths criss/cross over the land. This is justified please explain why also ideal for wild-life and we frequently see deer, badgers, foxes and know other small mammals live there. There are also a wide variety of birds attracted by the farmland space, This is therefore also an asset to the community as a whole with its clean air, space and wellbeing and a threat to losing our wildlife. Originally the proposal was for 900 houses plus community hub and now this has been reduced to 500. Does this mean there is not such demand for housing? Has the development of building been considered on Brown field sites in Chesham, with more amenities, i.e shops, doctors and rail station and buses closer to the town. Surely this is the first port of call. Any number of housing on the perimeter of Chesham would amount to more transport in and out of the town. Our town is already congested and not enough car parking, yet I understand building on some car parks is proposed in the overall town plan. The proposal for a shop as well as housing on the site would not be sufficient for all peoples need, so presumably frequent visits to the town would be necessary. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why.
9563 PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222269 Full Name Mrs Pamela Wignall ID 3586 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its
9564 legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Site selection methodology is not appropriate. Lye Green is around 1.5 miles from the centre of Chesham. not believe this policy to be Even though a shop is planned for the site, people will inevitably need to travel into or through Chesham. positively prepared please This is going to add a huge number of vehicles on roads that are already congested at the start and end of explain why the school and working day. I have already been finding it difficult to drive out from my house at those times for a number of years, and driving into or through Chesham at those times is endlessly frustrating and slow.
9565 And then there is the air pollution in the centre of Chesham at those times. Chesham is in desperate need of a bypass road. That would solve so many problems. Giving up one of the many rights of way that are in this area, even with all the issues of crossing private land would be well worth it to create such a bypass, with the route from Amersham to the A41 being the one that would remove much of the through traffic. Without such a change any plan to build more homes in Chesham is not a practical prospect. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5498178 Please attach any supporting evidence
Person ID 1221403 Full Name Mrs Pamela Hadley ID 4324 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details
9566 Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has
9567 met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Brownfield land should be used before we take away more green. Especially land which is in agricultural not believe this policy to be use. positively prepared please The area is completely unsuitable for an increase in housing especially as all the traffic will then be funneled explain why to an area of Broad Street where air quality is already known to be exceptionally poor. The traffic in this area is particularly heavy every day. Frequently almost a car park rather than moving. The fact that Chesham is in a valley and all traffic has therefore to be funneled down to the bottom of the valley naturally preludes it from too much expansion without gridlock. In any event Chesham cannot cope with such an increase in households unless the infrastructure particularly water supply and sewage system is completely upgraded first. Also more parking when the average home seems to need two or three parking spaces. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5497663 Please attach any supporting evidence
Person ID 1222300 Full Name Mr Michael Browne
9568 ID 3666 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its
9569 alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do My initial impression on reading the Local Plan proposed by the Chiltern District and South Bucks councils not believe this policy to be is that their concern is to build as many houses as possible wherever is easiest. The proposal to build 500+ positively prepared please homes on land at Lye Green, in the Green Belt, in a precious area which has been recently designated an explain why `Asset of Community Value' and from where access to the town is via steep hills 2.5 Km below, is difficult to understand. Access would be by car or intermittent bus service both of which would create more traffic congestion and increase environmental pollution of the existing adjacent residential areas and the town centre. The environmental pollution levels along Berkhamsted Road in the valley are already above recommended safe levels. The proposed Local Plan by the Chiltern and South Bucks Councils also fails to meet several of its own important criteria which are key to successful and appropriate development. It is evident from the proposals that the overriding question to be answered is ªWhere on earth can we put 500+ homesº. In Section 3.5 Strategic Objectives' paragraph 3.5.2 the plan states as follows ± ªTo have plan-led developments which will secure balanced sustainable growth or development commensurate to deliverable local needs and taking into account environmental, social and economic needs and restraintsº. This, in my opinion, has not been adequately demonstrated by the proposed Local Plan. A Masterplan prepared by the community led group Chesham Renaissance CIC has been formulated by local interests with local knowledge and widely supported by the residents and commercial interests of Chesham. The Chesham Renaissance proposals approach the requirement for more housing by making best use of those parts of Chesham needing rejuvenation, e.g. brownfield and deprived areas first, moving incompatible industries to the outskirts of the town and building genuinely affordable homes nearer the town centre, reducing the need for vehicular transport and thereby not adding to transport costs or increasing pollution levels. Regrettably Chiltern and South Bucks councils have not seen fit to include this valuable input in their consultations prior to producing their Local Plan although the Masterplan was available. Paragraph 3.4.9 states that ªwhere new development occurs (it is necessary?) to have a clear understanding of the infrastructure implications and to ensure that the required new or improved infrastructure is planned and as far as is possible delivered in a timely manner so as to avoid periods of infrastructure deficit, as an integral part of securing developmentº.
9570 It should be emphasised that infrastructure includes not only Roads and Sewers but also Schools, Medical and Leisure facilities, Emergency services, Transport facilities and most importantly, Water. It is not evident from the Local Plan that these essentials have been adequately considered. The Chilterns are (or maybe soon to be was) known for a geologically rare feature, namely its chalk streams. These chalk streams are dependent for their water supply on the replenishment of the aquifers.The increase of building in the Chilterns has resulted in a heavy water demand, particularly for domestic use. Affinity Water, the supplier for the area, has no other natural supply and, as a result, abstracts 60% of its water from the aquifers beneath the Chilterns. The water usage of the present population of the area has already had a seriously detrimental effect on this natural resource and, with a seasonal lack of rainfall, the chalk streams have little hope of flowing again and the proposed addition of 500+ houses will only exacerbate this already dire situation. Paragraph 3.5.7 ªEstablish a new strengthened Green Belt boundary that will continue to meet natural Green Belt purposes and prevent inappropriate developmentºThis is almost meaningless and is in no way reassuring. The present proposals in the Local Plan clearly illustrate that the existing well established Green Belt boundaries are not secure and the `reservation' of a further area of the Green Belt only illustrates the truth of this. The increase in population generated by the proposed housing would create a need for more employment, leisure facilities, shops and essential services, as mentioned in the infrastructure requirements above. In a town the size and location of Chesham there is a restricted opportunity for a significant increase in local employment to meet those needs. It is therefore logical to assume that some of the new residents would need to travel further afield, possibly by train, thus making the retention of the station carpark essential which would negate the Local Plan proposal for the station car park being developed for other purposes. The expected increase in population caused by the 500+ new houses would also create a greater use of the existing retail facilities and thereby an increased need for retention of the existing car parking.Thus proposals to redevelop the Star Yard carparks for retail use conflict with this need for car parking in an area close to the shopping centre. The proposals contained in the Local Plan show an acknowledged funding gap from the Community Infrastructure Levy (CIL) of between £179m and £231m which could result in only part of the plan being implemented. Based on the observation of previous projects those elements which were designed to make such a scheme more palatable, will be either omitted or downgraded to keep within budget. The Chilterns has been designated as Area of Outstanding Natural Beauty. But It has already been despoiled by the HS2 project which is destroying several ancient woodlands and miles of beautiful countryside and producing no benefit to the area it passes through. Now It is further proposed to build on precious Green belt -the lungs of the towns it surrounds, in opposition of the wishes of the people affected. All this after pledges in the Conservative Party manifestos of 2015 and 2017 to protect the Green Belt with no mention of building houses on it. The purpose of the Green Belt has conveniently been forgotten for the purposes of expediency. It must not be destroyed. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
9571 Policy-level file upload - 5498240 Please attach any supporting evidence
Person ID 1222306 Full Name Jeremy Elverson ID 3679 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications
9572 to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do This area for development does not meet the area©s objectively assessed needs and disregards alternative not believe this policy to be plans that have been proposed that would have a much wider and more beneficial effect on the town positively prepared please explain why PP Mods - Please specify as Developing alternative sites would deliver the housing where it was needed and avoid the development of precisely and succinctly as much loved green spaces. The site will only add to the traffic on Berkhampstead Road and Broad Street and possible how you would therefore the air quality as home owners would need to use these roads to access their school, medical and modify this policy to improve town centre requirements its alignment to this test of soundness. Policy 1 - If you do not I would adopt some or all of the Chesham Masterplan put togther by Chesham Renaissance group as this believe this policy to be gained widespread local support. justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why.
9573 PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not It disregards reasonable alternatives believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as adopt some or all of the Chesham Masterplan precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222369 Full Name B Healtharke ID 3771 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its
9574 legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Re: Proposed Green Belt site - Lye Green. not believe this policy to be I am writing to you to express my dismay at the prospect of 500 houses being built in Chesham on Green positively prepared please Belt land. explain why My understanding was that dividing land into Brownbelt and Greenbelt was to protect our countryside for future generations.
9575 Once an application for building on Green Belt is passed, however small a plot, this opens the door for future entrails on the land as it will be argued by developers that a precedent has been set! I will not go into further detail or reasons as to why I am against this project but would ask that you reject this proposal! PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222412 Full Name Mrs Janet Rance ID 3819 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details
9576 Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has
9577 met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do This site is 2kms from the town centre and despite planners believing everyone can walk to the centre and not believe this policy to be underground station they fail to take into account that we are in the Chiltern HILLS. Public transport is hourly. positively prepared please Nashleigh Hill is considered a challenge for top athletes who cycle the route every weekend thus holding up explain why the traffic as there is no room to overtake. Chesham has set up its own rescue service for this hill as during icy weather cars are abandoned and local volunteers provide towing service for drivers. At least 1,000 extra cars will be drawn to this site.The A416, with an AQMA corridor, runs from Ashley Green through to Amersham. Traffic from this site will generate increased traffic into Berkhampstead Road and Broad Street, the very worst of the AQMA. To quote CDC©s environmental policy, YOU CANNOT EXACERBATE AN EXISTING AQMA NOR CREATE ANOTHER. Look a the pinch point in White Hill running between the Grammar School and Victoria Road, surely a prime candidate for another AQMA. Virtually all roundabouts along the A416 operate at capacity the infrastructure is lacking. It is not sustainable. The Lepus sustainability report states that:- Negative effects to:- N35 Biodiversity, N36 Landscape, N37 Nature Conservation, N38 Poor Transport Links, congestion leading onto the AQMA. N39 and N40 good quality farmland loss. N43 2.5kms from Chesham undeground station, the second busiest station on the metropolitan line. No spare seats on any commuter trains. No extra capacity on the line. Hourly bus service, car required because of hills. Car park being built on-nowhere to park. Therefore, drive to Amersham. N44 Unmet housing need is not "exceptional circumstances". N45 Health - we had no GP for two years. A & E is at Stoke Mandeville, poor bus service. Lane through villages to close due to HS2. Extra travelling time on A41. N46 No local employment within walking distance. This is an overspill area from London, purchasers will be from that area. A large chunk of the Mash Farming estate would disappear. N49 Pollution will add greatly to AQMA. Local Chesham treatment plant unable to cope with current volume. Main sewer too small to cope. No storage capacity at works, often discharged untreated sewage into River Chess. N59 Soil loss and erosion. Surface water filters through system. N60 Water supply 60% extracted by Affinity. In hot weather only just coping with demand. N61. This site is clay. A nearby development had to pile drive the foundations, the noise and vibrations were intolerable. This site could take 5 years to build. Air source pump heating would create permanent noise pollution. N62 where will the surface water go? Thames Water are concerned at the volume of surface water on this clay site, currently filtering water down into the town. The Enviromental Agency has pronounced Chesham as being "too wet already". Although CDC wish to remove the whole site from the Greenbelt they propose to develop just part of it. Will they then cherry pick in later years to achieve the 900 homes they were originally looking for? There is currently an application to have this land turned into an Asset of Community Value. A decision is imminent. This land has been used for decades by local people not just dog walkers but as a social area and every weekend is used by the Duke of Edinburgh Award Scheme participants from London. The farmer, whose family have farmed here for decades, does not wish to sell all the land, deliverability is, therefore, in doubt. There will, of course, be an increase in water demand for the extra population (see attached photograph - River Chess). Milton Keynes is the current beneficiary of the majority of water extracted from the Vale Brook. MK is set for another 26,500 homes. Will we have a negative supply of water? Defra has brushed aside such concerns passing responsibility to the Water Companies. It is noted that CDC wish to see ground source heat pumps where possible. It would, of course, freeze the land should this methodbe used at the Lye Green Site. Using air heat source pumps would produce noise pollution and frighten away the multitude of wildlife affecting the biodiversity, should any remain following the piling of this site to provide homes. CDC have admitted that the plan will increase carbon emissions by 21% plus. Legally, it has been proven that unmet local housing needs of an area are not themselves exceptional circumstances. In April 2020 we will become a Unitary Authority. To the north of the County there is ample land available to build without the necessity to release greenbelt in the south. A culvert runs through the town, some repairs were carried out urgently when the surface of the market square collapsed. It currently runs under the shops (retailers are responsible for the cost of repairs) with an undersized sewer running parallel. I have personally spoken to the project manager at Thames Water who advises me that the sewer is too small and they are extremely worried about surface water at Lycrome Road impacting the Town Centre.
9578 Thames Water, together the enviroment agency have hosted many meetings regarding the sewer works is Latimer Road. They will confirm there is no spare capacity (there used to be a standby tank for flooding) for storing flood water only the ability to increase the speed of purification. Raw sewage is released into the Chess and onto farmland in Waterside and Latimer. The release of Green Belt/infilling at Ashley Green, Whelpley Hill, Botley, Ley Hill, Cholesbury and Hawridge will all lead directly into Chesham from this side of the town. Hyde Heath, South Heath, Ballinger Common, Chartridge The Lee will all filter down into the Town Centre. It will create yet more traffic to the "mother" town all requiring facilities within Chesham.Taking away car parks in Chesham will not encourage walking, cycling or buses the villages being too far out - no pavements for walking, hills too steep for cycling and infrequent buses. From Lycrome Road the first bus of the morning is 7.02 and the last bus from Chesham Broadway is 20.16. There appears to be a substantial amount of retail space, using two of our current car parks. Where then will we park to access the shops? A trip to Waitrose or Sainsbury©s usually involves carrying heavy bags - 2km up a hill? It appears that this town, eats, drinks, has its hair and nails done with very little else in between. There are many empty shops, even vacated by charity shops - three have disappeared since the increase in business rates. Provision of an on-site retail unit does not necessarily mean the facility will be taken as many new development sites lay provision for extra amenities and lay vacant/undeveloped for years.Yet again, what if Aldi/Lidl rent the site, what will be the volume of cars coming though the AQMA? Why then take away car parking for commuters and shoppers to provide yet more shops that will sit empty for years. This is inconsistent and unsustainable. (Annotations attached to pictures) Plan showing A416 running from the A41 through to Amersham. Arrows show direction of traffic from villages to the "mother" town. Photographs showing: Main road into the town and AQMA. Hourly buses, must be super fit athlete to ride up this hill. No space for cycle track so athletes at weekend (an international race used this route five years ago and ever since it has become a challenge for other athletes) block the road as there is no space to overtake. This road has a volunteer service in icy weather to tow abandoned vehicles. One badly parked vehicle along the A416 causes gridlock. Photograph showing: Meades Water Gardens. Over abstraction has resulted in "probably the best chalk stream in the world" dying. Defra©s response - "It©s up to the Water Companies". Photographs showing: White Hill, considered too minor by BCC to grit in winter until recently. A catastrophe on the hill caused gridlock in the town. This road would take a considerable proportion of the extra traffic from the Lye Green site and villages would produce. There is no room to widen this road concerned this could become a new AQMA as traffic already queues into the town centre during rush hours. One badly parked delivery van causes gridlock. No cycling and no buses on this hill. Photograph showing: view from Kitty©s Bridge, waterside. As a child, my school was just to the right of this picture and many a day we would wade through the flooded water. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not The Lye Green/Lycrome Road site is considered to be a "Lung" to counteract the very high pollution levels believe this policy to be within the town. Taking away this amenity cannot be justified or sustainable and certainly not in line with justified please explain why Government policy. It will also produce sprawl merging Lye Green with Chesham. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not It was a considerable shock to discover the proposed plan published just 24 hours prior to the planning believe this policy in committee meeting. There has been no consultation regarding the villages. A distinct lack of democracy I consistent with the National believe. Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve
9579 its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222443 Full Name Unknown 132 Lye Green Road ID 3880 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible.
9580 Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Re: Proposed development of land NE of Chesham not believe this policy to be I wish to object to the above proposed development on the following grounds: positively prepared please explain why Green Belt Green Belt status should not be removed and used for housing development when adequate brown space is available. Green Belt land is intended for use and enjoyment of future generations and once removed from Green Belt it cannot be restored. Land These fields are farm land and used for crops and grazing of cattle and sheep. My property initially had a style to fthe field at the rear. There is also a substantial amount of wildlife in and around these fields which should be protected Pollution Pollution levels in the town already exceed permitted EU levels. This would increase substantially with the amount of extra vehicles expected to pass through the town. Probably every property would have at least one vehicle-an extra 500 vehicles. Roads There is only one road through the centre of Chesham. Traffic is already gridlocked and at any time of day it is quite normal for traffic to be at a standstill for quite a distance on the approach to Chesham on the Amersham Road and in Berkhamsted Road and Broad Street. Car Parks
9581 I understand one of the town car parks and other properties are to be turned into shops. Chesham already had empty shop premises. It is unnecessary to build more. More shops would attract even more vehicles into the town resulting in further traffic chaos and pollution. Sewage We are told that Chesham©s sewerage system is already at full capacity. How will this be resolved? Travelers site It surely cannot be sensible to provide a travellers site adjacent to housing and I strongly object to this proposal. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222463 Full Name Unknown (London Road) ID 3930 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID
9582 Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination
9583 Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Building on or near Green Belt villages is a very silly idea, it will ruin the countryside. Building in Green Belt not believe this policy to be is wrong, the rest of the world is not going to feed us, we need green fields to grow food. Nashly Hill both positively prepared please side for building on New Road Old Amersham School Lane, London Road. explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1221530 Full Name Marilyn Eastlake ID 3310 Order 236 Number 11.3
9584 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible.
9585 Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I am writing to strongly object to the Draft Local Plan for 500 houses, a shop (only the one!?) and 15 Travellers not believe this policy to be Pitches to be built on GREEN BELT LAND north-east of Chesham. positively prepared please The VERY NARROW roads into Chesham that would be most affected by this overdevelopment (i.e. White explain why Hill, Eskdale Avenue and Nashleigh Hill) are already over-used and unsuitable for the additional numbers, as are the other local affected roads (Lye Green Road and Lycrome Road). PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not This Local Plan is far from sound and also is far from legally compliant. As has been pointed out to all and believe this policy to be sundry, there are plenty of Brown Sites available for development in Chesham which are more than justified justified please explain why and effective. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National
9586 Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1221532 Full Name Mr Gordon Eastlake ID 3312 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you
9587 consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The VERY NARROW roads into Chesham that would be most affected by this overdevelopment (i.e. White not believe this policy to be Hill, Eskdale Avenue and Nashleigh Hill) are already over-used and unsuitable for the additional numbers, positively prepared please as are the other local affected roads (Lye Green Road and Lycrome Road). explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not This Local Plan is far from sound and also is far from legally compliant. As has been pointed out to all and believe this policy to be sundry, there are plenty of Brown Sites available for development in Chesham which are more than justified justified please explain why and effective.
9588 Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
9589 Person ID 1221538 Full Name Mrs Margaret Hildreth ID 3373 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness?
9590 Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The Green Belt site NE of Chesham (SP BP 2) is not a sustainable location. It is over 2Km away from the not believe this policy to be train station and slightly further still from the town centre but anyone who cares to walk or cycle this distance positively prepared please also has to negotiate a steep hill too. Such an unsustainable location cannot be made sustainable merely explain why by upgrading a couple of public footpaths within the site into bridleways to facilitate cycling. Neither does adding a bus stop address the geography or topography of the area especially if the promised enhanced bus service (which is already infrequent) either does not materialise or if it subsequently fails to be maintained after a few years. Further doubt is cast upon the ªsoundnessº of this Plan by virtue of there being conflicting policies within it. The Council seem to think that the Green Belt site NE of Chesham is sustainable and provides easy access to public transport including the tube station yet the same Plan promotes a considerable increase in retail development in the town (local draft plan policy SP EP3) , part of which would be built on the very car park that serves the Chesham tube station. This is inconsistent and unsound. The land is also potentially an Asset Of Community Value and upon confirmation of this designation it would afford a community group the right to bid for the land. The community group (Brown Not Green) have stated their intention is to preserve the land given that many hundreds of local people have habitually used the fields at Lye Green as of right for various informal outdoor recreational purposes. These uses themselves may mean that many local individuals may have acquired easements over and across the land through prescription (20 years uninterrupted use) not least of whom would be the many private residences bordering the fields that have rear garden gates onto the fields at Lye Green. These easements and prescriptive rights may render the land very difficult to develop and make i undeliverable in planning terms. This land also provides an important habitat for wildlife that will be threatened by development of this land. It is perverse that the Local Authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Plan is unsound. PP Mods - Please specify as I refer to the comments previously submitted but in summary would advocate that; precisely and succinctly as
9591 possible how you would All other options are fully explored including increased density of development of brownfield land and the modify this policy to improve policies emerging from Chesham Masterplan and the Chesham Renaissance CIC. its alignment to this test of Green Belt land should only be considered when all other options are exhausted and in any event the soundness. proposals for developing land NE of Chesham (policy SP BP 2) should be removed as it is an unsustainable location the development of which will cause harm to the wider town including loss of an asset that improves the well-being for the community. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not For this Plan to be sound it must also be effective. Unfortunately, further review of the proposal to remove believe this policy to be land NE of Chesham at Lye Green from Green Belt designation is not effective as there are serious questions effective please explain why. about the deliverability of this land. The main landowner is a farmer who has asserted publicly and in a letter to the editor of Your Chesham, that he is not prepared to release all of the land in his ownership for development. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not The foregoing also points to flawed methodology of Green Belt site selection used by the Local Authority, believe this policy in which is neither effective, justified nor consistent with national policy and as such is unsound. Specifically, consistent with the National the selection of the land NE of Chesham at Lye Green (policy SP BP2) for removal from Green Belt designation Planning Policy Framework is inconsistent with National Planning Policy Framework (NPPF). Feb 2019 please explain why Paragraph 136 of the latest NPPF asserts that Green Belt boundaries should only be modified in ªexceptional circumstancesº. The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances. The Council engaged third party consultants to undertake the Part 1 Green Belt assessment and they identified numerous sites for ªfurther considerationº where exceptional circumstances ªmightº exist but expressly recommended further review of their assessment of each site against the 5 purposes of land being in Green Belt of all these sites. Unlike the neighbouring Local Authorities, the Part 2 Green Belt assessment was not undertaken by third party consultants but by the Local Authority itself who notably then did not undertake all the recommended reviews of each site including the land NE of Chesham at Lye Green (SP BP 2). Accordingly, this oversight in the Part 2 Green Belt assessment placed premature focus and fixation on releasing land at Lye Green NE of Chesham from Green Belt designation. The subsequent identification of the Chesham site for release is therefore unjustified. Another aim of Green Belt land stated in NPPF paragraph 134, is to prevent neighbouring towns and settlements from merging into one another.The Green Belt land NE of Chesham performs exceptionally well in maintaining a distinct separate between settlements of Chesham & Lye Green as well as helping to maintain separate identities of other nearby communities at Orchard Leigh, Botley, Whelpley Hill, Ashley Green. It is perverse and inconsistent with national guidance to allocate this land for removal from Green Belt in light of these facts especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if earmarked for development. A further aim of Green Belt designation stated in the NPPF at paragraph 134 (e) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. By allocating Green Belt land NE of Chesham for development, undermines this aim within Chesham. A community lead not for profit organisation called Chesham Renaissance CIC has been striving to create Chesham Masterplan that would not only provide many genuinely affordable homes in more sustainable locations nearer the town centre, but which would also regenerate some of the more deprived wards within Chesham. The Local Authority's proposals (policy SP EP3) are inconsistent with this local initiative and are therefore also inconsistent with national guidance and are consequently unsound. The Council have asserted that Government planning policy requires local councils to review Green Belt boundaries when considering how to accommodate the development needed in their areas. Just because the Council may be required to look, does not mean the Council should review Green Belt boundaries which as previously stated should only be modified in ªexceptional circumstancesº. National Planning Policy Framework (NPPF) as revised only last year, states in paragraph11 (b) I, directs ªplan makersº to create policies that are required in Local Plans for housing and other uses unless Framework policies (expressly including Green Belt) ªprovides a strong reason for restricting the overall scale type or distribution of development in the plan areaº Accordingly, I submit that given all of the above the land being proposed for release from Green Belt designation around Chesham is unjustified and contrary to national guidance. I feel the land NE of Chesham is an unsustainable location for development, that has been habitually used by the community for improved health & wellbeing for decades and the land performs well against Green Belt aims and objectives. Exceptional circumstances for reviewing Green Belt boundaries at this location, either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by Govt Policy and therefore the plan is unsound.
9592 Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222527 Full Name Fiona Harding ID 4008 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant
9593 legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not I believe the draft Local Plan is not legally compliant because it has not demonstrated sufficient regard to believe this policy to be the National Policy and guidance issued by the Secretary of State. justified please explain why The National Planning Policy Framework (NPPF) together with other guidance issued by the Government is also supported by recent ministerial statements that have made it clear that Local Authorities must demonstrate they have exhausted all options before considering revision of Green Belt boundaries. This Local Plan is seeking substantial modifications to Green Belt boundaries including the removal of Green Belt designation of 13 areas within the Districts as well as modifying the Green Belt status of many local villages.
9594 I contend this draft Local Plan has not demonstrated that all other options have been fully explored and as such this Plan is not justified, sound or in accordance with National Policy and accordingly is not legally compliant. Furthermore that Paragraph 11 b) of the NPPF (and the footnotes thereto) require Plan Makers to provide for objectively assessed needs for housing and other uses UNLESS the application of Framework policies (including Green Belt) provide a strong reason for restricting the overall scale, type or distribution of development in the plan area Chiltern District & South Bucks are significantly constrained by development policies such as Green Belt & Areas of Outstanding Natural Beauty (AONB). The Local Plan is therefore inconsistent with National Guidance and as such it is not legally compliant for the Local Authority to claim that housing needs justify a review of these same Green Belt boundaries. Policy 2a - Please specify as The Plan should be modified as follows; precisely and succinctly as Co-operating with other nearby authorities. Not just Aylesbury. It is simply unsatisfactory to assert this cannot possible how you would be done because they are different Functional Market Areas and that co-operation is not necessary. modify this policy to improve its alignment to this test of Exploring such wider co-operation may result in further housing needs being taken elsewhere. soundness. A more detailed appraisal of brownfield land opportunities should be undertaken. Some brownfield opportunities have been ignored or missed. Closer scrutiny of alternative options for housing delivery should be explored (such as Chesham Masterplan by CIC Chesham Renaissance). Green Belt boundary reviews should only be considered after all other reasonable alternatives have been exhausted. In the face of NPPF guidance and a more thorough appraisal of Green Belt sites being considered, it may then be necessary to conclude that it is not possible to identify poor performing Green Belt sites that can accommodate all the OAN for housing. Consequently it may be necessary to accept that a lower housing provision figure is appropriate. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5499139 Please attach any supporting evidence
Person ID 1221978 Full Name Mrs B A Land ID 3438 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of:
9595 Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is
9596 incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do If business properties are not needed why do we not build residential properties in brown field sites for the not believe this policy to be elderly to be close to these amenities, thus releasing larger properties for families. Why has a boarded piece positively prepared please of land in the high street been allowed to stay unused for so long. Are the builders wanting to build 4 & 5 explain why bedroom houses when 1,2 &3 bedroom properties are needed at reasonable prices? PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222011 Full Name Lesley Sims ID 3482
9597 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as
9598 precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not Should this project be allowed it will fundamentally breach a law that has protected green belt land for many believe this policy in generations.
9599 consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222014 Full Name Donna Turns ID 3484 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness?
9600 Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why
9601 Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not Should this project be allowed it will fundamentally breach a law that has protected green belt land for many believe this policy in generations. consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222016 Full Name Howard Wood ID 3486 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to
9602 make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this
9603 to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not Should this project be allowed it will fundamentally breach a law that has protected green belt land for many believe this policy in generations. consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222018 Full Name Dala Hole ID 3488 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name
9604 Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination
9605 Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not Should this project be allowed it will fundamentally breach a law that has protected green belt land for many believe this policy in generations. consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222021 Full Name A R Rings ID 3490 Order 236 Number 11.3
9606 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible.
9607 Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not Should this project be allowed it will fundamentally breach a law that has protected green belt land for many believe this policy in generations. consistent with the National Planning Policy Framework Feb 2019 please explain why
9608 Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222023 Full Name A Beniton ID 3492 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant
9609 legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve
9610 its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not Should this project be allowed it will fundamentally breach a law that has protected green belt land for many believe this policy in generations. consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222025 Full Name Valentina Demino-Grant ID 3494 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance?
9611 Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible
9612 Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not Should this project be allowed it will fundamentally breach a law that has protected green belt land for many believe this policy in generations. consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222029 Full Name Sarah Norman ID 3832 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details
9613 Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has
9614 met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The main consideration is not whether to remove Green Belt to Brown Belt but to ensure that the infrastructure not believe this policy to be to deal with an increase in housing will be implemented by developers and councils with a significant positively prepared please contribution from the government. explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222664 Full Name Mr Richard Skepper ID 4131 Order 236 Number 11.3 Title Policy SP BP2 - Chesham
9615 Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible.
9616 Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The Councils have stated that release of some Green Belt is necessary as part of an overall three part not believe this policy to be strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported positively prepared please proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where explain why sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. I question the soundness of such a general policy and whether all the brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites and in particular the Green Belt site NE of Chesham at Lye Green. The development of such Green Belt sites involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient and unfunded. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham cannot accommodate any significant highways improvements anyway due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion, with further worsening air quality. Air pollution is a particular concern in Chesham due to the already poor air quality along Berkhampstead Road where there is a designated Air Quality Management Area that already is recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will generate more traffic will make the air quality even worse and insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable nor justified nor is it in accordance with Govt policy. The Green Belt site NE of Chesham (SP BP 2) is not a sustainable location. It is over 2Km away from the TFL station and slightly further still from the town centre but anyone who cares to walk or cycle this distance also has to negotiate congested narrow roads and a winding steep hill. Such an unsustainable location cannot be made sustainable merely by upgrading a couple of public footpaths within the site into bridleways to facilitate cycling. Neither does adding a bus stop address the geography or topography of the area especially if the promised enhanced bus service (which is already infrequent) either does not materialise or if it subsequently fails to be maintained after a few years. Further doubt is cast upon the ªsoundnessº of this Plan by virtue of there being conflicting policies within it. The Council seem to think that the Green Belt site NE of Chesham is sustainable and provides easy access to public transport including the tube station yet the same Plan promotes a considerable increase in retail development in the town (local draft plan policy SP EP3), part of which would be built on the very car park that serves the Chesham tube station, and is already oversubscribed. Parking in inappropriate places up to ¾ ml form the station is already a problem. This is inconsistent and unsound. The land is an Asset Of Community Value and upon confirmation of this designation it would afford a community group the right to bid for the land. The community group (Brown Not Green) have stated their intention is to preserve the land given that many hundreds of local people have habitually used the fields at
9617 Lye Green as of right for various informal outdoor recreational purposesThese uses themselves may mean that many local individuals may have acquired easements over and across the land through prescription (20 years uninterrupted use) not least of whom would be the many private residences bordering the fields that have rear garden gates onto the fields at Lye Green. These easements and prescriptive rights may render the land very difficult to develop and make i undeliverable in planning terms. I and my family have have used this area for 25 years and shall be making a submission to the Bucks Rights of Way Team in support of recognising several of these easements as rights of way. This land also provides an important habitat for wildlife that will be threatened by development of this land. It is perverse that the Local Authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Plan is unsound. The primary aim of Green Belt land (as recited in NPPF 133) is to prevent urban sprawl and to preserve the openness of the area. The Lye Green site (SP BP2) self-evidently performs this function well and has done so for decades. Another aim of Green Belt land stated in NPPF paragraph 134, is to prevent neighbouring towns and settlements from merging into one another.The Green Belt land NE of Chesham performs exceptionally well in maintaining a distinct separate between settlements of Chesham & Lye Green as well as helping to maintain separate identities of other nearby communities at Orchard Leigh, Botley, Whelpley Hill, Ashley Green. It is perverse and inconsistent with national guidance to allocate this land for removal from Green Belt in light of these facts especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if earmarked for development. A further aim of Green Belt designation stated in the NPPF at paragraph 134 (e) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. By allocating Green Belt land NE of Chesham for development, undermines this aim within Chesham. A community lead not for profit organisation called Chesham Renaissance CIC has been striving to create Chesham Masterplan that would not only provide many genuinely affordable homes in more sustainable locations nearer the town centre, but which would also regenerate some of the more deprived wards within Chesham. PP Mods - Please specify as I refer to the comments previously submitted but in summary would advocate that; precisely and succinctly as All other options are fully explored including increased density of development of brownfield land and the possible how you would policies emerging from Chesham Masterplan. modify this policy to improve its alignment to this test of Green Belt land should only be considered when all other options are exhausted and in any event the soundness. proposals for developing land NE of Chesham (policy SP BP 2) should be removed as it is an unsustainable location the development of which will cause harm to the wider town including loss of an asset that improves the well-being for the community. Policy 1 - If you do not I refer to my comments previously submitted believe this policy to be justified please explain why Policy 2a - Please specify as I refer to my comments previously submitted precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not For this Plan to sound it must also be effective. Unfortunately, further review of the proposal to remove land believe this policy to be NE of Chesham at Lye Green from Green Belt designation is not effective as there are serious questions effective please explain why. about the deliverability of this land. The main landowner is a farmer who has asserted publicly and in a letter to the editor of Your Chesham, that he is not prepared to release all of the land in his ownership for development. PAa - Please specify as I refer to my comments previously submitted precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I believe the draft Local Plan is NOT legally compliant because it has not demonstrated sufficient regard to believe this policy in the National Policy and guidance issued by the Secretary of State. consistent with the National The National Planning Policy Framework (NPPF) together with other guidance issued by the Government Planning Policy Framework is also supported by recent ministerial statements that have made it clear that Local Authorities MUST Feb 2019 please explain why demonstrate they have exhausted all options BEFORE considering revision of Green Belt boundaries. This Local Plan is seeking substantial modifications to Green Belt boundaries including the removal of Green Belt designation of 13 areas within the Districts as well as modifying the Green Belt status of many local villages. I contend this draft Local Plan has not demonstrated that all other options have been fully explored and as such this Plan is not justified, sound or in accordance with National Policy and accordingly is not legally compliant. Furthermore that Paragraph 11 b) of the NPPF (and the footnotes thereto) require Plan Makers to provide for objectively assessed needs for housing and other uses UNLESS the application of Framework policies (including Green Belt) provide a strong reason for restricting the overall scale, type or distribution of development in the plan area Chiltern District & South Bucks are significantly constrained by development policies such as Green Belt & Areas of Outstanding Natural Beauty (AONB). The Local Plan is therefore inconsistent with National Guidance and as such it is not legally compliant for the Local Authority to claim that housing needs justify a review of these same Green Belt boundaries.
9618 It is perverse to claim that the combination of housing need and the presence of significant areas of development constraint policy collectively represent ªexceptional circumstancesº (as required in the NPPF) to justify modification of Green Belt boundaries especially given the NPPF states that one of the key features of Green Belts are their permanence. The Government has also recently confirmed its aim for the UK to have net zero carbon emissions by 2050 and it is noted within the Sustainability Appraisal supporting this Draft Local Plan, that the Plan area is forecast to see carbon emission increase by 21% in the Plan Period. Accordingly, the Plan is inconsistent with Government Policy and therefore not legally compliant. There is also a significant infrastructure funding gap acknowledged within the Community Infrastructure Levy evidence that supports this Local Plan, of between £179m & £231m. Given this infrastructure is vital to ensure that development is sustainable (as also required by the NPPF) this further demonstrates the Plan is both unsound and not legally compliant. Any local resident is painfully aware that transport, educational and NHS services are already running over capacity. The foregoing also points to flawed methodology of Green Belt site selection used by the Local Authority, which is neither effective, justified nor consistent with national policy and as such is unsound. Specifically, the selection of the land NE of Chesham at Lye Green (policy SP BP2) for removal from Green Belt designation is inconsistent with National Planning Policy Framework (NPPF). Paragraph 136 of the latest NPPF asserts that Green Belt boundaries should only be modified in ªexceptional circumstancesº. The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances. The Council engaged third party consultants to undertake the Part 1 Green Belt assessment and they identified numerous sites for ªfurther considerationº where exceptional circumstances ªmightº exist but expressly recommended further review of their assessment of each site against the 5 purposes of land being in Green Belt of all these sites. Unlike the neighbouring Local Authorities, the Part 2 Green Belt assessment was not undertaken by third party consultants but by the Local Authority itself who notably then did not undertake all the recommended reviews of each site including the land NE of Chesham at Lye Green (SP BP 2). Accordingly, this oversight in the Part 2 Green Belt assessment placed premature focus and fixation on releasing land at Lye Green NE of Chesham from Green Belt designation. The subsequent identification of the Chesham site for release is therefore unjustified. The Council have asserted that Government planning policy requires local councils to review Green Belt boundaries when considering how to accommodate the development needed in their areas. Just because the Council may be required to look, does not mean the Council should review Green Belt boundaries which as previously stated should only be modified in ªexceptional circumstancesº. National Planning Policy Framework (NPPF) as revised only last year, states in paragraph11 (b) I, directs ªplan makersº to create policies that are required in Local Plans for housing and other uses unless Framework policies (expressly including Green Belt) ªprovides a strong reason for restricting the overall scale type or distribution of development in the plan areaº Accordingly, I submit that given all of the above the land being proposed for release from Green Belt designation around Chesham is unjustified and contrary to national guidance. I feel the land NE of Chesham is an unsustainable location for development, that has been habitually used by the community for improved health & wellbeing for decades and the land performs well against Green Belt aims and objectives. Exceptional circumstances for reviewing Green Belt boundaries at this location, either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by Govt Policy and therefore the plan is unsound. Policy 3a - Please specify as The Plan needs to be modified by; precisely and succinctly as Co-operating with other nearby authorities. Not just Aylesbury. It is simply unsatisfactory to assert this cannot possible how you would be done because they are different Functional Market Areas and that co-operation is not necessary therefore. modify this policy to improve its alignment to this test of Exploring such wider co-operation may result in further housing needs being taken elsewhere. soundness. A more detailed appraisal of brownfield land opportunities MUST be undertaken. Some brownfield opportunities have been ignored or missed. Closer scrutiny of alternative options for housing delivery should be explored (such as Chesham Masterplan by CIC Chesham Renaissance). Green Belt boundary reviews should only be considered AFTER all other reasonable alternatives have been exhausted. In the face of NPPF guidance and a more thorough appraisal of Green Belt sites being considered, it may then be necessary to conclude that it is not possible to identify poor performing Green Belt sites that can accommodate all the OAN for housing. Consequently it may be necessary to accept that a lower housing provision figure is appropriate. Policy-level file upload - 5500674 Please attach any supporting evidence
Person ID 1222140 Full Name Mrs Sandra Wallington ID 3458 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details
9619 Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence
9620 Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The use of green belt land and nor brownfield ignores all guidelines. The quantity of housing proposed is not believe this policy to be excessive and will do nothing to enhance Chesham or its business and cultural strengths. positively prepared please The number of 500 is not necessary, and overwhelms Lye Green village. The proposals ignore planning explain why requirements to consider all options. The area©s objectively assessed needs are not taken into account ,and no needs from neighbouring areas are taken into account and therefore not accommodated. PP Mods - Please specify as The policy need to be totally reconsidered and to take into account the current needs of the area and those precisely and succinctly as of surrounding areas, as this does not. possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not As no co-operation nor meaningful consultation with local organisations and Chesham Masterplan has taken believe this policy to be place at all, the Duty to Co-operate cannot have been fulfilled. justified please explain why At no time have reasonable alternatives been taken into account and other suggestions and plans have been deliberately ignored. It is clear that CDC want this oversized and unhelpful development to go ahead, with the changes to the green belt, and want no even reasonable objections taken into account.It seems it©s a "done deal" to CDC. The threat to green belt continues if this is allowed to go ahead, as this proposal does not use up all the green belt land available. No one seems to have bothered to explain exactly WHY 500 homes are needed - who is going to use them ? Commuters no doubt, forcing up local house prices, and most likely a total lack of affordable housing for local people. Policy 2a - Please specify as Go back to the drawing board and work out with the relevant local interested people, why this development precisely and succinctly as is even needed. Smaller pockets of brown field, and renevated old buildings are far more sustainable and possible how you would of use to the town. modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not Not effective - no cross boundary strategy exists. believe this policy to be effective please explain why. PAa - Please specify as If there is a need to build on Lye Green, then look more realistically at the numbers that CAN be sustained precisely and succinctly as instead of driving a bulldozer through green belt and communities. possible how you would modify this policy to improve
9621 its alignment to this test of soundness. Policy 3 - If you do not . The correct consultation has not taken place and other plans such as Chesham Masterplan have been believe this policy in ignored. consistent with the National . The plan is not justified in any sense. Planning Policy Framework Feb 2019 please explain why . The proposals will create a totally new town outside of Chesham which ill have a detrimental effect on Chesham and not be part of it due to the size. . Other neighbourhoods should be considered for smaller and relevant development. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222160 Full Name Mr Paul Castaldini ID 3722 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be
9622 as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The current proposals to release Green Belt land to meet the housing targets, generally SP1 and specifically not believe this policy to be SP BP2 Lye Green are not justified from the evidence submitted by the councils. positively prepared please The proposed developments would put increased pressure on all services in the area, there are no significant explain why improvements to the Highways which combined with the topography of the area could indicate even more congestion in the local area not only at peak times but throughout the day time, with raised traffic and congestion there will be a significant increase in air pollution at the times the Government is pledged to reduce pollution.
9623 At times of heavy rainfall the current drainage system cannot contain run off, which less undeveloped plan more pressure is placed on the drainage system putting existing homes and businesses at risk from flooding, something already seen in Chesham. the current infrastructure is hard pressed to keep up with the existing housing businesses yet alone further developments and a wholesale takeover of the Green Belt. The development at Lye Green would put increased pressure on parking in Chesham as new dwellers are unlikely to walk the 2 miles to the station or central Chesham, indeed part of the Local plan under SP EP3 where the plan is to build housing on one of the existing car parks for the underground station thus putting further pressure on already limited car parking in town.Yet another example of un-joined up thinking and planning from this authority. PP Mods - Please specify as I would like to see that all other options are fully and correctly explored, the use of Brown Field sites and precisely and succinctly as policies as shown in the Chesham Masterplan should be followed. possible how you would The use of Green Belt land should only be considered when all other options have been exhausted. The modify this policy to improve development of an unsustainable location will cause great harm to the existing Town and its inhabitants. its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222163 Full Name David Grant ID 3481 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of:
9624 Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is
9625 incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not Should this project be allowed it will fundamentally breach a law that has protected green belt land for many believe this policy in generations. consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222671 Full Name Margaret Johnson ID 4158
9626 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as
9627 precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I write to express my strong objections to the local plan as it applies to Chesham. not believe this policy to be It was horrifying to learn that the excellent vision, expressing the best in planning knowledge, formulated positively prepared please over years by Chesham Renaissance and supported by so many Chesham people, has been completely explain why ignored and overridden. I have not contributed my objection until this late stage because of extreme depression at this utter lack of empowerment for local people, such a goal of the Cameron premiership. The plan for covering acres of green belt by Lye Green above Chesham with the usual housing sprawl is illegal and unsustainable on many grounds. It will seal up important agricultural land, and even more crucially, water catchment for the human water supply, the attempt to preserve the unique chalk stream habitats, and prevention of flooding in Chesham. It will add substantially to the carbon footprint of the town, far from mitigating it, or at least maintaining the current contribution of this green area to climate management. I also support the findings of the River Chess Association and others, that the runoff from a housing development could actually contaminate the water that does succeed in percolating to the aquifer. Paving over a further large area will also exacerbate soil erosion by increasing yet further the silt washed away in drains rather than soaked into the ground. This is another way in which the plan illegally ignores its sustainability obligations. Use of the green belt in an area of Outstanding Natural Beauty will reduce the effectiveness of this Chesham area as a buffer for preserving biodiversity, in addition to reducing the value of the entire area for both the local and wider population's wellbeing and security in terms of climate change and biodiversity. In this regard I support the work of Brown not Green, which again offers a true Vision for the sustainable future of the area which the current plan rides over roughshod. The proposed sprawl, lacking in infrastructure, simply exacerbates all the climate-damaging and welfare-reducing aspects of the current unsustainable lifestyle, while Chesham Renaissance's plan to instead increase density in the town centre would both enhance the social capital of the town, maximise most sustainable use of the transport link into London, and keep the retail sector, and make most artistically effective use of the assets of the historic building in the centre of town.This is in opposition to the unbelievably retrograde step of building redundant, business diluting and ambience-destroying new retail development. The proposed development would not contribute to the supply of social housing as it would be unsuitable for young families and elderly people needing ready access to services.This can only be supplied by providing homes for people where the services are ± within the town envelope. In this respect I fully support the Chesham Society's vision for a future sustainable vibrant and high quality environment for inhabitants to experience.
9628 There is only one thing, before anything is built there are too many cars on the road already. Most days time is spent sitting in queues of traffic. All very frustrating. So get the traffic solved as a priority. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222166 Full Name Ronny Davis ID 3585 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider
9629 the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to
9630 Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I believe the site selection methodology of using the Green Belt land at Lye Green to be flawed. Building 500 not believe this policy to be houses 2.5 miles from the town centre atop a very steep hill, will result in the widespread use of cars by positively prepared please residents to reach amenities in the town centre and tube station. These short journeys by car will only add explain why to the already high levels of pollution present in parts of Chesham. Indeed, Berkhamsted Road has a designated Air Quality Management Area that is already recording air quality that exceeds EU safe levels considerably. Lye Green is not a suitable location to build hundreds of homes.The congestion caused by residents needing to commute through the town, reach the tube station or schools, particularly down White Hill or Eskdale Avenue, will only add to the gridlock that drivers already experience on Berkhamsted Road during rush hour traffic, further worsening air quality. Some highway improvements have been suggested but they are insufficient. Evidence shows that most of the road junctions and infrastructure in Chesham are already operating above capacity. Limited verges and space beside the highway mean Chesham cannot accommodate any significant highways improvements. The Councils plan contains conflicting policies that states that the Green Belt site NE of Chesham provides easy access to public transport, including the tube station, yet the very same plan also promotes the building of shops on the car park that serves the tube station. I believe this to be inconsistent and unsound. Chesham already had two large supermarkets, a butcher and two bakeries. There are empty shops in the high street as well as along Berkhamsted Road. Chesham has many independent cafes and restaurants within its town centre. These, along with the existing shops, library, park and theatre, would be much better served if housing was built within easy walking distance of them. As well as providing recreational use over decades for local people, the land is good quality agricultural land. As such it soaks up rainfall which would otherwise run off the fields as floodwater into Chesham, adding to the problem of flooding on the Berkhamsted Road. As well as being inconvenient for pedestrians and traffic it also leads to the polluting of the River Chess, a fragile ecosystem and globally rare habitat. Brushwood Junior school, with its current 278 pupils, is located on the boundary of the said Green Belt land. In an age where cars are being discouraged or banned from idling or parking near schools, it is irresponsible and enviromentally unsustainable to build 500 homes, which will in turn bring a minimum of 500 cars so close to the school. This will have a detrimental effect on the health of the children and staff of the school. The Green Belt land at Lye Green supports rich biodiversity and provides crucial habitat for many species of birds, insects and mammals, most of which will be driven out if such a development goes ahead. Surely with all we now know and understand about the need to protect the environment, increase tree planting and reduce CO2 emissions, the idea of removing this land from the Green Belt and developing it for housing is completely unjustified, short sighted and irresponsible. PP Mods - Please specify as When Chesham residents were asked by community interest company Chesham Renaissance what was precisely and succinctly as most important to them about where they lived, the overwhelming majority said the AONB status. Increasing possible how you would the population density within the town boundary can protect the Green Belt that surrounds the town. This modify this policy to improve can be achieved by building on existing brownfield sites closer to the town centre where all the facilities and its alignment to this test of amenities are. soundness. Policy 1 - If you do not The proposals to release Green Belt land to meet housing targets are not justified from the evidence submitted. believe this policy to be I question the soundness of such a general policy and whether all Brownfield land that offers a more justified please explain why sustainable location for development have been identified. The plan itself estimates an increase in the districts carbon footprint of 21%.This points to the current proposal as being unsound. Therefore, the development of the Lye Green site NE of Chesham cannot be sustainable, nor justified, nor in accordance with government policy. National planning guidance requires the local authority to consider viable alternatives such as the Chesham Renaissance C/C Masterplan, devised by local people for local people, or to recycle brownfield land for housing. The divegence of the plan from these viable alternatives is inconsistent with local initiative and further suggests the plan is inconsistent with national guidance, ineffective and unjustified. The council employed third party consultants to undertake the part 1 Green Belt assessment, in doing this they identified numerous sites for "further consideration" where exceptional circumstances might exist, but firmly recommended further review of their assessment of each site against the 5 purposes of land being in Green Belt of all these sites. However, contrary to neighbouring local authorities, the Local Authority chose to undertake the part 2 Green Belt assessment itself and in doing so did not undertake all the recommended views of each site, including the land NE of Chesham at Lye Green.This oversight by the local Local Authority
9631 drew sole, excessive focus on releasing the said land from Green Belt designation.Therefore, the identification of the land for release from the Green Belt is unjustified. Policy 2a - Please specify as The Chesham Renaissance C/C Masterplan, a community led scheme, suggests more effective alternatives precisely and succinctly as such as higher densities of housing development on brownfield sites closer to the town centre. This would possible how you would be a more sustainable and enviromentally friendly alternative such as higher densities of housing development modify this policy to improve on brownfield sites closer to the town centre. This would be a more sustainable and environmentally friendly its alignment to this test of alternative, keeping development to land that has been previously built on and which is within the town soundness. boundary. This alternative plan would bring investment to Chesham by building the number and types of housing we need in areas where they will benefit and rejuvenate the town and the more deprived parts of Chesham. Policy 2 - If you do not The removal of the land NE of Chesham at Lye Green from Green Belt is not effective as there are serious believe this policy to be questions around the deliverability of this land. The main landowner has said publicly, including in a letter to effective please explain why. the editor of Your Chesham, that he is not prepared to release all the land for development. The land has also been granted status as an asset of community value, giving a community group the right to bid for the land. It is not effective, justified or in accord with the National Planning policy (policy SP BP2), that Green Belt land designated as an asset of Community Value be developed and undermines the objectives of the Localism Act 2011. This renders this aspect of the plan unsound. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not Selection of the land NE of Chesham at Lye Green for removal from Green Belt designation is inconsistent believe this policy in with the National Planning Policy Framework. Paragraph 136 of the latest NPPF states that Green Belt consistent with the National boundaries should only be modified in "exceptional circumstances".The courts have held that "unmet housing Planning Policy Framework needs of an area are themselves not exceptional circumstances. Feb 2019 please explain why The proposed development of this Green Belt land will destroy the distinctiveness of Chesham and promote urban sprawl into the neighbouring historical hamlet of Lye Green. This would contradict the primary aim of Green Belt land being to "prevent urban sprawl and preserve the openness of the area (NPPF133). The plan also proposes the removal of many neighbouring local villages from Green Belt which could lead to the infilling of others. It is incomprehensible that areas of ANOB could be negatively changed forever in this way. The NPPF paragraph 134 states that another aim of Green Belt is to "prevent neighbouring towns and settlements from merging into one another". The land has been used by the community for improved health and well being for decades and performs well against Green Belt aims and objectives. Exceptional circumstances for reviewing Green Belt boundaries at this location either do not exist or are insufficient to warrant the removal from the Green Belt designation as required by Government policy and therefore the plan is unsound. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222197 Full Name Neil Cooper ID 3766 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID
9632 Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination
9633 Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I am extremely concerned that this local plan is not sound. No one has consulted our surgery (or my colleagues not believe this policy to be at other Chesham Surgeries) to find out the huge impact this will have on local medical care (which is under positively prepared please great pressure due to limited NHS funding at present). Who is expected to care for this extra families? Where explain why are the plans for this? Who has been consulted? PP Mods - Please specify as You need to perform detailed research and propose a Health Care Plan to discuss with all the local providers precisely and succinctly as (that includes the three Chesham surgeries). possible how you would Will the plan include outreach clinics to help the new traveller families due to arrive? modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222197 Full Name Neil Cooper ID 3768 Order 236 Number 11.3
9634 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible.
9635 Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not I do not feel that this plan is justified as it is too large and building on Green Belt site which will harm its believe this policy to be purpose and integrity. I have not seen any justification that such a large site will not cause long term ham to justified please explain why our present community. Policy 2a - Please specify as A more detailed study on numbers over houses that our community could cope with (ie significantly les than precisely and succinctly as 500). possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why
9636 Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222748 Full Name Brenda Coxall ID 4315 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant
9637 legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The Green Belt site NE of Chesham (SP BP 2) is not a sustainable location. It is over 2Km away from the not believe this policy to be train station and slightly further still from the town centre but anyone who cares to walk or cycle this distance positively prepared please also has to negotiate a steep hill too. Such an unsustainable location cannot be made sustainable merely explain why by upgrading a couple of public footpaths within the site into bridleways to facilitate cycling. Neither does adding a bus stop address the geography or topography of the area especially if the promised enhanced bus service (which is already infrequent) either does not materialise or if it subsequently fails to be maintained after a few years. Further doubt is cast upon the ªsoundnessº of this Plan by virtue of there being conflicting policies within it. The Council seem to think that the Green Belt site NE of Chesham is sustainable and provides easy access to public transport including the tube station yet the same Plan promotes a considerable increase in retail development in the town (local draft plan policy SP EP3) , part of which would be built on the very car park that serves the Chesham tube station. This is inconsistent and unsound. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
9638 Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not For this Plan to sound it must also be effective. Unfortunately, further review of the proposal to remove land believe this policy to be NE of Chesham at Lye Green from Green Belt designation is not effective as there are serious questions effective please explain why. about the deliverability of this land. The main landowner is a farmer who has asserted publicly and in a letter to the editor of Your Chesham, that he is not prepared to release all of the land in his ownership for development. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not The Councils have stated that release of some Green Belt is necessary as part of an overall three part believe this policy in strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported consistent with the National proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where Planning Policy Framework sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity Feb 2019 please explain why of the Green Belt. I question the soundness of such a general policy and whether all the brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites and in particular the Green Belt site NE of Chesham at Lye Green. The development of such Green Belt sites involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient and unfunded. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham cannot accommodate any significant highways improvements anyway due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion, with further worsening air quality. Air pollution is a particular concern in Chesham due to the already poor air quality along Bekhampstead Road where there is a designated Air Quality Management Area that already is recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will generate more traffic will make the air quality even worse and insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable nor justified nor is it in accordance with Govt policy. The land is also potentially an Asset Of Community Value and upon confirmation of this designation it would afford a community group the right to bid for the land. The community group (Brown Not Green) have stated their intention is to preserve the land given that many hundreds of local people have habitually used the fields at Lye Green as of right for various informal outdoor recreational purposes. These uses themselves may mean that many local individuals may have acquired easements over and across the land through prescription (20 years uninterrupted use) not least of whom would be the many private residences bordering the fields that have rear garden gates onto the fields at Lye Green. These easements and prescriptive rights may render the land very difficult to develop and make i undeliverable in planning terms. This land also provides an important habitat for wildlife that will be threatened by development of this land. It is perverse that the Local Authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Plan is unsound. The foregoing also points to flawed methodology of Green Belt site selection used by the Local Authority, which is neither effective, justified nor consistent with national policy and as such is unsound. Specifically, the selection of the land NE of Chesham at Lye Green (policy SP BP2) for removal from Green Belt designation is inconsistent with National Planning Policy Framework (NPPF). Paragraph 136 of the latest NPPF asserts that Green Belt boundaries should only be modified in ªexceptional circumstancesº. The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances. The Council engaged third party consultants to undertake the Part 1 Green Belt assessment and they identified numerous sites for ªfurther considerationº where exceptional circumstances ªmightº exist but expressly recommended further review of their assessment of each site against the 5 purposes of land being in Green Belt of all these sites. Unlike the neighbouring Local Authorities, the Part 2 Green Belt assessment was not undertaken by third party consultants but by the Local Authority itself who notably then did not undertake all the recommended reviews of each site including the land NE of Chesham at Lye Green (SP BP 2). Accordingly, this oversight in the Part 2 Green Belt assessment placed premature focus and fixation on releasing land at Lye Green NE of Chesham from Green Belt designation. The subsequent identification of the Chesham site for release is therefore unjustified. The primary aim of Green Belt land (as recited in NPPF 133) is to prevent urban sprawl and to preserve the openness of the area. The Lye Green site (SP BP2) self-evidently performs this function well and has done so for decades. Another aim of Green Belt land stated in NPPF paragraph 134, is to prevent neighbouring towns and settlements from merging into one another.The Green Belt land NE of Chesham performs exceptionally well in maintaining a distinct separate between settlements of Chesham & Lye Green as well as helping to maintain
9639 separate identities of other nearby communities at Orchard Leigh, Botley, Whelpley Hill, Ashley Green. It is perverse and inconsistent with national guidance to allocate this land for removal from Green Belt in light of these facts especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if earmarked for development. A further aim of Green Belt designation stated in the NPPF at paragraph 134 (e) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. By allocating Green Belt land NE of Chesham for development, undermines this aim within Chesham. A community lead not for profit organisation called Chesham Renaissance CIC has been striving to create Chesham Masterplan that would not only provide many genuinely affordable homes in more sustainable locations nearer the town centre, but which would also regenerate some of the more deprived wards within Chesham. The Local Authority's proposals (policy SP EP3) are inconsistent with this local initiative and are therefore also inconsistent with national guidance and are consequently unsound. The Council have asserted that Government planning policy requires local councils to review Green Belt boundaries when considering how to accommodate the development needed in their areas. Just because the Council may be required to look, does not mean the Council should review Green Belt boundaries which as previously stated should only be modified in ªexceptional circumstancesº. National Planning Policy Framework (NPPF) as revised only last year, states in paragraph11 (b) I, directs ªplan makersº to create policies that are required in Local Plans for housing and other uses unless Framework policies (expressly including Green Belt) ªprovides a strong reason for restricting the overall scale type or distribution of development in the plan areaº Accordingly, I submit that given all of the above the land being proposed for release from Green Belt designation around Chesham is unjustified and contrary to national guidance. I feel the land NE of Chesham is an unsustainable location for development, that has been habitually used by the community for improved health & wellbeing for decades and the land performs well against Green Belt aims and objectives. Exceptional circumstances for reviewing Green Belt boundaries at this location, either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by Govt Policy and therefore the plan is unsound. Policy 3a - Please specify as I refer to the comments previously submitted but in summary would advocate that; precisely and succinctly as All other options are fully explored including increased density of development of brownfield land and the possible how you would policies emerging from Chesham Masterplan. modify this policy to improve its alignment to this test of Green Belt land should only be considered when all other options are exhausted and in any event the soundness. proposals for developing land NE of Chesham (policy SP BP 2) should be removed as it is an unsustainable location the development of which will cause harm to the wider town including loss of an asset that improves the well-being for the community. Policy-level file upload - Please attach any supporting evidence
Person ID 1222308 Full Name Mr & Mrs Stronehhs ID 3680 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is
9640 not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is
9641 proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do How can the existing surgeries, schools and most important the roads cope with the influx of more people. not believe this policy to be Green Belt becoming an urban sprawl. positively prepared please explain why Water is overstreched now with the once beautiful river chess dried up due to water abstraction by the water companies. Chesham is already gridlocked with traffic. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222309 Full Name Gemma Thomson ID 3684 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received:
9642 Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance
9643 with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do We support this policy not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not We support this policy believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not We support this policy believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not We support this policy believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
9644 Policy-level file upload - Please attach any supporting evidence
Person ID 1222781 Full Name Mr Douglas King ID 4310 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications
9645 to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I consider the Local Plan to be legally non-compliant. not believe this policy to be I am a lay person however, it seems to me fundamentally unsound to adopt a plan that involves substantial positively prepared please housing developments on the borders of Chesham. explain why Apart from the loss of a substantial community asset (the green fields) that are prized by both local residents and visitors alike, the Local Plan does not provide additional housing in a manner that benefits Chesham. I would ask that reference is made to The Chesham Renaissance Masterplan. Surely it is better to target development in the town centre to minimise additional traffic (the town is already clogged with traffic at some times of the day ± Monday to Saturday) which in turn will keep additional emissions and the detrimental health impacts to a much lower level. I feel the proposals to increase retail shopping are also unsound. The town has struggled to support the existing retail trade, furthermore, as on-line shopping becomes more popular the need for physical premises will diminish rather than increase. A greater density of population in the town centre will ameliorate this trend by creating demand for restaurants etc. However, as we have already seen premises on the High St. will be surplus to retail requirements and available for creating additional housing. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
9646 Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5500793 Please attach any supporting evidence
Person ID 1222784 Full Name Mr Charles Coxall ID 7208 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be
9647 as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public?
9648 Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Please find attached my objections to the planned building of 500 houses on part of Chesham©s green belt. not believe this policy to be Please use brown sites instead of green. We cant afford to lose any agricultural land, nor wooded areas and positively prepared please parks. Not only do we have a duty of care to people, but also to wildlife. Without one, the other will eventually explain why die too!! Once built on, the land is very hard to reclaim again, if ever we needed to. There are many sites all over that could be utilised, without building on green sites.What about wharehouses standing empty for years on end. There is a pub/restaurant on the B485 just outside of Chesham that could provide at least six to ten houses. I know it is not 500, but surely they don©t all need to be in the same place. that is a whole village!!! I believe the draft Local Plan is NOT legally compliant because it has not demonstrated sufficient regard to the National Policy and guidance issued by the Secretary of State. The National Planning Policy Framework (NPPF) together with other guidance issued by the Government is also supported by recent ministerial statements that have made it clear that Local Authorities MUST demonstrate they have exhausted all options BEFORE considering revision of Green Belt boundaries. This Local Plan is seeking substantial modifications to Green Belt boundaries including the removal of Green Belt designation of 13 areas within the Districts as well as modifying the Green Belt status of many local villages. I contend this draft Local Plan has not demonstrated that all other options have been fully explored and as such this Plan is not justified, sound or in accordance with National Policy and accordingly is not legally compliant. Furthermore that Paragraph 11 b) of the NPPF (and the footnotes thereto) require Plan Makers to provide for objectively assessed needs for housing and other uses UNLESS the application of Framework policies (including Green Belt) provide a strong reason for restricting the overall scale, type or distribution of development in the plan area Chiltern District & South Bucks are significantly constrained by development policies such as Green Belt & Areas of Outstanding Natural Beauty (AONB). The Local Plan is therefore inconsistent with National Guidance and as such it is not legally compliant for the Local Authority to claim that housing needs justify a review of these same Green Belt boundaries. It is perverse to claim that the combination of housing need and the presence of significant areas of development constraint policy collectively represent ªexceptional circumstancesº (as required in the NPPF) to justify modification of Green Belt boundaries especially given the NPPF states that one of the key features of Green Belts are their permanence. The Government has also recently confirmed its aim for the UK to have net zero carbon emissions by 2050 and it is noted within the Sustainability Appraisal supporting this Draft Local Plan, that the Plan area is forecast to see carbon emission increase by 21% in the Plan Period. Accordingly, the Plan is inconsistent with Government Policy and therefore not legally compliant. There is also a significant infrastructure funding gap acknowledged within the Community Infrastructure Levy evidence that supports this Local Plan, of between £179m & £231m. Given this infrastructure is vital to ensure that development is sustainable (as also required by the NPPF) this further demonstrates the Plan is both unsound and not legally compliant. PP Mods - Please specify as The Plan needs to be modified by; precisely and succinctly as Co-operating with other nearby authorities. Not just Aylesbury. It is simply unsatisfactory to assert this cannot possible how you would be done because they are different Functional Market Areas and that co-operation is not necessary therefore. modify this policy to improve its alignment to this test of Exploring such wider co-operation may result in further housing needs being taken elsewhere. soundness. A more detailed appraisal of brownfield land opportunities MUST be undertaken. Some brownfield opportunities have been ignored or missed. Closer scrutiny of alternative options for housing delivery should be explored (such as Chesham Masterplan by CIC Chesham Renaissance). Green Belt boundary reviews should only be considered AFTER all other reasonable alternatives have been exhausted. In the face of NPPF guidance and a more thorough appraisal of Green Belt sites being considered, it may then be necessary to conclude that it is not possible to identify poor performing Green Belt sites that can accommodate all the OAN for housing. Consequently it may be necessary to accept that a lower housing provision figure is appropriate. Policy 1 - If you do not The proposals to release Green Belt land to meet housing targets (Generally, Spatial Policy SP SP1 & believe this policy to be specifically Policy SP BP2 at Lye Green NE of Chesham) are not justified from the evidence submitted by justified please explain why the Councils. The Councils have stated that release of some Green Belt is necessary as part of an overall three part strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. I question the soundness of such a general policy and whether all the brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites and in particular the Green Belt site NE of Chesham at Lye Green.
9649 The development of such Green Belt sites involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient and unfunded. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham cannot accommodate any significant highways improvements anyway due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion, with further worsening air quality. Air pollution is a particular concern in Chesham due to the already poor air quality along Berkhamsted Road where there is a designated Air Quality Management Area that already is recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will generate more traffic will make the air quality even worse and insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable nor justified nor is it in accordance with Government policy. The Green Belt site NE of Chesham (SP BP 2) is not a sustainable location. It is over 2Km away from the train station and slightly further still from the town centre but anyone who cares to walk or cycle this distance also has to negotiate a steep hill too. Such an unsustainable location cannot be made sustainable merely by upgrading a couple of public footpaths within the site into bridleways to facilitate cycling. Neither does adding a bus stop address the geography or topography of the area especially if the promised enhanced bus service (which is already infrequent) either does not materialise or if it subsequently fails to be maintained after a few years. Further doubt is cast upon the ªsoundnessº of this Plan by virtue of there being conflicting policies within it. The Council seem to think that the Green Belt site NE of Chesham is sustainable and provides easy access to public transport including the tube station yet the same Plan promotes a considerable increase in retail development in the town (local draft plan policy SP EP3), part of which would be built on the very car park that serves the Chesham tube station. This is inconsistent and unsound. For this Plan to sound it must also be effective. Unfortunately, further review of the proposal to remove land NE of Chesham at Lye Green from Green Belt designation is not effective as there are serious questions about the deliverability of this land. The main landowner is a farmer who has asserted publicly and in a letter to the editor of Your Chesham that he is not prepared to release all of the land in his ownership for development. The land is also potentially an Asset Of Community Value and upon confirmation of this designation it would afford a community group the right to bid for the land. The community group (Brown Not Green) have stated their intention is to preserve the land given that many hundreds of local people have habitually used the fields at Lye Green as of right for various informal outdoor recreational purposes. These uses themselves may mean that many local individuals may have acquired easements over and across the land through prescription (20 years uninterrupted use) not least of whom would be the many private residences bordering the fields that have rear garden gates onto the fields at Lye Green. These easements and prescriptive rights may render the land very difficult to develop and make in undeliverable in planning terms. This land also provides an important habitat for wildlife that will be threatened by development of this land. It is perverse that the Local Authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Plan is unsound. The foregoing also points to flawed methodology of Green Belt site selection used by the Local Authority, which is neither effective, justified nor consistent with national policy and as such is unsound. Specifically, the selection of the land NE of Chesham at Lye Green (policy SP BP2) for removal from Green Belt designation is inconsistent with National Planning Policy Framework (NPPF). Paragraph 136 of the latest NPPF asserts that Green Belt boundaries should only be modified in ªexceptional circumstancesº. The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances. The Council engaged third party consultants to undertake the Part 1 Green Belt assessment and they identified numerous sites for ªfurther considerationº where exceptional circumstances ªmightº exist but expressly recommended further review of their assessment of each site against the 5 purposes of land being in Green Belt of all these sites. Unlike the neighbouring Local Authorities, the Part 2 Green Belt assessment was not undertaken by third party consultants but by the Local Authority itself who notably then did not undertake all the recommended reviews of each site including the land NE of Chesham at Lye Green (SP BP 2). Accordingly, this oversight in the Part 2 Green Belt assessment placed premature focus and fixation on releasing land at Lye Green NE of Chesham from Green Belt designation. The subsequent identification of the Chesham site for release is therefore unjustified. These comments apply equally to proposals effecting the villages in the Green Belt ± policies SP PP1 & DM PP1) The primary aim of Green Belt land (as recited in NPPF 133) is to prevent urban sprawl and to preserve the openness of the area. The Lye Green site (SP BP2) self-evidently performs this function well and has done so for decades. Another aim of Green Belt land stated in NPPF paragraph 134, is to prevent neighbouring towns and settlements from merging into one another.The Green Belt land NE of Chesham performs exceptionally well in maintaining a distinct separate between settlements of Chesham & Lye Green as well as helping to maintain separate identities of other nearby communities at Orchard Leigh, Botley, Whelpley Hill, Ashley Green. It is perverse and inconsistent with national guidance to allocate this land for removal from Green Belt in light of these facts especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if earmarked for development. A further aim of Green Belt designation stated in the NPPF at paragraph 134 (e) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. By allocating Green Belt land NE of Chesham for development, undermines this aim within Chesham. A community lead not for profit organisation called Chesham Renaissance CIC has been striving to create Chesham Masterplan that would not only provide many genuinely affordable homes in more sustainable locations nearer the town centre, but which would also regenerate some of the more deprived wards within Chesham. The Local Authority's
9650 proposals (policy SP EP3) are inconsistent with this local initiative and are therefore also inconsistent with national guidance and are consequently unsound. The Council have asserted that Government planning policy requires local councils to review Green Belt boundaries when considering how to accommodate the development needed in their areas. Just because the Council may be required to look, does not mean the Council should review Green Belt boundaries which as previously stated should only be modified in ªexceptional circumstancesº. National Planning Policy Framework (NPPF) as revised only last year, states in paragraph11 (b) I, directs ªplan makersº to create policies that are required in Local Plans for housing and other uses unless Framework policies (expressly including Green Belt) ªprovides a strong reason for restricting the overall scale type or distribution of development in the plan areaº Accordingly, I submit that given all of the above the land being proposed for release from Green Belt designation around Chesham is unjustified and contrary to national guidance. I am supportive of the Brown Not Green organisation's initiative to have the land listed as an Asset of Community Value and I feel they speak for me in respect of their objections to the draft Local Plan. Accordingly, I request that any representations made by them at any future examination in public regarding the soundness of this Local Plan be considered as an extension of my own comments herein. I feel the land NE of Chesham is an unsustainable location for development, that has been habitually used by the community for improved health & wellbeing for decades and the land performs well against Green Belt aims and objectives. Exceptional circumstances for reviewing Green Belt boundaries at this location, either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by Government Policy and therefore the plan is unsound. Policy 2a - Please specify as I refer to the comments previously submitted but in summary would advocate that; precisely and succinctly as All other options are fully explored including increased density of development of brownfield land and the possible how you would policies emerging from Chesham Masterplan. modify this policy to improve its alignment to this test of Green Belt land should only be considered when all other options are exhausted and in any event the soundness. proposals for developing land NE of Chesham (policy SP BP 2) should be removed as it is an unsustainable location the development of which will cause harm to the wider town including loss of an asset that improves the well-being for the community. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5500800 Please attach any supporting evidence
Person ID 1222857 Full Name Oliver Cupit ID 4341 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body?
9651 Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act
9652 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I am writing to contest the Local Plan and voice support for the Chesham Master Plan. not believe this policy to be The draft Local Plan is unsound because housing sites have been identified through a `call for sites', rather positively prepared please than an assessment of sites across the whole Plan area. Planning policies should give substantial weight to explain why the value of using suitable brownfield land within settlements for homes and other identified needs. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222357
9653 Full Name Mr A J Wootton ID 3747 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness?
9654 Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The proposed development on Green Belt land will saturate the existing and already inadequate facilities ie not believe this policy to be bus services, and car parking, sewerage and in particular local schools in Chesham and Amersham which positively prepared please are at present overwhelmed by pupils travelling in from well outside this area. Also there will be more explain why congestion on the roads. The development of Stat yard in Chesham will reduce car parking places, this will further deter people wanting to stop in Chesham, and why do we need more shop[s when many in town are empty. Why do we have to build on Green Belt land sure there are brown sites available. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why.
9655 PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222380 Full Name Mrs R Karczmarek ID 3776 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its
9656 legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Is the site selection methodology appropriate as Lye Green is good quality agricultural land that seperates not believe this policy to be Lye Green from Chesham and is almost 2.5km from the town centre & located up a steep hill, that will only positively prepared please generate more traffic congestion & worsen local air quality in Chesham? - is this a sustainable location to explain why build on? No Is Green Belt release consistent with other local plan polices to protect wildlife habitats or biodiversity or to protect our globally scarce local chalk stream rivers or does this plan undermine them? No.
9657 Many of the site allocations (such as at Lye Green. Policy SP BP2) are excluded from CIL and developers will therefore be required to deliver infrastructure directly or make financial contributions to mitigate development impact. However, these contributions cannot be quantified because much of the costs or related infrastructure is not even specified and is awaiting the preparation of (as yet unpublished) "masterplans" for each site. The fear is that many sites will either be undeliverable/unviable or worse, delivered without the appropriate infrastructure necessary to avoid adverse impacts on the wider area. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not Is a Local plan with an acknowledged funding gap from the community infrastructure Levy (CIL) for believe this policy to be infrastructure of between £179m & £231m justified, effective or even legal? No. justified please explain why Is it effective, justified or in accord with NPPF to allocate Green Belt land NE of Chesham (policy SP BP2) for housing when that site has been used for decades for informal recreation by locals and is potentially to be listed as an Asset of Community Value? No. Is a local plan that predicts an increased carbon footprint of +21% acceptable and where is the proof that any suggested mitigation will be delivered or will even work? No. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as Should the Council be looking at more effective alternatives (ie: higher densities of housing development on precisely and succinctly as brownfield sites) which are generally closer to the town centre and in more sustainable locations and which possible how you would will also rejuvenate Chesham, as advocated by an alternative community led scheme ie: Chesham modify this policy to improve Renaissance CIC Masterplan? Yes its alignment to this test of soundness. Policy 3 - If you do not Is the plan justified or in accordance with NPPF to remove land from Green Belt for housing (especially policy believe this policy in SP BP 2 which relates to land NE of Chesham at Lye Green)? No. consistent with the National Why was there no prior consultation on "Green Belt Villages Policies" (SP PP1 & DM PP1) nor any consultation Planning Policy Framework on proposals to build disproportionately so many new shops in Chesham (mostly on the town car parks - Feb 2019 please explain why see policy SP EP3) and is this justified or effective or even sensible? No. Govt guidance in NPPF tells plan makers to provide for housing & other uses unless Green Belt policies (for one) provide a strong reason not to. Why is this council doing otherwise? Policy 3a - Please specify as - site selection is inappropriate sue to distance from town centre and topography precisely and succinctly as - will damage wildlife habitats and biodiversity possible how you would modify this policy to improve -increase carbon footprint by 21% its alignment to this test of - large funding gap- its this legal? soundness. - decrease in car parking which are already at max capacity - Policy-level file upload - Please attach any supporting evidence
Person ID 1222958 Full Name Mrs Victoria Tubb ID 4464 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received:
9658 Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance
9659 with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do At 11.3 Policy No SP BP2 - Chesham development of Green Belt land between Chesham and Lye Green. not believe this policy to be This is no compliant because: positively prepared please explain why - the case for building dwellings has not been made. In 5.1 there is a generalised calculation for the number of new homes required in the county. There is little to no detail of population growth, changes to economic situation (particularly post Brexit), and initiatives to move economic centre away from the south east. - the detail on additional infrastructure needs in Chesham has not been made: at 11.3.3 there is an acknowledgement that the infrastructure in Chesham needs to be expanded however the Chesham Master Plan highlights the topography of Chesham means expansion is difficult. Releasing Green Belt from an Area of Outstanding Natural Beauty without sufficient correlating infrastructure plans is irresponsible. - the need for Gypsy Traveller sites has not been made and is not proportional: at Policy SP LP2 there is a division of Gypsy Traveller sites across the sites for development on an equal basis, rather than proportional ie larger sites such as Beaconsfield will have proportionally more Gypsy Traveller sites. - financial support for schools is insufficient: there is provision but insufficient detail on schools, which are limited to pre-school and primary level and should be extended to secondary school level. Chiltern Hills Academy (CHA) has just had a record intake requiring additional building work and expansion. If the plan for 500 homes goes ahead, additional infrastructure in secondary schools would be necessary. There is no analysis or mention of the increasing proportion of children attending grammar schools from outside the county. If this were set to increase, local students will need a new secondary school or vastly expanded CHA in order to supply school admission places. - car parking for residents is insufficient: residents car parking is only mentioned in relation to new developments and therefore quotas are insufficient. There are a number of occasions in the year when I cannot park my car close to my house, mainly due to events at the Chesham Grammar School on White Hill. Further the plans to remove car parking in town for development of retail outlets will exacerbate this issue, and for little reason because - retail development is not needed: releasing car parks for developing retail in a town with so many charity shops is foolhardy. - changes to road systems is irresponsible: taken with the Masterplan (to reduce the Chesham by-pass to one lane in either direction in order to make space for development) the suggested ©transport mitigation improvements© will be insufficient to enable flow of traffic through Chesham. I submit that this plan has been put together with no local knowledge. Overall the plan to release land for development from Green Belt land in an Area of Outstanding Natural Beauty is not balanced with the economic need to protect this land for environmental value (Chesham derives income from visitors to the Chilterns and it contributes to flood protection), to check the sprawl of large built up areas (this land is between Chesham and Hemel Hempstead) and to preserve the historic centre of Chesham (a town mentioned in the Doomsday book). Little information / detail in Local Plan PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve
9660 its alignment to this test of soundness. Policy 1 - If you do not No alternatives have been included, no evidence of why the new homes on Green Belt land are needed, no believe this policy to be calculation of specific need in county justified please explain why Policy 2a - Please specify as A calculation from the bottom up, rather than top down. precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not No acknowledgement of cross border policies on students at Grammar Schools. believe this policy to be effective please explain why. PAa - Please specify as Identify and analyse the increasing need for local school places at secondary school as increasing numbers precisely and succinctly as of Grammar School students commute in from other counties. possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not There is little detail between the Local Plan and the Chesham Masterplan on how the infrastructure changes believe this policy in will be met. There are discrepancies between the two such as improvements to A416 in Local PLan and consistent with the National decreasing the bypass in the Masterplan - the two are incompatible. Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222960 Full Name David Bird ID 4436 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to
9661 relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary
9662 to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Over the years there have been considerable alterations to the town, largely driven by transport requirements. not believe this policy to be Now I accept that Chesham must respond again and take its share of the pressing national need for more positively prepared please homes. However I have two strong reservations about the proposed plan. explain why Firstly I would dispute that Chesham needs more retail space as allowed for in the plan. The number of vacant retail units currently stands at 23, several of which have probably fallen victim to internet shopping. Of the occupied premises with trades which are difficult to replace on the internet there are 28 food outlets (restaurants, coffee bars, take-aways) and 18 personal grooming units (barbers, hairdressers, nail bars). It is difficult to see how this number can thrive in a town the size of Chesham. Secondly I am opposed to the proposal to ©safeguard© the green belt area to the north-east of Chesham for a possible 500 homes. It has been shown by the Chesham Renaissance Community Interest Company that this need can be largely met within the existing town by using brownfield sites, increased density and the unnecessary retail allocation. The real need is for affordable smaller homes for first-time buyers and the elderly wishing to downsize and they will need to be close to existing services of all types in the town. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222437 Full Name Tanya Baon ID 3870 Order 236 Number 11.3 Title Policy SP BP2 - Chesham
9663 Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible.
9664 Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I have lived in Chesham for almost 20 years. It is a lovely little town, quite unique in its diversity and sense not believe this policy to be of community. My husband and I have brought up our children here and have seen many changes during positively prepared please that time. I fully understand the need for development around London, especially considering the prohibitive explain why house price situation. My comments on the proposed development will not be unique. As you will have heard our town is not equipped to deal with up to 1000 more cars or 1500 people. Schools, doctors, dentists and other public facilities are simply already at breaking point. To cross our town during busier times of the day can take 30 minutes to complete 5 minute journeys. Schools, Newtown for example, simply do not have the physical space to expand and accommodate more children. The pollution that additional traffic will bring will have a significant impact, particularly on roads running through the valley; Berkhampstead Road - where Newtown school is situated, Broad Street, St Mary©s Way, Red Lion Street and further on towards Amersham. There must be better sites with more opportunity for infrastructure, there must be more opportunities to build in bigger towns that can manage the influx of people. Please add this to your ever expanding list of complaints, consider the affect on local residents of this wonderful community. Reconsider the plan for development. Look at the facts, not the figures for the profits that can be made. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why.
9665 PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222961 Full Name Dr James Conboy ID 4479 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details The Chesham Society Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its
9666 legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do 11 Building Places not believe this policy to be Policy SP BP2 (11.3.1) relates to Lye Green, a site ajacent to Chesham. This is covered in great detail by positively prepared please explain why the submission of Brown not Green, and we again support their submissions. We consider this plan to be unsound, because The housing allocation has not been reduced to reflect the constraints of Green Belt
9667 and AONB, or to protect the local Chalk Streams [ ChS, ChA] New developments on Green Belt sites are proposed in unsustainable locations [BnG]
The existing plans for use of Brownfield sites have been ignored [CR] Mitigation measures proposed for existing infrastructure problems (Water, Sewage, Traffic congestion, Air Quality ¼) appear unconvincing, and unlikely to compensate for the proposed additional housing.
PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222982 Full Name Mr Richard Dunn ID 4471 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID
9668 Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination
9669 Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do am writing in response to the proposal to put 500 dwellings in an area of Lye Green; and my main concern not believe this policy to be is with sustainability. positively prepared please It is clear to most people that climate change is going to have, and is having, a huge effect on the way we explain why operate now and in the future. So people need to live somewhere that is not going to increase fossil fuel usage and pollution. More effort to encourage people to cycle, walk and use public transport to get to work or school is vital, so I cannot see how putting 500 dwellings at the top of a hill some distance from local schools and the public transport system hub is going to help. I cycle a lot around here and know that quite a bit of the area is cycling-unfriendly, so I cannot imagine many of these new house-dwellers, who also work in London or various stops on the way, cycling back at night from the underground station up a very steep hill. (I've done it, so I know.) Or walking back at night from the underground station. The more likely scenario is that they will use a car, as will people who work over Amersham, Wycombe way or need to get the children to school. More congestion, more pollution, more fossil fuel. Any local plan now needs to incorporate sustainability into its scope, particularly with respect to transport and the effects on climate change. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
9670 Policy-level file upload - Please attach any supporting evidence
Person ID 1222995 Full Name David Hays ID 4507 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications
9671 to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do We are two of the enormous local residents horrified at the thought of our local government failing to protect not believe this policy to be the wonderful "Green Belt" around this part of Buckinghamshire. positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why.
9672 PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
9673 Person ID 1222996 Full Name Dorothea Hays ID 4509 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness?
9674 Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do We are two of the enormous local residents horrified at the thought of our local government failing to protect not believe this policy to be the wonderful "Green belt" around this part of Buckinghamshire. positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve
9675 its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222524 Full Name Byron Harding ID 4001 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible.
9676 Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
9677 Policy 1 - If you do not believe the draft Local Plan is not legally compliant because it has not demonstrated sufficient regard to the believe this policy to be National Policy and guidance issued by the Secretary of State. justified please explain why The National Planning Policy Framework (NPPF) together with other guidance issued by the Government is also supported by recent ministerial statements that have made it clear that Local Authorities must demonstrate they have exhausted all options before considering revision of Green Belt boundaries. This Local Plan is seeking substantial modifications to Green Belt boundaries including the removal of Green Belt designation of 13 areas within the Districts as well as modifying the Green Belt status of many local villages. I contend this draft Local Plan has not demonstrated that all other options have been fully explored and as such this Plan is not justified, sound or in accordance with National Policy and accordingly is not legally compliant. Furthermore that Paragraph 11 b) of the NPPF (and the footnotes thereto) require Plan Makers to provide for objectively assessed needs for housing and other uses UNLESS the application of Framework policies (including Green Belt) provide a strong reason for restricting the overall scale, type or distribution of development in the plan area Chiltern District & South Bucks are significantly constrained by development policies such as Green Belt & Areas of Outstanding Natural Beauty (AONB). The Local Plan is therefore inconsistent with National Guidance and as such it is not legally compliant for the Local Authority to claim that housing needs justify a review of these same Green Belt boundaries. Policy 2a - Please specify as The Plan should be modified as follows; precisely and succinctly as Co-operating with other nearby authorities. Not just Aylesbury. It is simply unsatisfactory to assert this cannot possible how you would be done because they are different Functional Market Areas and that co-operation is not necessary. modify this policy to improve its alignment to this test of Exploring such wider co-operation may result in further housing needs being taken elsewhere. soundness. A more detailed appraisal of brownfield land opportunities should be undertaken. Some brownfield opportunities have been ignored or missed. Closer scrutiny of alternative options for housing delivery should be explored (such as Chesham Masterplan by CIC Chesham Renaissance). Green Belt boundary reviews should only be considered after all other reasonable alternatives have been exhausted. In the face of NPPF guidance and a more thorough appraisal of Green Belt sites being considered, it may then be necessary to conclude that it is not possible to identify poor performing Green Belt sites that can accommodate all the OAN for housing. Consequently it may be necessary to accept that a lower housing provision figure is appropriate. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5499136 Please attach any supporting evidence
Person ID 1222524 Full Name Byron Harding ID 4003 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received:
9678 Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance
9679 with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not The proposals to release Green Belt land to meet housing targets (Generally, Spatial Policy SP SP1 & believe this policy to be specifically Policy SP BP2 at Lye Green NE of Chesham) are not justified from the evidence submitted by justified please explain why the Councils. The Councils have stated that release of some Green Belt is necessary as part of an overall three part strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. I question the soundness of such a general policy and whether all the brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites and in particular the Green Belt site NE of Chesham at Lye Green. The development of such Green Belt sites involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient and unfunded. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham cannot accommodate any significant highways improvements anyway due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion, with further worsening air quality. Air pollution is a particular concern in Chesham due to the already poor air quality along Berkhamstead Road where there is a designated Air Quality Management Area that already is recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will generate more traffic will make the air quality even worse and insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable nor justified nor is it in accordance with Government policy. The Green Belt site NE of Chesham (SP BP 2) is not a sustainable location. It is over 2Km away from the train station and slightly further still from the town centre but anyone who cares to walk or cycle this distance also has to negotiate a steep hill too. Such an unsustainable location cannot be made sustainable merely by upgrading a couple of public footpaths within the site into bridleways to facilitate cycling. Neither does adding a bus stop address the geography or topography of the area especially if the promised enhanced bus service (which is already infrequent) either does not materialise or if it subsequently fails to be maintained after a few years. Further doubt is cast upon the ªsoundnessº of this Plan by virtue of there being conflicting policies within it. The Council seem to think that the Green Belt site NE of Chesham is sustainable and provides easy access to public transport including the tube station yet the same Plan promotes a considerable increase in retail
9680 development in the town (local draft plan policy SP EP3), part of which would be built on the very car park that serves the Chesham tube station. This is inconsistent and unsound. For this Plan to sound it must also be effective. Unfortunately, further review of the proposal to remove land NE of Chesham at Lye Green from Green Belt designation is not effective as there are serious questions about the deliverability of this land. The main landowner is a farmer who has asserted publicly and in a letter to the editor of Your Chesham, that he is not prepared to release all of the land in his ownership for development. The land is also potentially an Asset Of Community Value and upon confirmation of this designation it would afford a community group the right to bid for the land. The community group (Brown Not Green) have stated their intention is to preserve the land given that many hundreds of local people have habitually used the fields at Lye Green as of right for various informal outdoor recreational purposes. These uses themselves may mean that many local individuals may have acquired easements over and across the land through prescription (20 years uninterrupted use) not least of whom would be the many private residences bordering the fields that have rear garden gates onto the fields at Lye Green. These easements and prescriptive rights may render the land very difficult to develop and make it undeliverable in planning terms. This land also provides an important habitat for wildlife that will be threatened by development of this land. It is perverse that the Local Authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Plan is unsound. The foregoing also points to flawed methodology of Green Belt site selection used by the Local Authority, which is neither effective, justified nor consistent with national policy and as such is unsound. Specifically, the selection of the land NE of Chesham at Lye Green (policy SP BP2) for removal from Green Belt designation is inconsistent with National Planning Policy Framework (NPPF). Paragraph 136 of the latest NPPF asserts that Green Belt boundaries should only be modified in ªexceptional circumstancesº. The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances. The Council engaged third party consultants to undertake the Part 1 Green Belt assessment and they identified numerous sites for ªfurther considerationº where exceptional circumstances ªmightº exist but expressly recommended further review of their assessment of each site against the 5 purposes of land being in Green Belt of all these sites. Unlike the neighbouring Local Authorities, the Part 2 Green Belt assessment was not undertaken by third party consultants but by the Local Authority itself who notably then did not undertake all the recommended reviews of each site including the land NE of Chesham at Lye Green (SP BP 2). Accordingly, this oversight in the Part 2 Green Belt assessment placed premature focus and fixation on releasing land at Lye Green NE of Chesham from Green Belt designation. The subsequent identification of the Chesham site for release is therefore unjustified. These comments apply equally to proposals affecting the villages in the Green Belt ± policies SP PP1 & DM PP1) The primary aim of Green Belt land (as recited in NPPF 133) is to prevent urban sprawl and to preserve the openness of the area. The Lye Green site (SP BP2) self-evidently performs this function well and has done so for decades. Another aim of Green Belt land stated in NPPF paragraph 134, is to prevent neighbouring towns and settlements from merging into one another.The Green Belt land NE of Chesham performs exceptionally well in maintaining a distinct separate between settlements of Chesham & Lye Green as well as helping to maintain separate identities of other nearby communities at Orchard Leigh, Botley, Whelpley Hill, Ashley Green. It is perverse and inconsistent with national guidance to allocate this land for removal from Green Belt in light of these facts especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if earmarked for development. A further aim of Green Belt designation stated in the NPPF at paragraph 134 (e) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. By allocating Green Belt land NE of Chesham for development, undermines this aim within Chesham. A community lead not for profit organisation called Chesham Renaissance CIC has been striving to create Chesham Masterplan that would not only provide many genuinely affordable homes in more sustainable locations nearer the town centre, but which would also regenerate some of the more deprived wards within Chesham. The Local Authority's proposals (policy SP EP3) are inconsistent with this local initiative and are therefore also inconsistent with national guidance and are consequently unsound. The Council have asserted that Government planning policy requires local councils to review Green Belt boundaries when considering how to accommodate the development needed in their areas. Just because the Council may be required to look, does not mean the Council should review Green Belt boundaries which as previously stated should only be modified in ªexceptional circumstancesº. National Planning Policy Framework (NPPF) as revised only last year, states in paragraph11 (b) I, directs ªplan makersº to create policies that are required in Local Plans for housing and other uses unless Framework policies (expressly including Green Belt) ªprovides a strong reason for restricting the overall scale type or distribution of development in the plan areaº Accordingly, I submit that given all of the above the land being proposed for release from Green Belt designation around Chesham is unjustified and contrary to national guidance. I am supportive of the Brown Not Green organisation's initiative to have the land listed as an Asset of Community Value and I feel they speak for me in respect of their objections to the draft Local Plan. Accordingly, I request that any representations made by them at any future examination in public regarding the soundness of this Local Plan be considered as an extension of my own comments herein. I feel the land NE of Chesham is an unsustainable location for development, that has been habitually used by the community for improved health & wellbeing for decades and the land performs well against Green Belt aims and objectives. Exceptional circumstances for reviewing Green Belt boundaries at this location, either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by Government Policy and therefore the plan is unsound.
9681 Policy 2a - Please specify as I refer to the comments previously submitted but in summary propose the following; precisely and succinctly as All other options are fully explored including increased density of development of brownfield land and the possible how you would policies emerging from Chesham Masterplan. modify this policy to improve its alignment to this test of Green Belt land should only be considered when all other options are exhausted and in any event the soundness. proposals for developing land NE of Chesham (policy SP BP 2) should be removed as it is an unsustainable location the development of which will cause harm to the wider town including loss of an asset that improves the well-being for the community. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222527 Full Name Fiona Harding ID 4011 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible.
9682 Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the
9683 examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not The proposals to release Green Belt land to meet housing targets (Generally, Spatial Policy SP SP1 & believe this policy to be specifically Policy SP BP2 at Lye Green NE of Chesham) are not justified from the evidence submitted by effective please explain why. the Councils. The Councils have stated that release of some Green Belt is necessary as part of an overall three part strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. I question the soundness of such a general policy and whether all the brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites and in particular the Green Belt site NE of Chesham at Lye Green. The development of such Green Belt sites involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient and unfunded. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham cannot accommodate any significant highways improvements anyway due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion, with further worsening air quality. Air pollution is a particular concern in Chesham due to the already poor air quality along Berkhampstead Road where there is a designated Air Quality Management Area that already is recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will generate more traffic will make the air quality even worse and insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable nor justified nor is it in accordance with Government policy. The Green Belt site NE of Chesham (SP BP 2) is not a sustainable location. It is over 2Km away from the train station and slightly further still from the town centre but anyone who cares to walk or cycle this distance also has to negotiate a steep hill too. Such an unsustainable location cannot be made sustainable merely by upgrading a couple of public footpaths within the site into bridleways to facilitate cycling. Neither does adding a bus stop address the geography or topography of the area especially if the promised enhanced bus service (which is already infrequent) either does not materialise or if it subsequently fails to be maintained after a few years. Further doubt is cast upon the ªsoundnessº of this Plan by virtue of there being conflicting policies within it. The Council seem to think that the Green Belt site NE of Chesham is sustainable and provides easy access to public transport including the tube station yet the same Plan promotes a considerable increase in retail development in the town (local draft plan policy SP EP3) , part of which would be built on the very car park that serves the Chesham tube station. This is inconsistent and unsound. For this Plan to sound it must also be effective. Unfortunately, further review of the proposal to remove land NE of Chesham at Lye Green from Green Belt designation is not effective as there are serious questions about the deliverability of this land. The main landowner is a farmer who has asserted publicly and in a letter to the editor of Your Chesham, that he is not prepared to release all of the land in his ownership for development. The land is also potentially an Asset Of Community Value and upon confirmation of this designation it would afford a community group the right to bid for the land. The community group (Brown Not Green) have stated their intention is to preserve the land given that many hundreds of local people have habitually used the fields at Lye Green as of right for various informal outdoor recreational purposes. These uses themselves may mean that many local individuals may have acquired easements over and across the land through prescription (20 years uninterrupted use) not least of whom would be the many private residences bordering the fields that have rear garden gates onto the fields at Lye Green. These easements and prescriptive rights may render the land very difficult to develop and make I undeliverable in planning terms.
9684 This land also provides an important habitat for wildlife that will be threatened by development of this land. It is perverse that the Local Authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Plan is unsound. The foregoing also points to flawed methodology of Green Belt site selection used by the Local Authority, which is neither effective, justified nor consistent with national policy and as such is unsound. Specifically, the selection of the land NE of Chesham at Lye Green (policy SP BP2) for removal from Green Belt designation is inconsistent with National Planning Policy Framework (NPPF). Paragraph 136 of the latest NPPF asserts that Green Belt boundaries should only be modified in ªexceptional circumstancesº. The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances. The Council engaged third party consultants to undertake the Part 1 Green Belt assessment and they identified numerous sites for ªfurther considerationº where exceptional circumstances ªmightº exist but expressly recommended further review of their assessment of each site against the 5 purposes of land being in Green Belt of all these sites. Unlike the neighbouring Local Authorities, the Part 2 Green Belt assessment was not undertaken by third party consultants but by the Local Authority itself who notably then did not undertake all the recommended reviews of each site including the land NE of Chesham at Lye Green (SP BP 2). Accordingly, this oversight in the Part 2 Green Belt assessment placed premature focus and fixation on releasing land at Lye Green NE of Chesham from Green Belt designation. The subsequent identification of the Chesham site for release is therefore unjustified. These comments apply equally to proposals affecting the villages in the Green Belt ± policies SP PP1 & DM PP1) . The primary aim of Green Belt land (as recited in NPPF 133) is to prevent urban sprawl and to preserve the openness of the area. The Lye Green site (SP BP2) self-evidently performs this function well and has done so for decades. Another aim of Green Belt land stated in NPPF paragraph 134, is to prevent neighbouring towns and settlements from merging into one another.The Green Belt land NE of Chesham performs exceptionally well in maintaining a distinct separate between settlements of Chesham & Lye Green as well as helping to maintain separate identities of other nearby communities at Orchard Leigh, Botley, Whelpley Hill, Ashley Green. It is perverse and inconsistent with national guidance to allocate this land for removal from Green Belt in light of these facts especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if earmarked for development. A further aim of Green Belt designation stated in the NPPF at paragraph 134 (e) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. By allocating Green Belt land NE of Chesham for development, undermines this aim within Chesham. A community lead not for profit organisation called Chesham Renaissance CIC has been striving to create Chesham Masterplan that would not only provide many genuinely affordable homes in more sustainable locations nearer the town centre, but which would also regenerate some of the more deprived wards within Chesham. The Local Authority's proposals (policy SP EP3) are inconsistent with this local initiative and are therefore also inconsistent with national guidance and are consequently unsound. The Council have asserted that Government planning policy requires local councils to review Green Belt boundaries when considering how to accommodate the development needed in their areas. Just because the Council may be required to look, does not mean the Council should review Green Belt boundaries which as previously stated should only be modified in ªexceptional circumstancesº. National Planning Policy Framework (NPPF) as revised only last year, states in paragraph11 (b) I, directs ªplan makersº to create policies that are required in Local Plans for housing and other uses unless Framework policies (expressly including Green Belt) ªprovides a strong reason for restricting the overall scale type or distribution of development in the plan areaº. Accordingly, I submit that given all of the above the land being proposed for release from Green Belt designation around Chesham is unjustified and contrary to national guidance. I am supportive of the Brown Not Green organisation's initiative to have the land listed as an Asset of Community Value and I feel they speak for me in respect of their objections to the draft Local Plan. Accordingly, I request that any representations made by them at any future examination in public regarding the soundness of this Local Plan be considered as an extension of my own comments herein. I feel the land NE of Chesham is an unsustainable location for development, that has been habitually used by the community for improved health & wellbeing for decades and the land performs well against Green Belt aims and objectives. Exceptional circumstances for reviewing Green Belt boundaries at this location, either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by Government Policy and therefore the plan is unsound. PAa - Please specify as I refer to the comments previously submitted but in summary propose the following; precisely and succinctly as All other options are fully explored including increased density of development of brownfield land and the possible how you would policies emerging from Chesham Masterplan. modify this policy to improve its alignment to this test of Green Belt land should only be considered when all other options are exhausted and in any event the soundness. proposals for developing land NE of Chesham (policy SP BP 2) should be removed as it is an unsustainable location the development of which will cause harm to the wider town including loss of an asset that improves the well-being for the community. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would
9685 modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1223075 Full Name Jon Hildreth ID 4983 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as
9686 precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The area©s needs have not been objectively assessed to an acceptable standard when compared with the not believe this policy to be assessments made by Chesham Society, Chesham Renaissance and Brown Not Green Chesham. All of positively prepared please whom have put a lot more detail into their proposals and objections. explain why PP Mods - Please specify as Adopt the Chesham Masterplan proposed by local people via the Chesham Renaissance Community Interest precisely and succinctly as Company. This plan re-generates Chesham town centre and seeks to build on brown-field sites. possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not This policy has not taken into account any parts of the very reasonable and well thought through proposal believe this policy to be made by the Chesham Renaissance Community Interest Company. An opportunity to meet the objectives justified please explain why of building new homes in a sustainable, environmentally friendly way and also to re-generate Chesham is being missed. Policy 2a - Please specify as Adopt the Chesham Masterplan proposed by local people via the Chesham Renaissance Community Interest precisely and succinctly as Company. This plan re-generates Chesham town centre and seeks to build on brown-field sites. possible how you would modify this policy to improve
9687 its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not Insufficient exploration of the brown-field site opportunities within Chesham. believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as Build on brown-field sites first. precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5512316 Please attach any supporting evidence
Person ID 1222561 Full Name Karen Ballantine ID 4030 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance?
9688 Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible
9689 Policy Level - PP - If you do I am writing with regard to the proposed development in Chesham which I feel is wrong on many levels and not believe this policy to be will destroy the beautiful country town that it currently is. These are the reasons that I object at the highest positively prepared please level to this failed plan:- explain why · Removal of land from Green Belt protection I have lived in Chesham since 1995 and have regularly walked across the land and enjoyed all the local wildlife, flora and fauna ± which this area enjoys in abundance. I note detail of The National Planning Policy Framework (NPPF) 133: The primary aim of Green Belt land is to prevent urban sprawl and to preserve the openness of the area. I am acutely aware that the Lye Green site (Policy SP BP 2) does not adhere to this at all and in fact does exactly the opposite. To remove this area from the Green Belt will be in breach of NPPF paragraph 134 which states that it is to prevent neighbouring towns and settlements from merging. The green belt areas around Chesham separate all the smaller villages/hamlets so that they are able to keep their identity. In fact on speaking to many friends who live in these villages/hamlets they were completely unaware that this protection was being removed and that the potential of `in fill' building was very much a possibility, therefore swallowing them up into the larger out-going sprawl from Chesham itself. This is completely unacceptable. NPPF Paragraph 136 asserts that Green Belt boundaries should only be modified in ªexceptional circumstancesº. I understand that the courts ªhave held that unmet local housing needs of an area are themselves not exceptional circumstancesº. This means that using this particular site for release is incorrect and is not justified. The recently revised NPPF paragraph 11(b)i, directs ªplan makersº to create policies that are required in Local Plans for housing and other uses unless Framework policies (expressly including Green Belt) ªprovides a strong reason for restricting the overall scale type or distribution of development in the plan areaº. Consequently, the land around Chesham proposed for release from Green Belt designation is contrary to national guidance and, therefore, wholly unjustified. o Greenbelt development around Chesham is not sustainable The Green Belt area North East of Chesham is not a sustainable location. It is over 2 miles from the train station and town, both routes in and out are up/down two extremely steep hills (Nashleigh Hill and White Hill) as Chesham is situated in a valley. Having walked these routes many times, I can assure you pushing a baby in a pram and/or carrying shopping is a challenge to anyone fit and healthy! On attending a Council meeting it was suggested that this was perfectly acceptable because everyone would be able to cycle!! A simple upgrade to footpaths or adding an additional bus stop to a service that is very limited already will not make it any easier. Traffic in Chesham is already a huge problem, making a simple short journey during the rush `hour' a complete nightmare due to the volume of traffic. Adding hundreds of new homes to this will make things inevitably far worse and make an already huge issue ten times worse! There is nowhere that any sort of by-pass can be built due to the hills around the town. The roads are already clogged for a large part of the day and I do question if any decision maker has attempted to travel during busy times?! Air quality is already a major issue as well ± with readings taken in the Berkhamsted Road - a designated Air Quality Management area already, showing air quality significantly above Government and E.U. guidelines. This is of huge concern to me as I moved to the countryside in order to breath `fresh' air! Any additional homes will of course add to the traffic/pollution problem. With New Town school sited along this road this is of considerable concern to Chesham children's health. The Councils' Sustainability Appraisal (CSA) makes reference to increases in air pollution (N58, N87). N98 table N4 ªThe Local Plan is anticipated to lead to a reduction in local air quality with implications for human health.ºThis is in direct opposition to NPPF 181 ºPlanning policies and decisions should sustain and contribute towards compliance with relevant limit values or national objectives for pollutants, taking into account the presence of Air Quality Management Areas.º This is something all authorities under national law, have to actively promote measures that will decrease rather than increase pollution. · o Draft local plan is not sound I feel that the Councils have not investigated thoroughly other brownfield options within Chesham, or alternatively increasing the density on these sites. Brownfield sites are generally closer to the centre of town therefore more sustainable. The Councils have said that they need to release green belt as part of their overall three-part strategy ± ie: focus on built up areas on previously developed land, export some to Aylesbury District ± although Aylesbury is almost destroyed due to the immense construction that is happening, release green belt where sustainable built area extensions can be achieved without unacceptably harming the purposes of integrity of the green belt. Any of these parameters seem to have been ignored in the case of the Green Belt site North East of Chesham at Lye Green which is inconsistent with NPPF 137 a) ªBefore changing Green belt boundaries, authorities should make as much use as possible of suitable brownfield sites and underutilised land.º A further aim of Green Belt designation as stated in the NPPF at paragraph 134 (e) is to ªassist urban regeneration by encouraging the recycling of derelict any other urban landº. By allocating Green Belt land NE of Chesham for development, undermines this aim within Chesham. The Chesham Masterplan created by a local community lead not-for-profit organisation called Chesham Renaissance CIC, have produced excellent alternatives to provide additional affordable housing which would regenerate some of the deprived areas and would of course be more sustainable for our town. I feel that the Local Authority and our Councillors have completely ignored this initiative. At the Council meeting it was suggested that the development of the Green Belt NE of Chesham would provide easy access to public transport including the tube station, but part of this flawed plan includes building on an already over-subscribed station car park! Our town has many independent shops which have managed survive in the local climate, however removing anywhere for people to park will impact hugely on the shops leading to more closures and an unused and uninviting high street. Of course, if anybody is actually able to drive into Chesham with the ridiculous amounts of grid locked traffic blocking every entry/exit to the town the thought of then attempting to find non-existent parking would not be very appealing when they managed to get there. · o Draft local plan is in breach of environmental policies
9690 I have walked across and enjoyed the Green Belt land NE of Chesham for many years and have delighted in the vast diversity of wildlife that I have seen there. Wildlife bird, mammals and many types of insect as well different types of hedgerow, woodland along with the grazing and arable land have created a haven for many creatures ± including humans to enjoy. CSA N56 states: ªA significant potential issue to be considered for Green belt locations is the fragmentation of habitats following development, reducing the connectivity of habitats.º CSA N86 states ªdevelopment is likely to result in a direct loss of habitat links.º These policies breach National Planning Policy Framework on two counts: NPPF 2.8c) ªan environmental objective ± to contribute to protecting and enhancing our natural environment; including helping to improve biodiversity.º NPPF 171 ªplans should: safeguard components of local wildlife-rich habitats.º The CSA N55 admits that ªDevelopment at all potential Green Belt locations is anticipated to have a negative effect on biodiversity for various reasons.º This is in direct contradiction to the NPPF 174 a ªPlans should protect and enhance biodiversityº NPPF174 b ªand identify and pursue opportunities for securing measurable net gains for biodiversity.º In terms of endangered species this area hosts many of them on the national list for endangered British wildlife, which of course makes it even more important. An extended phase 1 habitat survey which was carried out on part of the site in 2016 concluded that the site could be of value to protected species and recommended further surveys in order to adhere to wildlife legislation. Upon examination of the Councils' Evidence base, it does not appear that any of this work has been carried out, which I find incredibly disturbing and shows the contempt held for our local wildlife. The Green Belt land NE of Chesham is currently used for grazing and arable farming and has therefore never been developed. This land is incredibly important as it is of a high quality as it is flexible in delivering crops for food and/or non-food. If development is approved there is a huge concern - CSA N59 states ªSoil within the districts is a highly valuable and non-renewable resource. Many of the potential Green Belt locations are largely located on previously undeveloped land, which is undesirable due to potential for soil contamination, soil loss and erosion, loss of carbon sink and water filtering capabilities¼ many (sites) would require development of Grade 3 agricultural land. Development would therefore be likely to result in the loss of some of the district's most versatile and productive soils.º CSA N91 states ªA significant quantity of development is proposed by the Local Plan, a large proportion on greenfield sites where it is expected that new buildings will result in the direct loss of the soil resource. The loss to BMV land would reduce the quantity of the most productive and flexible agricultural land that can best deliver food and non-food crops for future generations. Soil provides essential services to the local area that include nutrient cycling, abating flood risk, filtering water and carbon storage. Direct loss to soil through construction will reduce these essential ecosystem services.º The NPPF 170 states: ºPlanning policies and decisions should contribute to and enhance the natural and local environment by: a) protecting and enhancing¼.. soils.º Another concern is the local water situation. The River Chess is a rare chalk stream which in itself attracts many varieties of wildlife. Due to the current levels of abstraction currently carried out from the local aquifer, has had a detrimental effect with the river running dry for extended periods over the year through the Chesham area. Water demand will increase and this will add to the existing problem. There are already issues within Chesham with flooding and sewerage, with Chesham sewage treatment works already struggling when there is heavy rainfall. There have been times in the past that sewage has flooded the high street and entered local shops. Adding additional housing onto an already overloaded system will have a huge impact with potential water pollution. CSA N60: ªNone of the potential Green Belt removal locations are anticipated to have a positive effect on water quality due to the significant increase in demand on water demand and treatment facilities. Water pollution may also be of concern.º N92 ªThe Local Plan is likely to have negative impacts upon water. Inputs into the watercourse may cause significant harm to the quality of water Development proposed within the Local Plan is likely to increase total water consumption.º N87 ªDevelopment in the plan area¼ may exacerbate flood risk.º The NPPF 170 e) says: ªDevelopment should, wherever possible, help to improve local environmental conditions such as... water quality.º and NPPF 155.ªInappropriate development in areas at risk of flooding should be avoided.º Areas of the Hill Top housing would face great potential for extended flooding adding to an existing problem, along with the Lye Green area. · Draft local plan is not deliverable The Green Belt land NE of Chesham is a farmer who has said ± in published documentation ± that he does not wish to release the land for development, so I do question why and how this land has been identified for development potential. The local plan has a significant funding gap from the Community Infrastructure Levy (CIL). As Lye Green (Policy SP BP2) would be excluded from CIL the developers would be required to make financial contributions/deliver infrastructure directly. The `Masterplans' have not been prepared so how can any of these contributions be quantified? Without any idea on costs how can anything be delivered appropriately ± this would clearly have an adverse effect on the rest of the local community. This land has become and Asset of Community Value and now gives the right to the community to bid for it. I have for more than 24 years walked over this land and I welcome a local community group's (Brown Not Green) intention to preserve the land for recreational purposes. It is unbelievable that the Local Authority would seek to remove this area for development when it promotes it - NPPF 96. ªAccess to a network of high-quality open spaces and opportunities for sport and physical activity is important for the health and well-being of communities.º NPPF 180 b) ºidentify and protect tranquil areas which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason.º Removing this valuable asset, I believe undermines the objectives of the Localism Act 2011. · o Lack of consultation and transparency I feel that this way of pushing through enormous amounts of development onto the local area has been handled in a very obstructive way. Having attended a Council Meeting relating to the Local Plan, I was incredibly shocked at the number of Councillors who stood up and voiced that their constituents were extremely concerned and were against the plans. However, their comments and concerns were pushed aside as they then chose to vote for the Local Plan ± are the councillors not the voice of their constituents? It was a complete shock to find that the villages were being removed from the Green Belt wash, therefore opening them up to
9691 infill building. There was no previous mention of ªgreen Belt Villages Policiesº (SP PP1and DM PP1) and many friends who live in these villages have absolutely no idea that their Green Belt protection would disappear. I tried repeatedly to log onto the Objective Portal to complete a ªRepresentation to the Public Examination of the Local Planº form and was c to complete it as it consistently timed out ± very frustrating. Perhaps a `conspiracy theory' but it feels very much like make something difficult enough and everyone will give up. For the reasons above I would like my objections noted as I feel that this Plan is unjustified, it does not work with national policy, is unsound and works to the detriment of our town and the area of outstanding natural beauty that we are lucky to be the safe guardians of. I fully support the local community group Brown Not Green and agree with their objections. I would also like it noted that any representations to any further submissions that they make will echo my own opinions and thoughts. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5499153 Please attach any supporting evidence
Person ID 1222593 Full Name Richard Morris ID 4061 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body?
9692 Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act
9693 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not The proposal to release Green Belt land to meet the housing targets in my opinion are not justified from the believe this policy to be evidence submitted. I would ask the question, have all brownfield land sites been fully identified and explored justified please explain why with a view to increasing the density of development on these sites? Such sites are probably closer to the town and more sustainable than a Green Belt location with particular reference to the Green Belt site North East of Chesham at Lye Green. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not The primary aim of Green Belt land, as recited in NPPF 133, is to prevent urban sprawl and maintain openness believe this policy in of the area. The site to the North East of Chesham at Lye Green currently prevents the urban sprawl whilst consistent with the National maintaining a distinct separate settlement between Chesham and Lye Green and has done so for decades. Planning Policy Framework The Green Belt land as stated in NPPF 134 has prevented neighbouring settlements from merging into one Feb 2019 please explain why another. It is perverse and inconsistent with national guidance to allocate this land for removal from Green Belt. Especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if developed. There appears to be flawed methodology of Green Belt site selection used by the local authority which is neither effective, justified nor consistent with National Policy and is therefore unsound. With regards to the land North East of Chesham at Lye Green, the removal of this land from Green Belt is inconsistent with National Planning Policy Framework (NPPF). Paragraph 136 of the latest NPPF asserts that Green Belt boundaries should only be modified in "exceptional circumstances". The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances. Unlike neighbouring local authorities, the part 2 Green Belt assessment was not undertaken by third party consultants but by the local authority itself who notably then did not undertake all the recommended reviews of each site including the land N.E
9694 of Chesham from Green Belt designation. The subsequent identification of the Chesham site for release is therefore unjustified. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5500434 Please attach any supporting evidence
Person ID 1223104 Full Name Tim Gee ID 4703 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you
9695 consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Specifically Policy SP BP2 at Lye Green NE of Chesham) are ludicrous from the evidence submitted by the not believe this policy to be Councils. positively prepared please The Councils have said that the release of some Green Belt is necessary & are part of the overall three part explain why strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. This is questionable and unsound. Have the council adequately looked at the brownfiled options in exsisting parts of the town properly? If so where is the evidence? Isn't it going to be an environmental disaster to rip up greenbelt land that is a host to Badgers, Bats, Rare birds and Great Crested Newts at a time where we are approaching midnight of catastrophic proportions upon our planet. Not to mention the increase in pollution caused by the traffic in an area where private transport is the only option because the area in consideration is so far from the town.
9696 Evidence shows that the town is already at capacity and pollution levels are up there with the highest in the country with respiratory ailments rising due to poor air quality. Do you want to approve this and more or less sign a death warrant on our citizens? One of my biggest concerns is water and lack of it. Our Town shares its name with the River Chess. Water is life. There is now no river, what is the town without its river, which was what the town was originally founded on. The towns past and industry/ growth was all based from the river. Our local water authority `Affinity Water' relies on our water source to be directly taken from the local chalk Aquifers. Chesham is already suffering from their criminality and under investment in water collecting infrastructure¼(They have no reservoirs) Our local Chalk River that supported a whole Eco system has been destroyed it has run dry through over abstraction. By increasing the population of housing int NE Chesham/ Lye Green, more Boreholes will have to be dug, more water will have to be found.This will devastate any chances on our eco system ever recovering and thus aid yet more pressure and destruction on our planet. Not to mention the increase in sewer treatment that will need to be dealt with, which is already running into difficulty with Thames water currently dumping sewer overflow into the remaining part of the River Chess upstream when it rains. This beautiful land that is in the Green Belt is an Asset of Community Value, taking it out of the Green Belt would be very Unsound and an environmental disaster. Lets have some imagination, lets explore the Brown field sites, lets think of the future, lets act now and be sensible. PP Mods - Please specify as Please explore other options including the development of brownfield land and take a look at the plans that precisely and succinctly as are being made within the Chesham Masterplan. It would be Unsound not to look at this carefully. possible how you would Green Belt land is there for a reason, not for development and profit. Never should it be looked at until all modify this policy to improve other possibilities have been exhausted. The greenbelt land is of value to the residents and it is important its alignment to this test of for wellbeing. soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I have done a lot of reading and research into this issue, which will affect myself and the whole Town of believe this policy in Chesham. From the research that I've done what is being planned goes against everything that has been consistent with the National laid out in The National Planning Policy Framework (NPPF) together with other guidance issued by the Planning Policy Framework Government. The policy which has been highlighted in the press has also been supported by some recent Feb 2019 please explain why ministerial statements, and to me this has made it very clear that what is being steam rolled is unlawful,unsound and feels very corrupt. The draft Local Plan isn't legally compliant. It doesn't show or demonstrate any regard to the National Policy and guidance issued by the Secretary of State. As far as I am aware, Local Authorities need to demonstrate that they have exhausted every single option prior to even considering the change/ revision of Green Belt boundaries. This ridiculous local wants modifications to Green Belt boundaries. This includes the total removal of Green Belt designation of 13 areas within the Districts on top of the Green Belt status of many local villages, which was announced as a surprise without any prior warning. This awful draft of a ªLocal Planº definitely hasn't shown that every other options have been totally explored and considered and therefore this Plan is not justified, lawful, or sound & in accordance with National Policy. How can it be said to be legally compliant when rules have been broken? Please can I draw your attention to Paragraph 11 b) of the NPPF (and the footnotes thereto) which require Plan Makers to provide for objectively assessed needs for housing and other uses UNLESS the application of Framework policies (including Green Belt) provide a strong reason for restricting the overall scale, type or distribution of development in the plan area Chiltern District & South Bucks are significantly constrained by development policies such as Green Belt & Areas of Outstanding Natural Beauty (AONB). The Local Plan is therefore inconsistent with National Guidance and as such it is not legally compliant for the Local Authority to claim that housing needs justify a review of these same Green Belt boundaries. I understand the need for more homes and housing, we're a small island nation with a growing and ageing population, there is a squeeze on land and resources. However I think it is ludicrous and sad to hear claims that the need for more housing & the presence of significant areas of development constraint policy
9697 collectively represent ªexceptional circumstancesº (as required in the NPPF) are used to justify the modification of Green Belt boundaries. This is in excusable, especially as the NPPF says that one of the key features of the Green Belt is their ªpermanenceº... You have to also ask yourself how this sits with the UK Governments pledge to have net zero carbon emissions by 2050? I also see it as totally contradictory that the Sustainability Appraisal supporting this Draft Local Plan, expects to see carbon emissions increase by 21% in the Plan Period.? This seems to go against everything, and highlights the inconsistency with UK Governments Policy. How can this be legally compliant? Lastly, through all the meetings I have been along and seen, I understand that there is also a massive infrastructure funding gap acknowledged within the Community Infrastructure Levy evidence that supports this Local Plan. This Gap is estimated to be between £179m & £231m. Isn't Infrastructure massively vital to ensure that development is sustainable? The NPPF certainly seems to think so. Again another demonstration that this unnecessary Plan is both unsound and not legally compliant. Policy 3a - Please specify as Lets be real with this. Here is a list below of what needs to occur. precisely and succinctly as I'm no rocket scientist, but as a guardian of this planet that we live on, doesn't it make sense for Green Belt possible how you would boundary reviews to only be considered when all other reasonable alternatives have beenexhausted.? modify this policy to improve its alignment to this test of *Shouldn't there be a better detailed appraisal of brownfield land opportunities needs be undertaken. soundness. Some brownfield opportunities have been totally ignored or ªaccidentallyº missed. *There also needs to be proper Co-operation with all nearby authorities. Not just Aylesbury. It is simply unsatisfactory to assert this cannot be done because they are different Functional Market Areas and that co-operation is not necessary therefore. It's hoped that wider co-operation may result in further housing needs being taken elsewhere. *We should allow closer scrutiny of all alternative options for housing. These need to be properly explored, such as Chesham Masterplan by CIC Chesham Renaissance, which have had some amazing and viable ideas that have been totally ignored by this whole process. In the face of NPPF guidance and a more thorough appraisal of Green Belt sites being considered, it may then be necessary to conclude that it is not possible to identify poor performing Green Belt sites that can accommodate all the OAN for housing. Consequently it may be necessary to accept that a lower housing provision figure is appropriate. Policy-level file upload - 5502321 Please attach any supporting evidence
Person ID 1222611 Full Name Andrew Ketteringham ID 4086 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be
9698 as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public?
9699 Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Before giving my comments on the Emerging Local Plan (ELP), I should declare an interest, that I am a not believe this policy to be director of Chesham Renaissance community interest company (CR) which company has been responsible positively prepared please for the production of the Chesham Master plan. explain why My understanding is that plans should be shaped by early, proportionate and effective engagement between policy-makers and communities, local organisations, businesses, infrastructure providers and operators and statuary consultee. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not Bringing people back to live in the centre of our town is the key policy in the Chesham master plan, it plays believe this policy to be no part in the ELP. effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not The ELP is not in my view legally compliant because it does not comply with NPPF guidance. Where is the believe this policy in ©positive vision for the future© of the largest town in the Chiltern district? Why was the Chesham master plan consistent with the National not considered as a alternative to ELP ©fulfilling© justified requirement? How can an increased carbon footprint Planning Policy Framework of 21% comply with a government ambitions of net zero carbon emission by 2050? Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222653 Full Name Mrs Kate Morris ID 4098 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body?
9700 Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act
9701 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I believe the draft Local Plan is NOT legally compliant because it has not demonstrated sufficient regard to not believe this policy to be the National Policy and guidance issued by the Secretary of State. positively prepared please The National Planning Policy Framework (NPPF) together with other guidance issued by the Government explain why is also supported by recent ministerial statements that have made it clear that Local Authorities MUST demonstrate they have exhausted all options BEFORE considering revision of Green Belt boundaries. This Local Plan is seeking substantial modifications to Green Belt boundaries including the removal of Green Belt designation of 13 areas within the Districts as well as modifying the Green Belt status of many local villages. I contend this draft Local Plan has not demonstrated that all other options have been fully explored and as such this Plan is not justified, sound or in accordance with National Policy and accordingly is not legally compliant. Furthermore that Paragraph 11 b) of the NPPF (and the footnotes thereto) require Plan Makers to provide for objectively assessed needs for housing and other uses UNLESS the application of Framework policies (including Green Belt) provide a strong reason for restricting the overall scale, type or distribution of development in the plan area Chiltern District & South Bucks are significantly constrained by development policies such as Green Belt & Areas of Outstanding Natural Beauty (AONB). The Local Plan is therefore inconsistent with National Guidance and as such it is not legally compliant for the Local Authority to claim that housing needs justify a review of these same Green Belt boundaries. It is perverse to claim that the combination of housing need and the presence of significant areas of development constraint policy collectively represent ªexceptional circumstancesº (as required in the NPPF) to justify modification of Green Belt boundaries especially given the NPPF states that one of the key features of Green Belts are their permanence. The Government has also recently confirmed its aim for the UK to have net zero carbon emissions by 2050 and it is noted within the Sustainability Appraisal supporting this Draft Local Plan, that the Plan area is forecast to see carbon emission increase by 21% in the Plan Period. Accordingly, the Plan is inconsistent with Government Policy and therefore not legally compliant. There is also a significant infrastructure funding gap acknowledged within the Community Infrastructure Levy evidence that supports this Local Plan, of between £179m & £231m. Given this infrastructure is vital to ensure that development is sustainable (as also required by the NPPF) this further demonstrates the Plan is both unsound and not legally compliant. PP Mods - Please specify as The Plan needs to be modified by; precisely and succinctly as Co-operating with other nearby authorities. Not just Aylesbury. It is simply unsatisfactory to assert this cannot possible how you would be done because they are different Functional Market Areas and that co-operation is not necessary therefore. modify this policy to improve its alignment to this test of Exploring such wider co-operation may result in further housing needs being taken elsewhere. soundness. A more detailed appraisal of brownfield land opportunities MUST be undertaken. Some brownfield opportunities have been ignored or missed. Closer scrutiny of alternative options for housing delivery should be explored (such as Chesham Masterplan by CIC Chesham Renaissance). Green Belt boundary reviews should only be considered AFTER all other reasonable alternatives have been exhausted. In the face of NPPF guidance and a more thorough appraisal of Green Belt sites being considered, it may then be necessary to conclude that it is not possible to identify poor performing Green Belt sites that can accommodate all the OAN for housing. Consequently it may be necessary to accept that a lower housing provision figure is appropriate.
9702 Policy 1 - If you do not The proposals to release Green Belt land to meet housing targets (Generally, Spatial Policy SP SP1 & believe this policy to be specifically Policy SP BP2 at Lye Green NE of Chesham) are not justified from the evidence submitted by justified please explain why the Councils. The Councils have stated that release of some Green Belt is necessary as part of an overall three part strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. I question the soundness of such a general policy and whether all the brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites and in particular the Green Belt site NE of Chesham at Lye Green. The development of such Green Belt sites involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient and unfunded. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham cannot accommodate any significant highways improvements anyway due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion, with further worsening air quality. Air pollution is a particular concern in Chesham due to the already poor air quality along Berkhamsted Road where there is a designated Air Quality Management Area that already is recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will generate more traffic will make the air quality even worse and insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable nor justified nor is it in accordance with Government policy. The Green Belt site NE of Chesham (SP BP 2) is not a sustainable location. It is over 2Km away from the train station and slightly further still from the town centre but anyone who cares to walk or cycle this distance also has to negotiate a steep hill too. Such an unsustainable location cannot be made sustainable merely by upgrading a couple of public footpaths within the site into bridleways to facilitate cycling. Neither does adding a bus stop address the geography or topography of the area especially if the promised enhanced bus service (which is already infrequent) either does not materialise or if it subsequently fails to be maintained after a few years. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not The land is also potentially an Asset Of Community Value and upon confirmation of this designation it would believe this policy in afford a community group the right to bid for the land. The community group (Brown Not Green) have stated consistent with the National their intention is to preserve the land given that many hundreds of local people have habitually used the Planning Policy Framework fields at Lye Green as of right for various informal outdoor recreational purposes. Feb 2019 please explain why These uses themselves may mean that many local individuals may have acquired easements over and across the land through prescription (20 years uninterrupted use) not least of whom would be the many private residences bordering the fields that have rear garden gates onto the fields at Lye Green. These easements and prescriptive rights may render the land very difficult to develop and make in undeliverable in planning terms. This land also provides an important habitat for wildlife that will be threatened by development of this land. It is perverse that the Local Authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Plan is unsound. The foregoing also points to flawed methodology of Green Belt site selection used by the Local Authority, which is neither effective, justified nor consistent with national policy and as such is unsound. Specifically, the selection of the land NE of Chesham at Lye Green (policy SP BP2) for removal from Green Belt designation is inconsistent with National Planning Policy Framework (NPPF). Paragraph 136 of the latest NPPF asserts that Green Belt boundaries should only be modified in ªexceptional circumstancesº. The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances. The Council engaged third party consultants to undertake the Part 1 Green Belt assessment and they identified numerous sites for ªfurther considerationº where exceptional circumstances ªmightº exist but expressly recommended further review of their assessment of each site against the 5 purposes of land being in Green Belt of all these sites. Unlike the neighbouring Local Authorities, the Part 2 Green Belt assessment was not undertaken by third party consultants but by the Local Authority itself who notably then did not undertake all the recommended reviews of each site including the land NE of Chesham at Lye Green (SP BP 2). Accordingly, this oversight in the Part 2 Green Belt assessment placed premature focus and fixation on releasing land at Lye Green NE of Chesham from Green Belt designation. The subsequent identification of the Chesham site for release is therefore unjustified.
9703 The primary aim of Green Belt land (as recited in NPPF 133) is to prevent urban sprawl and to preserve the openness of the area. The Lye Green site (SP BP2) self-evidently performs this function well and has done so for decades. Policy 3a - Please specify as I refer to the comments previously submitted but in summary would advocate that; precisely and succinctly as All other options are fully explored including increased density of development of brownfield land and the possible how you would policies emerging from Chesham Masterplan. modify this policy to improve its alignment to this test of Green Belt land should only be considered when all other options are exhausted and in any event the soundness. proposals for developing land NE of Chesham (policy SP BP 2) should be removed as it is an unsustainable location the development of which will cause harm to the wider town including loss of an asset that improves the well-being for the community. Policy-level file upload - 5500417 Please attach any supporting evidence
Person ID 1223202 Full Name A Cooke ID 4791 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness?
9704 Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Whilst most would see the need for additional affordable housing in the area, surely this must be carried out not believe this policy to be with as little impact on the `Green Belt' as possible. It is clearly only the green belt around our major cities positively prepared please that have resisted urban sprawl and made The United Kingdom a more pleasant place to live and work. The explain why Draft Local Plan, with its recommendations to build o large areas of green belt do not comply with my comments above. My understanding is that it is also not justifiable from the perspective of the National Planning Policy Framework, which clearly stated that green belt land should only be taken in exceptional circumstances. PP Mods - Please specify as I am informed that there are local groups such as `Chesham renaissance CIC' and `Brown not Green' which precisely and succinctly as have identified areas for development which would satisfy the requirements of the planning authority and possible how you would also get the consent of current residents. It would seem reasonable for Chiltern and South Bucks Authority modify this policy to improve to meet with these groups and take note of their ideas and suggestions. its alignment to this test of soundness.
9705 Policy 1 - If you do not The area to the north east of Chesham at Lye Green is one of the main areas identified on the Draft Local believe this policy to be Plan for the building of several hundred houses. How can this be justified? The Hamlet of Lye Green would justified please explain why certainly lose its identify under this proposed development. This are is also a significant distance from the centre of Chesham, which would necessitate the use of still more vehicle on local roads an even more congestion to an already congested are. Clearly the draft local plan, as it stands at the moment is not sound. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1223206 Full Name Susan Darvell ID 4707 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies
9706 and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary
9707 to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I am writing to state my concerns about the proposed plan to develop Nalder©s fields. I feel this development not believe this policy to be will be detrimental to the Chesham area. The extra traffic that 500 houses, a large retail outlet and traveller positively prepared please site will generate in an already overcrowded road system through Chesham. Chesham is a bottleneck if explain why there is an issue on the A41 and sometimes even on the M1 traffic tries to get to the M25 at Chorleywood by filtering through Chesham. This last time this happened about three months ago it took all morning and most of the afternoon until about 4pm for the traffic to flow freely again. Another big worry is water or lack of it. The river chess has none if any more due to our extraction. Chesham has its own springs feeding the chalk stream that was the chess. More properties mean that more water is required, from where? PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not My other big worry is wild life. Nalder©s fields is perfect it contains hedgerows and woodland as habitat. believe this policy to be These fields, woods and hedges support a variety at wildlife and we really should be sharing this world with justified please explain why them, instead of destroying their habitat and ultimately them as well. I thought that now government thinking was to encourage protection and conservation of wildlife and the environment. We need to use every bit of brownfield land available. The brown not green group has identified 400 sites , There is also lots of empty space above shops and empty shops - all redundant space that could be made or converted into homes. The green belt is good for people mental and physical health, perhaps more than even. Just to look across to fields and woods feeds the soul. It was first though of to stop frown from merging into each other and for peace and quiet for us as well as nature. We need it. This land is green belt and that should be respected. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222716 Full Name Len Cooke ID 4175 Order 236 Number 11.3 Title Policy SP BP2 - Chesham
9708 Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible.
9709 Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do 1.2 Disregarding the negative impact of this plan upon the community not believe this policy to be · Councils Sustainability Plan N58, N87). N98 table N4 ªThe Local Plan is anticipated to lead to a reduction positively prepared please in local air quality with implications for human health.º NPPF 181.º Planning policies and decisions should explain why sustain and contribute towards compliance with relevant limit values or national objectives for pollutants, taking into account the presence of Air Quality Management Areas.º 1.4 Removal from Greenbelt of Asset of Community Value Land. · NPPF 96. ªAccess to a network of high-quality open spaces and opportunities for sport and physical activity is important for the health and well-being of communitiesº. · NPPF 180 b)º identify and protect tranquil areas which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason;º 2.0 UNSOUND FINANCIAL PLANNING This Local Plan has an acknowledged funding gap from the Community Infrastructure Levy (CIL) of between £179m ± £231m. Whilst developers will be required to deliver infrastructure directly or make financial contributions to mitigate development impact there is no fixed framework to work to as the related infrastructure has not been specified. 3.0 UNJUSTIFIED AND IN EFFECTIVE PLANNING 3.1 Consultation The plan has been developed with the minimum of consultation. It appears that there was no consultation at all with residents whose villages are planned to be cleared for infilling or to be removed from greenbelt protection altogether. Many of these villagers are still unaware of this plan. The means of commenting on the plan have, until recently, been made as esoteric and as difficult as possible. This is not justifiable and certainly not positively prepared. 3.2Á Contradictory Plans The Council plans to build houses on the Green Belt site North East of Chesham which is over 2km from the town centre and which will result in more residents using their car to commute to the tube station, yet it also plans to build upon the only car park that serves that station. This is not effective planning. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
9710 Policy 1 - If you do not 1.3 Damaging the Natural Environment believe this policy to be · CSA N56: ªA significant potential issue to be considered for Green belt locations is the fragmentation of justified please explain why habitats following development, reducing the connectivity of habitats.º NPPF 171 ªplans should: safeguard components of local wildlife-rich habitats.º NPPF 174 a ªPlans should protect and enhance biodiversityº · CSA N86: ªdevelopment is likely to result in a direct loss of habitat links.º NPPF 2.8c) ªan environmental objective ± to contribute to protecting and enhancing our natural environment; including helping to improve biodiversity.º NPPF174 b ªand identify and pursue opportunities for securing measurable net gains for biodiversity. · CSA N87. ªProposed development within Local Plan is likely to increase the Plan area's carbon emissions by 21%º. NPPF 148. ªThe planning system should support the transition to a low carbon future in a changing climate. It should help to: shape places in ways that contribute to radical reductions in greenhouse gas emissions.º · CSA N91 ªA significant quantity of development is proposed by the Local Plan, a large proportion on greenfield sites where it is expected that new buildings will result in the direct loss of the soil resource. The loss to BMV land would reduce the quantity of the most productive and flexible agricultural land that can best deliver food and non-food crops for future generations.º NPPF 170: ºPlanning policies and decisions should contribute to and enhance the natural and local environment by: a) protecting and enhancing¼.. soilsº · CSA N60: ªNone of the potential Green Belt removal locations are anticipated to have a positive effect on water quality due to the significant increase in demand on water demand and treatment facilities. Water pollution may also be of concern.º NPPF 170 e) says: ªDevelopment should, wherever possible, help to improve local environmental conditions such as... water quality.º · N92 ªThe Local Plan is likely to have negative impacts upon water. Inputs into the watercourse may cause significant harm to the quality of water. Development proposed within the Local Plan is likely to increase total water consumption.º N87 ªDevelopment in the plan area¼ may exacerbate flood risk.º NPPF 155. ªInappropriate development in areas at risk of flooding should be avoided..º Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not I am concerned that the extra traffic created in the vicinity of Lycrome Road, which in parts is narrow, bendy believe this policy to be and has no pavement, will result in more road accidents. This is particularly worrying given that the road is effective please explain why. used extensively for journeys to and from Chesham Preparatory School and Chesham Grammar School. The plan breaches numerous national planning policy guidelines and is unjustifiable, ineffective and not deliverable. To progress a plan with such a huge funding gap is recklessly irresponsible.The Local Plan should be rejected in its entirety. I support the Brown not Green organisation's views and feel that they speak for me in respect of their objections as to the draft Local Plan. Accordingly, I am happy for them to represent my views at any future examination in public regarding the soundness of this Local Plan. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not 1.0 BREACHING NATIONAL PLANNING POLICY FRAMEWORK GUIDELINES believe this policy in I have examined the Chiltern and South Bucks Councils' Local Plan and cross-referenced it with the relevant consistent with the National portions of the National Planning Policy Framework (NPPF). The Local Plan is deeply flawed as it breaches Planning Policy Framework many of the national guidelines which have been developed to create parameters within which local Feb 2019 please explain why government can create sustainable, justified and effective plans. In particular: Using Greenbelt land to meet Government Housing Targets and extend urban sprawl to merge Chesham with Lye Green · The National Planning Policy Framework (NPPF) 133: The primary aim of Green Belt land is to prevent urban sprawl and to preserve the openness of the area. · NPPF paragraph 134: to prevent neighbouring towns and settlements from merging. · NPPF at paragraph 134 (e) is to assist urban regeneration by encouraging the recycling of derelict and other urban land. · NPPF Paragraph 136: Green Belt boundaries should only be modified in ªexceptional circumstancesº. (Meeting local housing targets do not constitute ªexceptional circumstancesº). · NPPF 137 a) ªBefore changing Green belt boundaries, authorities should make as much use as possible of suitable brownfield sites and underutilised land;º · NPPF paragraph 11(b)i, directs ªplan makersº to create policies that are required in Local Plans for housing and other uses unless Framework policies (expressly including Green Belt) ªprovides a strong reason for restricting the overall scale type or distribution of development in the plan areaº Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve
9711 its alignment to this test of soundness. Policy-level file upload - 5500698 Please attach any supporting evidence
Person ID 1222724 Full Name Leonard Cooke ID 4203 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible.
9712 Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do 2.0 UNSOUND FINANCIAL PLANNING not believe this policy to be This Local Plan has an acknowledged funding gap from the Community Infrastructure Levy (CIL) of between positively prepared please £179m ± £231m. Whilst developers will be required to deliver infrastructure directly or make financial explain why contributions to mitigate development impact there is no fixed framework to work to as the related infrastructure has not been specified. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not 3.0 UNJUSTIFIED AND IN EFFECTIVE PLANNING believe this policy to be 3.1 Consultation justified please explain why The plan has been developed with the minimum of consultation. It appears that there was no consultation at all with residents whose villages are planned to be cleared for infilling or to be removed from greenbelt protection altogether. Many of these villagers are still unaware of this plan. The means of commenting on the plan have, until recently, been made as esoteric and as difficult as possible. This is not justifiable and certainly not positively prepared. Contradictory Plans
9713 The Council plans to build houses on the Green Belt site North East of Chesham which is over 2km from the town centre and which will result in more residents using their car to commute to the tube station, yet it also plans to build upon the only car park that serves that station. This is not effective planning. I am concerned that the extra traffic created in the vicinity of Lycrome Road, which in parts is narrow, bendy and has no pavement, will result in more road accidents. This is particularly worrying given that the road is used extensively for journeys to and from Chesham Preparatory School and Chesham Grammar School. The plan breaches numerous national planning policy guidelines and is unjustifiable, ineffective and not deliverable. To progress a plan with such a huge funding gap is recklessly irresponsible.The Local Plan should be rejected in its entirety. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not 1.0 BREACHING NATIONAL PLANNING POLICY FRAMEWORK GUIDELINES believe this policy in I have examined the Chiltern and South Bucks Councils' Local Plan and cross-referenced it with the relevant consistent with the National portions of the National Planning Policy Framework (NPPF). The Local Plan is deeply flawed as it breaches Planning Policy Framework many of the national guidelines which have been developed to create parameters within which local Feb 2019 please explain why government can create sustainable, justified and effective plans. In particular: 1.1 Using Greenbelt land to meet Government Housing Targets and extend urban sprawl to merge Chesham with Lye Green · The National Planning Policy Framework (NPPF) 133: The primary aim of Green Belt land is to prevent urban sprawl and to preserve the openness of the area. · NPPF paragraph 134: to prevent neighbouring towns and settlements from merging. · NPPF at paragraph 134 (e) is to assist urban regeneration by encouraging the recycling of derelict and other urban land. · NPPF Paragraph 136: Green Belt boundaries should only be modified in ªexceptional circumstancesº. (Meeting local housing targets do not constitute ªexceptional circumstancesº). · NPPF 137 a) ªBefore changing Green belt boundaries, authorities should make as much use as possible of suitable brownfield sites and underutilised land;º · NPPF paragraph 11(b)i, directs ªplan makersº to create policies that are required in Local Plans for housing and other uses unless Framework policies (expressly including Green Belt) ªprovides a strong reason for restricting the overall scale type or distribution of development in the plan areaº 1.2 Disregarding the negative impact of this plan upon the community · Councils Sustainability Plan N58, N87). N98 table N4 ªThe Local Plan is anticipated to lead to a reduction in local air quality with implications for human health.º NPPF 181.º Planning policies and decisions should sustain and contribute towards compliance with relevant limit values or national objectives for pollutants, taking into account the presence of Air Quality Management Areas.º 1.4 Removal from Greenbelt of Asset of Community Value Land. · NPPF 96. ªAccess to a network of high-quality open spaces and opportunities for sport and physical activity is important for the health and well-being of communitiesº. · NPPF 180 b)º identify and protect tranquil areas which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason;º 1.3 Damaging the Natural Environment · CSA N56: ªA significant potential issue to be considered for Green belt locations is the fragmentation of habitats following development, reducing the connectivity of habitats.º NPPF 171 ªplans should: safeguard components of local wildlife-rich habitats.º NPPF 174 a ªPlans should protect and enhance biodiversityº · CSA N86: ªdevelopment is likely to result in a direct loss of habitat links.º NPPF 2.8c) ªan environmental objective ± to contribute to protecting and enhancing our natural environment; including helping to improve biodiversity.º NPPF174 b ªand identify and pursue opportunities for securing measurable net gains for biodiversity. · CSA N87. ªProposed development within Local Plan is likely to increase the Plan area's carbon emissions by 21%º. NPPF 148. ªThe planning system should support the transition to a low carbon future in a changing climate. It should help to: shape places in ways that contribute to radical reductions in greenhouse gas emissions.º · CSA N91 ªA significant quantity of development is proposed by the Local Plan, a large proportion on greenfield sites where it is expected that new buildings will result in the direct loss of the soil resource. The loss to BMV land would reduce the quantity of the most productive and flexible agricultural land that can best
9714 deliver food and non-food crops for future generations.º NPPF 170: ºPlanning policies and decisions should contribute to and enhance the natural and local environment by: a) protecting and enhancing¼.. soilsº · CSA N60: ªNone of the potential Green Belt removal locations are anticipated to have a positive effect on water quality due to the significant increase in demand on water demand and treatment facilities. Water pollution may also be of concern.º NPPF 170 e) says: ªDevelopment should, wherever possible, help to improve local environmental conditions such as... water quality.º · N92 ªThe Local Plan is likely to have negative impacts upon water. Inputs into the watercourse may cause significant harm to the quality of water. Development proposed within the Local Plan is likely to increase total water consumption.º N87 ªDevelopment in the plan area¼ may exacerbate flood risk.º NPPF 155. ªInappropriate development in areas at risk of flooding should be avoided..º Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5511916 Please attach any supporting evidence
Person ID 1222741 Full Name Mr Peter Ward ID 4288 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be
9715 as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do These plans provide no properly specified or adequate remedy to the traffic problems in and around Chesham. not believe this policy to be An obvious example of these problems is the queue into Chesham that regularly forms on the A416 Amersham positively prepared please Road each weekday evening. If the town centre is to be developed and 500 homes are to be built at Ley Hill explain why the roads that provide access into Chesham and beyond will be put under further strain. We see nothing these plans that will solve the existing problems let alone cope with future traffic needs. PP Mods - Please specify as precisely and succinctly as
9716 possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222742 Full Name Miss Neena Bhatti ID 4226 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is
9717 not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is
9718 proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I STRONGLY OBJECT!! to the removal of Higher Denham, Denham Village and Tattling End from areas not believe this policy to be classified and categorised as green belt land.This decision is completely unnecessary and is in contravention positively prepared please of clear Government Green Belt Policies and the Bucks County Council policy to PROTECT THE GREEN explain why BELT. A review by Bucks County Council of green belt sites has already strongly rejected taking the mentioned settlements out of green belt land. The mitigation measures are vague and have no evidence to support them. The detailed sustainability appraisal which informs the local plan makes no mention of my settlement "Higher Denham", but it has been included in the settlements removed from the green belt. I strongly object!! to the proposed destruction of green belt land in my area, when brownfield sites elsewhere in the district are under utilised due to the high costs in assessing them.Your proposal will damage and deface the Denham country park and Colne valley park visitor centre. This proposal will damage the needed green spaces people need to combat mental health and physical wellbeing it will also increase traffic based pollution and congestion. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222743 Full Name Mr D Stratford ID 4257 Order 236 Number 11.3
9719 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible.
9720 Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The Council have asserted that government planning policy required local councils to review Green Belt not believe this policy to be boundaries when considering how to accommodate the development needed in their areas. Just because positively prepared please the Council may be required to look does not mean the Council should review Green Belt boundaries which explain why as previously stated should only be modified in ªexceptional circumstancesº. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not The proposals to release Green Belt land to meet housing targets are not cannot be justified from the evidence believe this policy to be submitted. justified please explain why Things that need to be considered are 1. Roads within the area would not be able to take the extra traffic 2. Water issues as the River Chess is already dry most of the year 3. Schools with the sizes needing to be increased which will lead to more Traffic issues 4. Shops and parking in the town would need to increase and improve 5. Waste water and the increased sewage will cause an issue A good example of traffic issues was on Thursday 18th July when Berkhamsted Road was closed due to the police incident.The Chesham side roads with all the on street parking will cause issues as using the side roads in the area is the only way to get round this when problems like this arise. I think that the council should reconsider not that an application has made for the land to be considered for Asset of Community Value that it is not a good thing to go any further with the plan for the Area. I question the soundness of this general policy and where all the brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable. How will the issue of waste water and sewage are covered as in the past years we in Chesham have had the issue where the sewage works. Has not been able cover the amount of waste and the river Chess has taken over flow which has caused issues with the quality of the water. Which has had an adverse effect on the river and wildlife of the area? The development of such Green Belt sites involving many hundreds of homes will cause issues with the local roads generate increased traffic and although some highways improvements are suggested they are
9721 insufficient.You can see the issues that will arise if you try to drive into and out of the town between the hours of 8.00am and 9.00am and 4.30pm and 6.00pm on a work day. Chesham cannot accommodate any significant highways improvements due to the already limited verges and space beside the highway and combines with the topography of the town this means that there will be increased traffic congestion with further worsening. Air pollution needs to be considered as some areas already fail Air Quality Management levels. Areas in Chesham already are recording air quality that is considerably worse than EU safe levels. Further doubt is cast upon the ªsoundnessº of this Plan by virtue of there being conflicting policies within it.The Council seem to think that the Green Belt sire NE of Chesham is sustainable and provides easy access to public transport including the tube station yet the same plan promotes a considerable increase in retail development in the town (local draft plan policy SP EP3), part of which would be built on the very car park that serves the Chesham tube station. This is inconsistent and unsound. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not For this plan to sound it must also be effective. Unfortunately, further review of the proposal to remove land believe this policy to be NE of Chesham at Lye Green from Green Belt designation is not effective as there are serious questions effective please explain why. about the deliverability of this land. The main landowner is a farmer who has asserted publically and in a letter to the editor of Your Chesham magazine that he is not prepared to release all of the land in his ownership for development. The land is also potentially an Asset of Community Value and upon confirmation of this designation it would afford a community group the right to bid for the land. The community group (Brown Not Green) have stated their intention is to preserve the land given that many hundreds of local people have habitually used the fields at Lye Green as of right for various informal outdoor recreational purposes. These uses themselves may mean that many local individuals may have acquired easements over and across the land through prescriptions (20 years uninterrupted use) not least of whom would be the many private residence bordering the fields that have rear garden fares onto the fields at Lye Green.These easement and prescriptive rights may render the land very difficult to develop and make it undeliverable in planning terms. It is perverse that the Local Authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the plan is unsound. The primary aim of green belt land (as recited in NPPF 133) is to prevent urban sprawl and to preserve the openness of the area. The Lye Green site self-evidently performs this function well and has done so for decades. I believe if this goes ahead we soon are part of Berkhamsted and next it will be Hemel Hempstead and before long will be the same size as Milton Keynes. This will be a loss of all the small villages that are in the area. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not National Planning Policy Framework (NPPF) as revised only last year, states in paragraph 11(b)I, directs believe this policy in ªplan makersº to create policies that are required in Local Plans for housing and other uses unless Framework consistent with the National policies (expressly including Green Belt) ªprovides a strong reason for restricting the overall scale type or Planning Policy Framework distribution of development in the plan areaº Accordingly, I submit that given all of the above land being Feb 2019 please explain why proposed for release from Green Belt designation around Chesham is unjustified and contrary to national guidance. I am supportive of the Brown Not Green organisation's initiative to have the land listed as an Asset of Community Value and I feel they speak for me in respect of their objections to the draft Local Plan. Accordingly, I request that any representations made by them at any future examination in public regarding the soundness of the Local Plan be considered as an extension of my own comments herein. I feel the land NE of Chesham is an unsustainable location for development, that has been habitually used by the community for improved health & wellbeing for decades and the land performs well against Green Belt aims and objectives. Exceptional circumstances for reviewing Green Belt boundaries at this location either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by Govt Policy and therefore the plan is unsound. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222748 Full Name Brenda Coxall ID 4259
9722 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as
9723 precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The proposals to release Green Belt land to meet housing targets (Generally, Spatial Policy SP SP1 & not believe this policy to be specifically Policy SP BP2 at Lye Green NE of Chesham) are not justified from the evidence submitted by positively prepared please the Councils. explain why The Councils have stated that release of some Green Belt is necessary as part of an overall three part strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. I question the soundness of such a general policy and whether all the brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites and in particular the Green Belt site NE of Chesham at Lye Green. The development of such Green Belt sites involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient and unfunded. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham cannot accommodate any significant highways improvements anyway due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion, with further worsening air quality. Air pollution is a particular concern in Chesham due to the already poor air quality along Bekhampstead Road where there is a designated Air Quality Management Area that already is recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will generate more traffic will make the air quality even worse and insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable nor justified nor is it in accordance with Govt policy. The Green Belt site NE of Chesham (SP BP 2) is not a sustainable location. It is over 2Km away from the train station and slightly further still from the town centre but anyone who cares to walk or cycle this distance also has to negotiate a steep hill too. Such an unsustainable location cannot be made sustainable merely by upgrading a couple of public footpaths within the site into bridleways to facilitate cycling. Neither does adding a bus stop address the geography or topography of the area especially if the promised enhanced bus service (which is already infrequent) either does not materialise or if it subsequently fails to be maintained after a few years. Further doubt is cast upon the ªsoundnessº of this Plan by virtue of there being conflicting policies within it. The Council seem to think that the Green Belt site NE of Chesham is sustainable and provides easy access to public transport including the tube station yet the same Plan promotes a considerable increase in retail
9724 development in the town (local draft plan policy SP EP3) , part of which would be built on the very car park that serves the Chesham tube station. This is inconsistent and unsound. The land is also potentially an Asset Of Community Value and upon confirmation of this designation it would afford a community group the right to bid for the land. The community group (Brown Not Green) have stated their intention is to preserve the land given that many hundreds of local people have habitually used the fields at Lye Green as of right for various informal outdoor recreational purposes. These uses themselves may mean that many local individuals may have acquired easements over and across the land through prescription (20 years uninterrupted use) not least of whom would be the many private residences bordering the fields that have rear garden gates onto the fields at Lye Green. These easements and prescriptive rights may render the land very difficult to develop and make i undeliverable in planning terms. This land also provides an important habitat for wildlife that will be threatened by development of this land. It is perverse that the Local Authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Plan is unsound. PP Mods - Please specify as I refer to the comments previously submitted but in summary would advocate that; precisely and succinctly as All other options are fully explored including increased density of development of brownfield land and the possible how you would policies emerging from Chesham Masterplan. modify this policy to improve its alignment to this test of Green Belt land should only be considered when all other options are exhausted and in any event the soundness. proposals for developing land NE of Chesham (policy SP BP 2) should be removed as it is an unsustainable location the development of which will cause harm to the wider town including loss of an asset that improves the well-being for the community. Policy 1 - If you do not I refer to my comments previously submitted. believe this policy to be justified please explain why Policy 2a - Please specify as I refer to my comments previously submitted. precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not For this Plan to sound it must also be effective. Unfortunately, further review of the proposal to remove land believe this policy to be NE of Chesham at Lye Green from Green Belt designation is not effective as there are serious questions effective please explain why. about the deliverability of this land. The main landowner is a farmer who has asserted publicly and in a letter to the editor of Your Chesham, that he is not prepared to release all of the land in his ownership for development. PAa - Please specify as I refer to my comments previously submitted. precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I believe the draft Local Plan is NOT legally compliant because it has not demonstrated sufficient regard to believe this policy in the National Policy and guidance issued by the Secretary of State. consistent with the National The National Planning Policy Framework (NPPF) together with other guidance issued by the Government Planning Policy Framework is also supported by recent ministerial statements that have made it clear that Local Authorities MUST Feb 2019 please explain why demonstrate they have exhausted all options BEFORE considering revision of Green Belt boundaries. This Local Plan is seeking substantial modifications to Green Belt boundaries including the removal of Green Belt designation of 13 areas within the Districts as well as modifying the Green Belt status of many local villages. I contend this draft Local Plan has not demonstrated that all other options have been fully explored and as such this Plan is not justified, sound or in accordance with National Policy and accordingly is not legally compliant. Furthermore that Paragraph 11 b) of the NPPF (and the footnotes thereto) require Plan Makers to provide for objectively assessed needs for housing and other uses UNLESS the application of Framework policies (including Green Belt) provide a strong reason for restricting the overall scale, type or distribution of development in the plan area Chiltern District & South Bucks are significantly constrained by development policies such as Green Belt & Areas of Outstanding Natural Beauty (AONB). The Local Plan is therefore inconsistent with National Guidance and as such it is not legally compliant for the Local Authority to claim that housing needs justify a review of these same Green Belt boundaries. It is perverse to claim that the combination of housing need and the presence of significant areas of development constraint policy collectively represent ªexceptional circumstancesº (as required in the NPPF) to justify modification of Green Belt boundaries especially given the NPPF states that one of the key features of Green Belts are their permanence. The Government has also recently confirmed its aim for the UK to have net zero carbon emissions by 2050 and it is noted within the Sustainability Appraisal supporting this Draft Local Plan, that the Plan area is forecast to see carbon emission increase by 21% in the Plan Period. Accordingly, the Plan is inconsistent with Government Policy and therefore not legally compliant. There is also a significant infrastructure funding gap acknowledged within the Community Infrastructure Levy evidence that supports this Local Plan, of between £179m & £231m. Given this infrastructure is vital to ensure that development is sustainable (as also required by the NPPF) this further demonstrates the Plan is both unsound and not legally compliant.
9725 The foregoing also points to flawed methodology of Green Belt site selection used by the Local Authority, which is neither effective, justified nor consistent with national policy and as such is unsound. Specifically, the selection of the land NE of Chesham at Lye Green (policy SP BP2) for removal from Green Belt designation is inconsistent with National Planning Policy Framework (NPPF). Paragraph 136 of the latest NPPF asserts that Green Belt boundaries should only be modified in ªexceptional circumstancesº. The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances. The Council engaged third party consultants to undertake the Part 1 Green Belt assessment and they identified numerous sites for ªfurther considerationº where exceptional circumstances ªmightº exist but expressly recommended further review of their assessment of each site against the 5 purposes of land being in Green Belt of all these sites. Unlike the neighbouring Local Authorities, the Part 2 Green Belt assessment was not undertaken by third party consultants but by the Local Authority itself who notably then did not undertake all the recommended reviews of each site including the land NE of Chesham at Lye Green (SP BP 2). Accordingly, this oversight in the Part 2 Green Belt assessment placed premature focus and fixation on releasing land at Lye Green NE of Chesham from Green Belt designation. The subsequent identification of the Chesham site for release is therefore unjustified. The primary aim of Green Belt land (as recited in NPPF 133) is to prevent urban sprawl and to preserve the openness of the area. The Lye Green site (SP BP2) self-evidently performs this function well and has done so for decades. Another aim of Green Belt land stated in NPPF paragraph 134, is to prevent neighbouring towns and settlements from merging into one another.The Green Belt land NE of Chesham performs exceptionally well in maintaining a distinct separate between settlements of Chesham & Lye Green as well as helping to maintain separate identities of other nearby communities at Orchard Leigh, Botley, Whelpley Hill, Ashley Green. It is perverse and inconsistent with national guidance to allocate this land for removal from Green Belt in light of these facts especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if earmarked for development. A further aim of Green Belt designation stated in the NPPF at paragraph 134 (e) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. By allocating Green Belt land NE of Chesham for development, undermines this aim within Chesham. A community lead not for profit organisation called Chesham Renaissance CIC has been striving to create Chesham Masterplan that would not only provide many genuinely affordable homes in more sustainable locations nearer the town centre, but which would also regenerate some of the more deprived wards within Chesham. The Local Authority's proposals (policy SP EP3) are inconsistent with this local initiative and are therefore also inconsistent with national guidance and are consequently unsound. The Council have asserted that Government planning policy requires local councils to review Green Belt boundaries when considering how to accommodate the development needed in their areas. Just because the Council may be required to look, does not mean the Council should review Green Belt boundaries which as previously stated should only be modified in ªexceptional circumstancesº. National Planning Policy Framework (NPPF) as revised only last year, states in paragraph11 (b) I, directs ªplan makersº to create policies that are required in Local Plans for housing and other uses unless Framework policies (expressly including Green Belt) ªprovides a strong reason for restricting the overall scale type or distribution of development in the plan areaº Accordingly, I submit that given all of the above the land being proposed for release from Green Belt designation around Chesham is unjustified and contrary to national guidance. I feel the land NE of Chesham is an unsustainable location for development, that has been habitually used by the community for improved health & wellbeing for decades and the land performs well against Green Belt aims and objectives. Exceptional circumstances for reviewing Green Belt boundaries at this location, either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by Govt Policy and therefore the plan is unsound. Policy 3a - Please specify as The Plan needs to be modified by; precisely and succinctly as Co-operating with other nearby authorities. Not just Aylesbury. It is simply unsatisfactory to assert this cannot possible how you would be done because they are different Functional Market Areas and that co-operation is not necessary therefore. modify this policy to improve its alignment to this test of Exploring such wider co-operation may result in further housing needs being taken elsewhere. soundness. A more detailed appraisal of brownfield land opportunities MUST be undertaken. Some brownfield opportunities have been ignored or missed. Closer scrutiny of alternative options for housing delivery should be explored (such as Chesham Masterplan by CIC Chesham Renaissance). Green Belt boundary reviews should only be considered AFTER all other reasonable alternatives have been exhausted. In the face of NPPF guidance and a more thorough appraisal of Green Belt sites being considered, it may then be necessary to conclude that it is not possible to identify poor performing Green Belt sites that can accommodate all the OAN for housing. Consequently it may be necessary to accept that a lower housing provision figure is appropriate. Policy-level file upload - 5500704 Please attach any supporting evidence
Person ID 1223416 Full Name Mr and Mrs D J Blower ID 5023 Order 236
9726 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as
9727 precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I feel I must write to you about the planned proposal to build 500 houses on Green Belt land. Apart from not believe this policy to be destroying the wild life, and the countryside how is chesham supposed to handle all the extra traffic, which positively prepared please will cause more pollution as jams through Chesham are bad enough now! explain why It is hard to get children into their preferred school now, without the influx of more families. Utilities such as the sewerfarm, as we know sewage at times is let out into the river, which surely is a health hazard. It seems to be a numbers game for the amount of houses to be built, no thought for the enviroment or infrastructure. I therefore request that the council now reconsider the flawed proposal NE of Chesham and request that you remove this land from any further consideration of development or the removal of the lands Green Belt status. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve
9728 its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1223461 Full Name Jennifer White ID 5292 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible.
9729 Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do There is effectively one road going through Chesham (A413) and anyone going south or west of the town not believe this policy to be will use it. This road is already congested at rush hours, leading to concern over quality of air in a road with positively prepared please an Infants school. explain why - More cars (hundreds?) coming down the hill to join the A413 is not an acceptable situation. - Torrential rain still brings flooding to the A413 in town making it very difficult for pedestrians. With land concreted over there is more water to flow down the hill. - Have planners assessed housing needs locally considering both social housing and others? PP Mods - Please specify as precisely and succinctly as
9730 possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not - The area of fields is enjoyed by local people for dog walking, jogging and relaxing. This has been so since believe this policy to be the hilltop estate was built (1960?) justified please explain why - The area is home to many birds, animals and butterflies because of natural habitats. Do we really want to ignore the decline in nature species in our country? Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1223462 Full Name Brian Moulton ID 5233 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you
9731 consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible.
9732 Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do We have live in Chesham for over 40 years and our community in Chesham should be undertaken. The plan not believe this policy to be presented by the council shows a total lack of understanding as to the wants and needs of Chesham town positively prepared please and its people. explain why Chesham town has empty shops and a shortage of car parking spaces.That the plan should propose a large retail development on the station car park shows how much the planners have failed to understand local circumstances. PP Mods - Please specify as `Chesham renaissance' and `Brown not Green' have worked hard to present well thought out proposals which precisely and succinctly as are well supported by the local community. possible how you would Planners have failed to engage with these organisations in a professional way.The local plan must be guided modify this policy to improve by these organisations. An appraisal of brownfield land opportunities and alternative options for housing its alignment to this test of must be undertaken. soundness. Green belt boundary reviews must be the last resort. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not The green belt site NE of Chesham (SP BP 2) is not a sustainable location. It is over 2km away from the believe this policy to be train station. The increase in traffic, due to increased housing, will become impossible. It is already difficult effective please explain why. to pull out of our house in Lye Green Road in the morning and evening, and the roundabout at the top of Eskdale Avenue can become quite dangerous, especially with all the cars belonging to Chesham Grammar School pupils parked around the surrounding roads. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not We consider the local plan is legally non-compliant because the local authority has not demonstrated they believe this policy in have exhausted all options before considering revision of green belt boundaries. consistent with the National Local infrastructure is irresponsible and shows that the plan is unsound and not legally complaint. Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1223473 Full Name Mrs Mary Adlington ID 5199 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details
9733 Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence
9734 Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The local authority has not demonstrated they have exhausted all options before considering revisions of not believe this policy to be Green Belt boundaries. positively prepared please The plan area is forecast to increase carbon emission by 21% which is not consistent with government policy. explain why There is also a significant infrastructure funding gap. PP Mods - Please specify as There must be more detailed appraisal of brown field sites as alternative options for housing delivery. precisely and succinctly as There are various sites nearer the town centre which would enable residents to walk into town and not use possible how you would cars, especially as car parking is limited and the pollution is Chesham is high. modify this policy to improve its alignment to this test of It may be necessary to accept a lower housing provision. soundness. If there has to be more housing here, then build it on the brown field sites that already exist in the town. We need cycle paths and safe pedestrian ways, so we do not have to be so reliant on the car. Policy 1 - If you do not It is impossible for me to drive into Chesham during the morning rush hours. The flooding is increasingly a believe this policy to be problem and the loss of water in the Chess is appalling. Because of the topography of the town, the only justified please explain why way to have more housing is close to the town centre. The public transport from outlying villages where I live has been cur, the post offices and shops have gone. The infrastructure cannot cope with houses being built on the outskirts of the town. The hills are steep and are too hard to walk as people get older. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why
9735 Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1223490 Full Name R HOYLE ID 5070 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant
9736 legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve
9737 its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not Firstly:See NPPF para.s 134, 137. believe this policy in Green Belt exists to restrict sprawl of large built-up areas; inconsistent on both the macro scale (the removal consistent with the National of the recreation ground which opens out Chesham) and the Mega scale (the infilling of the belt around Planning Policy Framework london increasing it©s sprawl, presumably occupied by commuters) Feb 2019 please explain why (c) encroachment on the countryside; (e) the recycling of derelict and other urban land has not been explored fully. 137. " the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development " This has not been demonstrated, Secondly: Does not include " landscape and visual enhancements _(beyond those needed to mitigate the immediate impacts of the proposal)_; NPPF, Guidance, Paragraph: 002 Reference ID: 64-002-20190722 Policy 3a - Please specify as Firstly: Abandon this satellite suburb on rural land, extending and linking two urban areas. Adopt instead the precisely and succinctly as Chesham masterplan, propossed by award winning town planners, allowing infilling insid e the town on possible how you would bwrownfield sites. modify this policy to improve Secondly: Incorporate such its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1223534 Full Name David Skepper ID 5092 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies
9738 and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary
9739 to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not The proposals to release Green Belt land to meet housing targets (Generally, Spatial Policy SP SP1 and believe this policy to be specifically Policy SP BP2 at Lye Green NE of Chesham) are not justified from the evidence submitted by justified please explain why the Councils. The Councils have stated that release of some Green Belt is necessary as part of an overall three part strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. I question the soundness of such a general policy and whether all the brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites and in particular the Green Belt site NE of Chesham at Lye Green. The development of such Green Belt sites involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient and unfunded. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham cannot accommodate any significant highways improvements anyway due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion, with further worsening air quality. Air pollution is a particular concern in Chesham due to the already poor air quality along Berkhampstead Road where there is a designated Air Quality Management Area that already is recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will generate more traffic will make the air quality even worse and insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable nor justified nor is it in accordance with Government policy. The Green Belt site NE of Chesham (SP BP 2) is not a sustainable location. It is over 2Km away from the TFL station and slightly further still from the town centre but anyone who cares to walk or cycle this distance also has to negotiate congested narrow roads and a winding steep hill. Such an unsustainable location cannot be made sustainable merely by upgrading a couple of public footpaths within the site into bridleways to facilitate cycling. Neither does adding a bus stop address the geography or topography of the area especially if the promised enhanced bus service (which is already infrequent) either does not materialise or if it subsequently fails to be maintained after a few years. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not For this Plan to sound it must also be effective. Unfortunately, further review of the proposal to remove land believe this policy to be NE of Chesham at Lye Green from Green Belt designation is not effective as there are serious questions effective please explain why. about the deliverability of this land. The main landowner is a farmer who has asserted publicly and in a letter to the editor of Your Chesham, that he is not prepared to release all of the land in his ownership for development. The land is an Asset Of Community Value and upon confirmation of this designation it would afford a community group the right to bid for the land. The community group (Brown Not Green) have stated their intention is to preserve the land given that many hundreds of local people have habitually used the fields at Lye Green as of right for various informal outdoor recreational purposes. These uses themselves may mean that many local individuals may have acquired easements over and across the land through prescription (20 years uninterrupted use) not least of whom would be the many private residences bordering the fields that have rear garden gates onto the fields at Lye Green. These easements and prescriptive rights may render the land very difficult to develop and make it undeliverable in planning terms. I and my family have used this area for 25 years. As a father of an 18 month old, I believe that this area should continue to be available for future generations. This land also provides an important habitat for wildlife that will be threatened by development of this land.
9740 It is perverse that the Local Authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Plan is unsound. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I believe the draft Local Plan is NOT legally compliant because it has not demonstrated sufficient regard to believe this policy in the National Policy and guidance issued by the Secretary of State. consistent with the National The National Planning Policy Framework (NPPF) together with other guidance issued by the Government Planning Policy Framework is also supported by recent ministerial statements that have made it clear that Local Authorities MUST Feb 2019 please explain why demonstrate they have exhausted all options BEFORE considering revision of Green Belt boundaries. This Local Plan is seeking substantial modifications to Green Belt boundaries including the removal of Green Belt designation of 13 areas within the Districts as well as modifying the Green Belt status of many local villages. I contend this draft Local Plan has not demonstrated that all other options have been fully explored and as such this Plan is not justified, sound or in accordance with National Policy and accordingly is not legally compliant. Furthermore that Paragraph 11 b) of the NPPF (and the footnotes thereto) require Plan Makers to provide for objectively assessed needs for housing and other uses UNLESS the application of Framework policies (including Green Belt) provide a strong reason for restricting the overall scale, type or distribution of development in the plan area Chiltern District and South Bucks are significantly constrained by development policies such as Green Belt & Areas of Outstanding Natural Beauty (AONB). The Local Plan is therefore inconsistent with National Guidance and as such it is not legally compliant for the Local Authority to claim that housing needs justify a review of these same Green Belt boundaries. It is perverse to claim that the combination of housing need and the presence of significant areas of development constraint policy collectively represent ªexceptional circumstancesº (as required in the NPPF) to justify modification of Green Belt boundaries especially given the NPPF states that one of the key features of Green Belts are their permanence. The Government has also recently confirmed its aim for the UK to have net zero carbon emissions by 2050 and it is noted within the Sustainability Appraisal supporting this Draft Local Plan, that the Plan area is forecast to see carbon emission increase by 21% in the Plan Period. Accordingly, the Plan is inconsistent with Government Policy and therefore not legally compliant. There is also a significant infrastructure funding gap acknowledged within the Community Infrastructure Levy evidence that supports this Local Plan, of between £179m & £231m. Given this infrastructure is vital to ensure that development is sustainable (as also required by the NPPF) this further demonstrates the Plan is both unsound and not legally compliant. Any local resident is painfully aware that transport, educational and NHS services are already running over capacity. Policy 3a - Please specify as The Plan needs to be modified by: precisely and succinctly as Co-operating with other nearby authorities. Not just Aylesbury. It is simply unsatisfactory to assert this cannot possible how you would be done because they are different Functional Market Areas and that co-operation is not necessary therefore. modify this policy to improve its alignment to this test of Exploring such wider co-operation may result in further housing needs being taken elsewhere. soundness. A more detailed appraisal of brownfield land opportunities MUST be undertaken. Some brownfield opportunities have been ignored or missed. I refer to the comments previously submitted but in summary would advocate that; All other options are fully explored including increased density of development of brownfield land and the policies emerging from Chesham Masterplan. Green Belt land should only be considered when all other options are exhausted and in any event the proposals for developing land NE of Chesham (policy SP BP 2) should be removed as it is an unsustainable location the development of which will cause harm to the wider town including loss of an asset that improves the well-being for the community. The foregoing also points to flawed methodology of Green Belt site selection used by the Local Authority, which is neither effective, justified nor consistent with national policy and as such is unsound. Specifically, the selection of the land NE of Chesham at Lye Green (policy SP BP2) for removal from Green Belt designation is inconsistent with National Planning Policy Framework (NPPF). Paragraph 136 of the latest NPPF asserts that Green Belt boundaries should only be modified in ªexceptional circumstancesº. The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances. The Council engaged third party consultants to undertake the Part 1 Green Belt assessment and they identified numerous sites for ªfurther considerationº where exceptional circumstances ªmightº exist but expressly recommended further review of their assessment of each site against the 5 purposes of land being in Green Belt of all these sites. Unlike the neighbouring Local Authorities, the Part 2 Green Belt assessment was not undertaken by third party consultants but by the Local Authority itself who notably then did not undertake all the recommended reviews of each site including the land NE of Chesham at Lye Green (SP BP 2). Accordingly, this oversight in the Part 2 Green Belt assessment placed premature focus and fixation on releasing land at Lye Green NE of Chesham from Green Belt designation. The subsequent identification of the Chesham site for release is therefore unjustified. Closer scrutiny of alternative options for housing delivery should be explored (such as Chesham Masterplan by CIC Chesham Renaissance). Green Belt boundary reviews should only be considered AFTER all other reasonable alternatives have been exhausted.
9741 In the face of NPPF guidance and a more thorough appraisal of Green Belt sites being considered, it may then be necessary to conclude that it is not possible to identify poor performing Green Belt sites that can accommodate all the OAN for housing. Consequently it may be necessary to accept that a lower housing provision figure is appropriate. Policy-level file upload - Please attach any supporting evidence
Person ID 1222800 Full Name Miss Stella Pearson ID 4327 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as
9742 precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I consider that the Local Plan's proposals to release Green Belt land to meet housing targets (generally: not believe this policy to be Spatial Policy SP SP1 and specifically: Policy SP BP2 at Lye Green NE of Chesham) are not sound nor positively prepared please justified, for the following reasons: explain why · There is insufficient consideration to infrastructure, traffic capacity and air quality. The development of these Green Belt sites involving hundreds of new homes, 15 traveller sites, a 5000sq foot shop and a `community hub' will generate significantly increased traffic, and the highways improvements suggested in the Plan are insufficient and unfunded. In Chesham, most of the roads and infrastructure are already operating above capacity. Chesham's topography and limited space beside the highways means little opportunity to expand lanes, resulting in increased traffic congestion, with further worsening air quality. Chesham already suffers from poor air quality along Berkhampstead Road where a designated Air Quality Management Area is already reporting air quality considerably poorer than EU safe levels. · The Green Belt site NE of Chesham (SP BP 2) is not a sustainable location. It is over 2km from Chesham train station and town centre, and up a steep hill, making it an unlikely location from which new residents will walk or cycle. Residents from this development will be commuting to Chesham, Aylesbury or Hemel Hempstead down already congested single carriageways, and the Plan does not include extension of provision for car parking; indeed it suggests that new retail development would be built on some of the existing car park space in Chesham. Promises to enhance the local bus service from Lye Green are unfounded and unlikely to prevent the vast majority from using their cars.
9743 · This land also provides an important habitat for wildlife that will be threatened by development. I submit that for all the reason given above the land being proposed for release from Green Belt designation around Chesham is unjustified, unsound and legally non-compliant. The Local Plan should be modified to include: · A more detailed appraisal of brownfield land opportunities, including underused sites closer to or within Chesham town centre. · Closer scrutiny of alternative options for housing delivery. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I consider that the Local Plan is not legally compliant as it does not accord with the National Planning Policy believe this policy in Framework (NPPF) which states that: consistent with the National · Green Belt boundaries should only by revised in `exceptional circumstances' (NPPF paragraph 136) and Planning Policy Framework after Local Authorities have demonstrated that they have exhausted all options before considering such Feb 2019 please explain why revision. This Local Plan is seeking to remove the Green Belt designation of 13 areas within the Districts as well as modifying the Green Belt status of many local villages.The Plan does not demonstrate that alternatives have been explored which utilise existing brownfield sites, as suggested for the town of Chesham by local group Chesham Renaissance CIC in their `Chesham Masterplan'. · Green Belt aims to prevent neighbouring towns and settlements from merging into one another (NPPF paragraph 134). The Green Belt land North East of Chesham maintains a distinct separateness between settlements of Chesham and Lye Green as well as helping to maintain separate identities of other nearby communities at Orchard Leigh, Botley, Whelpley Hill and Ashley Green. It is inconsistent with national guidance, and therefore not legally compliant, to allocate this land for removal from Green Belt. · Green Belt also aims to assist in urban regeneration by encouraging the recycling of derelict and other urban land. (NPPF paragraph 134(e)). The aforementioned vision put forward by Chesham Renaissance CIC offers to do this by proposing affordable homes in more sustainable locations nearer the town centre, which would also regenerate some of the more deprived wards within Chesham. Allocating Green Belt land NE of Chesham for development undermines this aim within Chesham, and without due consideration of the alternatives is therefore legally unsound. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5500813 Please attach any supporting evidence
Person ID 1222808 Full Name Mr Stuart Brown ID 4244 Order 236 Number 11.3
9744 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible.
9745 Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do If an ANOB is considered Green Belt how can it be sound to release it from Green Belt if it has qualified as not believe this policy to be such. This is a complete contradiction of criteria. Is Green Belt release consistent with other policies such positively prepared please as to protect wildlife habitats or biodiversity. Housing needs alone are not exceptional circumstances to explain why release areas from the Green Belt. This plan is not justified, it's reactive.There is clearly a housing shortage, but the authorities need to consider building on existing areas/expansion or using brown sites; just releasing areas from Green Belt to build (which developers will be required to deliver infrastructure as part of the development) is outrageous. These sites which are proposed are socially used, intrinsic to habitat and are not a solution to a problem which we acknowledge is there but no effort has gone into a reasonable solution. The council are not thinking about the current use of the land but what is can be used for. The town of Chesham is already over populated. PP Mods - Please specify as Build on Brownfield sites precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not The plan does not evaluate the current town and use of the land. The land is an asset of community value. believe this policy to be There is no mention in the plan with alternative sites for recreation. justified please explain why Policy 2a - Please specify as Removing Green Belt areas from Green Belt diminishes the value of the area. precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not It is not effective to put a plan I place with an acknowledged funding gap, there are no exceptional believe this policy to be circumstances to remove the land from green belt, and there was no prior consultation on Green Belt Village effective please explain why. Policies (SP PP & DM PP 1). PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve
9746 its alignment to this test of soundness. Policy 3 - If you do not As above. There are no exceptional circumstances. believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as Build on brownfield sites. precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1222864 Full Name Adrian Pearce ID 4345 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Managing Director Zoggs Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible.
9747 Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I wish to object to the plans to build 500 houses in the Lye Green area of Chesham. not believe this policy to be The draft Local plan is unsound because all the current infrastructure in Chesham is inadequate and there positively prepared please is no detail or costing in the Infrastructure Delivery Schedule to show how the current situation will be improved, explain why let alone accommodate additional dwellings. I am especially concerned about the capacity of Berkhamsted Road and Broad Street to cope with additional rush hour traffic. It already takes too long to navigate through the town already. What feasible/cost effective way could Berkhamsted and Amersham be connected that is more efficient to know? A Chesham town bypass?
9748 PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1223544 Full Name Mrs Tricia Wilson ID 5131 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant.
9749 Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as
9750 precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not The proposals to release Green Belt land to meet housing targets (Generally, Spatial Policy SP believe this policy to be SP1 & specifically Policy SP BP2 at Lye Green NE of Chesham) are not justified based on the evidence justified please explain why submitted by the Councils. The Councils have stated that release of some Green Belt is necessary as part of an overall three part strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. We question the soundness of such a general policy given that the council has repeatedly failed to demonstrate that it has sought to identify and rigorously assess the suitability of brownfield land opportunities, and the desirability of achieving higher densities of development on these sites, which are generally closer to the town centre and more consistent with the Councils' strategic objectives. The development of Green Belt sites to the north of Chesham involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient, unfunded and not planned for completion before development of the sites. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity with air pollution already a significant issue. The Councils are aware that Air pollution is a particular concern in Chesham due to the already poor air quality along Berkhamsted Road. The designated Air Quality Management Area there is already recording air quality levels considerably worse than legal safe levels. The traffic associated with additional housing will further exacerbate this issue unless significant remodelling of local roads and transport infrastructure is carried out. Again, these changes need to be made in advance of any significant addition to housing and local populations. In particular, from the point of view of transportation and travel the Green Belt site NE of Chesham (SP BP 2) is not a sustainable location. It is over 2Km away from the train station and slightly further still from the town centre. The Councils declared intent to increase use of, for example, cycling or walking in order to reduce environmental impact are unrealistic given the steep hill that separates the planned development from the town centre's shops, health services, schools, sites of employment and transportation links. Policy 2a - Please specify as Modifications precisely and succinctly as We refer to the comments previously submitted but in summary would advocate that: possible how you would modify this policy to improve · All other options are fully explored including increased density of development of brownfield land its alignment to this test of · As it relates to Chesham, the Councils embody and embrace in their plans the community-focused policies soundness. and exciting opportunities for the future development of Chesham as outlined in the Chesham Masterplan and the work being undertaken by CIC Chesham Renaissance. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I believe the draft Local Plan is NOT legally compliant because it has not demonstrated sufficient regard to believe this policy in the National Policy and guidance issued by the Secretary of State. consistent with the National
9751 Planning Policy Framework The National Planning Policy Framework (NPPF) together with other guidance issued by the Government Feb 2019 please explain why is also supported by recent ministerial statements that have made it clear that Local Authorities MUST demonstrate they have exhausted all options BEFORE considering revision of Green Belt boundaries. This Local Plan is seeking substantial modifications to Green Belt boundaries including the removal of Green Belt designation of 13 areas within the Districts as well as modifying the Green Belt status of many local villages. I contend this draft Local Plan has not demonstrated that all other options have been fully explored and as such this Plan is not justified, sound or in accordance with National Policy and accordingly is not legally compliant. Furthermore that Paragraph 11 b) of the NPPF (and the footnotes thereto) require Plan Makers to provide for objectively assessed needs for housing and other uses UNLESS the application of Framework policies (including Green Belt) provide a strong reason for restricting the overall scale, type or distribution of development in the plan area Chiltern District and South Bucks are significantly constrained by development policies such as Green Belt & Areas of Outstanding Natural Beauty (AONB). The Local Plan is therefore inconsistent with National Guidance and as such it is not legally compliant for the Local Authority to claim that housing needs justify a review of these same Green Belt boundaries. It is perverse to claim that the combination of housing need and the presence of significant areas of development constraint policy collectively represent ªexceptional circumstancesº (as required in the NPPF) to justify modification of Green Belt boundaries especially given the NPPF states that one of the key features of Green Belts are their permanence. The Government has also recently confirmed its aim for the UK to have net zero carbon emissions by 2050 and it is noted within the Sustainability Appraisal supporting this Draft Local Plan, that the Plan area is forecast to see carbon emission increase by 21% in the Plan Period. Accordingly, the Plan is inconsistent with Government Policy and therefore not legally compliant. There is also a significant infrastructure funding gap acknowledged within the Community Infrastructure Levy evidence that supports this Local Plan, of between £179m & £231m. Given this infrastructure is vital to ensure that development is sustainable (as also required by the NPPF) this further demonstrates the Plan is both unsound and not legally compliant. · The selection of the land NE of Chesham at Lye Green (policy SP BP2) for removal from Green Belt designation is inconsistent with National Planning Policy Framework (NPPF). Policy 3a - Please specify as The Plan needs to be modified by: precisely and succinctly as Demonstrating that you have cooperated fully with neighbouring and nearby authorities -not just Aylesbury. possible how you would Your assertion this cannot be done because they are different Functional Market Areas and that co-operation modify this policy to improve is not necessary makes no sense and is counter to the declared strategic aims of the authority. its alignment to this test of soundness. Exploring such wider co-operation may result in further housing needs being taken elsewhere or opportunities to optimise investments in infrastructure, improve environmental sustainability, and increase economic growth in the region. As mentioned in earlier responses to earlier consultation rounds, an integrated plan responding to all Strategic goals ± rather than one that focuses disproportionately on housing provision is required. It should take account of the excellent work already done by, for example, CIC Chesham Renaissance in its Chesham Masterplan. Specifically, more detailed appraisals of brownfield land opportunities MUST be undertaken. Many brownfield opportunities have been ignored or missed. Green Belt boundary reviews should only be considered AFTER all other reasonable alternatives have been exhausted. The authority has repeatedly failed to respond to this point, which has been made repeatedly in earlier rounds of consultation. In the face of NPPF guidance and a more thorough appraisal of Green Belt sites, it may then be necessary to conclude that it is not possible to identify poor performing Green Belt sites that can accommodate all the OAN for housing. Consequently, it may be necessary to accept that a lower housing provision figure is appropriate. Policy-level file upload - 5512462 Please attach any supporting evidence
Person ID 1223091 Full Name Colin Blundel ID 4630 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Local Authority select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body?
9752 Agent on behalf of - Chiltern Society Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act
9753 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not The Society objects to this allocation because it would lead to a loss of open Green Belt land on the edge believe this policy to be of Chesham. justified please explain why The Exceptional Circumstances Report assessed the site and concluded that the benefits of the development clearly outweighed the harm. The Society disagrees with this assessment as we consider the development would have a significant impact on the openness and permanence of the Green Belt. In particular, the Green Belt makes a significant contribution to reducing urban sprawl and preventing the encroachment of open countryside. The justification for the allocation relies very heavily on incorporating mitigation measures to make it acceptable. The conclusion states that the impacts on the Green Belt can be mitigated. With the most significant impact being the loss of openness, we do not see how this could be mitigated through the development. The conclusion seems to suggest the Green Belt is a landscape and biodiversity designation rather than a mechanism for protecting the openness of the countryside. We do not consider that the evidence exists to demonstrate exceptional circumstances for removing the site from the Green Belt. The need for housing is not, on its own, an exceptional circumstance, particularly as there is a significant alternative option within the town. The Chesham Renaissance have developed a Masterplan to provide 450 homes within the Chesham Town Centre.This could provide new homes in a highly sustainable location close to public transport interchanges. Works could also be undertaken to enhance the amenity of the town centre by removing the culvert from the Vale Brook. Developing a site with a high density within the town centre will enable this site to be removed from the plan, thus protecting both the Green Belt and the setting of the AONB. The development would lead to more traffic passing through the Air Quality Management Zone on Berkhamstead Road in Chesham. We question whether residents would cycle from this site due to the poor air quality and the hilly terrain. A development within walking distance of the town centre / station would be preferable. We, therefore, consider that this proposal is unacceptable on sustainability grounds. The site would be in the setting of the AONB and would bring the developed area of the town much further out into the countryside. As well as potential visual impacts on the AONB it would conflict with the aim of the Green Belt to prevent encroachment into open countryside. It is unclear from the Local Plan why the Chesham Masterplan has been ignored in favour of this site. We recommend that this site is removed from the Plan and the development strategy for Chesham revised. Policy 2a - Please specify as The development strategy for Chesham needs to be fundamentally reviewed and should incorporate the precisely and succinctly as recommendations of the Chesham Masterplan, moving development to a more sustainable location within possible how you would the town centre. modify this policy to improve
9754 its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1223598 Full Name Jeremy Russell ID 5273 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance?
9755 Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible
9756 Policy Level - PP - If you do I am writing to express my concerns about the recently published Local Plan for Chiltern and South Bucks not believe this policy to be and to submit my comments to the Independent Planning Inspector. I have come to the conclusion that the positively prepared please explain why Local Plan as it stands is unsound for the following reasons: The developments proposed in the Local Plan will result in an increase in the carbon footprint of the Chiltern/South Bucks area of 21% or more ( Sustainability Appraisal of the Chiltern and South Bucks Local Plan, Table N4, p. xxxiii ). This is unacceptable. Chapter 3 - Sustainable Places, para. 3.1.2 states that `the Councils will strive to conserve the environment whilst also promoting sustainable economic growth' and will `conserve the Green Belt through the planning process, whilst balancing the need for housing'. The Local Plan proposes to remove 60 hectares of Green Belt land at Lye Green on the outskirts of Chesham for housing (Policy SP BP 2) . This site is 2.5 km from the town centre and at the top of a steep hill, not within practicable walking or cycling distance, so any future residents travelling into Chesham would have to drive into the town. Clearly this development, if built, would substantially increase the present rush hour traffic congestion in the town, and add to air pollution, which is already at dangerous levels. For example, Berkhampstead Road is a designated Air Quality Management Area where the air quality is already above EU safe levels. Building on this site would also destroy an area which has recently been officially listed as an Asset of Community Value and thus plays a vital role in the health and well-being of the local population. As I understand it, that there have to be `exceptional circumstances' in order for land to be removed from the Green Belt and that housing needs alone are not considered by the courts to be `exceptional circumstances'. Therefore I consider that this policy is unsustainable and therefore unsound. I would suggest that brownfield sites in the area should be looked at first. Obviously these are more difficult and less attractive to developers but I don't think that we should destroy the Green Belt for their convenience. However should these housing plans go ahead, there are two opportunities that I think have been missed. One is to make the new housing carbon neutral. There is a `low carbon' statement in the report which refers to a measly 20% reduction which will scarcely make a dent in the extra carbon created. Why not insist on complete sustainability? There is an opportunity here for Chesham and Buckinghamshire to lead the way in sustainable development and to create something amazing. Which is why I think the plan should also specify that the land should be either self- build or given to small developers so it has a mixture of styles and aesthetics just as an organically grown area has. I also understand that the Local Plan has an infrastructure funding gap of between £179m and £231m ( CIL Funding Gap Analysis June 2019 ). This is another indication that the Local Plan has not been thought through and is therefore unsound.
PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
9757 Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1223129 Full Name Shailini Ghelani ID 4730 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness?
9758 Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Having read the plan and seen arguments for and against, I would like to object to the current proposals on not believe this policy to be the grounds below: positively prepared please 1. Increased pollution on Berkhampstead Road where several nurseries and schools are situated. The area explain why already has higher than EU recommended level of pollution 2. Increased congestion on our limited tube service. The 7.35am train already is standing room only and Chesham cannot have more than two trains per hour 3. Use of greenbelt land when we have not considered proper use of brownfield land or land near the town centre which needs regeneration 4. Increased pressure on Chesham when opportunities for development exist in top Amersham which has better transport links PP Mods - Please specify as precisely and succinctly as
9759 possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1223272 Full Name Satbir Dhillon ID 4776 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is
9760 not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is
9761 proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I am writing to you to register my serious concerns regarding the proposal to build 500 houses in Green Belt not believe this policy to be land, within the Lye Green area to the northeast of Chesham as detailed in the Chiltern Local Plan. positively prepared please My concern is that is has been prepared without any detailed appreciation of the impacts on the local explain why environment. As a Principal Engineer with over 16 years knowledge and expertise in the transport industry I have put together proposals and business cases in support of LEN/LGF fund bids. Therefore, I feel qualified to state, unequivocally, that the Local plan and accompanying modelling is UNSOUND and LACKING IN SUPPORTING EVIDENCE. A significant increase in population would lead to a corresponding increase in traffic volumes, leading to higher congestion, air and noise pollution levels. There is only one viable north to south route from the proposed site, Lye Green Rd / White Hill Road linking to the A416. It is a single lane carriageway that cannot accommodate the existing levels let alone additional traffic. The A416 is already saturated during the peak periods and pretty much all day on the weekends. Lye Green Road leads drivers heading north to south to Whitehill, which is an even narrower single lane carriageway. This road is already treacherous due to its steep gradient and severe bends, which results in vehicles, particularly buses straddling into the direct path of oncoming traffic. Also, traffic using the mini-roundabout at the junction with Eskdale Avenue regularly fails to give-way due in part due to bad visibility. I mention these issues as higher traffic levels will inevitable worsen road safety due to increased risk of collisions this brings.You can't build new road or widen existing roads due to the local topography and adjacent land use.Therefore, there are no appropriate mitigation measures that can alleviate the projected increase flow, making the proposed the plan unsuitable and undeliverable. Unsound Sustainable modes of transport Walking · The narrow footway widths (less than 1m in places) are substandard along the walking routes leading to the Town Centre e.g. with 1500mm regarded as the minimum acceptable under most circumstances, giving sufficient space for a wheelchair user and a walker to pass one another (Inclusive mobility DfT). This has not been addressed in the Local Plan actively disadvantage disabled and other vulnerable pedestrians (parents with push chairs, the elderly etc). The proposed development will not be suitable for these users' groups which raises a question as to whether the Local Plan is legally compliant. Similarly, the development is does not meet the standards required to encourage the use or active a sustainable mode of transport e.g. walking and cycling. This increase levels of traffic along will further discourage walking and cycling. · Increase levels of motor traffic will lead to an inevitable increase in collisions, which will increase the risks particularly where there are already existing issues. Lye Green Road / Eskdale - wide crossing distances for pedestrians, frequent conflicts as a result of drivers on Lye Green Rd & White Hill failing to give-way. (likely to increase as flow increased). No mention of a mitigation measures to improve road safety in the Local Plan. Increased concern regarding road safety further deters sustainable modal choices. · White Hill ± further issues that discourage pedestrians from walking e.g. vegetation reduces the effective width further, proximity of passing vehicles to pedestrians (risk of wing mirror strike) due to narrow lanes/footway, footway one side only, not enough space for pedestrians in both directions along narrow sections. Poor lighting due to old sodium lanterns/obscuring vegetation, increased traffic will deter walking, poor visibility due to bends in road (same issue on Eskdale Avenue). · Cycling is barely mentioned in the Local Plan. There are no safe or complaint route for cyclists to the Town Centre due to the following issues e.g. steep gradient, visibility due to bends, lack of space for improvements (space to separate cyclists), it should be noted that the current conditions on White Hill/Lye Green Road would fail any quality assessment for a cycle route (TfL's Cycleway assessment criteria). If there are quieter roads that cyclists can use they would be well off their desire lines and are also subject to similar problems¼. gradients (e.g. Eskdale Avenue). Sustainable transport - Chesham Station · There is No mention is made of the increased passenger demand at Chesham Station as a result of the development, especially as the train services is only once every 30 mins. The already long queues exiting the station resulting in overcrowding both on the platforms and in the carriages. Additional trips will be generated by the station itself which may not be captured in the trip generation figures used. There will also be road safety issues as a result of more vehicles and pedestrians on the station forecourt and capacity / safety issues at the junction of Station Rd/White Hill which hasn't been covered. This is a serious oversight. No mention of what is being done to improve tube/rail services into Chesham or discussions with Transport for London. · There are plans to reduce parking at the Station and generally in the Town Centre which goes against these projected plans. A resident of the new development proposed can only realistically access the Station through parking their car in the immediate vicinity.
9762 Sustainable transport ± Buses · Due to the narrowness and steepness on the Whitehill Road, the route cannot safely accommodate more frequent bus services. Furthermore, this becomes a deterrent to cycling and particularly walking (due to narrow footways and emissions). This means residents have no realistic sustainable transport mode choice to assess the site. Jacobs Transport modelling · It is mentioned that re-routing could occur to avoid Chesham Town Centre. This statement indicates a lack of knowledge of the local roads as there is no realistic and viable routes to avoid the Town Centre. This is due to the topography and the existing constraints of the local road network. Plus, the Local Plan should not be actively encouraging traffic to rat run along local residential roads in order to mitigate the impacts of the development. · You do not need to be expert to know that converting a roundabout to a signalised junction is highly unlikely to reduce delays. However, to explain this is due to significant amount of unutilised green time associated with traffic signals e.g. intergreen (safety periods), loss of green time, pedestrian crossing stages etc. Long delays and queue lengths are inevitable especially on the minor roads, which can be related to worsening of air quality. Strategic Marco-modelling cannot be used to determine the impact of converting a junction to signal control, instead more localised micro-modelling is required to prove this. No evidence of suitable modelling to this effect has been presented to this effect in the report. · The impacts of traffic and additional delay on air quality has not been covered (Broad Street ± Air Quality Zone).This is highly controversial issue and relates directly to the sustainability of the development proposals, especially with Theresa May's recent target for the UK to cut net carbon emissions by 2050. The Local Plan would do nothing to meet these targets, making the development unsustainable as it can only be realistically access via motor vehicles. · The cumulative impacts of the proposed development in neighbouring authorities (e.g. Dacourm etc - considering the proximity of the authorities boundary, this is a major oversight), infilling proposals around the villages or the retail proposals for the Town Centre. Also, the impacts of HS2 (works traffic routes) and a third runway at Heathrow have not been considered. This means that the Jacobs modelling is not fit for purpose and seriously underestimates the impacts on the road network. · One major oversight in the Jacobs modelling is the lack of analysis of the traffic impact at the roundabout at Amersham Road / Moor Road and the PM peak more generally. The Amersham Road / Moor Road is biggest cause of delay in Chesham and would worsen as a result of the forecast traffic growth, particularly in the PM period. However, the extent of the delays in not even covered in the modelling. · Air quality impacts of the development could have been easily including with the modelling. However, it has not been completed further reducing the quality of the evidence base behind the Local Plan. How can you propose such large developments in the local plan without an evidence base surely there are legal implications? Especially when you consider the lack of consultation. The only reason I heard about this was through an independent source, a local newspaper article and not the Council directly. A large development like this warrants a letter drop as a minimum. Further transport issues Maintenance of the road network and footway is not mentioned at all in the Local plan or an assessment of the existing condition. Increased volumes will only add to more damage, resulting in further road safety risks. This brings further into question the sustainability of the proposals. The point being that it's already in poor condition with Buck County Council unable to cope, which will only worsen as traffic grows. Increased residents will add further strain on parking, particularly in the town centre. There is no chance of the authority increasing car park capacity therefore there would be increased levels of parking on the public highway leading to obstructions, congestion and potentially collisions. The required infrastructure improvements are undeliverable to the site constraints mentioned and the resultant costs. No cost / benefit analysis has been completed for any mitigation measures of infrastructure improvements. Further undermining the evidence base behind the proposals. Ecology / Environment The increased levels of residents will also add further stress to the sewage system, increasing the regularity of pollution incidents in River Chess, causing further environmental damage. Chesham is also prone to flooding, the removal of green space, a natural sustainable drainage system is only going to worsen the problem. Air Quality will be further worsened by the removal of green infrastructure to make way for the development. Not only does vegetation absorb carbon dioxide (reducing contributions to climate change) but it traps small particulate (PM10) emissions.The loss of green space will be permanent making this development unsuitable. The noise pollution impacts are not covered at all in the Local Plan or any mitigation measures. The impact of the forecast growth in traffic as well as construction traffic needs to be understood. Loss of habitat for wildlife again barely mentioned in the report.The wildlife and green spaces are at the core of what makes the area what it is. Local Services There are also adverse impacts on GP availability, the emergency services, litter, street cleaning, waste disposal and other public services, no proposals to mitigate this is indicated. To provide housing in Chesham more sustainable plans should be explored e.g., brownfield opportunities in the Town Centre as they close to existing transport hubs, reducing reliance on motor vehicle. However, this is clearly been considered in the Local Plan despite sufficient scope for it in the existing Town Centre. The scope of Town Centre will only increase due to the lack of demand for traditional retail space and the inevitable decline of the High Street due to online shopping trends. Developments on the Green belt should be a last resort, but this cannot be the case when other alternatives have not been explored in any detail.
9763 Conclusions The plan being put forward is NON-COMPLIANT on multiple levels. PP Mods - Please specify as The Plan needs to be modified by; precisely and succinctly as Co-operating with other nearby authorities. Not just Aylesbury. It is simply unsatisfactory to assert this cannot possible how you would be done because they are different Functional Market Areas and that co-operation is not necessary therefore. modify this policy to improve its alignment to this test of Exploring such wider co-operation may result in further housing needs being taken elsewhere. soundness. A more detailed appraisal of brownfield land opportunities MUST be undertaken. Some brownfield opportunities have been ignored or missed. Closer scrutiny of alternative options for housing delivery should be explored (such as Chesham Masterplan by CIC Chesham Renaissance). Green Belt boundary reviews should only be considered AFTER all other reasonable alternatives have been exhausted. In the face of NPPF guidance and a more thorough appraisal of Green Belt sites being considered, it may then be necessary to conclude that it is not possible to identify poor performing Green Belt sites that can accommodate all the OAN for housing. Consequently it may be necessary to accept that a lower housing provision figure is appropriate. Transport modifications I refer to the comments previously submitted but in summary would advocate that; All other options are fully explored including increased density of development of brownfield land and the policies emerging from Chesham Masterplan. Green Belt land should only be considered when all other options are exhausted. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5502312 Please attach any supporting evidence
Person ID 1223314 Full Name Mrs Susan Green ID 4862 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee:
9764 Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider
9765 the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I do not consider the plan sound for a number of reasons, some of which have been detailed in the previous not believe this policy to be sections. However, there are further reasons for me taking this position. positively prepared please The plan makes some provision for infrastructure, but nowhere near enough. Plans for tackling issues such explain why as traffic, access to the site, parking in town, drainage, flooding risk, school places, doctors and employment opportunities are just some areas which have very little explanation. Although some highways improvements are suggested, they are insufficient and unfunded. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham cannot accommodate any significant highways improvements anyway due to the already limited verges and space beside the highway and, combined with the topography of the town, this means that there will be increased traffic congestion, with further worsening air quality. Regarding the homes being built, there is no mention of which form these will take. Where they will be placed on the land nor how tall they will be.These factors could have major implications for residents in the adjoining and surrounding areas. In the plan, 114,000 square feet of retail space is suggested for the town. This is a town centre where many shops are already shut or may be shutting soon. This demonstrates an incredible lack of understanding of Chesham's town centre and the issues it faces. Not only will the viability of these retail spaces be under huge pressure, but there will be also the extra factors such as parking for shoppers and access for delivery vehicles. If the plan believes there is room for this level of retail space, can this not be considered for town centre housing instead? It is in the Chesham Masterplan. I also have deep concerns for how this plan was approved at a recent public meeting. Councillors spoke of serious reservations about the plan, but even after this only two voted against and I understand these councillors have now been suspended. Some of the reasons then given for their approval (despite these serious reservations) were that only 2.7% of green belt would be lost (setting a bad precedent). Central Government would only write one for us if we reject this one and that this is the least worst option. Hardly ringing endorsements and it suggests the councillors are taking the path of least resistance. We need to remember that this plan will change our town and the surrounding villages forever and any negative impact will affect future generations very badly. I am supportive of the Brown Not Green organisation's initiative to have the land listed as an Asset of Community Value and I feel they speak for me in respect of their objections to the draft Local Plan. Accordingly, I request that any representations made by them at any future examination in public regarding the soundness of this Local Plan be considered as an extension of my own comments herein. PP Mods - Please specify as I refer to the comments previously submitted but in summary would advocate that: precisely and succinctly as All other options should be fully explored including increased density of development of Brown Field land possible how you would and the policies emerging from Chesham Masterplan. modify this policy to improve its alignment to this test of Green Belt land should only be considered when all other options are exhausted and in any event, the soundness. proposals for developing land NE of Chesham (policy SP BP 2) should be removed as it is an unsustainable location the development of which will cause harm to the wider town including loss of an asset that improves the well-being of the community.
9766 Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I believe the draft Local Plan is NOT legally compliant in regard to the National Policy and guidance issued believe this policy in by the Secretary of State. consistent with the National The National Planning Framework (NPPF) makes it clear that Local Authorities must demonstrate they have Planning Policy Framework exhausted all options BEFORE considering revisions of Green Belt boundaries. I do not believe the draft Feb 2019 please explain why Local Plan has demonstrated that all other option have been fully explored and as such this Plan is not justified, sound nor in accordance with National Policy and accordingly is not legally compliant. There are entire sections of the NPPF to which this draft plan falls critically short. Chapter 7 ± Ensuring the vitality of town centres. Building homes at the top of a steep hill, at least 2km outside the town centre, will do little to enhance the vitality of the town centre in Chesham. With the development including some (admittedly limited) retail units, residents are likely to use this rather than travel into the town centre. Chapter 8 ± Promoting healthy and safe communities and Chapter 9 ± Promoting sustainable transport. Chesham already has some severe air quality issues, not helped by congested roads. Building homes at the top of the hill will mean the majority of residents will use cars when they do come into the town centre or to access the train station. Independent surveys predict the traffic congestion will increase by 400% under this plan. The Government has also recently confirmed its aim for the UK to have net zero carbon emissions by 2050 and it is noted within the Sustainability Appraisal supporting this Draft Local Plan, that the Plan area is forecast to see carbon emission increase by 21% in the Plan Period. Accordingly, the Plan is inconsistent with Government Policy and therefore not legally compliant. Chapter 13 ± Protecting Green Belt Land. I do not believe the ªexceptional circumstancesº required to remove Green Belt protection has been met by this plan. There are a number of alternative Brown Field Sites and plans (such as Chesham Masterplan by CIC Chesham Renaissance) which will enable the housing needs to be met and the Green Belt to be protected. Chapter 14 ± Meeting the challenge of climate change, flooding and coastal change. Flooding and drainage is already an issue in many parts of Chesham. Building on Green Belt land (which will absorb vast quantities of water, will increase flooding risk. With the development being sited at the top of a hill there is also only one way for this water to flow. Chapter 15 ± Conserving and enhancing the natural environment. The area highlighted for development is rich in countless species of wildlife and home to threatened bird species. Areas like these are vital for maintaining biodiversity. There is also a significant infrastructure funding gap acknowledged within the Community Infrastructure Levy evidence that supports this Local Plan, of between £179m and £231m. Given this infrastructure is vital to ensure that development is sustainable (as also required by the NPPF) this further demonstrates the Plan is both unsound and not legally compliant. Policy 3a - Please specify as I believe the plan needs to be modified in a number of ways. precisely and succinctly as Alternative options for housing development should be explored in much greater detail, in particular The possible how you would Chesham Masterplan by CIC Chesham Renaissance. This plan resolves almost all of the issues mentioned modify this policy to improve in the previous section and takes greater steps to reduce the impact of those it cannot completely resolve. its alignment to this test of It also had the backing of at least 70% of Chesham residents. soundness. It is a more visionary plan, but one which has the potential to reinvigorate Chesham from the centre out and may even become a historic turning point in how suburban development addresses sustainability. A more detailed appraisal of Brown Field land opportunities MUST be undertaken with far greater scrutiny. Some Brown Field opportunities have been ignored or missed. Green Belt boundary reviews should only be considered AFTER all other reasonable alternatives have been exhausted. Policy-level file upload - 5503037 Please attach any supporting evidence
9767 Person ID 1223319 Full Name Roger Green ID 4871 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness?
9768 Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I do not consider the plan sound for a number of reasons, some of which have been detailed in the previous not believe this policy to be sections. However, there are further reasons for me taking this position. positively prepared please The plan makes some provision for infrastructure, but nowhere near enough. Plans for tackling issues such explain why as traffic, access to the site, parking in town, drainage, flooding risk, school places, doctors and employment opportunities are just some areas which have very little explanation. Although some highways improvements are suggested, they are insufficient and unfunded. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham cannot accommodate any significant highways improvements anyway due to the already limited verges and space beside the highway and, combined with the topography of the town, this means that there will be increased traffic congestion, with further worsening air quality. Regarding the homes being built, there is no mention of which form these will take, where they will be placed on the land nor how tall they will be.These factors could have major implications for residents in the adjoining and surrounding areas. In the plan, 114,000 square feet of retail space is suggested for the town. This is a town centre where many shops are already shut or may be shutting soon. This demonstrates an incredible lack of understanding of Chesham's town centre and the issues it faces. Not only will the viability of these retail spaces be under huge pressure, but there will be also the extra factors such as parking for shoppers and access for delivery vehicles. If the plan believes there is room for this level of retail space, can this not be considered for town centre housing instead? It is in the Chesham Masterplan. I also have deep concerns for how this plan was approved at a recent public meeting. Councillors spoke of serious reservations about the plan, but even after this only two voted against and I understand these councillors have now been suspended. Some of the reasons then given for their approval (despite these serious reservations) were that only 2.7% of green belt would be lost (setting a bad precedent). Central Government would only write one for us if we reject this one and that this is the least worst option. Hardly ringing endorsements and it suggests the councillors are taking the path of least resistance. We need to remember that this plan will change our town and the surrounding villages forever and any negative impact will affect future generations very badly.
9769 I am supportive of the Brown Not Green organisation's initiative to have the land listed as an Asset of Community Value and I feel they speak for me in respect of their objections to the draft Local Plan. Accordingly, I request that any representations made by them at any future examination in public regarding the soundness of this Local Plan be considered as an extension of my own comments herein. PP Mods - Please specify as I refer to the comments previously submitted but in summary would advocate that: precisely and succinctly as All other options should be fully explored including increased density of development of Brown Field land possible how you would and the policies emerging from Chesham Masterplan. modify this policy to improve its alignment to this test of Green Belt land should only be considered when all other options are exhausted and in any event, the soundness. proposals for developing land NE of Chesham (policy SP BP 2) should be removed as it is an unsustainable location the development of which will cause harm to the wider town including loss of an asset that improves the well-being of the community. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not I believe the draft Local Plan is NOT legally compliant in regard to the National Policy and guidance issued believe this policy in by the Secretary of State. consistent with the National The National Planning Framework (NPPF) makes it clear that Local Authorities must demonstrate they have Planning Policy Framework exhausted all options BEFORE considering revisions of Green Belt boundaries. I do not believe the draft Feb 2019 please explain why Local Plan has demonstrated that all other option have been fully explored and as such this Plan is not justified, sound nor in accordance with National Policy and accordingly is not legally compliant. There are entire sections of the NPPF to which this draft plan falls critically short. Chapter 7 ± Ensuring the vitality of town centres. Building homes at the top of a steep hill, at least 2km outside the town centre, will do little to enhance the vitality of the town centre in Chesham. With the development including some (admittedly limited) retail units, residents are likely to use this rather than travel into the town centre. Chapter 8 ± Promoting healthy and safe communities and Chapter 9 ± Promoting sustainable transport. Chesham already has some severe air quality issues, not helped by congested roads. Building homes at the top of the hill will mean the majority of residents will use cars when they do come into the town centre or to access the train station. Independent surveys predict the traffic congestion will increase by 400% under this plan. The Government has also recently confirmed its aim for the UK to have net zero carbon emissions by 2050 and it is noted within the Sustainability Appraisal supporting this Draft Local Plan, that the Plan area is forecast to see carbon emission increase by 21% in the Plan Period. Accordingly, the Plan is inconsistent with Government Policy and therefore not legally compliant. Chapter 13 ± Protecting Green Belt Land. I do not believe the ªexceptional circumstancesº required to remove Green Belt protection has been met by this plan. There are a number of alternative Brown Field Sites and plans (such as Chesham Masterplan by CIC Chesham Renaissance) which will enable the housing needs to be met and the Green Belt to be protected. Chapter 14 ± Meeting the challenge of climate change, flooding and coastal change. Flooding and drainage is already an issue in many parts of Chesham. Building on Green Belt land (which will absorb vast quantities of water, will increase flooding risk. With the development being sited at the top of a hill there is also only one way for this water to flow. Chapter 15 ± Conserving and enhancing the natural environment. The area highlighted for development is rich in countless species of wildlife and home to threatened bird species. Areas like these are vital for maintaining biodiversity. There is also a significant infrastructure funding gap acknowledged within the Community Infrastructure Levy evidence that supports this Local Plan, of between £179m and £231m. Given this infrastructure is vital to ensure that development is sustainable (as also required by the NPPF) this further demonstrates the Plan is both unsound and not legally compliant. Policy 3a - Please specify as I believe the plan needs to be modified in a number of ways. precisely and succinctly as Alternative options for housing development should be explored in much greater detail, in particular The possible how you would Chesham Masterplan by CIC Chesham Renaissance. This plan resolves almost all of the issues mentioned modify this policy to improve in the previous section and takes greater steps to reduce the impact of those it cannot completely resolve. its alignment to this test of It also had the backing of at least 70% of Chesham residents. soundness.
9770 It is a more visionary plan, but one which has the potential to reinvigorate Chesham from the centre out and may even become a historic turning point in how suburban development addresses sustainability. A more detailed appraisal of Brown Field land opportunities MUST be undertaken with far greater scrutiny. Some Brown Field opportunities have been ignored or missed. Green Belt boundary reviews should only be considered AFTER all other reasonable alternatives have been exhausted. Policy-level file upload - 5503041 Please attach any supporting evidence
Person ID 1223365 Full Name Greg Butler ID 4928 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including
9771 references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Soundness not believe this policy to be I consider the plan to be unsound, for the reasons set out in the response of the Chesham Society, which is positively prepared please in turn based on the responses of explain why · Brown not Green (BnG) · Chesham Renaissance / CIC (CR) · The Chiltern Society (ChS) · The Chess Association (ChA) In summary, the plan is unsound because · The housing allocation has not been reduced to reflect the constraints of Green Belt and AONB, or to protect the local Chalk Streams, as provided for in NPPF paragraph 11. [ChS, ChA] · New developments on Green Belt sites are proposed in unsustainable locations, to the detriment of traffic flow and air quality in the town. [BnG] · The existing plans for use of Brownfield sites have been ignored, and no comparable plans put forward. [CR]
9772 · Mitigation measures proposed for existing infrastructure problems (Water, Sewage, Traffic congestion, Air Quality ¼) appear unconvincing, and unlikely to compensate for the proposed additional housing.[ChA, Chesham Society] PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5503086 Please attach any supporting evidence
Person ID 1223463 Full Name Elizabeth Moulton ID 5234 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider
9773 the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to
9774 Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do We consider the local plan is legally non-compliant because the local authority has not demonstrated they not believe this policy to be have exhausted all options before considering revision of green belt boundaries. positively prepared please Local infrastructure is irresponsible and shows that the plan is unsound and not legally complaint. explain why PP Mods - Please specify as `Chesham renaissance' and `Brown not Green' have worked hard to present well thought out proposals which precisely and succinctly as are well supported by the local community. possible how you would Planners have failed to engage with these organisations in a professional way.The local plan must be guided modify this policy to improve by these organisations. An appraisal of brownfield land opportunities and alternative options for housing its alignment to this test of must be undertaken. soundness. Green belt boundary reviews must be the last resort. Policy 1 - If you do not We have live in Chesham for over 40 years and our community in Chesham should be undertaken. The plan believe this policy to be presented by the council shows a total lack of understanding as to the wants and needs of Chesham town justified please explain why and its people. Chesham town has empty shops and a shortage of car parking spaces.That the plan should propose a large retail development on the station car park shows how much the planners have failed to understand local circumstances. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not The green belt site NE of Chesham (SP BP 2) is not a sustainable location. It is over 2km away from the believe this policy to be train station. The increase in traffic, due to increased housing, will become impossible. It is already difficult effective please explain why. to pull out of our house in Lye Green Road in the morning and evening, and the roundabout at the top of Eskdale Avenue can become quite dangerous, especially with all the cars belonging to Chesham Grammar School pupils parked around the surrounding roads. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1223464 Full Name Joy Furley ID 5224 Order 236
9775 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as
9776 precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The Green Belt site NE of Chesham (SPBP 2) is not a sustainable location. It is over 2 km away from the not believe this policy to be train station. The increase in traffic, due to increased housing, will become impossible. It is already difficult positively prepared please to pull out of my house in Lye Green Road in the morning and evening, and the roundabout at the top of explain why Eskdale Avenue can become quite dangerous, especially with all the cars belonging to Chesham Grammar School pupils parked around the surrounding roads. At times is has taken me half an hour to drive through the town to my home. That is the situation now; what will be like with hundreds of additional cars? Due to the topography of Chesham, there is only one route through the town, which limits the options to an increased traffic flow. Air pollution is already a problem in parts of Chesham. An additional 500 houses on the edge of town will introduce at least a further 1000 motor vehicles into an already over stretched system. The plan is therefore unsound. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not I consider the local plan is legally non-compliant because the Local Authority has not demonstrated they believe this policy to be have exhausted all options before considering revision of Green Belt boundaries. Local infrastructure is justified please explain why already inadequate and underfunded. To propose this plan without identifying adequate infrastructure is irresponsible and shows that the plan is unsound and not legally compliant. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not A complete reappraisal of the needs of the community in Chesham should be undertaken.The plan presented believe this policy to be by the council shows a total lack of understanding as to the wants and needs of Chesham town and its effective please explain why. people.
9777 Chesham town has empty shops and a shortage of car parking spaces.That the plan should propose a large retail development on the station car park shows how much the planners have failed to understand local circumstances. PAa - Please specify as `Chesham Renaissance' and `Brown not Green' have worked hard to present well thought out proposals precisely and succinctly as which are well supported by the local community. possible how you would Planners have failed to engage with these organisations in a professional way, The Local Plan must be modify this policy to improve guided by these organisations. its alignment to this test of soundness. An appraisal of brownfield land opportunities and alternative options for housing must be undertaken. Green belt boundary reviews must be the last resort. Policy 3 - If you do not I do not believe that the Local plan is positively prepared, effective, justified or consistent with national policy. believe this policy in I feel that that the local plan is unsound. From the evidence submitted, the proposal to release Green Belt consistent with the National land to meet housing targets are unjustified. Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as I am a supporter of ©Brown not Green Chesham© and confirm that we are happy for them to speak for me at precisely and succinctly as any hearing or public examination. possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1223554 Full Name Mrs Estelle Foster ID 5321 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested
9778 modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do RESPONSE TO DISTRICT EMERGING DRAFT LOCAL PLAN TO 2036 not believe this policy to be
9779 positively prepared please In general I feel positive about the local plan strategy as it covers all necessary aspects of planning BUT: explain why 1. There is inadequate mention of how water supply will be managed, given that our local rivers already suffer from over abstraction of the chalk aquifer. 2. The plan is unrealistic in its requirements for "improvements" to local public transport in Chesham as no feasible proposals have yet been published for such improvements. This makes your strategy plan unsound. 3. The plan©s assessment of the need for increased retail facilities in line with increased population seems unsound. It may fit with theoretical planning calculations but the reality on the ground is that shops stand empty. We don©t need any new retail space in Chesham. 4. Green belt development is unwise in the NE of Chesham - creating a potentially isolated community and leading to people feeling like ©strangers© in the town centre. At the moment Chesham has a lovely friendly community keep it that way! 4. I commend the aim to encourage as modal shift from prioritising car use to prioritising cycle and pedestrian streets. Remember the motor bike however! The plan could be inadequate to enforce provision of charging points for electric cars. The plan also doesn©t mention how the additional land for laying electrical services to charging points would be found. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1223578 Full Name Davina Kirby ID 5252 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received:
9780 Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance
9781 with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The site in Chesham is some distance from the centre of Chesham. Those new householders if they went not believe this policy to be into Chesham for food and other shopping or to park at the station would go by car.The proposed development positively prepared please is on top of a steep hill. If someone cycled down they would not wish to cycle back. The residents of the new explain why site couldn't park as the plan also provides for a retail park on the station car park. In any event there is already a large number of empty retail premises in Chesham why create more when statistics show people buy on line. The Councils have stated that release of some Green Belt is necessary as part of an overall three part strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. I question the soundness of such a general policy and whether all the brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites and in particular the Green Belt site NE of Chesham at Lye Green. The development of such Green Belt sites involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient and unfunded. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham cannot accommodate any significant highways improvements anyway due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion, with further worsening air quality. Air pollution is a particular concern in Chesham due to the already poor air quality along Bekhampstead Road where there is a designated Air Quality Management Area that already is recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will generate more traffic will make the air quality even worse and insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable nor justified nor is it in accordance with Govt policy. The Green Belt site NE of Chesham (SP BP 2) is not a sustainable location. It is over 2Km away from the train station and slightly further still from the town centre but anyone who cares to walk or cycle this distance also has to negotiate a steep hill too. Such an unsustainable location cannot be made sustainable merely by upgrading a couple of public footpaths within the site into bridleways to facilitate cycling. Neither does adding a bus stop address the geography or topography of the area especially if the promised enhanced bus service (which is already infrequent) either does not materialise or if it subsequently fails to be maintained after a few years. PP Mods - Please specify as refer to the comments previously submitted but in summary would advocate that; precisely and succinctly as All other options are fully explored including increased density of development of brownfield land and the possible how you would policies emerging from Chesham Masterplan. modify this policy to improve its alignment to this test of Green Belt land should only be considered when all other options are exhausted and in any event the soundness. proposals for developing land NE of Chesham (policy SP BP 2) should be removed as it is an unsustainable location the development of which will cause harm to the wider town including loss of an asset that improves the well-being for the community. Policy 1 - If you do not The foregoing also points to flawed methodology of Green Belt site selection used by the Local Authority, believe this policy to be which is neither effective, justified nor consistent with national policy and as such is unsound. Specifically, justified please explain why
9782 the selection of the land NE of Chesham at Lye Green (policy SP BP2) for removal from Green Belt designation is inconsistent with National Planning Policy Framework (NPPF). Policy 2a - Please specify as refer to the comments previously submitted but in summary would advocate that; precisely and succinctly as All other options are fully explored including increased density of development of brownfield land and the possible how you would policies emerging from Chesham Masterplan. modify this policy to improve its alignment to this test of Green Belt land should only be considered when all other options are exhausted and in any event the soundness. proposals for developing land NE of Chesham (policy SP BP 2) should be removed as it is an unsustainable location the development of which will cause harm to the wider town including loss of an asset that improves the well-being for the community. Policy 2 - If you do not For this Plan to sound it must also be effective. Unfortunately, further review of the proposal to remove land believe this policy to be NE of Chesham at Lye Green from Green Belt designation is not effective as there are serious questions effective please explain why. about the deliverability of this land. The main landowner is a farmer who has asserted publicly and in a letter to the editor of Your Chesham, that he is not prepared to release all of the land in his ownership for development. The land is also potentially an Asset Of Community Value and upon confirmation of this designation it would afford a community group the right to bid for the land. The community group (Brown Not Green) have stated their intention is to preserve the land given that many hundreds of local people have habitually used the fields at Lye Green as of right for various informal outdoor recreational purposes. These uses themselves may mean that many local individuals may have acquired easements over and across the land through prescription (20 years uninterrupted use) not least of whom would be the many private residences bordering the fields that have rear garden gates onto the fields at Lye Green. These easements and prescriptive rights may render the land very difficult to develop and make i undeliverable in planning terms. This land also provides an important habitat for wildlife that will be threatened by development of this land. It is perverse that the Local Authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Plan is unsound PAa - Please specify as refer to the comments previously submitted but in summary would advocate that; precisely and succinctly as All other options are fully explored including increased density of development of brownfield land and the possible how you would policies emerging from Chesham Masterplan. modify this policy to improve its alignment to this test of Green Belt land should only be considered when all other options are exhausted and in any event the soundness. proposals for developing land NE of Chesham (policy SP BP 2) should be removed as it is an unsustainable location the development of which will cause harm to the wider town including loss of an asset that improves the well-being for the community. Policy 3 - If you do not I believe the draft Local Plan is NOT legally compliant because it has not demonstrated sufficient regard to believe this policy in the National Policy and guidance issued by the Secretary of State. consistent with the National The National Planning Policy Framework (NPPF) together with other guidance issued by the Government Planning Policy Framework is also supported by recent ministerial statements that have made it clear that Local Authorities MUST Feb 2019 please explain why demonstrate they have exhausted all options BEFORE considering revision of Green Belt boundaries. This Local Plan is seeking substantial modifications to Green Belt boundaries including the removal of Green Belt designation of 13 areas within the Districts as well as modifying the Green Belt status of many local villages. I contend this draft Local Plan has not demonstrated that all other options have been fully explored and as such this Plan is not justified, sound or in accordance with National Policy and accordingly is not legally compliant. Furthermore that Paragraph 11 b) of the NPPF (and the footnotes thereto) require Plan Makers to provide for objectively assessed needs for housing and other uses UNLESS the application of Framework policies (including Green Belt) provide a strong reason for restricting the overall scale, type or distribution of development in the plan area Chiltern District & South Bucks are significantly constrained by development policies such as Green Belt & Areas of Outstanding Natural Beauty (AONB). The Local Plan is therefore inconsistent with National Guidance and as such it is not legally compliant for the Local Authority to claim that housing needs justify a review of these same Green Belt boundaries. It is perverse to claim that the combination of housing need and the presence of significant areas of development constraint policy collectively represent ªexceptional circumstancesº (as required in the NPPF) to justify modification of Green Belt boundaries especially given the NPPF states that one of the key features of Green Belts are their permanence. The Government has also recently confirmed its aim for the UK to have net zero carbon emissions by 2050 and it is noted within the Sustainability Appraisal supporting this Draft Local Plan, that the Plan area is forecast to see carbon emission increase by 21% in the Plan Period. Accordingly, the Plan is inconsistent with Government Policy and therefore not legally compliant. How can you propose a huge new Housing estate without details of the infra structure or funding. There is presently no available provision for this in the proposed area. Bear in mind there is also the additional strain that this huge increase in housing will place on our struggling water supply and sewerage systems. There is also a significant infrastructure funding gap acknowledged within the Community Infrastructure Levy evidence that supports this Local Plan, of between £179m & £231m. Given this infrastructure is vital to ensure that development is sustainable (as also required by the NPPF) this further demonstrates the Plan is both unsound and not legally compliant. Paragraph 136 of the latest NPPF asserts that Green Belt boundaries should only be modified in ªexceptional circumstancesº. The courts have held that unmet local housing needs of an area are themselves not exceptional circumstances. The Council engaged third party consultants to undertake the Part 1 Green Belt assessment and they identified numerous sites for ªfurther considerationº where exceptional circumstances ªmightº exist but expressly recommended further review of their assessment of each site against the 5
9783 purposes of land being in Green Belt of all these sites. Unlike the neighbouring Local Authorities, the Part 2 Green Belt assessment was not undertaken by third party consultants but by the Local Authority itself who notably then did not undertake all the recommended reviews of each site including the land NE of Chesham at Lye Green (SP BP 2). Accordingly, this oversight in the Part 2 Green Belt assessment placed premature focus and fixation on releasing land at Lye Green NE of Chesham from Green Belt designation. The subsequent identification of the Chesham site for release is therefore unjustified. These comments apply equally to proposals effecting the villages in the Green Belt ± policies SP PP1 & DM PP1) The primary aim of Green Belt land (as recited in NPPF 133) is to prevent urban sprawl and to preserve the openness of the area. The Lye Green site (SP BP2) self-evidently performs this function well and has done so for decades. Another aim of Green Belt land stated in NPPF paragraph 134, is to prevent neighbouring towns and settlements from merging into one another.The Green Belt land NE of Chesham performs exceptionally well in maintaining a distinct separate between settlements of Chesham & Lye Green as well as helping to maintain separate identities of other nearby communities at Orchard Leigh, Botley, Whelpley Hill, Ashley Green. It is perverse and inconsistent with national guidance to allocate this land for removal from Green Belt in light of these facts especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if earmarked for development. further aim of Green Belt designation stated in the NPPF at paragraph 134 (e) is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. By allocating Green Belt land NE of Chesham for development, undermines this aim within Chesham. A community lead not for profit organisation called Chesham Renaissance CIC has been striving to create Chesham Masterplan that would not only provide many genuinely affordable homes in more sustainable locations nearer the town centre, but which would also regenerate some of the more deprived wards within Chesham. The Local Authority's proposals (policy SP EP3) are inconsistent with this local initiative and are therefore also inconsistent with national guidance and are consequently unsound. The Council have asserted that Government planning policy requires local councils to review Green Belt boundaries when considering how to accommodate the development needed in their areas. Just because the Council may be required to look, does not mean the Council should review Green Belt boundaries which as previously stated should only be modified in ªexceptional circumstancesº. National Planning Policy Framework (NPPF) as revised only last year, states in paragraph11 (b) I, directs ªplan makersº to create policies that are required in Local Plans for housing and other uses unless Framework policies (expressly including Green Belt) ªprovides a strong reason for restricting the overall scale type or distribution of development in the plan areaº Accordingly, I submit that given all of the above the land being proposed for release from Green Belt designation around Chesham is unjustified and contrary to national guidance. I am supportive of the Brown Not Green organisation's initiative to have the land listed as an Asset of Community Value and I feel they speak for me in respect of their objections to the draft Local Plan. Accordingly, I request that any representations made by them at any future examination in public regarding the soundness of this Local Plan be considered as an extension of my own comments herein. I feel the land NE of Chesham is an unsustainable location for development, that has been habitually used by the community for improved health & wellbeing for decades and the land performs well against Green Belt aims and objectives. Exceptional circumstances for reviewing Green Belt boundaries at this location, either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by Government Policy and therefore the plan is unsound. It is a pity that pressure to build on the Green belt is focussed on Chesham. I also consider that there should be no further development in Little Chalfont. The village feel of Little Chalfont has been eroded by the recent developments and the increasing pressure on the station. It would be wholly improper for the local plan to impact on the Chess Valley and put increasing strain on the Latimer Road by increased traffic. Chiltern District Council has proudly protected the green belt and should continue to do so. The above proposals will also go a long way to enhance Chesham town centre. Policy 3a - Please specify as The Plan needs to be modified by; precisely and succinctly as Co-operating with other nearby authorities. Not just Aylesbury. It is simply unsatisfactory to assert this cannot possible how you would be done because they are different Functional Market Areas and that co-operation is not necessary therefore. modify this policy to improve its alignment to this test of Exploring such wider co-operation may result in further housing needs being taken elsewhere. soundness. A more detailed appraisal of brownfield land opportunities MUST be undertaken. Some brownfield opportunities have been ignored or missed. Closer scrutiny of alternative options for housing delivery should be explored (such as Chesham Masterplan by CIC Chesham Renaissance). Green Belt boundary reviews should only be considered AFTER all other reasonable alternatives have been exhausted. In the face of NPPF guidance and a more thorough appraisal of Green Belt sites being considered, it may then be necessary to conclude that it is not possible to identify poor performing Green Belt sites that can accommodate all the OAN for housing. Consequently it may be necessary to accept that a lower housing provision figure is appropriate. refer to the comments previously submitted but in summary would advocate that; All other options are fully explored including increased density of development of brownfield land and the policies emerging from Chesham Masterplan. Green Belt land should only be considered when all other options are exhausted and in any event the proposals for developing land NE of Chesham (policy SP BP 2) should be removed as it is an unsustainable
9784 location the development of which will cause harm to the wider town including loss of an asset that improves the well-being for the community. Policy-level file upload - Please attach any supporting evidence
Person ID 1225241 Full Name Great Missenden Parish Council ID 4903 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please Agent/Developer select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID 1225240 Full Name Christopher Thompson Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible.
9785 Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Overview not believe this policy to be The soundness of the plan is questionable in that it does not provide a process for addressing general positively prepared please infrastructure issues other than for the 13 designated Strategic Site Plans SP BP2 to 14. explain why Whilst critical for the development of the Strategic Sites, there needs to be a requirement on developers and the local authority to evaluate the impact on the infrastructure of smaller developments in excess of say 5 dwellings, which will be more prevalent in the Chilterns AONB. Developers and the local authority should assess current and future needs for the provision of services such as water, waste water, power as well as facilities including road, rail, cycle and footways, together with the availability of schools and health services. The plan in order to be sound also needs to recognise the condition of the existing infrastructure such as roads, footpaths and make adequate provision for maintenance and upkeep particularly to facilitate their use by those older or less able members of the population. Public/ sustainable Transport Section 96 of the Infrastructure plan and N15 of the Sustainability Plan accepts that there are high rates of commuting in and out of Chiltern and South Bucks, facilitated by the major transport routes including a number of rail links to London, and three main road transport routes across Chiltern and South Bucks (the A404, A413, and A416/A355) which provide access to the national road network, including the M4, M25 and M40. The main north to south arterial route is the A413. It will of course be impacted by HS2 and the fact that in the adjoining northerly district some 5,500 new homes are to be built as a part of the agreement between AVDC and CDC. These factors will inevitably have a significant impact upon the A413, and yet mention of it is virtually non-existent, with no reference to any plans to improve it to provide any level of sustainability.
9786 In particular the Infrastructure Delivery Plan suggests that the ambulance service have no infrastructure needs identified to be incorporated in the local plan. However the Sustainability appraisal fails to refer to the local hospital being at Stoke Mandeville and incorrectly refers only to hospitals at Wexham Park and in London as serving the District. If the Infrastructure Delivery Plan is based on the Sustainability Appraisal it is fundamentally flawed in this regard. Community Cohesion and Education Section 73: Expansion of Misbourne School is planned by 1 Form Entry (30 or so pupils). However, there is no reference to the requirement for a travel plan or its potential impact. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1223616 Full Name Mr Warren Blyth ID 5276 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID
9787 Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination
9788 Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do I have major concerns about the Paradigm Housing in association with their Planning Agent, Pegasus Group not believe this policy to be who intend to challenge the Green Belt assessment of a plot of land off High View. I wish to object most positively prepared please strongly to this. explain why I strongly support the draft Local Plan since it is legal and sound and I am pleased to see that Green Belt land is actually protected under Section 10 of the Plan. This is important for future generations, and we need to ensure that the environment is saved. The land off High View is highly regarded by the Chiltern District Council as Green Belt land, and is protected against development. I am pleased to hear that the Chiltern District Council are following the National Planning Policy Framework guidelines re Green Belt land as Planning Permission for 99 houses was rejected for a plot of Green Belt land in Chesham (Planning Application Reference is CH/2018/0659/OA) and the plot is very similar to the land off High View. Why are there different rules for similar places? I have a major interest in the possible loss of wildlife habitat. Badgers, bats, deer, birds all reside in the land off High View and I also have major geological concerns. The area is historically known for being prone to subsidence and sink holes and we have experienced minor ones in our area. There is a further problem when considering the inevitable traffic congestion and pollution that will be caused by a major influx of traffic. Thus causing congestion to access A413 and on the A413. Our local surgery is already under pressure and it is difficult to get an appointment. The new proposal will increase waiting times at the Medical Centre to see a GP. There are also concerns about appointments in getting NHS dental appointments. Finally there will be more pressure on local schools which will make parents and children travel to schools outside their designated area causing more traffic congestion. I have confidence in the local plan and believe that the draft Local Plan is sound. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National
9789 Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5512654 Please attach any supporting evidence
Person ID 1223674 Full Name Mrs Jean Slater ID 5360 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you
9790 consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do In framing my response the Plan, I have considered the views put forward by Brown not Green, The Chesham not believe this policy to be Society, The Chiltern Society, The Chess Association and Chesham Renaissance. Whilst I acknowledge positively prepared please the need for new housing in the Chesham area, I agree with their conclusions that the Plan is unsound for explain why the following reasons: · The housing allocation has not been reduced to reflect the constraints of Green Belt and AONB, or to protect the local Chalk Streams, as provided for in NPPF paragraph 11. [ChS, ChA] · New developments on Green Belt sites are proposed in unsustainable locations, to the detriment of traffic flow and air quality in the town. [BnG] · The existing plans for use of Brownfield sites have been ignored, and no comparable plans put forward. [CR] · Mitigation measures proposed for existing infrastructure problems (Water, Sewage, Traffic congestion, Air Quality ¼) appear unconvincing, and unlikely to compensate for the proposed additional housing. [ChA, Chesham Society]
9791 I wish to add a further point, on which I consider the Plan to be unsound. The Plan identifies 31 Red Lion Street, the site of the current Water Meadow Surgery and Job Centre, as a suitable and potential site for retail ± possibly a supermarket. This is unsound for two reasons: (1) The provision of a doctor's surgery on this site is a vital facility for residents in this part of the town, who could not be adequately served either by the location or the resources of the Chess Medical Centre in Berkhamsted Road.The plan makes no mention of replacing the Watermeadow Surgery were its site to be given to other purposes. In addition, Chesham would need an additional surgery to in the location of the new housing to cater for new residents' needs. (2) The land in question at 31 Red Lion Street borders both the River Chess (and Chess Valley Walk) and picturesque Germain Street. To change the use of 31 Red Lion Street to a supermarket or other retail-led uses would have a severe and adverse impact on these immediate surroundings, in terms of visual impact and noise. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5512671 Please attach any supporting evidence
Person ID 1222926 Full Name Mr R Manning ID 4510 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of:
9792 Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is
9793 incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The plan does not protect the Green Belt. It is essential for future generations that all land is protected for not believe this policy to be food production and environmental benefit. positively prepared please We are regularly being told by the government that due to climate change we should do everything to preserve explain why the enviroment. Building on Green Belt land goes against this advice. Accomodating new housing should be on brownfield sites and should be flats to give higher densities on these sites. Even in the 1930s they showed future and cities with very tall skyscrapers. They knew then but we still fail to learn. The Chesham Renaissance CIC Masterplan shows a good solution for building more accommodation in our area. It may alter the look of the town but it is far preferable than building on Green Belt land. Please, please protect the Green Belt for future generations. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
9794 Policy-level file upload - Please attach any supporting evidence
Person ID 1223015 Full Name Mr Graham Green ID 4536 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications
9795 to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Chesham is already an over developed town. The topography does not allow for more infrastructure, the not believe this policy to be local roads are now starting to become car parks. I can often walk faster along the main roads than the traffic, positively prepared please particularly on school days. Increased traffic will cause an increase in the already poor air quality in the valley explain why of Chesham.The quality of life in Chesham as gradually decreased in recent years, due to over development. Building a large number of homes on green belt land should never be considered, land is needed for food, wildlife and recreation.When building such a large number of homes, will require extra schooling and medical facilities. PP Mods - Please specify as The local plan should be scrapped for the reasons already stated. precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.
9796 Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not Council has not fully informed local residents about their proposed plan. The plan seeks to build on green believe this policy in belt land which to me if not legally wrong is certainly morally wrong. consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1224099 Full Name Inland Homes ID 7313 Order 236 Number 11.3 Title Policy SP BP2 - Chesham Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID 1224098 Full Name Hywel James Organisation Details Nexus Planning Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You
9797 will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan©s ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be
9798 positively prepared please explain why PP Mods - Please specify as Without modification, allocation SP BP2 is unsound and should be deleted from the Plan with additional precisely and succinctly as housing sites identified to make-up the shortfall of 500 dwellings (plus the extra needed to provide sufficient possible how you would flexibility and meet the housing needs in full - see our representations to Policy SP LP1 and Table LPb). modify this policy to improve Alternatively, the allocation (and associated Green Belt release) needs to be substantially reduced, its alignment to this test of be defined by a strong Green Belt boundaries and have a reduced landscape impact. soundness. (see full response attached) Policy 1 - If you do not 24. The site is identified by Policy SP BP2 as having an area of 22.9 hectares however, the whole site is not believe this policy to be considered achievable for residential development due to the policy requirements to conserve the existing justified please explain why woodland blocks, trees and hedgerows, as well as the requirement to provide nonresidential uses including a community hub, primary school, shopping parade and 15 pitches for Gypsies and Travellers 25. Extracting the woodland blocks in the south-eastern and north-western parts of the site (which are required to be retained in accordance with criterion 10(2) of Policy SP BP2) from the developable area reduces this to circa 18.5ha. It is reasonable to assume that the non-residential land-uses will require the following land areas: gypsy and traveller pitches, with appropriate landscaping - 0.75ha (in accordance with supporting paragraph 11.3.7); primary school and pre-school - at least 1.8ha (in accordance with the `Area guidelines for mainstream schools' (BB103) published by the Department for Education and Education Funding Agency, contrary to the land take identified within Policy SP BP2); and shopping parade and community hub - 1ha. 26. Moreover, there are electricity pylons and public rights of way running through the site which further constrain the developable area. 27. As a result, the gross development area for residential uses would measure a maximum of 14.95ha. From this, it is reasonable to conclude that the net developable area for residential development is 10ha when the necessary landscaping and green infrastructure is incorporated.To deliver 500 dwellings, a density of 50 dwellings per hectare would therefore need to be achieved, which would be wholly odds with the existing character of the area and consequently conflict with Policy DM DP7 of the Plan. We consider that a density of 30-35 dwellings per hectare would be more appropriate, yielding a scheme of 300 - 350 new homes, significantly below the allocated figure. 28. As such, the capacity assumptions in Policy SP BP2 are not justified. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence
Person ID 1212969 Full Name Richborough Estates ID 5476 Order 239
9799