Consultation Point: Foreword

Person ID 1214453 Full Name Mr Steven Fayers ID 41 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Individual/Resident Date Received - Date Received: 2016-11-29 Duty to Cooperate Body - Is this organisation a Duty to Cooperate No Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to Legally Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the No Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to Please see attached letter describing the reasons for the plan being unsound. improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Not Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the There is no reference in the plan to having co-operated or attempting to Local Plan has met/not met the requirements of the Duty to co-operated with the following neighbouring authorities: Co-operate.Please be as precise and succinct as possible. Hertfordshire County Council Dacorum District Council Three Rivers District Council London Borough of Hillingdon Windsor and Maidenhead Unitary Authority Attendance at the EiP - If your representation is proposing a No modification(s), do you consider is necessary to participate at the examination in public?

2153 Attend EiPb - If you wish to participate at the examination in 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 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 1216826 Full Name Ms Rachel Padgett ID 88 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 Non-Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the With the construction of HS2 taking place at the same time it will be in breach Local Plan is/is not legally compliant, including references to of noise and pollution compliance relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the No Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local The infrastructure cannot sustain extra traffic to include construction traffic of Plan is/is not sound, including references to relevant legislation, new build and HS2. The roads between Beaconsfield and Amersham are already policies and/or regulations. Please be as precise and succinct as full to capacity causing road users to divert through smaller villages (including possible. taxis and heavy vehicles) causing noise, disruption and damage to the small roads in the area (notably cosehill, Penn street and Winchmore Hill)

2154 Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1217713 Full Name Dr Iain miller ID 97 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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

2155 Plan-Level: Legally Compliant - Do you consider the Local Plan to Non-Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the I believe that the use of green belt resources is non-compliant, as exceptional Local Plan is/is not legally compliant, including references to circumstances have not been established. A more optimal solution would be to relevant legislation, policies and/or regulations. Please be as precise delayed until the Unitary Council is in place, when more brownfield sites could and succinct as possible. be considered Legally compliant b - Are you proposing a modification to make the Yes Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) The plan should be delayed below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local The plan will impose an unreasonable burden on local communities. The Plan is/is not sound, including references to relevant legislation, development should be more dispersed across a unitary council. policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to Yes strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to A re-review should take place under Unitary control improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1211042 Full Name Mrs Elizabeth

2156 Richardson ID 102 Order 1 Number Title Foreword Organisation Details Deputy Town Clerk Amersham Town Council Consultee Type - Please select the type of consultee: Parish Council Date Received - Date Received: 2016-01-18 Duty to Cooperate Body - Is this organisation a Duty to Cooperate No Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to Legally Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the No Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Yes Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to No strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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.

2157 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 1218117 Full Name Mr Ian Campbell ID 114 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 Non-Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the There are three reasons why this local plan is not compliant Local Plan is/is not legally compliant, including references to 1. the plan is not sustainable. what happens after 2036? where will new homes relevant legislation, policies and/or regulations. Please be as precise needed after 2036 be located if this local plan already has an overspill problem? and succinct as possible. 2. It ignores its duty to cooperate obligation to Slough council which as very little land. This local plan is produced as if Slough does not exist. It also ignores the fact that Slough cannot grow to the South as Windsor and Maidenhead local plan has made no provisions. 3. The Plan is based entirely on local concerns and needs. These ignore the wider sub-regional needs, like Reading's growth and needs, and those of Heathrow Airport. This approach is neither positive nor is it sound. There is no government policy which restricts the local plan cycles to 16 years. I refer you to a letter to Rob Wilson, ex- MP for Reading East sent to him by the Secretary of State for Housing. I have a copy. NPPF requires sustainable local plans. Yours is not for the reasons given above. Legally compliant b - Are you proposing a modification to make the Yes Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) A sustainable Local Plan for an area like here needs to be produced on a below:You will need to say why this modification(s) will make the sustainable timescale for a sustainable area. 16 years is not. Restricting vision Local Plan legally compliant/strengthen its legal compliance. Please to the boundaries of the two council areas is not. be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local House prices in the Thames Valley are now about 12:1. A generation ago they Plan is/is not sound, including references to relevant legislation, were nearer 3:1. The increase imposes a massive and unjust additional cost

2158 policies and/or regulations. Please be as precise and succinct as burden on new buyers. The reason is years of restricted supply. It also transfer possible. wealth from the have nots to haves. This is not fair nor sound. Because the prime focus is on no change in the e siting rural areas. Most policies, said to be drafted to be positive are not. Would be suppliers of new homes will find these policies difficult to navigate in extremis. If there is an inadequate supply of white land, ie. undeveloped land which is not protected nor sufficient supply of brown land, ie. land already in use for residential purpose, then the council must decide where this generation and the next generations of local residents new homes will be located. If this means they have a growing overspill problem then the answer is to identify alternative white land and reach an agreement with the relevant councils to direct their overspill needs to the new host location. This may have to be done in conjunction with Slough council, who also have an overspill issue. Soundness mods - Are you proposing any modifications to Yes strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to see my response above. improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Not Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the The housing needs of Slough are ignored Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a Yes modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, The Plan’s failure to work with Slough council to solve its housing needs. 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 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 1218095 Full Name Jeff Barlow ID 119 Order 1 Number Title Foreword Organisation Details

2159 Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 Legally Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Not aware of lack of compliance as set out in your document Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the No Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local Environmental impact Plan is/is not sound, including references to relevant legislation, I wish to object to the proposal to create a roundabout at the junction of policies and/or regulations. Please be as precise and succinct as Ledborough lane and the A355. This will create a very large increase of traffic possible. down both Sandleswood End and Ledborough Lane , past primary schools and through a residential area. The environmental impact on air quality and noise pollution will have a large negative impact. This area is also used a lot by cyclists and children walking to school and their safety will be put at risk. Soundness mods - Are you proposing any modifications to Yes strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a No modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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.

2160 PAa - Please specify as precisely and 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 1226466 Full Name Arqiva Ltd ID 122 Order 1 Number Title Foreword Organisation Details Arqiva Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID 1218116 Full Name Matthew Waugh Organisation Details Town Planning Manager Arqiva Ltd Plan-Level: Legally Compliant - Do you consider the Local Plan to Legally Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the It is considered that the local plan is compliant with section 20 (5) (a) of the Local Plan is/is not legally compliant, including references to planning and compulsory purchase act 2004. relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the No Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Yes Soundness? Soundness mods - Please give details of why you consider this Local The authorities have adopted a balanced evidence based approach to meeting Plan is/is not sound, including references to relevant legislation, their aims, objectives and vision. Please see the attached supporting letter relating policies and/or regulations. Please be as precise and succinct as to our site Chalfont Grove possible. Soundness mods - Are you proposing any modifications to No strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to Other than the typographical correction as detailed in the accompanying improve its alignment to this test of soundness. Please be as precise supporting letter and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the The two authority approach to local plan formulation shows cooperation across Local Plan has met/not met the requirements of the Duty to authority boundaries and which better reflects housing market area and Co-operate.Please be as precise and succinct as possible. economic boundaries.

2161 Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 5491879

Person ID 1212915 Full Name Mr Andrew Booth ID 155 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Individual/Resident Date Received - Date Received: 2016-03-14 Duty to Cooperate Body - Is this organisation a Duty to Cooperate No Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to Legally Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the From the way it reads and references regulations, has notified and a Sustainability Local Plan is/is not legally compliant, including references to appraisal has been done, to a lay person it appears to meet the compliance relevant legislation, policies and/or regulations. Please be as precise criteria and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Yes Soundness?

2162 Soundness mods - Please give details of why you consider this Local As any local government and government can write a woolly document a Plan is/is not sound, including references to relevant legislation, judgement on soundness is always subjective. policies and/or regulations. Please be as precise and succinct as It is not totally clear about how much cross boundary working has gone on with possible. neighbouring authorities not in Buckinghamshire. Soundness mods - Are you proposing any modifications to Yes strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to Be very clear on cross boundary working that has happened with Windsor & improve its alignment to this test of soundness. Please be as precise Maidenhead, Hillingdon and Slough and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Not Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Cross boundary co-operation is unclear and very important given the determined Local Plan has met/not met the requirements of the Duty to stance that Slough Borough Council have put forward a number of times with Co-operate.Please be as precise and succinct as possible. their wish to grow and expand through force into South Buckinghamshire. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1215029 Full Name Mr Neil Chauhan ID 249 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Individual/Resident Date Received - Date Received: 2016-12-10 Duty to Cooperate Body - Is this organisation a Duty to Cooperate No Body? Agent on behalf of - Consultee is an agent on behalf of:

2163 Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to Yes strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to Pleased to see our previous concerns have been factored in to the conditions of improve its alignment to this test of soundness. Please be as precise granting planning permission. and succinct as possible. In addition there should be a condition whereby developers on sites near existing residential premises are not allowed to conduct building work in early morning, evening or weekends. Many of us have young children around here and we need to protect their wellbeing, health and quality of life. Finally could you include a condition that developers must set up a local residents engagement committee to ensure strong communication with a clear independent escalation point within the local council if residents feel conditions or otherwise acceptable standards are being broken. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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.

2164 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 1211655 Full Name Mrs Yvette Phillips ID 344 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Individual/Resident Date Received - Date Received: 2016-02-25 Duty to Cooperate Body - Is this organisation a Duty to Cooperate No Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local We are already having much greenbelt being taken away with HS2, Pinewood, Plan is/is not sound, including references to relevant legislation, Heathrow New Runway and many other proposed land being taken up by policies and/or regulations. Please be as precise and succinct as Contractors. possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public?

2165 Attend EiPb - If you wish to participate at the examination in 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 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 1218746 Full Name Mr Iain Hutchison ID 588 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 No Soundness? Soundness mods - Please give details of why you consider this Local We do not believe this plan to be effective: Plan is/is not sound, including references to relevant legislation, 1) The site is not fully available. Not all landowners to sell, how can the plan be policies and/or regulations. Please be as precise and succinct as guaranteed? possible.

2166 2) There is not sufficient viable vehicle access so how can the site physically be delivered? We do not believe this plan complies with National Policy: 1) National Policy prevents this land from being released from the Green Belt and the proposed site would negatively impact the AONB nearby. 2) The site is not sustainable. 3) The proposed plan will negatively impact the beauty and character of the site, valley, woodland and rural landscape if it was built on. We believe the Green Belt should be left alone for future generations. 4) The village itself is too small to support such a proposed increase in housing stock. The knock-on effect on congestion, pollution, parking, transport and amenities would be catastrophic. We have followed the Community Association and Parish Council joint representations throughout the Local Plan process, and continue to support them. Please stop this terrible plan from ever reaching reality. As village residents with a young family, we have grave concerns about the social impact on village life and feel very strongly that the Green Belt should be left alone for the benefit of future generations. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1214002 Full Name Mrs Debbie

2167 Marsden ID 594 Order 1 Number Title Foreword Organisation Details Beaconsfield Society Consultee Type - Please select the type of consultee: Local Interest Group/Amenity Society Date Received - Date Received: 2016-06-21 Duty to Cooperate Body - Is this organisation a Duty to Cooperate No Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local There is also concern that signing up to the Local Plan would be expected before Plan is/is not sound, including references to relevant legislation, we know the detail of any of the suggested mitigating policies which are yet to policies and/or regulations. Please be as precise and succinct as be completed. possible. There is also confusion as to how these comments I have made and those others will make are going to be assessed and reported to the Secretary of State? The actual consultation process is unclear. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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.

2168 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 1212915 Full Name Mr Andrew Booth ID 646 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Individual/Resident Date Received - Date Received: 2016-03-14 Duty to Cooperate Body - Is this organisation a Duty to Cooperate No Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to Legally Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the No Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Yes Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to Yes strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to I have made comments in various sections improve its alignment to this test of soundness. Please be as precise I am, however, concerned about the method of commenting on line as repeatedly and succinct as possible. the system has lost my comments. I have been back after about four weeks and it appears all my saved comments have been lost.

2169 For local consultation this is totally unacceptable and calls into question the overall soundness of this consultation. You shall be required to consult with your IT provider to recover and then combine all comments attributed to the allocated username. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Unsure if this document really covers the ongoing issues with Slough Borough Local Plan has met/not met the requirements of the Duty to Council and there apparent lack of co-operation. Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a No modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1218869 Full Name Tara Morris ID 786 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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.

2170 Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local I am writing to express my objections to The Local Plan. Please register my Plan is/is not sound, including references to relevant legislation, objections accordingly. policies and/or regulations. Please be as precise and succinct as The reason for my objections are numerous but focus mainly on: possible. - Not all brownfield sites have been identified. - A more strategic county-wide view should be taken by the new Unitary Authority before release of any green belt sites. - The housing need figures have been over-inflated. - Planning consents have been granted for development at higher densities than accounted for in the councils’ housing availability figures which means their figures for housing need are unreliable. - Insufficient attention has been paid to previously developed land, both residential and commercial. The councils have merely carried out a request via a “Call for Sites”, inviting landowners and developers to nominate land for development, rather than carrying out their own assessment of land availability. This means, for example, that a large proportion of Beaconsfield green belt has, wrongfully, been nominated rather than previously developed land. This flawed green belt assessment goes against government policy. Previous consultation responses have been ignored. Evidence does not support this green belt release which breaches national policy. Consultation with the communities has been extremely poor. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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.

2171 Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and 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 1218886 Full Name Miss Angela Ryan ID 818 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 Non-Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the I believe the draft Local Plan is NOT legally compliant because it has not Local Plan is/is not legally compliant, including references to demonstrated sufficient regard to the National Policy and guidance issued by relevant legislation, policies and/or regulations. Please be as precise the Secretary of State. and succinct as possible. 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 “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.

2172 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. Legally compliant b - Are you proposing a modification to make the Yes Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) The Plan needs to be modified by; below:You will need to say why this modification(s) will make the Co-operating with other nearby authorities. Not just Aylesbury. It is simply Local Plan legally compliant/strengthen its legal compliance. Please unsatisfactory to assert this cannot be done because they are different Functional be as precise and succinct as possible. Market Areas and that co-operation is not necessary therefore. 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 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. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a No modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, I am a supporter of Brown Not Green Chesham and I confirm I am content for please outline why you consider this to be necessary (please be as them to speak for me at any hearing or public examination. 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.

2173 PAa - Please specify as precisely and 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 1218980 Full Name Kim Macgreevy ID 835 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 Non-Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the No Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local I am writing in protest against the above plan as I feel the whole plan is unjust Plan is/is not sound, including references to relevant legislation, and not justified and not properly planned. policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to No strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible.

2174 Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1218884 Full Name Ms Avis Pightling ID 817 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 No Soundness?

2175 Soundness mods - Please give details of why you consider this Local I feel that we need to find a sensitive balance between the need for more housing Plan is/is not sound, including references to relevant legislation, in the Chilterns area, and protecting the natural environment which is vital for policies and/or regulations. Please be as precise and succinct as our well-being and wildlife: once built over it is gone for ever. Housing should possible. harmonize with the natural environment. For instance close to the little church in my village of Bellingdon an old bungalow has been replaced with a modest 'cottage' dwelling with dormer windows, which sits nicely in its rural surroundings. Increasing population in rural areas will require extensive infrastructure such as roads, schools and medical services. Traffic congestion has now reached a critical point in the area: bringing in yet more, especially private vehicles, would be unsustainable. A curb on immigration would help to alleviate population/housing pressure in rural areas. The Chilterns is a rather lovely part of our countryside: let us not spoil it. Soundness mods - Are you proposing any modifications to Yes strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to As outlined above. improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1219046 Full Name Roland Brewer ID 883 Order 1 Number Title Foreword Organisation Details

2176 Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 Non-Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Non Compliant Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the No Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to No strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Not Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a No modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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.

2177 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 1215574 Full Name Mr Frederick Felix ID 1063 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Individual/Resident Date Received - Date Received: 2018-10-29 Duty to Cooperate Body - Is this organisation a Duty to Cooperate No Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to Legally Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Provides desperately needed housing for the community and supports the Local Plan is/is not legally compliant, including references to infrastructure. I totally agree with the release of green belt land in order to prove relevant legislation, policies and/or regulations. Please be as precise vital housing opportunities for people of all levels. Please do release more green and succinct as possible. belt land if at all possible. Legally compliant b - Are you proposing a modification to make the No Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Yes Soundness? Soundness mods - Please give details of why you consider this Local It is sound as it is detailed and critical thus giving a great deal of information Plan is/is not sound, including references to relevant legislation, which supports community projects policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to No strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the It's very important to provide land for self building as well as giving council Local Plan has met/not met the requirements of the Duty to housing and gypsy travellers while also developing services for families and Co-operate.Please be as precise and succinct as possible. students and the elderly. Attendance at the EiP - If your representation is proposing a Yes modification(s), do you consider is necessary to participate at the examination in public?

2178 Attend EiPb - If you wish to participate at the examination in public, I would like to talk and support self builder's 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 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 1211183 Full Name Mrs Elizabeth Jones ID 5852 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Individual/Resident Date Received - Date Received: 2016-01-28 Duty to Cooperate Body - Is this organisation a Duty to Cooperate No Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Please see ADRAs response to the local plan. Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible.

2179 Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1211224 Full Name Mr Richard Biddle ID 6855 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Individual/Resident Date Received - Date Received: 2016-01-18 Duty to Cooperate Body - Is this organisation a Duty to Cooperate No Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details

2180 Plan-Level: Legally Compliant - Do you consider the Local Plan to Non-Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the The unsightly derelict Field has no purpose and is surrounded by residential Local Plan is/is not legally compliant, including references to dwellings on two of its three boundaries with a main road on the other. relevant legislation, policies and/or regulations. Please be as precise Developing the land with suitable properties similar to those opposite would and succinct as possible. round off the existing settlement and significantly enhance and improve the current Bowstridge Lane street scene by tiding the local environment whilst complementing the existing settlement. (Please see photos in Exhibit No.2, attached, portraying the existing dwellings and Bowstridge Lane street view). Legally compliant b - Are you proposing a modification to make the Yes Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) The unsightly derelict Field has no purpose and is surrounded by residential below:You will need to say why this modification(s) will make the dwellings on two of its three boundaries with a main road on the other. Local Plan legally compliant/strengthen its legal compliance. Please Developing the land with suitable properties similar to those opposite would be as precise and succinct as possible. round off the existing settlement and significantly enhance and improve the current Bowstridge Lane street scene by tiding the local environment whilst complementing the existing settlement. (Please see photos in Exhibit No.2, attached, portraying the existing dwellings and Bowstridge Lane street view). Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local The unsightly derelict Field has no purpose and is surrounded by residential Plan is/is not sound, including references to relevant legislation, dwellings on two of its three boundaries with a main road on the other. policies and/or regulations. Please be as precise and succinct as Developing the land with suitable properties similar to those opposite would possible. round off the existing settlement and significantly enhance and improve the current Bowstridge Lane street scene by tiding the local environment whilst complementing the existing settlement. (Please see photos in Exhibit No.2, attached, portraying the existing dwellings and Bowstridge Lane street view). Soundness mods - Are you proposing any modifications to Yes strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to The unsightly derelict Field has no purpose and is surrounded by residential improve its alignment to this test of soundness. Please be as precise dwellings on two of its three boundaries with a main road on the other. and succinct as possible. Developing the land with suitable properties similar to those opposite would round off the existing settlement and significantly enhance and improve the current Bowstridge Lane street scene by tiding the local environment whilst complementing the existing settlement. (Please see photos in Exhibit No.2, attached, portraying the existing dwellings and Bowstridge Lane street view). Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Not Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the The unsightly derelict Field has no purpose and is surrounded by residential Local Plan has met/not met the requirements of the Duty to dwellings on two of its three boundaries with a main road on the other. Co-operate.Please be as precise and succinct as possible. Developing the land with suitable properties similar to those opposite would round off the existing settlement and significantly enhance and improve the current Bowstridge Lane street scene by tiding the local environment whilst complementing the existing settlement. (Please see photos in Exhibit No.2, attached, portraying the existing dwellings and Bowstridge Lane street view). Attendance at the EiP - If your representation is proposing a No modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, The unsightly derelict Field has no purpose and is surrounded by residential please outline why you consider this to be necessary (please be as dwellings on two of its three boundaries with a main road on the other. precise and succinct as possible Developing the land with suitable properties similar to those opposite would round off the existing settlement and significantly enhance and improve the current Bowstridge Lane street scene by tiding the local environment whilst complementing the existing settlement. (Please see photos in Exhibit No.2, attached, portraying the existing dwellings and Bowstridge Lane street view). Policy Level - PP - If you do not believe this policy to be positively prepared please explain why

2181 PP 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 1212381 Full Name Mr Patrick Tarrant ID 5674 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Individual/Resident Date Received - Date Received: 2016-03-13 Duty to Cooperate Body - Is this organisation a Duty to Cooperate No Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to Non-Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the No Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to No strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible.

2182 Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Not Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a No modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1211899 Full Name Ms Sophie Blakes ID 6614 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Individual/Resident Date Received - Date Received: 2016-03-09 Duty to Cooperate Body - Is this organisation a Duty to Cooperate No Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible.

2183 Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local The Draft Local Plan has not been positively prepared. South Bucks is a popular Plan is/is not sound, including references to relevant legislation, place to live and demand for housing is very strong. But the council does not policies and/or regulations. Please be as precise and succinct as seem to understand this as the Draft Local Plan only provides for standard possible. method annual minimum housing need and does not produce a housing requirement figure which the NPPF and the PPG guidance advises. Soundness mods - Are you proposing any modifications to Yes strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to Whilst South Bucks’ area is dominated by the Green Belt, the demand for housing improve its alignment to this test of soundness. Please be as precise in Chiltern and South Bucks is so great that there are exceptional circumstances and succinct as possible. to release MORE land from the Green Belt within the district. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Not Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Iver is very close to the border with Slough, less than 10 minutes’ drive from Local Plan has met/not met the requirements of the Duty to Langley Station. For many years South Bucks has resisted any incursion of housing Co-operate.Please be as precise and succinct as possible. development in its area but it is now being forced by the NPPF to consider taking neighbours’ unmet housing need. Large numbers of people living in South Bucks work in Slough and this helps the local economy. Many people working in retail and elsewhere in South Bucks live in Slough because they cannot afford South Bucks property prices. More housing in South Bucks should go to the large centres such as Amersham-on-the-Hill and Gerrards Cross which are not included in the Draft Local Plan. This is more sustainable. It seems inevitable that South Bucks will have to assist in taking some land out of the Green Belt to assist Slough with its housing need. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1213291

2184 Full Name Mr Tony W A H Molesworth ID 6638 Order 1 Number Title Foreword Organisation Details Chairman Chesham Renaissance Community Interest Company Consultee Type - Please select the type of consultee: Local Interest Group/Amenity Society Date Received - Date Received: 2016-03-14 Duty to Cooperate Body - Is this organisation a Duty to Cooperate No Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to Non-Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the 3. The National Planning Policy Framework at (paragraphs 20 band 20c} requires Local Plan is/is not legally compliant, including references to that relevant legislation, policies and/or regulations. Please be as precise strategic policies should make sufficient provision for: and succinct as possible. b) infrastructure for transport, telecommunications, security, waste management, water supply, wastewater, flood risk and coastal change management, and the provision of minerals and energy (including heat): Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local 1. In response to the Regulation 18 Consultation, the Councils stated that they Plan is/is not sound, including references to relevant legislation, would policies and/or regulations. Please be as precise and succinct as engage with infrastructure and service providers and that 'an Infrastructure possible. Delivery Schedule will be prepared alongside the Local Plan which will set out what infrastructure investment is needed to support new development, when this should be provided, by whom and where the funding is expected to come from.' 2. The 2019 Infrastructure Delivery Schedule (IDS} is little more than a 'wish list' of un costed and unfunded projects which have not been costed despite at least five years preparation. Furthermore appendix 3 of the IDS reveals a£ 179m to £231 m funding gap over the Local Plan Area. Therefore, not only is the IDS unsound but also all measures seeking to make policies sustainable in other areas must be considered unsound. Even the availability of CILs is unlikely to fill this funding gap. community facilities (such as health, education and cultural infrastructure): Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any

2185 non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1214459 Full Name Mr & Mrs Charles and Teresa Watters ID 5900 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Individual/Resident Date Received - Date Received: 2016-12-11 Duty to Cooperate Body - Is this organisation a Duty to Cooperate No Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the

2186 Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 6734 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Individual/Resident Date Received - Date Received: 2016-12-10

2187 Duty to Cooperate Body - Is this organisation a Duty to Cooperate No Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to Non-Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the I believe the draft Local Plan is not legally compliant because it has not shown Local Plan is/is not legally compliant, including references to sufficient regard to the National Policy and guidance issued by the Secretary of relevant legislation, policies and/or regulations. Please be as precise State. and succinct as possible. The National Planning Policy Framework (NPPF) have made it clear that Local Authorities must show they have tried all options before considering development of Green Belt land. This Local Plan is seeking significant changes to Green Belt boundaries including the removal of 13 Green Belt areas as well as changing the Green Belt status of many local villages. I oppose this draft Local Plan as it has not proved that all other options have been fully explored and therefore this Plan is not justified, sound or in line with National Policy and so is not legally compliant. The Local Plan is 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 Government has recently confirmed its 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 area is forecast to see carbon emission increase by 21% in the Plan Period. Accordingly, the Plan is not consistent 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. Legally compliant b - Are you proposing a modification to make the Yes Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) Working with other nearby authorities, not just Aylesbury. It is unsatisfactory below:You will need to say why this modification(s) will make the to state this cannot be done because they are different Functional Market Areas Local Plan legally compliant/strengthen its legal compliance. Please and that co-operation is not necessary. be as precise and succinct as possible. Exploring wider co-operation which may result in further housing needs being taken elsewhere. It is essential that a more detailed appraisal of brownfield land opportunities 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 as a last resort after all other reasonable alternatives have been considered and used. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local The proposals to release Green Belt land to meet housing targets (Generally, Plan is/is not sound, including references to relevant legislation, Spatial Policy SP SP1 & specifically Policy SP BP2 at Lye Green NE of Chesham) policies and/or regulations. Please be as precise and succinct as are not justified from the evidence submitted by the Councils. possible. 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 and unfunded. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. 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

2188 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. Chesham cannot accommodate any significant highways improvements due to the already limited verges and space beside the highway and combined with the structure of the town this means that there will be 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 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 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 Government policy. The Green Belt site NE of Chesham (SP BP 2) is not a sustainable location. It is over a mile away 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. Further doubt is cast upon the “soundness” 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 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 including myself and my family 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 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

2189 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 “exceptional circumstances”. 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 Government Policy and therefore the plan is unsound. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to I refer to the comments previously submitted but in summary would emphasise improve its alignment to this test of soundness. Please be as precise that; and succinct as possible. 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. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why

2190 Policy 3a - Please specify as 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 1214022 Full Name Mrs M Walker ID 3433 Order 1 Number Title Foreword Organisation Details Hilltop and Lye Green Residents Association Consultee Type - Please select the type of consultee: Local Interest Group/Amenity Society Date Received - Date Received: 2016-07-20 Duty to Cooperate Body - Is this organisation a Duty to Cooperate No Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible

2191 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 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 1215359 Full Name Mr Yogesh Pattni ID 6612 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Individual/Resident Date Received - Date Received: 2016-12-12 Duty to Cooperate Body - Is this organisation a Duty to Cooperate No Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local This Local Plan identifies a minimum local housing need of 763 homes per year Plan is/is not sound, including references to relevant legislation, and under the NPPF and PPG guidance this council’s calculation of 763 homes policies and/or regulations. Please be as precise and succinct as is a minimum starting point in determining the number of homes need in our possible. area. South Bucks is an area of economic growth, a place where more and more people want to live. Therefore, a minimum local housing need fails to recognise the pent-up demand for housing. Since this local Plan was drawn up, the expansion

2192 of Heathrow has been approved by Parliament and this will place extra strain on housing demand in South Bucks this is not properly recognised in the Plan. Soundness mods - Are you proposing any modifications to Yes strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to Clearly there are not enough homes for this local Plan 2013-3036 and there improve its alignment to this test of soundness. Please be as precise needs to be additional allocations. and succinct as possible. The Policy SP BP11 for land north of Iver Station is not sound because this site may not deliver the 1,000 homes as suggested. It is likely that some part of the land could not be developed so the numbers here should be cutback. Also, the land North of Iver Station does not guarantee that the Iver Relief Road will be completed. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Not Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the The Local Plan states that “as no formal requests have been received to meet Local Plan has met/not met the requirements of the Duty to any unmet housing needs of neighbouring areas, the housing strategy of the Co-operate.Please be as precise and succinct as possible. Local Plan has been drafted so as to provide for 15260 homes over the period 2013-2036.” Both Chiltern and South Bucks are aware that Slough has unmet housing need for sooner or later it will have to be met with land close to Slough. Yet there is no mention in the Local Plan that Chiltern and South Bucks have joined with Slough and Windsor and Maidenhead in searching for potential housing sites. Slough has already expressed a desire for a new garden village in South bucks. Slough have to be helped and it is more than likely that south Bucks will have to meet its obligations. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1215995 Full Name Ranty Res ID 52 Order 1 Number Title Foreword

2193 Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 Non-Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the hate it Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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.

2194 PAa - Please specify as precisely and 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 1216601 Full Name georgina barretta ID 58 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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) test below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible.

2195 Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1217623 Full Name Bridget Fox ID 6851 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 Legally Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the The Local Plan is inconsistent with the enhanced protection afforded ancient Local Plan is/is not legally compliant, including references to woodland in the relevant legislation, policies and/or regulations. Please be as precise NPPF. and succinct as possible. The National Planning Policy Framework (NPPF) (paragraph 175c) states: “When determining planning applications, local planning authorities should apply the following principles: …… c) development resulting in the loss or deterioration of irreplaceable habitats (such as ancient woodland and ancient or veteran trees) should be refused, unless there are wholly exceptional reasons and a suitable compensation strategy exists” In particular, we object to the allocation of sites BP6 and BP9 for development and to the wholly inadequate wording of policy NP5 Legally compliant b - Are you proposing a modification to make the Yes Local Plan legally compliant and/or to strengthen its compliance?

2196 Legally compliant c - Please set out your suggested modification(s) 1) Remove allocation of sites BP6 and BP9 from the Local Plan. below:You will need to say why this modification(s) will make the 2) Add to policy NP5 as set out below Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Ancient woodland, veteran trees and development i. Development resulting in the loss or deterioration of irreplaceable habitats (such as ancient woodland and ancient or veteran trees) should be refused, unless there are wholly exceptional reasons. ii. As ancient woodland and ancient or veteran trees are irreplaceable, discussions over possible compensation should not form part of the assessment to determine whether the exceptional benefits of the development proposal outweigh the loss. iii. Ancient wood pasture and historic parkland should receive the same consideration as other forms of ancient woodland. The protection of the whole habitat is necessary even though tree cover may be comparatively sparse. Development on open space between trees in an area of ancient wood pasture or historic parkland should not be permitted. These and further changes are set out in the following consultation response. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a Yes modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, The Woodland Trust is the UK's leading woodland conservation body, providing please outline why you consider this to be necessary (please be as expert advice on ancient woodland and planning policy. 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 believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why

2197 Policy 3a - Please specify as 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 1215360 Full Name Mr Youy Wong ID 6631 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Individual/Resident Date Received - Date Received: 2016-12-12 Duty to Cooperate Body - Is this organisation a Duty to Cooperate No Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local This Draft Local Plan has a greater requirement for housing than is allocated. Plan is/is not sound, including references to relevant legislation, The Draft Local Plan does not reflect the Government’s objective to significantly policies and/or regulations. Please be as precise and succinct as boost the supply of homes. possible. Both the NPF and PPG guidance advises that the Standard Method identifies only the minimum housing need figure and does not produce a housing requirement figure (Reference 2a-002-20190220). A higher level is required because of the demand for housing and especially affordable housing. In some ways this Draft Local Plan does not seem to have up to date information as latest figures on affordability rations have been published by the ONS which show a worsening in housing affordability in Chiltern and South Bucks. Soundness mods - Are you proposing any modifications to Yes strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to This Draft Local Plan needs to have greater numbers of homes otherwise it will improve its alignment to this test of soundness. Please be as precise not have five year housing supply. and succinct as possible. With pressure on the Green Belt perhaps smaller greenfield sites in and outside the Green Belt could be allocated sot that these sites can deliver homes more quickly. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Not Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination

2198 Duty to Co-operate a - Please give details of why you consider the Chiltern and South Bucks have not seriously considered the unmet housing need Local Plan has met/not met the requirements of the Duty to from Greater London and Slough. They could be asked to take around 200 homes Co-operate.Please be as precise and succinct as possible. a year from Greater London’s unmet housing need. I know Slough’s unmet housing need is urgent. Slough is the UKs second worst authority for overcrowding. Just as the Royal borough of Windsor and Maidenhead ignored Slough’s plight when drawing up its Local Plan, which is still awaiting a re-start with an Inspector at the EiP, Chiltern and South Bucks have not taken account of Slough’s unmet housing need. Rather it has joined with the Royal Borough and Slough to produce a Wider Area Growth Study (WAGS). As Slough’s need is urgent, hopefully the Part 2 of the WAGs report will be published before the Chiltern and south Bucks EiP. But from reading Part 1 on the council’s website it looks as if the report will say that this unmet housing need will need to be close up Slough. Having read the Atkins Report, commissioned by Slough borough Council and published in September 2017 it is likely that land north of the railway line in Wexham parish and around Shreding Green could, if released from the Green Belt, be used for housing. This would put additional pressures on Langley Park Road and Iver High Street with construction traffic using these roads. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1215567 Full Name Mr Malcolm Griffiths ID 6569 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Individual/Resident Date Received - Date Received: 2018-09-22 Duty to Cooperate Body - Is this organisation a Duty to Cooperate No Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name

2199 Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to Non-Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Issue Local Plan is/is not legally compliant, including references to 2 relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. -- The Plan does not support the objectives of the 2008 Climate Change Act as amended in June 2019, it is doubtful therefore if the plan represents sustainable development as expected by the NPPF. The Plan Appraisal of Sustainability states: -- It is considered likely that the total impact of proposed development within

2200 the Local Plan would increase the Plan area’s carbon footprint by 21% or more. This impact would be expected to accelerate anthropogenic climate change and is likely to lead to cumulative effects, which exacerbate global events such as sea level rise, melting polar ice caps and extreme weather events. Given the plan is designed for a population increase

2201 of 12.2% (2014 basis) or 7.3% based on the latest 2016 ONS predictions the impact on carbon footprint is astounding. It comes in part by the planned oversupply to bring down house prices but also significantly from building 4/5--bedroom property when 1 or 2 bedroom property are required creating very low occupancy rates in the larger new property.

2202 Effectively the plan proposes a strategy of leaving older people living on their own or in couples in their 3, 4 or more bedroom family properties until they die or go into care homes and building new larger homes for newly forming family households. The strategic alternative is to encourage older people to move to smaller property designed

2203 to meet their needs as they reach about 75 -- 80 releasing existing larger property for newly forming families. In 2017 residential space heating in Chiltern and South Bucks created 238kt CO2 (43% of C & SB residential emissions). Without changing the mix of housing, the mix of heating fuel or insulation standards the planned 16,786 (15,260 +

2204 10%) new dwellings would increase CO2 emissions by 60kt (25% increase). Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local The Plan is/is not sound, including references to relevant legislation, Plan policies and/or regulations. Please be as precise and succinct as possible. facilitates the development of 16,786 dwellings, made up of a projected need for 10,900 homes, an increase of 40% (4360) in accordance with national guidance, to help reduce the high prices in the area, and a further 10%

2205 increase (1526) locally imposed to account for non--delivery. 5687 of the dwellings will be built in Aylesbury Vale. After allowing for a 10% under delivery, if economic conditions permit, about 10,000 homes may be built in the Plan area probably resulting in increased rather than the desired decreased house prices in the Chiltern & South Bucks (C &

2206 SB) district. The Plan facilitates the development of 16,786 dwellings, made up of a projected need for 10,900 homes, an increase of 40% (4360) in accordance with national guidance, to help reduce the high prices in the area, and a further 10% increase (1526) locally imposed to account for non--delivery. 5687 of the dwellings will be built in

2207 Aylesbury Vale. After allowing for a 10% under delivery, if economic conditions permit, about 10,000 homes may be built in the Plan area probably resulting in increased rather than the desired decreased house prices in the Chiltern & South Bucks (C & SB) district. Sheltered and Extra care housing. The HEDNA identifies that a backlog of 2,529 and

2208 2,818 new properties to cover demand growth to 2036 (total 5347) are required for older persons sheltered and extra care housing. These are usually one or two bedroom properties; the plan proposes 3,408 one & two bedroom properties for all purposes. A 1939 shortfall before consideration of 25--35 single households or older households not requiring sheltered housing. !0.5%

2209 0% 0.5% 1% 1.5% 2% 2.5% 3% 3.5% One%person% Couple%and%no%other% adult% Couple%and%one%or% more%other%adult% With%one%dependent% child% With%two%dependent% children% With%three%or%more% dependent%children% Other% Households%000s% Chiltern)&)South)Bucks)increase)in)housholds)by)composi8on)2016)to)2036)) 2014%based%household%projec@ons%Tables%420%&%424% 0" 5" 10" 15" 20" 25" 30" 35" 1"Bedroom" 2"Bedrooms" 3"Bedrooms" 4"or"more"Bedrooms" Households)000s) Chiltern)and)South)Bucks)Area)Plan)proposals) 2019"HEDNA"&"2011"Census" Households"in"2011"census" Proposed"2016"to"2036"increase" 4 It appears that rather than an analysis of the needs for Chiltern and Bucks the HEDNA identified the requirement based on the

2210 outcome of an assessment of the Metropolitan Borough of Bury in 2012. Bury had different health parameters, older person age profiles (the proportion over 85 are fewer) and lower projected life expectancy growth than Chiltern and South Bucks. Bury was used as an example of how to carry out the analysis by the Housing Learning & Innovation Network

2211 the recognised experts in the field, they stress that LAs need to do their own analysis specific to their needs and circumstances It seems the HEDNA consultants thought the output from the Bury analysis was input for all areas. Not having access to all the equivalent health and mobility data used by HousingLIN it is not possible to

2212 fully assess the corrections required. However an analysis in accordance with their approach (using the 2011 census health and disability data) suggests that to meet the criteria set by Bury the backlog for Chiltern and South Bucks is less than noted in the HEDNA and that required for growth to 2036 is more than included in the HEDNA.

2213 The LA with advice from Buckinghamshire CC Social services and the Buckinghamshire Healthcare NHS Trust could, if they wish, establish the number and types of dwellings required and develop a strategy to deliver them. The proposed plan does not address the requirements established in the HEDNA and the HEDNA is based on manifestly flawed analysis. The plan does

2214 not evidence that the needs of older peoples housing has been effectively addressed. The plan does not explain how or where the required dwellings for sheltered, extra care or down size dwellings for others over 75 will be provided, Or as some say “we all know they (developers) are building too many four, five and six bedroom properties

2215 and not enough 1 and 2 bedrooms properties that local people may be able to afford”. The issue of an older population will hit Chiltern District harder and quicker than any other of the 325 England LA districts. Chilterns has the second highest life expectancy of any LA and has had the second highest increase in life expectancy

2216 from 2002 to 2011. Camden has both the highest life expectancy and highest increase since 2002 however the proportion of population over 70 in Camden is 8%; Chiltern has 15% over 70 making the impact greater. The Camden figures may also be influenced by internal (in UK) migration before or at about 65. Based on ONS life expectancy

2217 projections the issue of later life housing is going to grow, if not addressed for 20 years by Chiltern & South Bucks and other LAs it will dramatically further exacerbate the UK housing shortage. Increased life expectancy is to be celebrated but it needs to be planned for. Through a mix of smaller houses, insulation improvements and restricting

2218 new properties to areas with mains gas or large scale wood chip generated energy it should be possible to at least half this figure. Transport emissions may also be a significant contributor to the plans excessive carbon footprint. In 2017 Chiltern & South Bucks had CO2 emissions of 243 kt (44% of C & SB residential emissions) attributable

2219 to local road transport (excluding pass through motorways). The eventual move to electric cars will reduce local emissions but, due to current and future projected power generation fuel mix and distribution losses, it does not in the short and mid term (50 years) reduce overall UK CO2 emissions. The most effective way to reduce transport emissions is to

2220 place and design new development so that people can reduce car use. Analysis from the National Travel Survey published by the DfT (January 2018) concludes that on average people living in small settlements of less than 3,000 people travel 9109 miles/person/year by car, 48% more that those that live in settlements of 25,000 to 100,000 (6745 miles). The

2221 Local Plans Settlement Capacity Study states: -- The Councils' legal advice has been to not place too much weight on transport sustainability when considering different settlements as this can easily change over time owing to factors outside the Councils control. This is counter to the advice of Buckinghamshire County Council (the entity legally responsible for transport in the

2222 area) who has objected to a number of Chiltern District planning applications on the grounds of a lack of sustainable transport. Presumably because of the legal advice there would appear to have been no effective analysis of the increase in road transport CO2 emissions as a result of the plan or any assessment of how alternative arrangements (locations,

2223 planned usage, house type, density etc.) may produce lower emissions. As 88% of the projected population increase comes from over 65s it is worth looking at their travel practices. From the 2017 National travel survey it is clear that while in the first 10 years of retirement travel does not reduce it is interesting to see that 40%

2224 of it is for shopping up from 15 --20% in the 25 to 60 age range. In later retirement years at age 85--90 trips have reduced to about 55% of the 40--65 peak years. For this older group shopping remains about 50 of their trips. Given this without intervention transport CO2 emissions increase should be less than the

2225 increase in population (12%). It may be possible by encouraging older people to live in areas near to or with public (or community bus) transport to shopping and other services to half the increase attributable to new development. The plan does not effectively evaluate or address the issue of climate change. Abstracts of the relevant Policy Practice Guidance

2226 that may not have been complied with are included in Appendix 2 Issue 3 -- The proposal to remove 12 smaller settlements from the green belt may not be in accordance with the NPPF. The NPPF at 136 states “Once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the

2227 preparation or updating of plans…” and at 137 “Before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, 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.” I do not believe that the LA has carried out an evaluation

2228 to justify the removal of these settlements and based on the Settlements Capacity Report they do not have expectations that the action will bring forward significant additional windfall development. I think they are removing the settlement on their interpretation of the NPPF at Para 140 If it is necessary to restrict development in a village primarily because of

2229 the important contribution which the open character of the village makes to the openness of the Green Belt, the village should be included in the Green Belt. The question of interpretation therefore is whether 140 is applicable to defining new green belt areas as referred to in Paras. 135 and 139 or the removal from existing green belt

2230 as referred to in 136 and 137. In either interpretation Para. 138 is applicable. 138 When 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 channeling development towards urban areas inside the Green Belt boundary,

2231 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. As far as I can see the

2232 Plan does not consider the consequences for sustainable development of channeling development towards these smaller settlements. Also the settlements consist predominantly of residential property and their gardens and are not previously developed land as defined in the NPPF Glossary. Some of them do not have well served public transport (I think the NPPF expects this to be considered

2233 irrespective of the C & SB Legal advice) As a matter of "plain English" interpretation (the standard set by the Appeal court) does clause 140 set in context (illogically in my opinion?) override and make redundant clauses 134 e), 136, 137 & 138 concerning removals from the green belt or does it (logically in my opinion?) add to

2234 the advice in 135 and 139 concerning adding new Green belts. It is worth noting that the wording of Para. 140 talks about when a village should be "included" not when one already in the Green belt should be "excluded". In the context of the substance of the overall plan this may not be a major issue compared

2235 to issues 1 & 2 above. I expect for most of those living in such a settlements it is a mixed point however the decision is establishing the interpretation of the NPPF and in particular what constitutes Sustainable Development. The back history of reports and circumstance would indicate that while it may not be justifiable via 136, 137

2236 or 138 the objective of removing these settlements is to encourage further development in the areas beyond that allowable as Green Belt Land. As such to comply with the NPPF it must therefore be deemed "Sustainable Development" which on objective criteria it may not be. On the issue of windfall development generally I note the first sentence of

2237 the letter from the Secretary of State to the Chief Executive of the Planning Inspectorate 18 June 2019 and wonder if depending on and facilitating windfall development to meet the area's housing need is consistent with the SoS's guidance. "The Government wants to see every community covered by an up-to-date plan for sustainable development - meaning that communities are in control of development and are not exposed to speculative development". Abstracts of the NPPF that may not have been complied with are included in Appendix 3

2238 Appendix 4 provides background and "colour" to the issue, by example of one of the settlements concerned. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1215998 Full Name Annoyed

2239 Res ID 53 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 Non-Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the get in the bin Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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

2240 Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and 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 1219480 Full Name Tim Mayell ID 1283 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 Non-Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the I believe that the local plan is not legally compliant because: Local Plan is/is not legally compliant, including references to - it solely considers the positive benefit from being in close proximity to local relevant legislation, policies and/or regulations. Please be as precise transport, schools and GP surgeries without adequately assessing the major and succinct as possible. strains on existing local infrastructure and ensuing traffic chaos from implementing the plans - The sustainability report refers to several unmitigated adverse impacts from the proposal plans which appear to have been ignored in the final site selection process including significant air quality concerns, impact on Chilterns AONB, increased risk of urban sprawl, loss of tranquility, water pollution etc. I am asthmatic and any increase in pollution levels would have a significant adverse impact on my health. - The housing needs figures have been over-inflated meaning green belt land would be taken without a clear need for the housing on it. - Planning consents have been granted for development at higher densities than accounted for in the council's housing availability figures which means the figures of housing need are unreliable. - Insufficient attention has been paid to previously developed land, both residential and commercial - not all brownfield sites have been identified. - the councils have merely carried out a request via a 'call for sites, inviting land owners and developers to nominate land for development, rather than carrying out their own assessment of land availability. This means, for example, that a large proportion of Beacosnfield green belt has, wrongfully, been nominated rather than previously developed land - a more strategic county-wide view should be taken by the new Unitary Authority before release from any green belt sites. This plan has been submitted without waiting for a county wide review allowing for all impacts. - This flawed green belt assessment goes against government policy on protection of the green belt which permits developments on green belt land only in 'very special' and 'exceptional circumstances' which are fully evidenced and justified.

2241 In my view these circumstances have not been properly evidenced and justified in the current plan. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1219485 Full Name Mrs J M Collier ID 1169 Order 1

2242 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 Non-Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local Not all brownfield sites in the area have been identified. Plan is/is not sound, including references to relevant legislation, A county-wide review should be undertaken by the forthcoming new Unitary policies and/or regulations. Please be as precise and succinct as Authority before release of any green belt sites. possible. The housing figures for the Beaonsfield area have been overstated based on reasonable demographic figures. Planning consents have been granted for development at higher densities than accounted for in the council's housing availability figures. This means that their figures for housing need are unreliable. Insufficient attention has been paid to previously developed land, both residential and commercial. Such sites should always be considered for redevelopment before any green belt site, regardless of the cost involved. The councils have merely carried out a request via a 'Call for sites', inviting landowners and develops to nominate land for development, rather than carrying out their own assessment of land availability, This means that large proportion of Beaocnsfield green belt has been nominated for development rather than previously developed land. This flawed green belt assessment goes against government policy. Previous consultation responses have been ignored. Evidence does not support this green belt release, which breaches national policy. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Not Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Consultation with the communities has been extremely poor. Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public?

2243 Attend EiPb - If you wish to participate at the examination in 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 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 1219788 Full Name Denise Howard ID 1378 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 No Soundness? Soundness mods - Please give details of why you consider this Local The Development policy of the South Bucks council is flawed and I strongly object Plan is/is not sound, including references to relevant legislation, to it. policies and/or regulations. Please be as precise and succinct as It is not positively prepared – it is an unsound plan. The infrastructure is incorrect possible. and doesn’t seem to responsibly thought through.

2244 It is not justified – the plan has far more houses then are needed in the area – far more than the government outlines. If this development goes through it will cause serious congestion in the town and surrounding roads. This could lead to anarchy and conflict in the community. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1219808 Full Name Julia Riddle ID 1307 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID

2245 Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to Legally Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Farmglade raises no issues in relation to the legal compliance of the Plan. Local Plan is/is not legally compliant, including references to No modifications are proposed in this regard. relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the No Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local Farmglade considers the Consultation Draft Local Plan (the Plan) to be unsound Plan is/is not sound, including references to relevant legislation, in its present form but believes it could be made sound by the amendment of policies and/or regulations. Please be as precise and succinct as sections as stated in this detailed representation. possible. Statement on Soundness Submissions were previously made by Farmglade to earlier consultation as follows: - Initial Consultation and Call for Sites, April 2015. - Call for Sites process, January 2018. Farmglade `act as agents for other Group companies which own the freeholds of the relevant sites. Specifically in relation to this Plan, Farmglade make comments in relation to landholdings at: 1. Longbottom Lane, Beaconsfield - Learmount Castle Developments Ltd are owners of 27 acres of land to the east of the junction with Amersham Road. This land is currently open space within the Green Belt, with an existing structure on part of the site. It has a planning permission for a recreational use (6 hole golf course). 2. Tatling End – Capswood Investments Ltd are owners of the site of Phoenix House. The Consultation draft of the Chiltern and South Bucks Local Plan (The Plan) covers the 20 years to 2036, during which time, it will seek to deliver 15,026 new homes. 11,000 of these are intended to be within the Plan area and 5,750 in Aylesbury Vale. The Plan states that Chiltern and South Bucks have worked with Aylesbury Vale District Council (AVDC) in the preparation of this consultation draft Plan. As such, Chiltern and South Bucks have an agreement to deliver part of their housing requirement through the AVDC Local Plan. The level of growth in the Chiltern and South Bucks Consultation draft Plan will require a delivery rate of 763 new homes per annum for the next 20 years in Chiltern and South Bucks. This is a challenging rate and level of growth for this area in the context of recent delivery rates, which have been below this level. The focus of this growth is intended to be driven by development in built up areas and on previously developed land. It should make efficient use of land and permitted development already in place. This is in accordance with national policy in the NPPF (paragraph 117). 87-88% of the Chiltern and South Bucks area lies within the Green Belt. In this context, Farmglade supports the approach of seeking to release areas of Green Belt to deliver the growth needed in this Plan period, in accordance with the Council’s Green Belt review. This approach to review and release of Green Belt land is in accordance with paragraph 136 of the NPPF. Farmglade therefore support the Spatial Vision of the Plan at 3.4. In terms of the Strategic Objectives at 3.5; Farmglade supports these and in particular notes the intention to: - Address traffic issues at the A355 Corridor in Beaconsfield (at Longbottom Lane) - Reconsider the Green Belt boundary. Farmglade represents companies with landholdings in Beaconsfield directly to the south east of the junction on the A355 at Longbottom Lane, which are not allocated in this Plan, but which are believed to offer a future development opportunity in this area and which would expand upon the development and growth to the East of Beaconsfield and could assist in the delivery of upgraded infrastructure to facilitate this.

2246 Farmglade supports the overall aims of the Plan, and, as a housebuilder and developer with land in the area both within the built up areas and within the Green Belt, is well placed to assist in the delivery of much needed homes within this Plan period and in accordance with the stated strategy of this Plan. In terms of economic growth; it is noted that there are over 2,000 businesses in the area and that the Council seeks to promote sustainable economic growth. Farmglade support this and the means of promoting sustainable growth at page 5 of the Plan. It is however considered that this must be achieved in the context of the delivery also of much needed homes and recognising that employment and economic growth would be held back without adequate homes. Economic and employment growth should be focussed in approrpiate locations and not at the expense of residential development. Farmglade’s position in relation to this Plan is therefore as follows: 1. Strategic Objectives – Farmglade overall support the Strategic Objectives of the Plan as set out at 3.5. 2. Housing – The delivery of new homes is imperative. This is an area with significant housing need and where demand is having a direct impact on raising house prices. This Plan has a strategy for delivering new homes, but it is heavily reliant on Aylesbury Vale District Council (AVDC) for achieving this. Whilst there is an agreement in place with AVDC for this, this is reliant on their delivering a challenging target to achieve this. In this context, it is considered Chiltern and South Bucks could do more and identify further areas of land for housing delivery during this Plan period in order to make this Plan sound. This could have been further progressed through the work of the Berkshire Strategic Housing Market Assessment (SHMA) and it is not clear why this has not formed part of the ongoing Plan work for South Bucks. 3. Employment – The Plan also recognises that it is imperative to support and grow employment and the economy in this area. The Plan seeks to do this through focussing growth around existing employment locations and transport hubs. It is believed that this is a suitable strategy, but that there are sites identified for this growth, such as at Tatling End, which whilst representing an existing employment area are not fulfilling these aspirations – they are not in an EZ or near any transport hubs. These areas could therefore make an alternative equally valuable residential contribution, whilst focussing employment on more suitable locations such as Uxbridge and Slough. 4. Green Belt – The release of Green Belt land to assist with housing provision is supported in appropriate locations. Specifically, at Tatling End for example, release in this area has been supported by Farmglade in previous representations. However, it is not clear as to why the Phoenix House site should only be released for employment use and why this was not assessed for residential use in the Green Belt review and Sustainability Appraisal. Furthermore, at Beaconsfield, there is scope to look at further Green Belt release for housing and to assist in the delivery of junction improvement work at the A355/ Ledborough Lane/ Longbottom Lane junction. This is a key transport interchange location, which currently relies on its delivery based on a single land allocation. By identifying additional land for development in this area which could further contribute to this infrastructure, this would reduce the risk in terms of its delivery, but any such land should be identified now as part of the Local Plan process, in accordance with paragraph 136 of the NPPF. Soundness mods - Are you proposing any modifications to Yes strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to Modifications to policy to meet the tests of soundness. improve its alignment to this test of soundness. Please be as precise We have set out proposed modifications to ensure the soundness of the Plan in and succinct as possible. the context of the issues set out above in relation to the specific policies of the Plan. Overall it is deemed however that the Plan is unsound as follows: The strategy of reliance on Aylesbury Vale to deliver a significant proportion of the known housing need is unsound. Not only does this place reliance on an area with an already challenging growth figure, it will not reduce the pressure of demand for homes in South Bucks and will not provide housing to support the employment growth around Slough, Uxbridge, the Thames Valley and West London. Further work should be undertaken to look at further sites which are available within the Plan period and in the area of Chiltern and South Bucks which could deliver more of this need in the Plan period. This could include areas such as: - Farmglade’s land at Longbottom Lane, which could form a logical and sustainable extension to the allocation East of Beaconsfield, and - At Tatling End, where an employment designation is proposed, but which could assist in meeting vital housing need as opposed to employment, for which there are more suitable locations in existing centres such as Slough and Uxbridge and around transport hubs. The Plan would be more effective in reconsidering these matters.

2247 The Plan should be reconsidered to ensure that the locations for employment growth reflect the objectives of the Plan in terms of the location and nature of growth. For example, Tatling End could make a sustainable location for housing delivery but does not necessarily fulfil the criteria in terms of employment growth locations. Further consideration is required in this regard to ensure that the Plan is justified and is capable of meeting its delivery requirements in terms of housing need. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a Yes modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, Farmglade is the agent for companies which own a number of landholdings, please outline why you consider this to be necessary (please be as particularly in South Bucks, beyond those specifically referenced in these precise and succinct as possible representations. Farmglade have made many planning applications in the area and continue to do so and would welcome the opportunity to participate in the Examination to progress the areas of consideration raised in these representations as approrpiate. 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 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 1222784 Full Name Mr Charles Coxall ID 7205 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of:

2248 Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to Non-Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the I believe the draft Local Plan is NOT legally compliant because it has not Local Plan is/is not legally compliant, including references to demonstrated sufficient regard to the National Policy and guidance issued by relevant legislation, policies and/or regulations. Please be as precise the Secretary of State. and succinct as possible. 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 “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. Legally compliant b - Are you proposing a modification to make the Yes Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) The Plan needs to be modified by; below:You will need to say why this modification(s) will make the Co-operating with other nearby authorities. Not just Aylesbury. It is simply Local Plan legally compliant/strengthen its legal compliance. Please unsatisfactory to assert this cannot be done because they are different Functional be as precise and succinct as possible. Market Areas and that co-operation is not necessary therefore. 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 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. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local The proposals to release Green Belt land to meet housing targets (Generally, Plan is/is not sound, including references to relevant legislation, Spatial Policy SP SP1 & specifically Policy SP BP2 at Lye Green NE of Chesham) policies and/or regulations. Please be as precise and succinct as are not justified from the evidence submitted by the Councils. possible. 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

2249 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. Further doubt is cast upon the “soundness” 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 “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

2250 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 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 “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” 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. Soundness mods - Are you proposing any modifications to Yes strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to I refer to the comments previously submitted but in summary would advocate improve its alignment to this test of soundness. Please be as precise that; and succinct as possible. 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. Plan-level upload - Please upload any supporting evidence

2251 Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 5500800

Person ID 1223273 Full Name Sandy Oxley ID 6878 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Landowner Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID 1223271 Full Name Paul Airey Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible.

2252 Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local Soundness. I consider that the Plan is not sound for the following reasons: Plan is/is not sound, including references to relevant legislation, 1. The Plan has not been positively prepared in that while an agreement has policies and/or regulations. Please be as precise and succinct as been made with the neighbouring authority at Aylesbury Vale District Council possible. to accommodate 5725 units out of the total housing requirement for Chiltern and South Bucks, there has no similar agreement with Slough despite that authority preparing proposals for the northern expansion of Slough into the Borough. In these circumstances it is not possible to be certain that the calculated housing need and spatial strategy in the plan is sound. 2. The Plan is not justified because the housing strategy has underestimated the overall housing requirement in the Borough. It is noted that the table LP b (Homes Requirement and supply) shows in row N that the figures include an additional 10% to account for potential non-delivery of homes. This percentage, which generates a figure of 1,526, has been copied from the figure used in the draft proposal in the Vale of Aylesbury Local Plan. The figure was however questioned in the Inspectors Interim findings (29/08/2018). 17) At the time the evidence base was prepared there was no definitive guidance on what level of uplift for affordability is appropriate. Reference is made to professional judgments made by other examining Inspectors such as at Eastleigh and comparisons made between affordability in Eastleigh and affordability in the Central Buckinghamshire Housing Market Area to arrive at a recommendation for the Central Buckinghamshire HMA. Comparisons are also made within the Buckinghamshire HMA to arrive at different recommendations for Aylesbury Vale and for the rest of the HMA. 18) But, if these recommendations are tabulated, it becomes clear that the uplift recommended for VALP in comparison with Eastleigh is too low: Location Affordability ratio National comparison Uplift recommended England 7x Eastleigh 8.6x 20% higher 10% Aylesbury Vale 10.4x 50% higher 10% Bucks HMA 12.1x 75% higher 15% Rest of HMA 13.9x 100% higher 20% 19) The disconnect between the affordability ratio, the national comparison and the uplift recommended for Aylesbury Vale is obvious. An affordability ratio for Eastleigh 20% higher than the national average leads to a recommendation for a 10% uplift. An affordability ratio for Aylesbury Vale 30% higher still leads to no further recommended uplift yet an affordability ratio for the Buckinghamshire HMA only 25% higher leads to an uplift 5% higher as does the increase in the affordability ratio for the rest of the HMA excluding Aylesbury Vale. Even if the 20% uplift for the rest of the HMA is correct, the uplift for VALP should be 15% to be in proportion with that recommended for Eastleigh and that for the whole HMA should be about 17-18%. Moreover, more recent evidence shows the differences between Aylesbury Vale and the rest of the Housing Market Area decreasing which suggests that the uplift for VALP should more likely be 20% than 15%. On the basis of the above, it would appear that the housing requirement for the Plan area has been underestimated. If the 10% uplift is changed to 20% as it appears it should be, then the uplift adjustment will increase from 1526 to 3052. This will increase the overall shortfall (row P) to 7213 units. The agreement with Aylesbury Vale allows for only 5725 units which means that the Plan under-provides by 1488 housing units. Under these circumstances there is a need for significant additional housing provision within the Plan. 3. The Plan is not effective because it does not properly deal with cross-boundary strategic housing matters and does not provide sufficient housing allocations to meet the OAN, as detailed above. 4. The Plan is also not consistent with government policy. NPPF paragraph 67 requires the Council to identify a supply of: a) specific, deliverable sites for years one to five of the plan period; and b) specific, developable sites or broad locations for growth, for years 6- 10 and, where possible, for years 11-15 of the plan

2253 The Plan does not allocate sufficient sites or broad locations for growth to meet the requirement and as a result this is contrary to current Government Policy. It is also considered that at least one of the housing allocations made (SB BP 11) is not necessarily deliverable in the required timescales. Further details of this are considered below in respect of specific policy considerations. Soundness mods - Are you proposing any modifications to Yes strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to Proposed modifications to strengthen the Plan's ability meet the test of improve its alignment to this test of soundness. Please be as precise soundness and succinct as possible. To help meet the shortfall in housing allocations a site (HELAA ref 0299) to the east of Richings Park is put forward to be considered as a new allocation. This site has previously been submitted to the LPA as part of the plan making process, but has not been included in the Plan despite representations being made at both the Local Plan Reg 18 stage and the Green Belt Preferred Options consultation in 2016. The site, which is referred to as SBO299 in the HELAA and is under a single ownership, is approximately 5.77 ha in size and lies between Thorney Lane, South and the M25. It is bounded on the north by the main rail line to London. The site is immediately adjacent to the settlement boundary for Richings Park but is currently in designated greenbelt. Planning permission has recently been granted for a commuter car park at the north west corner of the site, to serve the soon to be upgraded railway station at Iver (Crossrail). A considerable amount of work has been undertaken to demonstrate that the site is both available and deliverable and the following documents are submitted in support of the site. 1. A draft layout plan of the site providing for 136 two storey houses on the site ranging from 2 to 5 bedrooms. A relatively high density of development is proposed due to the sustainability of the site and the proximity of the rail station. The layout has been guided by the results of the other surveys undertaken particularly the archaeological assessment (see below). 2. A Phase 1 Ecology Survey which concluded that it was considered unlikely that there will be any overarching ecological constraints to developing the site. 3. A Landscape and Visual Impact Assessment and a critique of the Green Belt Review process that was undertaken by the Council, by Lizard Landscape Design and Ecology. The LVIA incorporates a Capacity Study in line with assessment criteria within the 2017 Terra Firma produced Landscape Capacity Study for Green Belt Development Options (2017), and informed by a desktop study, site visit and photographs from publicly accessible land. The site is provided with a comparable level of assessment to justify its removal from the Green Belt. This report is significant as it firstly questions the basis of the Council commissioned assessment which included the land as part of a much wider area of land to the south of Richings Park (site 99) but then failed to undertake a more detailed assessment of this discreet and isolated area of land, despite having done so for another site within the wider area. Secondly, the study concludes that the site is consistent with the general suitability of areas for development identified by Terra Firma for alternative sites within the Study Area. 4. An Archaeological Assessment and Geophysical Report confirming the presence of Archaeological remains on part of the site, but questioning the exact location of the Scheduled Ancient Monument. 5. A site survey confirming the features and contours of the site. The site is within Flood Zone 1 and it is considered that there are a range of options for dealing with run-off within the site. It is also considered that there is likely to be adequate service provision within the area for a development of this size. The site’s primary benefits are its location adjacent to the railway station at Iver and the community facilities at Richings Park. It is considered that these factors should have been afforded much greater weight during the site selection process. In addition the Green Belt Assessment was flawed in respect of this site. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public?

2254 Attend EiPb - If you wish to participate at the examination in 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 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 1223055 Full Name mh mmm ID 6397 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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.

2255 Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1223383 Full Name clary Greenhalgh ID 5342 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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

2256 Plan-Level: Legally Compliant - Do you consider the Local Plan to Legally Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the I fully support the Chalfont St Giles Neighbourhood Plan and Chiltern & South Local Plan is/is not legally compliant, including references to Bucks Plan and believe it is legally compliant and should be upheld. I was very relevant legislation, policies and/or regulations. Please be as precise supportive of the Green belt land being protected as part of the plan, given its and succinct as possible. environmental importance to the county, the fact that the greenbelt areas are long standing. I am pragmatic - and understand that some land will have to be developed, and am supportive of the 15 sites highlighted for potential development - however the land above High View was NOT included in any of these potential sites for good reason. I fully appreciate it appeals to developers due to the size and possible economies of scale of construction - but these are financial gains for the companies selling the land and the companies developing said land, and in no way benefits the community when protected areas of green belt are built on in such large scale. This was not in the spirit of the Neighbourhood plan, which fully accepts reasonable housing development within the town which will not 1. Spoil the nature of the village 2. Destroy large and important areas of our green belt and 3. put excessive pressure on the village infrasctructure. In summary the Neighbourhood plan was well thought out and thoroughly undertaken, and the community was highly invested in it with a staggering high local support in the referendum. The subsequent challenge to the plan especially with a view to High View development is equally as staggering, given how unsuitable the site is, the lack of services and employment in the village, and the fact that there are a number of alternative sites which would have the support of the community - I can only assume the financial gain of High View is so significant that Paradigm are willing to ignore the years of Plan development, a robust acceptance of that plan by residents and the wishes of the local community. Legally compliant b - Are you proposing a modification to make the No Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Yes Soundness? Soundness mods - Please give details of why you consider this Local I believe that the Plan is sound and should be upheld Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to No strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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

2257 Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and 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 1223580 Full Name Mrs Dianne Taylor ID 5231 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 No Soundness? Soundness mods - Please give details of why you consider this Local The plan is not well founded. It gives scant regard for the needs and capacity to Plan is/is not sound, including references to relevant legislation, meet these needs in the area. It does not build on the existing plan, and the policies and/or regulations. Please be as precise and succinct as experience of the previous plan periods. As a result it is aspirational and not able possible. to be delivered. For example there is insufficient attention to the infrastructural demands such a plan would create (roads, utilities provision, schools etc). It would have benefitted from a review of performance in the last plan period. On the housing front this would have highlighted that the overall increase was limited and much of the development was the extension or replacement of existing smaller properties to/by larger homes. This has resulted in a significant reduction in starter homes (and an unbalanced distribution of homes by size). However and bizarrely the draft plan proposes to build proportionately more larger homes thereby preserving and extending this imbalance rather than correcting it. This may reflect the pattern of demand (by owners and developers who are both motivated by personal and not community needs) but does not reflect the needs of a balanced community. Planning authority has failed to provide support for its plan in the form of officers available to talk to or meet residents to explain the plan.

2258 It has not considered planning history and infrastructural needs. As such it is an aspirational description of what might be achieved if there were no obstacles to the plan. There clearly are as the highways infrastructure struggles to support existing levels of development Chiltern has never (in my experience) achieved its plan objectives. Given its consistent failure to manage its district I find it hard to believe all will change, particularly when the plan is not soundly founded. Soundness mods - Are you proposing any modifications to Yes strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to This plan is so remote from the needs of the community that it should be improve its alignment to this test of soundness. Please be as precise abandoned and the process started again from the proper starting point - a and succinct as possible. detailed needs analysis across all use classes and within each use class for each property type (eg for housing, homes by room numbers). This could be complemented by a review of the last plan period, what was planned, what was achieved, what lessons were learnt etc. I say this because over the 40 years I have lived in the district successive plans have resulted in an increasingly distorted community (loss of starter homes, dead retail centres, loss of local businesses). As drafted the plan gives just aspirational and environmental guides and then leaps to a series of detailed proposals for new developments without explaining how these could be serviced, or indeed justifying the need for them. It also refers to changes in green belt alignment in certain rural communities (eg Botley) without giving any detail of what this means (no plans showing the areas impacted by the proposed relaxation of green belt). This problem has been exacerbated by an unwillingness of the planning department to provide officers to speak with or meet residents raising questions. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Not Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Officers not available to discuss plan. Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1223569 Full Name Mrs Janet Bradley

2259 ID 5228 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 Non-Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the The evidence does not support the proposals and these do not seem to have Local Plan is/is not legally compliant, including references to been fully disclosed to the Councillors when their decision was made to adopt relevant legislation, policies and/or regulations. Please be as precise this Local Plan and succinct as possible. Legally compliant b - Are you proposing a modification to make the No Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local The evidence does not support the proposals. I support Chalfont St Giles Parish Plan is/is not sound, including references to relevant legislation, Council's decision to support the Troy Planning Report dated 3rd July 2019 with policies and/or regulations. Please be as precise and succinct as all the arguments that this Local Plan proposal is unsound. possible. Soundness mods - Are you proposing any modifications to No strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Not Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the The evidence does not support the proposals and at the time of voting CDC Local Plan has met/not met the requirements of the Duty to Councillors were not fully briefed on the evidence vs the proposed changes in Co-operate.Please be as precise and succinct as possible. the Green Belt boundaries. I support the Troy Planning Report dated 3rd July 2019 with all their arguments. Attendance at the EiP - If your representation is proposing a No modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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

2260 Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and 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 1223748 Full Name Janice Pendall ID 6570 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 Legally Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the I consider it essential to preserve the Green Belt across the UK. Otherwise Local Plan is/is not legally compliant, including references to unwanted relevant legislation, policies and/or regulations. Please be as precise development can be pushed through by any organisation, whether unscrupulous and succinct as possible. or not. Open spaces in this area in particular are much used and valued. Local amenities need to be preserved and not stretched beyond breaking point by unnecessary development. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local I consider it essential to preserve the Green Belt across the UK. Otherwise Plan is/is not sound, including references to relevant legislation, unwanted policies and/or regulations. Please be as precise and succinct as development can be pushed through by any organisation, whether unscrupulous possible. or not. Open spaces in this area in particular are much used and valued. Local amenities need to be preserved and not stretched beyond breaking point by unnecessary development. Soundness mods - Are you proposing any modifications to No strengthen the Plan's ability meet the test of soundness?

2261 Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a No modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 5501668

Person ID 1223621 Full Name Louise Blyth ID 5281 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 Legally Compliant be legally compliant/non-compliant.

2262 Legally compliant a - Please give details of why you consider the I would like to state that I completely support the draft Local Plan which is clearly Local Plan is/is not legally compliant, including references to legal and sound. The Green Belt land must be protected and I understand that relevant legislation, policies and/or regulations. Please be as precise it is protected under Section 10 of the Plan. It is important that this is respected. and succinct as possible. Our ancestors initially protected land and we must do this for the next generation. I am horrified that that Paradigm Housing in association with their Planning Agent, Pegasus Group are intending to challenge the Green Belt assessment of a plot of land off High View. This should be strongly rejected. It is not for the good of the village, we have had this for more than 60 years and it protects us from over development. We have voted in our councillors on the councils to protect us from such rampant overdevelopment. Clearly they should have our concerns registered and make sure they vote with us. If they do not listen to the people of the village and district they should consider whether they wish to represent us and we should also consider their position. The speculative development will not be acceptable to the residents. The land off High View is highly regarded by the Chiltern District Council as Green Belt land and I gather that similar proposals have been rejected. We are under siege with HS2, Heathrow airport and now the green belt issues. There are key environmental issues we should consider with the possible loss of wildlife habitat. Badgers, bats, deer, birds which all reside in the land off High View. There is also a concern about a loss of open spaces and increased pollution and general environment destruction. This will not be a healthy place to live and bring up children. We already have a problem with serving the community with schools and medical services which are stretched and will not cope with an increase in population. Legally compliant b - Are you proposing a modification to make the No Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Yes Soundness? Soundness mods - Please give details of why you consider this Local I believe that the draft Local Plan is sound. Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to No strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a No modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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.

2263 Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and 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 1223672 Full Name Mrs Nicola Wood ID 6806 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 Legally Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the I believe the Chiltern and South Bucks Local plan to be sound and legally Local Plan is/is not legally compliant, including references to compliant and I fully support it and the Chalfont St Giles Neighbourhood Plan. relevant legislation, policies and/or regulations. Please be as precise I support the Green Belt land under section 10 being protected and understand and succinct as possible. that Paradigm Housing association are intending to challenge the green belt land assessment of a plot of land know as High View. I object most strongly to this. This part of green belt fully meets the assessment of green belt in todays definition and if it didn’t Chiltern and South Bucks would have already released it as I understand that a full review of Green Belt across the whole of Buckinghamshire County has in the last few years been undertaken by independent specialists, leading to the release of some green belt and this area is not one of the 15 sites which are potentially being considered for development. I understand that Chiltern DC follow the NPF guidance regarding Green Belt as a plot similar to Highview in Chesham has recently been rejected. If this plot of land were to be released for housing, I have significant concerns regarding its suitability not least because of the extra traffic congestion it would cause onto local roads which are already very congested eg A413. It would also cause issues with waiting times at local medical centres and schools leading to more competition for my grandchildren who also live locally. I am very concerned regarding the access to this site as Stylecroft Road is a steep hill which is virtually impassable in wintry conditions and where it would be possible to site a suitable secondary entrance as a development of this size must have a minimum of two entrances/exits. High View forms a lovely open green space in Chalfont St Giles which contributes to many varieties of local wildlife which live there and is an important ecosystem locally. Legally compliant b - Are you proposing a modification to make the No Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) Not necessary, I believe the current plan to be legally compliant below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Yes Soundness?

2264 Soundness mods - Please give details of why you consider this Local I believe that the draft Local Plan is sound. I believe it has been prepared in Plan is/is not sound, including references to relevant legislation, accordance with all relevant government legislation, policies and regulations policies and/or regulations. Please be as precise and succinct as and that it does not require any amendments possible. Soundness mods - Are you proposing any modifications to No strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the i believe that the draft Local Plan is sound. I believe it has been prepared in Local Plan has met/not met the requirements of the Duty to accordance with all relevant government legislation, policies and regulations Co-operate.Please be as precise and succinct as possible. and that it does not require any amendments Attendance at the EiP - If your representation is proposing a No modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, I don’t wish to participate at the public examination 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 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 1224099 Full Name Inland Homes ID 6502 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID 1223253 Full Name Ian

2265 Gillespie Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local We believe the Local Plan is unsound, because it has not been positively prepared, Plan is/is not sound, including references to relevant legislation, does not represent the most appropriate strategy (when considered against policies and/or regulations. Please be as precise and succinct as reasonable alternatives) and because there are significant concerns over possible. deliverability. We also raise concerns in relation to compliance with the NPPF Feb 2019. The Spatial Vision is very generic and isn’t very spatial. It does not explain the reasoning for the proposed distribution of development across the two Districts, with reference to the hierarchy of settlements. The Spatial Vision does refer to meeting needs locally (i.e. within Chiltern and South Bucks) but if this is not possible, the authorities will work with adjacent Local Plan areas (i.e. Aylesbury Vale District Council) to meet these needs elsewhere as part of sustainable development proposals. There is clearly a matter of planning balance here, with significant weight to be attached to the benefits of meeting housing need where it arises, not least to avoid unsustainable travel patterns. We do recognise also the importance to be attached to focusing new development in accessible locations (JLP para 3.5.3); protecting and enhancing the local environment (JLP para 3.5.8); maximising the provision of affordable housing (JLP para 3.5.10); conserving the landscape and scenic beauty of the Chilterns Area of Outstanding Natural Beauty, (JLP para 3.5.9); and the need for a strong Green Belt policy (JLP para 3.5.7). In relation to this last Strategic Objective, the JLP references the importance of establishing a Green Belt boundary that will endure beyond 2036. This is an appropriate Strategic Objective, which fits with national Green Belt policy. The issue is that having undertaken a full Green Belt Assessment, looking at all of the opportunities to meet the needs of Chiltern and South Bucks locally, why is there reference in the JLP (paragraph 3.5.7) to the need for further consideration of the Green Belt boundary to the north of Slough, with the clear inference that there may need to be further amendments to the Green Belt boundary in this area prior to 2036. It seems perverse to countenance further Green Belt releases in the JLP area prior to 2036 to meet an adjoining authority’s unmet housing needs, but not to propose such releases to meet the existing needs of Chiltern and South Bucks District Councils. If there are opportunities to accommodate further development in Chiltern and South Bucks to the north of Slough (or indeed anywhere else in the JLP area, including at Beaconsfield) these opportunities ought to be taken forward as part of the current JLP, in the interests of good planning and to accord with the Memorandum of Understanding (July 2017), which requires that each authority does everything it possibly can to meet their own housing needs locally. Soundness mods - Are you proposing any modifications to Yes strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to We believe that it is possible for Chiltern and South Bucks Districts to identify improve its alignment to this test of soundness. Please be as precise additional sites for development in the Districts now (rather than in a Local Plan and succinct as possible. review), which would reduce the level of unmet housing need to be accommodated in Aylesbury Vale, and increase the likelihood of the housing requirement figures for both Chiltern and South Bucks Districts, and the wider Buckinghamshire HMA, being delivered in the period to 2036. Land South of Holtspur should be released from the Green Belt and allocated for development in the JLP. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the

2266 Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1223684 Full Name J Waters ID 6853 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 Legally Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the I fully support and approve the Chiltern & S Bucks “Local Plan” as well as the very Local Plan is/is not legally compliant, including references to recently agreed Chalfont St Giles Neighbourhood Plan. However, I TOTALLY relevant legislation, policies and/or regulations. Please be as precise OPPOSE a recent proposal by Paradigm Housing to build on the Green Belt at and succinct as possible. High View, Chalfont St Giles . This is in ABSOLUTE CONTRADICTION to both local plans. The Green Belt is an important resource for the local community and should continue to be protected, as stated within the Local Plan.

2267 The area for the proposed development is unsuitable in many ways, e.g. accessed by a steep hill (Stylecroft Road) which can be treacherous in the winter and is generally unsuited for pedestrians unless they are “fit”. The size of the development will put even more burden on already stretched local resources, e.g. schools, the medical facilities and the roads. Legally compliant b - Are you proposing a modification to make the No Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Yes Soundness? Soundness mods - Please give details of why you consider this Local Having reviewed it, I am of the opinion that the draft Local Plan is sound. Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to No strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a No modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, I do not consider it necessary to participate at any examination in 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 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

2268 ID 6574 Order 1 Number Title Foreword 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 Non-Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the The NPPF (latest update 24th January 2019) expects strategic policy-making Local Plan is/is not legally compliant, including references to authorities to use the government’s new standard method when calculating relevant legislation, policies and/or regulations. Please be as precise housing need. The standard method sets out a minimum annual housing need and succinct as possible. figure although it does not produce a housing requirement figure. The CSB Councils have used the standard method for the basis of their Local Plan without electing to apply considerations for exceptional circumstances (such as the AONB). The result of this approach means that the proposals include significant release of Green Belt land in order to contribute to meeting development needs to 2036. Additionally, as per the announcement earlier this year, the standard methodology is to be revised next year with the use of up to date National Statistics data and this method is likely to be used in assessing the new local housing need for the new Buckinghamshire Council. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local Since the publication of the Reg 18 document, the County Council has actively Plan is/is not sound, including references to relevant legislation, been involved in conversations with Chiltern and South Bucks District Councils policies and/or regulations. Please be as precise and succinct as (CSB) and has commented on various evidence base documents. Our officers possible. have shared their professional and technical knowledge with CSB officers; the updated and revised evidence work recently published suggests that many of the technical matters in relation to specific sites have been addressed through the evidence work prepared (some jointly). To a large extent, the CSB draft Plan has incorporated many comments received from the discussions that we have had with CSB to date. However, there are a number of issues we wish to raise. BCC continues to have strong reservations in relation to the spatial strategy of the draft plan and its reliance on Green Belt release, and especially the robustness of the Green Belt assessment and justification for meeting very special circumstances. The Councils could have considered an alternative approach since 3% of the South Bucks district and 72% if the Chiltern district is covered by AONB. An example of this alternative approach can be seen in the recently adopted AONB Development Plan Document (DPD) that was prepared by South Lakeland District Council and Lancaster City Council for Arnside and Silverdale AONB. Based on the advice from relevant Counsel and organisations such as Planning Advisory Service, the Councils concluded that it is not necessary to identify a specific housing requirement for the AONB. South Lakeland district council and Lancaster City Council are set to consider the AONB DPD for inclusion in their Local Plans. South Lakeland District Council and Lancaster City adopted the Plan in March 2019. In relation to the proposed CSB development allocations in the Green Belt, the County Council continues to value and respect the unique quality of the Buckinghamshire Green Belt and Chilterns Area of Outstanding Natural Beauty (AONB) and will continue to resist inappropriate development in the Green Belt and AONB. This remains the Council’s consistent policy position. In some instances, the draft plan does not provide sufficient consideration to the proposals which will harm the AONB and/or its setting; this is particularly the

2269 case for the allocation in Little Chalfont (site SP BP6) where there is potential for that allocation to have a detrimental effect on the AONB/Green Belt. BCC would like to see the Green Belt protected in accordance with the National Planning Policy Framework and relevant guidance such as Chilterns AONB Management Plan; the County Council recognises the need for a robust assessment of deliverable sites for housing and employment uses within the Local Plan area. We continue to have concerns in regards to adequacy of the green belt assessment particularly where these allocations are large strategic sites. Specific sites of serious concern include Holmer Green, Little Chalfont, and Chalfont St Peter – South East. At the same time, also aware of a number of significant concerns being raised by the local community regarding the Beaconsfield site. Inappropriate assessment and subsequent release of the land in the Green Belt may lead to creating new Green Belt boundaries which will be less resistant to future alterations due to growth pressures from adjoining authorities, for example where it has been suggested that Slough should meet its housing need in Green Belt allocations in South Buckinghamshire. We would also be concerned that these strategic allocations may weaken the Metropolitan Green Belt which greatly contributes to maintaining the distinctive character and identity of Buckinghamshire as well as serving as the ‘London buffer’ in those areas. Unfortunately, the overall strategic narrative in the Plan leaves much of the detail to be agreed within the individual master plans for the specific site allocations. We note that the Landscape Capacity Assessment could be better incorporated into the approach on specific sites on matters of density and boundary revisions, particularly where the ‘openness’ character of the Green Belt and AONB is a factor. The County Council would welcome additional detail in site specific policies which would address the results of the Landscape Capacity Assessment. However, the County Council notes that CSB have emphasised that the Landscape work is part of the evidence base that will help inform the extent of the developable area within the larger identified area to be released from the Green Belt. On a wider strategic scale, the draft Plan highlights major projects within the local plan area (and further afield). We are pleased to see the references made to Western Rail Link to Heathrow (WRLtH), Heathrow, and the Oxford – Cambridge Arc/Expressway. These references would benefit from further information or details about those projects included in the Plan and how they potentially can affect the Local Plan area. The possibility of an early Plan review should be added to the Monitoring Chapter. There is also a need of an additional policy which would allow early review of the Plan in order to address Heathrow expansion or other significant strategic projects. Given the scale of the development proposed across the districts, we would like to see the plan provide more on the expected cumulative impacts of all the proposals. This is especially true in relation to the communities in the Iver area where a number of sites have been proposed within the context of a number of major significant projects (i.e. WRLtH, Healthrow Expansion). Considering the uncertainty regarding the Heathrow expansion it is suggested that additional wording is added to the Monitoring Chapter which would allow for the Plan’s policies to be reviewed once more details are known about the DCO application. BCC maintain that the spatial strategy for the plan area should focus on enabling development within the existing settlement boundaries where possible to enable the provision of well-planned infrastructure to support sustainable development and conserve the County’s distinctive, rural character. Such a strategy would also better support existing local services and facilities and safeguard the County’s green belt and areas of AONB from inappropriate development. In addition to these high level comments, technical officer teams from across the council have provided detailed comments on the Plans which you can find in Appendix A and B of this response. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination

2270 Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1223712 Full Name William Waters ID 6816 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 Legally Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the I consider the “Local Plan” for the Chiltern & S Bucks District to be legally Local Plan is/is not legally compliant, including references to compliant and support it. Furthermore I also support the Chalfont St Giles relevant legislation, policies and/or regulations. Please be as precise Neighbourhood Plan. and succinct as possible. Some of the reasons that I support them are: - The Chiltern area is very attractive because of its openness and natural beauty, and the Local Plan supports the continuation of these important features. - The Green Belt, which is a very valuable local asset is protected. It is there for people’s enjoyment and to retain the openness and the feel of not living in a city. - Specifically, Chalfont St Giles is a village, and needs to remain so. It is characterised by its Norman church, the Village Green, the duck pond and the “local” shops. It does not need, and neither must it have, any significant

2271 development, whether it be housing or anything else, which irreversibly undermines its status. - Furthermore, Chalfont St Giles is a community with its annual Village Show and library run by volunteers; it needs to remain so and not become a town or suburb. - The one point that I would make is that the only road of significance within the Village is the A413 and that has become increasingly congested over the past 40 years. Any further development in the general area will undoubtedly make matters even worse. Alongside the finalisation of the Local Plan has come the publication of an attempt by Paradigm Housing to develop on Green Belt land to the north side of the Village at High View, Stylecroft Road. THIS IS IN CONTRAVENTION OF THE LOCAL PLAN NOR IN THE NEIGHBOURHOOD PLAN. It must be rejected for the following reasons: - It is not within the plans that I support. - It involves the destruction of Green Belt which the Local Council has been successful in maintaining. - The area in question is used very frequently by ramblers, dog walkers and casual strollers, like myself. - Such a development would involve the removal of trees, and the like. - Access to the site would be via Stylecroft Road which is narrow and steep. In winter time it can become iced up and impassable with the consequence of cars being abandoned in surrounding roads. And generally it is not suitable for pedestrians who are not “fit or able” for any reason. - The resultant increase in housing would further stretch local amenities such as health services, educational establishments and transport, to name but three. - As mentioned above, the A413 is already extremely busy during peak hours; additional traffic would exacerbate this problem. Legally compliant b - Are you proposing a modification to make the No Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Yes Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to No strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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.

2272 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 7019 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: St Congar Land 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 Non-Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the We have assessed the sustainability appraisal (SA) which has been prepared Local Plan is/is not legally compliant, including references to alongside the Local Plan. relevant legislation, policies and/or regulations. Please be as precise Initially a range of spatial strategy options were set out within the earlier drafts and succinct as possible. of the Plan as options A to L (this is set out as Table 5.1 of the Sustainability Appraisal). These do set out a sensible range of reasonable alternatives, including (options C and E) built area extensions to a range of settlements across the two districts, including Chalfont St Giles. Taking forward these options to the full extent would have necessitated a proper review of the Green Belt boundaries in those areas. However, the SA goes on to explain (para 5.3.3) that “the spatial options were revisited by the plan makers in 2019 and presented as a suite of four options”. This was a fundamental change, unsupported by the outcomes of any SA work. The four options relate to housing numbers only (below), with no real spatial detail about where the housing will go in terms of its distribution across the two districts. One of the options is ‘do nothing’ which is clearly not a reasonable alternative for consideration. The three other options all involve exporting some degree of growth to Aylesbury Vale. The four options set out below do not cover a wide enough range of alternatives; other reasonable alternatives would have led to the testing of options around accommodating more of the housing needs within the two districts and undertaking a more fundamental Green belt assessment. These are realistic options which should have been tested to assess their social, economic and environmental effects. There is also no detailed explanation as to how the outcomes of the process of SA have led to the change in approach and a move away from a sensible assessment of a spatial strategy for the Districts.

2273 Additionally, the option of assisting in meeting the unmet needs of other areas, such as Slough, have not been explored through the Sustainability Appraisal. The Plan therefore fails to address one of the main strategic cross-boundary issues. There are therefore shortcomings in the Duty to Cooperate process, as well as in the Sustainability Appraisal which need to be remedied before the Plan progresses further. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1224462 Full Name Croudace Homes

2274 ID 6586 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID 1210966 Full Name Mr Richard Butler Organisation Details Associate Bidwells Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local Spatial Vision Plan is/is not sound, including references to relevant legislation, 3.1 The Spatial Vision sets out some key requirements for the plan to achieve. policies and/or regulations. Please be as precise and succinct as Having reviewed the possible. plan there are concerns over some elements of the spatial vision, these are detailed below. 3.2 Paragraph 3.4.3 “Plan to meet the development needs of all of our communities, both now and expected within the Plan period. Particular attention being given to: the needs of those people who find private market housing unaffordable; the accommodation needs of an ageing population including those with special care requirements and people with disabilities; requirements for young people such as access to play spaces and schools; and the needs of others with specialist housing requirements such as travellers and people with self-build aspirations.” 3.3 The vision to meet the needs of the community is commended, particularly with a view to addressing the needs of those people who find private market housing unaffordable. There is a concern that the reliance of neighbouring authorities to accommodate unmet need from Chiltern and South Bucks, will result in further affordability issues within the plan area. There is no evidence within the plan or supporting evidence base on the impact on affordability, employment prospects and development of infrastructure, by failing to meet as much local housing needs within the plan area as possible and relying on delivery outside of the plan area. 3.4 For this reason, this spatial vision will be poorly addressed through the plan; leading to the

2275 conclusion the plan is not ‘positively prepared’ or ‘effective.’ Further evidence is needed to demonstrate that as much local need is met within the plan area as possible, to ensure everything in being done to meet this element of the spatial vision. 3.5 Paragraph 3.4.6 of the plan notes a vision to, “Reinforce the role of our Green Belt to help deliver our Plan and the urban regeneration objectives of other plans around us whilst reviewing the Green Belt now to ensure that it remains an up to-date, effective, long-term part of our strategic planning policy.” 3.6 We have provided comments relating to the strategy concerning the Green Belt Assessment and general approach to Green Belt protection over sustainable development, and the requirements of Local Plans facilitating a review of Green Belt Boundaries in exceptional circumstances that must prevail beyond the plan period. The strategy adopted by the plan and the supporting documents does not meet this requirement and as such the plan is not positively prepared, is not effective and is not consistent with National Policy. To be positively prepared and consistent with national policy the plan should remove land from the Green Belt and safeguard such land for future development; providing flexibility to a plan that is likely to result in limited control over housing delivery across the plan period and providing adjustments to Green Belt boundaries that will last beyond the lifetime of the plan. Further discussion of our considerations of Green Belt matters are noted in the response to Policy SP1. 3.7 Paragraph 3.4.7 of the plan provides the following, “In recognising the difficulties of meeting all of the above, working with adjacent local plan areas so that any of our needs which cannot be met locally are met as part of sustainable development proposals within the wider housing and economic market areas.” 3.8 Our representations under Duty to Cooperate express concerns over AVDC’s ability to facilitate the unmet need from Chiltern and South Bucks, and Wycombe, in the future, due to an increase in housing need for AVDC’s own needs at the next plan review (due to increase from Standard Methodology). In addition to this, there is considerable concern that Chiltern and South Bucks are placing close to 40% of their housing needs to a neighbouring authority and in doing so have very limited control over the delivery of development to meet their needs. There appears to be no mechanism for intervention or contingency should there be a lack of development coming forward at the neighbouring authority. For this reason, the Chiltern and South Bucks plan is in danger of being ineffective and is not prepared positively. 3.9 As a solution to this matter, we suggest the spatial vision must be reviewed to place a greater focus on meeting housing and other development needs within the Local Authority area; this will allow the plan to be positively prepared and effective; addressing concerns of truly meeting affordable housing need, where the need originates and in having control over deliverability of the plan. Strategic Objectives

2276 3.10 This section reviews the strategic objectives of the Local Plan, which comprise the elements below. 3.11 Paragraph 3.5.2 sets of the objective, “To 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 constraints and opportunities.” 3.12 The Sustainability Appraisal is limited in its content and true evidence of consideration of alternatives. A sustainable alternative to review would be sustainable sites on the edge of existing settlements. Option C reviewed this approach to an extent, but focussed only on some initial options, but did not review opportunities that were submitted to the January 2019 Call for Sites Submission. Land South of Botley Road, Chesham is one such opportunity that has not been reviewed by the Local Authorities fully. Due to this plan is not positively prepared and fails to meet national policy as it is not supported by a thorough Sustainability Appraisal. In the Inspectors letter for the Wycombe Local Plan (11th July 2019) the consideration of alternatives is noted as being a true and proper exercise, paragraph 66 of the letter notes, “A number of alternative strategy options were considered as part of the Local Plan: Options Consultation (2014)34. This included the consideration of a range of different housing and employment growth and spatial development options. These options were assessed and refined in light of the findings of the SA process, public consultation, the Duty to Cooperate and the evidence contained in a range of studies including those in relation to the settlement hierarchy, housing and functional economic market areas, retail, viability, land supply, the Green Belt, the AONB, transport, green infrastructure and flood risk and water. I am content that the process of assessing options and all reasonable alternative strategies was comprehensive and undertaken in a positive and robust manner.” The consideration of alternatives given the Chiltern and South Bucks SA is not as robust as this approach. 3.13 Paragraph 3.5.3 provides an objective “To focus new development in accessible locations, reducing the need to travel and increasing opportunities for walking, cycling and use of passenger transport.” 3.14 By meeting a significant proportion of housing need outside of the Local Plan area there is an evitable contradiction against this objective. In particular, the town of Chesham is one of the larger settlements in the Local Plan area and limited levels of development proportionality are being allocated to the settlement; Chesham is well served by public transport including rail and has many opportunities for employment and education. The failure to fully examine development opportunities for this settlement, or at least safeguard land for future development compromises the ability to reduce the need to travel and increasing opportunities for walking, cycling and use of passenger transport. Land north of Botley Road, Chesham is a sustainable location where the

2277 objective of reducing the need to travel and increasing opportunities for walking and cycling and use of passenger transport can be realised. 3.15 Paragraph 3.5.7 details the objective to, “Establish a new, strengthened Green Belt boundary that will continue to meet national Green Belt purposes, prevent inappropriate development, secure opportunities for enhancement in accordance with national Green Belt objectives and, subject potentially to further consideration of the Green Belt boundary north of Slough in a review of the Plan, have boundaries that will endure beyond 2036.” Our comments previously submitted regarding the Green Belt review apply to this point. Further to this, updated guidance to the NPPG (22nd July 2019) direct plan makers to note potential improvements to Green Belt areas as compensatory measures; the guidance notes that, “strategic policy-making authorities should set out policies for compensatory improvements to the environmental quality and accessibility of the remaining Green Belt land. These may be informed by supporting evidence of landscape, biodiversity or recreational needs and opportunities including those set out in local strategies.” It is not clear how such matters have been considered in the preparation of the plan. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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.

2278 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 1224474 Full Name Taplow Parish Council ID 6546 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID 1224803 Full Name M Maund Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to Non-Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Policy DM CP1 and Policy DM CP2 would permit significant and even major Local Plan is/is not legally compliant, including references to development without the need for appropriate Transport Assessments or Travel relevant legislation, policies and/or regulations. Please be as precise Plans to accompany such proposals. This in turn would prevent the necessary and succinct as possible. measures to alleviate traffic impacts and to deliver sustainable transport to be put in place, used or monitored for effectiveness. Policy DM CP1 and Policy DM CP2 are therefore inconsistent with and arguably contrary to one of the principal and seminal strategic objectives of the PVLP (at paragraph 3.5.2) and these policies fail to meet the objectives and purposes of sustainable transport at paragraphs 7.0.1 and 7.0.2 of the 'Connected Places' section. PVLP does not meet the test of soundness at Paragraph 35 of the NPPF because Policy DM CP1 and Policy DM CP2 are NOT; a) positively prepared, because they fail to provide a strategy which, as a minimum, seeks to meet the area?s objectively assessed needs; b) justified, because it is not an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence; c) effective, because the thresholds for development that requires Transport Assessment and Travel Plans are too high and the sustainable transport measures needed are therefore unlikely to be delivered; d) consistent with national policy, because they do not enable the delivery of sustainable transport as an essential and defining component of sustainable development and are therefore contrary to the policies of the NPPF and not in compliance with the presumption in favour of sustainable development - for plan- making - at Paragraph 11. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local Our grounds of objection relate to points of detail in the appendices that will Plan is/is not sound, including references to relevant legislation, have potentially significant consequences when applied through the policies policies and/or regulations. Please be as precise and succinct as themselves and which in our view render the policies unsound currently. First, possible. of the various types of development and planning uses listed in Appendix CP1, Appendix CP2, Appendix CP3 and 7.9.12 there is no express reference to 'sports centres' or 'sports facilities' and all three of the related policies (Policy DM CP1,

2279 Policy DM CP2 and Policy DM CP3) could be interpreted as not applying the relevant threshold or standard to sports centres or sports facilities. This is an unacceptable omission. Whilst "swimming baths, skating rinks, gymnasiums or area for indoor or outdoor sports and recreations" fall within the D2 (Assembly and Leisure) planning use class, which therefore clearly includes 'sports centres' and 'sports facilities', none of the appendices in question refers solely or uniformly to use classes. Although they refer to 'leisure' development, it is by no means clear or unequivocal that sporting facilities are included in that description. On the contrary it may be argued that sports centres and sports facilities are not included, and in that case there are no threshold or standards given for sports centres or facilities. Secondly, the thresholds for triggering the need for Transport Assessment (TA) and Travel Plans (TP) in Appendix CP1 and Appendix CP2 are much, much too high. These high threshold are not explained, justified or reasoned, and they appear not to be based on any evidence but instead seem to be quite arbitrary. They clearly have little regard to the principle of sustainable development or to the strategic objectives of the Local Plan. Furthermore, for TAs under Policy DM CP1 and Appendix CP1 the terms 'Basic Assessment' and 'Detailed Assessment' are not clearly or consistently defined, and the circumstances in which one or other should apply are not clearly explained or justified. In our view, all development of any size and description should be accompanied by a basic transport assessment of the type described, and covering the four points set out, at paragraph 7.7.4. This is hardly an onerous requirement and for development of a type or scale within minimal transport impacts, a basic transport assessment will be commensurate with that and entirely straightforward. This should be reflected in a modified Policy DM CP1. Development of a type or scale with more significant potential transport impacts should be subject to a detailed transport assessment, the contents of which should either be prescribed in Appendix CP1 or by planning officers on a case-by-case basis. The need for a detailed transport assessment should, as a general rule, be triggered by much lower thresholds and this too should be reflected in Appendix CP1 and applied by Policy DM CP1. We maintain that all the applicable thresholds should be reduced to be only 25% of the current figures at paragraph 7.7.2. The same principles apply to Travel Plans. All planning applications should be accompanied by a basic travel plan, the content of which should be prescribed in Appendix CP2. Again, much lower thresholds - at 25% of the current figures at paragraph 7.8.1 - should be used to trigger the need for a detailed travel plan that should in all cases be required to cover the elements at paragraphs 7.8.6 to 7.8.10. The current, optional, requirements for the 'Contents' of a TP at paragraph 7.8.5 can be far too easily avoided. It is just as important and there is just the same plan-making responsibility to assess the transport implications of, and make plans for sustainable transport in relation to,five or ten new dwellings as it is for 20 or 40. The higher thresholds simply encourage developers to contrive to avoid what should be universal requirements if the underlying objectives of these policies are to stand any chance of being met. Thirdly, Policy DM CP2: Connected ? Pedestrian Routes and Cycleways should impose a substantive requirement to deliver direct, safe and secure pedestrian routes and cycleways where a proposed development exceeds the suggested lower thresholds for Appendix CP2, rather than merely requiring a Travel Plan to include measures for such. A detailed travel plan should set out how occupants of the development will be encouraged to use such facilities, but that can only happen if the infrastructure - the direct, safe and secure pedestrian routes and cycleways - is delivered as part of and conditional to the development. As currently drafted, Policy DM CP2 is a weak and ineffective policy that achieves very little and in its final paragraph adds nothing to the allocations policies it refers to. Fourthly, the 'Non-residential car parking standards' set out at paragraph 7.9.12 of Appendix CP3 should reflect a minimum standard in each case. Any variation due to exceptional circumstances should not reduce the optimum standard by more than 10%. This should be reflected in the notes to Appendix CP3. Paragraph 7.9.12 should have a parking standard based on GFA as a default and the GFA should be clearly stated that it includes floors on all levels.

2280 Lastly, paragraph 7.7.1 currently states that the Council can reduce the scope of the TA dependent upon unquantified circumstances, however guidelines are meaningless if they are not required to be adhered to and those affected by the development are rendered unable to contest it by the Council?s discretionary ability to reduce it, which should not be possible as this is unsound and thus requires changing to prevent circumstantial appraisal and reduction by the Council. Overall these policies and their supporting appendices are not well resolved but confused and lacking the focus and consistency of approach needed to meet the very important strategic objectives they should be contributing to. We are concerned that unless these policies are comprehensively modified they will fail in their purposes. Soundness mods - Are you proposing any modifications to Yes strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to We accept that there are different ways in which the wording of Appendix CP1 improve its alignment to this test of soundness. Please be as precise and and succinct as possible. Appendix CP2 may be modified to meet this objection but we propose that as a minimum; (i) the threshold figures be reduced to 25% of the current figures (eg. 4,000 sq m reduced to 1,000 sq m, 2,000 sq m reduced to 500 sq m, 40 residential units reduced to 10 etc.,) for detailed Transport Assessments and Travel Plans; (ii) that the different types of transport assessment and travel plan are defined by reference to the content required from each, and the circumstances in which they are required clearly set out; (iii) the introductory sentence of 7.7.2 is amended to reflect that all development should provide a basic TA in accordance with 7.7.4. Likewise, 7.8.1 should also be changed to say Travel Plans to be submitted with the planning application, and the Thresholds sentence should be amended to ?Proposals over the following thresholds will require a detailed TP:? (iv) 7.8.5 should have the wording ?should be considered? replaced with ?are required?. (v) Appendix CP1, Appendix CP2, Appendix CP3 and 7.9.12 to have an entry for 'sports facilities' under the various types of development and planning uses listed (vi) remove from 7.7.1 the sentence ?The Council may agree to the scope of the TA being reduced if the development proposal is in a suitable location and in line with planning policy? (vii) paragraph 7.9.12 should say that ?Each class parking standard is based on Gross Floor Area (GFA) as default, or by staff/consultation room where indicated, and the GFA includes floors on all levels.? Policy DM CP1 : Connected – Transport Assessments and Travel Plans A basic Transport Assessment and Travel Plan must be submitted with a planning application for any development of a type listed in Appendix CP1. Where a proposed development would exceed the thresholds set out in Appendix CP1, a detailed Transport Assessment must be submitted with a planning application. Transport Assessments must meet the requirements of Appendix CP1 and assess the multi-modal impacts of development proposals and demonstrate the measures which would be used to mitigate the development’s impact.

2281 A detailed Travel Plan with specific, measurable and achievable objectives, accompanied by a target and monitoring review procedure, must be submitted to the Council as part of planning applications for development that are likely to have significant transport implications in accordance with the requirements in Appendix CP2. Delivery and Servicing Management Plans are required to be submitted for proposals that may affect a Town or District Centre and also for sites in close proximity to residential areas. They should set out measures that will be introduced to minimise impacts, such as managing delivery times and vehicles. Policy DM CP2 - Connected – Pedestrian Routes and Cycleways Where a proposed development would exceed the thresholds set out in Appendix CP2, the planning application should include full details of the direct, safe and secure pedestrian routes and cycleways to be delivered as part of the development, and the Travel Plan submitted under Policy DM CP1 must include measures for encouraging and monitoring their use. All development on allocated sites must provide for safe and secure pedestrian routes and cycleways with appropriate lighting and cycle locking facilities. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1224485 Full Name Jardin Smith International Pte Ltd ID 6193

2282 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Other Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Jardin Smith International Pte Ltd Person ID 1224484 Full Name Spencer Copping Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local The Local Plan is not considered to be sound because the Council is unable to Plan is/is not sound, including references to relevant legislation, provide for its Objectively Assessed Need. The Council identifies that 5,687 homes policies and/or regulations. Please be as precise and succinct as will need to be provided by the Vale of Aylesbury Local Plan. The Council refer to possible. a Memorandum of Understanding signed by other Buckinghamshire authorities in July 2017. However, the Memorandum of Understanding does not automatically mean that the Council’s need can be re distributed and states the following: “The Councils agreed that that the housing need within the HMA would first fall to be met within each plan area based on the needs of each individual plan area, but if that was proven to be impossible then the resultant need would be met elsewhere within the ‘best fit’ HMA where it was reasonable to do so and was consistent with achieving sustainable development. Only if needs could not be met fully within the ‘best fit’ HMA would consideration then be given to needs being met outside of the HMA with authorities that have the next strongest functional links.” However, far from being impossible there are available sites in close proximity to urban areas within Chiltern and South Bucks that could accommodate their need. The draft Local Plan makes no reference to the term “impossible” with regard to finding sites to meet future housing need. We believe that sufficient land can be identified by additional Green Belt releases that would meet the requirements set out in the NPPF. The Council should be leaving no stone unturned in the search for additional housing sites to meet their objectively assessed need. The Council’s Green Belt Exceptional Circumstances Report (May 2019) identifies that due to the limited urban land available coupled with the fact that the District is Green Belt constrained and also partly covered by AONB that exceptional circumstances exist to release Green Belt land for development. It is considered that land to west of Amersham Road performs better against the criteria used by the Council for assessing sites that many of the Green Belt sites proposed to be released. We have supported the allocation of land to the south east of Gerrards Cross and shown that it can provide up to 150 dwellings. A copy of the report submitted for the Green Belt review identifies the site in question and provides a masterplan and is attached to this submission at Appendix 1. The masterplan provides up to 150 dwellings and also includes a considerable area of public open space in accordance with the latest requirements for the release of Green Belt land.

2283 The site is bounded to the north by the non-Green Belt settlement of Gerrards Cross and also by the A413. To the east and the south, the site is bounded by the M25 and by the A40. The northern portion of the western boundary is formed of a small block of woodland which is subject to a Tree Preservation Order (TPO) and as such would be protected and therefore arguably permanent and defensible. The indicative Masterplan has taken guidance from the surrounding area and also has had regards for the site constraints. In addition, specific regard has also been given to the issue of defensible boundaries as set out in more detail in the attached cover letter. The indicative masterplan shows a development buffer proposed along the western boundaries with additional planting proposed along the eastern boundary which not only reinforces the defensible boundaries, would also screen the proposal when viewed from the east and west, thereby reducing the visual impact. Access is proposed from Oxford Road to the south and Amersham Road to the north east to ensure that the site is well integrated and connect to the existing community. Gerrards Cross is considered to be a particularly sustainable town which benefits from a good level of service provision including the following: • Railway station • Schools • Cinema • Medical Centre • Community Centre • Sports/recreational facilities • Local Shops and Café/Restaurants • Regular Bus Service • Good links to surrounding settlements • Local businesses and employment opportunities. As set out above there are sites that perform well against Green Belt purposes, maintains strong defensible Green Belt boundaries, has limited impact on the purposes of GB. On balance the site would assist with the council’s search for available land to meet their housing need. Soundness mods - Are you proposing any modifications to Yes strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to As set out above we believe the Council should undertake a further Green Belt improve its alignment to this test of soundness. Please be as precise Review to identify additional land to meet the housing needs of the District. and succinct as possible. Policy SP LP1 identifies site allocations for 5200 homes. This policy should be amended to include additional land for housing within the District including land to the west of Amersham Road. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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.

2284 Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and 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 1224490 Full Name Global Infusion Group ID 6473 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID 1224489 Full Name Lydia Prince Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to Non-Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Not Legally compliant Local Plan is/is not legally compliant, including references to The Local Plan is not legally compliant as it does not have regard to national relevant legislation, policies and/or regulations. Please be as precise policy and is contrary to that set out within the National Planning Policy and succinct as possible. Framework and National Planning Practice Guidance. This is explored further within the submitted representation. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination

2285 Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1224099 Full Name Inland Homes ID 6543 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty 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 Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible.

2286 Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local Sections 3.4 & 3.5 Plan is/is not sound, including references to relevant legislation, Spatial Strategy and Housing Needs Apportionment policies and/or regulations. Please be as precise and succinct as possible. 4. Typically, to deliver such a vision, a local plan spatial strategy would seek to focus growth, where possible, at the area’s principal and most sustainable settlements, but with an appropriately decreasing proportion of growth down through the settlement hierarchy. Within Green Belt authorities such as Chiltern and South Bucks, the NPPF is clear (paragraph 138) that where exceptional circumstances to review the Green Belt boundary exist (as the Councils have demonstrably concluded there are) the need to promote sustainable patterns of development should be taken into account. Furthermore, the NPPF is also clear (paragraph 172) that the scale and extent of development within the AONB (a designation covering much of Chiltern District) should be limited and demonstrated to be in the public interest i.e. amongst other things, development limited to meeting identified housing needs at individual settlements. 5. Of concern, and despite the key urban areas / settlements being identified on the LP Key Diagram (3.3), the LP appears absent of any such spatial strategy. 6. By reference to LP paragraphs 5.1.7 to 5.1.16 and the Settlement Capacity Study (SCS), it is evident that the LP is effectively based on delivering a collection of ad-hoc potential housing supply sources1, as opposed to delivering a spatial strategy that meets individual community / settlement needs over the LP period. The approach within the LP consequentially will fail to deliver key elements of the LP vision and is clearly contrary to national policy. 7. The SCS outlines that the purpose of the study is to calculate the required housing numbers for each parish within Chiltern and South Bucks. The SCS draws together the various strands of the Councils’ assessed total housing supply potential from all sources on a parish by parish basis; and concludes there is total housing supply potential of between 11,165 and 11,458 dwellings over the Local Plan (LP) period (2016 to 2036). 10.As previously referred, it is evident that the LP is underpinned by a housing site-led strategy. Indeed the SCS confirms that the approach for determining the housing figure for each of the parish / Neighbourhood Plan areas focuses on housing land supply potential. While the SCS also infers that the sustainability of settlements has also been taken into account, it is not evident how settlement / parish area sustainability has, if at all, informed the parish / Neighbourhood Plan area figures or the LP strategy more generally. 11.In the absence of any clear spatial strategy within the LP, Table 1 below summarises what is understood to be the spatial distribution of housing growth proposed over the LP period. For comparative purposes each parish’s demographic-based proportion of the LP area is provided. The demographic proportion of the LP area is based on the proportion of the LP areas total population, household number and dwelling stock within each parish. The parishes with the highest percentage figures represent the parishes within which the highest proportion of the LP areas existing communities live i.e. the parishes with the greatest level of current and future housing need based on demographic-trend factors. Analysis of both short- and long-term demographic trends also indicate that the parish demographic-based proportion across the LP area has generally remained broadly constant. Further details of the analysis underpinning the demographic-based parish proportion is provided within Appendix 1 of these representations. 12. What is evident from Table 1 above, is that the Parish / Neighbourhood Plan area housing figure apportionment derived via the SCS, and which appear to underpin the LP, results in a number of instances where there is a meaningfully difference between planned housing growth over the LP period vis-à-vis the parish demographic apportionment. 13. Parishes such as Chesham, Amersham, Burnham, Great Missenden and Chalfont St Giles have a disproportionality lower proportion of the LP housing figure to the demographic-based proportion. The SCS and LP housing apportionment is therefore potentially spatially out-of-kilter with where current and future housing needs are arising over the LP period. 14. Given the above, the LP spatial strategy appears to be effectively a collection of strategic allocations (including Green Belt) and other housing supply sources, which have limited or no regard to the LP areas settlement hierarchy and the need to promote sustainable patterns of development; or other important factors such as meeting individual community’s demographic and housing needs over the LP period. Of very fundamental concern is that this approach taken by the Councils is broadly identical to that applied within the West of England Joint Spatial Strategy. A copy of the West of England Inspectors decision letter is included as Appendix 2. 15.Having reflected on the West of England Inspectors letter, we would strongly recommend that the Councils address the LPs spatial strategy flaw prior to submission to the Secretary of State. This is particularly pertinent given, as

2287 highlighted in the West of England, the flaw which goes to the heart of the soundness of the LP and cannot be rectified post submission via the Main Modifications process. 16.We consider that the Councils must, as a minimum, present evidence which demonstrates that the proposed LP housing delivery strategy has at least had regard to promoting sustainable patterns of development and where possible meets current and future housing needs within individual parishes and settlements across the LP area. 17.To assist the Councils we set out below what we consider to be the most appropriate parish housing apportionment based on meeting demographic-based housing needs. We encourage the Councils to test this apportionment given is represents a credible reasonable alternative option to meeting the LP areas housing requirement. Demographic-based Parish Housing Apportionment 18.The NPPF (paragraph 60) standard methodology housing figure for the LP area are currently based on the 2014-based household projections (HHPs) with a 40% (capped) uplift in response to market signals. 19.The 2014-based HHPs, are underpinned by the 2014-based sub-national population projections, and therefore provide a robust and credible demographic starting point assessment of housing need across the LP area. 20.To get a basic understanding of each parish’s likely demographic housing needs over the LP period, the 2014-based HHP starting point figure for the LP area (Stage 1 of the standard methodology) can be apportioned based on the demographic-based proportion of the LP area(Table 1 above and Appendix 1). The Parish apportionment based on meeting the 2014-based HPP household needs is set out within Table 2 below.21.The 2014-based HHP demographic housing needs apportionment is considered to provide the minimum housing need figure for each parish area. However, this demographic-based apportionment does not take into account the 40% market signals uplift as required (as a minimum) by national policy and guidance. The Parish apportionment based on 2014-based HHP demographic household needs with the (minimum) 40% upward adjustment is also set out within Table 2 below. Population Structure 30. An issue associated with an aging population trend is that elderly residents have a tendency to occupy larger family sized dwellings. This can act as a barrier to younger households being able to stay within, or move into an area. Unchecked this can lead to a spiral of decline as the resident population ceases to viably support existing community facilities such as pre-schools, primary schools, public houses and convenience stores. 31. Indeed, analysis of Census 2011 data (Table Reference: QS408) demonstrates that the settlement already has a significantly greater proportion of under-occupied dwellings i.e. large family-sized properties being occupied by single or couple households than the LP area as a whole (90% under-occupied household spaces within Hyde Heath compared to 78% within the wider LP area). 32. Housing size, analysis also highlights that Hyde Heath has a notably lower proportion of small (1-bed) properties (3% of the stock) and medium sized (3-bed) properties (20% of the stock) in comparison to the LP area as a whole (8% and 34% of the stock respectively). Conversely, Hyde Heath has a much greater proportion of large (4+ bed) properties (55% of the stock) compared to the LP area as a whole (365 of the stock). The settlements existing stock acts as a barrier to elderly residents being able downsize if they wish to continue living within the settlement, but also for young families requiring 3-bed properties (typically those households headed by the 25-39 age cohort). 33. Housing tenure and affordability are also particular housing need issues within Hyde Heath. According to Census 2011 data (Table Reference: KS402) the settlement has a limited range of housing tenure compared to the LP areas as a whole. The majority of housing stock is owner-occupied (81% compared to 75% for the LP area as a whole) and only 5% being private-rented (compared to 10% of the LP area as a whole). Where private market housing is less affordable, there is an increased reliance, and need for other forms of housing tenure, such as private-rent. As illustrated within Table 4 below, of concern is that analysis of housing affordability data (lower quartile house prices being the more affordable) shows that housing affordability within Hyde Heath has worsened over the past 10-years (in absolute and annual average terms) at a greater rate than the LP area. 34. The Hyde Heath example, which represents one of many settlements within the LP area, demonstrates the need for the LP to seek to positively to assess and then positively plan to meet as a minimum the apportioned 2014-based HHP need figures. For Hyde Heath this would be 70 dwellings between 2016 and 2036 (an average of 3.5 dwellings per annum over the LP period). 35. However, the worsening affordability issue is unlikely to be an isolated issue for Hyde Heath. In view of this we consider that the Councils should leave no stone unturned in proactively seeking to meet the standard methodology based

2288 figures for each settlement within the LP area before looking toward neighbouring authorities such as Aylesbury Vale. The standard methodology based figure for Hyde Heath would be 98 dwellings between 2016 and 2036 (an average of 5 dwellings per annum over the LP period). 36. Not only will the delivery of between at least 70 dwellings and 98 dwellings over the LP period at Hyde Heath assist with delivering the LP vision, it would also demonstrably be in the public interest and would contribute to a sustainable pattern of development given that this level of new housing could help to rebalance the settlements aging population by facilitating the delivery of new smaller (3-bed) family sized homes and housing more suited to elderly residents which collectively would meet the needs of young families but also facilitate down-sizing and the consequential release of the settlements existing large (4+ bed) and largely under-occupied housing stock. Furthermore, by helping to address the settlements demographic and housing need issues will also maintain and protect the settlements vitality and viability over the LP period – again a key aim of the LP Vision. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to Recommended Amendments improve its alignment to this test of soundness. Please be as precise 37. The LP should identify a spatial strategy that ‘secures balanced sustainable and succinct as possible. growth’ (in-line with paragraph 3.5.2 of the LP), which has regard to the respective projected housing needs of each settlement in apportioning housing growth. 38. As per our representations to Table LPb, the LP should meet a greater portion of its housing needs within the Plan area. To do so it will need to provide additional housing allocations (in accordance with our representations to Policy LP1), and these should be determined having regard to the HHPs for each settlement in the LP area. Whilst significant development should be focussed in accessible locations (in-line with NPPF paragraph 103), such as Amersham, regard should also be had to protecting the vitality of rural settlements (in accordance with NPPF paragraph 78), such as Hyde Heath (which contains a range of community facilities) Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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.

2289 Policy-level file upload - Please attach any supporting evidence

Person ID 1224499 Full Name Mr and Mrs and Mrs Jones and Jones and Vaux ID 4889 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Landowner Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID 1224498 Full Name Angela Banks Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to Legally Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Yes Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) The plan would be strengthened in terms of protecting the environment and below:You will need to say why this modification(s) will make the social health by including aims to cut pollution, both air pollutants and other Local Plan legally compliant/strengthen its legal compliance. Please man-made products known to be damaging the environment, such as non be as precise and succinct as possible. decompostable materials. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a No modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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

2290 PP 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 1224235 Full Name Oliver Bell ID 6841 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty 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 Plan-Level: Legally Compliant - Do you consider the Local Plan to Legally Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Please see representation to Policy SP BP5. Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Yes Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) Please see representation to Policy SP BP5. below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Yes Soundness? Soundness mods - Please give details of why you consider this Local Please see representation to Policy SP BP5. Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible.

2291 Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Not Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Please see representation to Policy SP BP5. Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1224518 Full Name Geltex Properties Limited ID 7223 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Other Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Geltex Properties Limited 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 Legally Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the 2.1 Supporting Text Section 3.4 Spatial Vision - considered legally compliant and Local Plan is/is not legally compliant, including references to sound.

2292 relevant legislation, policies and/or regulations. Please be as precise 2.2 The Spatial Vision of the Local Plan is strongly supported as it meets the and succinct as possible. requirements of sustainable development set out in the Framework. 2.3 In particular, support is given to the approach that acknowledges that the Local Plan must meet the development needs of the community with particular attention given, in relation to new homes, to those who find private market housing unaffordable. The approach also supports the Government's objective of significantly boosting the supply of homes and additionally provides for choice and opportunity in the general housing market. The Councils are right to reference both the continued importance of the Green Belt but also the need for a review of the boundary to ensure that it remains up-to-date and effective. The Councils may wish to consider additional explanatory text to make it clear that the Green Belt review is required to ensure that the Local Plan is meeting as much of the identified local need for development as possible. 2.4 The reference to working with adjacent local plan areas to ensure that the needs of the area are met in full is also welcomed. However, in doing so, the Councils should ensure that the planned development within the Local Plan area, particularly that arising as a result of Green Belt release, must realise their maximum potential to contribute to the identified need. In that way the unmet need accommodated by neighbouring Local Plan Authorities is minimised. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Yes Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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

2293 PP 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 1224577 Full Name Frontier Escapes Limited ID 6152 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID 1210964 Full Name Mrs Anna Gillings Organisation Details Director Turley Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local As you are of course aware, we act for Frontier Estates in respect of their interest Plan is/is not sound, including references to relevant legislation, in the eastern parcel of the site known as ‘Land Adjacent to Taplow Station’ (as policies and/or regulations. Please be as precise and succinct as per the red line plan below), and have previously provided our comments to the possible. emerging Chiltern and South Bucks Local Plan. Our full commentary in respect of the proposed site allocation (for land adjacent to Taplow Station – policy SP BP14) is set out in previous letters, which should be considered in full alongside these representations.

2294 Overall, we re-confirm our continued support for the removal of this site (known as ‘Land Adjacent to Taplow Station’) from the Green Belt, and allocation for redevelopment (under policy ref: SP BP14). The site – insofar as it reflects my client’s interests - is available for redevelopment and a draft masterplan has been prepared for the site that is considered both deliverable and viable in general terms. We also support in general terms policy DM LP7 of the draft Local Plan, which acknowledges the need for older persons and supported specialist care accommodation, and confirms that planning permission for such uses would be granted where the development is located with good access to local facilities and services. However, we consider that these two policies do not meet the tests of Soundness, whereby they are not wholly positively prepared, justified, effective or consistent with national policy (as noted with specific reference to the policies below). Accordingly, we set out below our detailed representations to the following: • Policy DM LP7 Homes – Older Persons, Specialist and Supported Living • Policy SP BP14 Building – Land Adjacent to Taplow Station Soundness mods - Are you proposing any modifications to No strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1225226 Full Name The Thorney Lane LLP ID 6593 Order 1 Number

2295 Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Agent/Developer Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: The Thorney Lane LLP Person ID 1210915 Full Name Mr Neil Rowley Organisation Details Director Savills Plan-Level: Legally Compliant - Do you consider the Local Plan to Non-Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the In line with the revised NPPF published in July 2018, viability assessments should Local Plan is/is not legally compliant, including references to be supported by appropriate relevant legislation, policies and/or regulations. Please be as precise available evidence informed by engagement with developers, landowners, and and succinct as possible. infrastructure and affordable housing providers. In plan making and decision making, viability helps strike a balance between the aspirations of developers and landowners, in terms of returns against risk. Viability assessments should therefore be used to analyse and justify planning obligations to ensure that Section 106 requirements do not make a scheme unviable, alongside ensuring that emerging allocated sites are considered viable. The RICS define financial appraisals for planning purposes as: ‘An objective financial viability test of the ability of a development project to meet its costs including the cost of planning obligations whilst ensuring an appropriate site value for the landowner and a market risk adjusted return to a developer in delivering a project.’ In simple terms, if the value generated by a proposed development is more than the costs of development, and the resultant residual land value of a proposed scheme is above an appropriate viability benchmark sum, it is viable to pursue such a scheme, and the scheme is likely to proceed. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local The western area of the subject site and access road comprises circa 40 acres of Plan is/is not sound, including references to relevant legislation, brownfield land, providing open policies and/or regulations. Please be as precise and succinct as and container storage areas as well as a number of light industrial units. possible. The storage areas and buildings provide a wide variety of options for potential tenants and let well in the market. We are advised by our clients that the total average rent roll for the full brownfield area in recent years, whilst fluctuating over time as tenancies are reviewed or replaced, averages at circa £4m per annum. Likely voids, management and maintenance costs would need to be assessed by any purchaser of the property to arrive at a view on the net income generated by the investment – we have assumed a deduction of 12.5%, based on an average industry wide assumption of between 10% and 15%, which our clients confirm is in line with their experience of operating and running this particular property. We have therefore assumed a net income generation of circa £3.5m per annum.

2296 Whilst the property lets well, the risk profile of the income generated could be said to be average, given firstly that a small number of 6 key tenants make up a significant proportion of the rental income from occupiers – so a failure in one of those tenants could give rise to a significant loss of income whilst the matter is resolved – and secondly that the remainder of the income is generated from circa 30 much smaller companies which could give rise to concerns over long term covenant strength. As such, and having discussed with colleagues in our National Industrial and Logistics team, we have applied an initial gross yield of 6.5% in perpetuity to the net income figure to generate a gross capital value of circa £54,850,000. Properties of this type and scale rarely trade in the market, however we are advised of a 15 acre open storage and light industrial site within Croydon with similar market characteristics to the subject area which transacted earlier this year at a similar initial gross yield. Allowing for purchaser costs at circa 6.8% (to allow for Stamp Duty Land Tax, solicitor fees etc.), generates a net capital value in the region of £51,100,000. Setting a suitable premium to be applied to the Existing Use Value of £51,100,000 to arrive at a relevant Benchmark Land Value is challenging – there is no direct guidance through the NPPF, PPG or industry guidance documents, other than that the premium must be a reasonable level to incentivise a prudent landowner to release their asset for development rather than hold as an investment or simply sell at Existing Use Value rather than seek planning permission for development. Any given landowner will take a different view on the level of premium required, dependant on circumstances, the established EUV, alternative development proposals or potential etc. Where a property has a relatively high EUV, such as this site, a precedent range of acceptable premium of circa 20 to 30% of the EUV has been established, through a number of appeal decisions where site specific viability submissions have been considered, as well evidence submitted to Examinations in Public of local plan policies relating to Community Infrastructure Levy and Affordable Housing, as well as full Local Plan Examinations. As a general rule, the higher the Existing Use Value, the lower the premium needs to be to incentivise a landowner to release. For the purposes of robustness we have adopted a premium of 25% above EUV, i.e. in the middle of the generally accepted range, generating a Benchmark Land Value in relation to the brownfield element of the site of circa £63,875,000. 6.2. Greenfield Land Establishing a Benchmark Land Value for Greenfield Land under the EUV+ approach is also challenging – greenfield land will have an intrinsically low initial EUV level, and guidance issued by the (then) Homes and Communities Agency in 2010 on Transparent Viability Assumptions suggested a multiplier of EUV of between 10 and 20. With bulk greenfield land values within the area, ignoring any hope value for development potential at circa £8,000 per acre, this approach would generate a BMV of between £80,000 and £160,000 per acre). A recent viability study undertaken by Dixon Searle Partnership in relation to Local Plan d CIL Viability Testing for Chiltern and South Bucks District Councils utilised benchmark land values for Greenfield Land of between £100,000 and £370,000 per hectare (£40,000 and £150,000 per acre). The DSP rightly notes that in general, the larger the

2297 quantum of land to be released, the lower the BLV (on a per acre or hectare basis) needs to be – the study cites the £40,000 per acre value in relation to “bulk greenfield land release”. For the purposes of robustness, we have assumed a BMV for the Greenfield Land of £100,000 per acre, applied to the circa 70 acres of Greenfield Land this generates a BMV of circa £7,000,000. 6.3. Combined The combined BMV for the Brownfield and Greenfield Land is therefore circa £70,875,000. 7.1. Information Provided We have relied upon the following information: Illustrative Master Plan documents including extract attached at Appendix A – Developable Plots, Densities and Areas Draft Local Plan policy wording, SP BP11 7.2. Appraisal Methodology In order to assess the viability of the development proposals, we have assumed a two stage “master developer” model. This approach assumes that the property, once a planning permission has been secured, is sold in its entirety to a master developer who then provides infrastructure, open space, drainage, utilities and services as well as covering all major S106 obligations (financial contributions and delivery of works). This allows the master developer to then sell on fully serviced parcels to the residential and commercial developer markets, in order to realise a return. We therefore have undertaken residual appraisals to arrive at a view on the value of serviced residential and office land, and used the results to inform a further residual appraisal to assess the value of the site to a Master Developer. To facilitate the required residual appraisals (firstly for serviced residential land and serviced commercial land, plus an overriding master developer appraisal) we have made the following assumptions. 7.3. Residential To make an assumption on the total residential accommodation that is likely to be built and sold within the development, we have made assumptions on an average unit size (Net Sales Area) within each of the four “density areas” shown within the masterplan documents (high, medium high, medium, low). Our Residential Gross Development Value calculator at Appendix B, shows how these average unit sizes are then applied to the areas and assumed densities of the developable plots to generate total accommodation. In summary, the total Net Sales Area of the anticipated accommodation of 1,200 dwellings is circa 99,600 sq M (1,070,000 sq ft), with each dwelling having an average unit size of 82 sq M or 885 sq ft. You will note that the master plan documentation suggests circa 1,200 dwellings would be achievable at the proposed densities – we acknowledge that the emerging policy allocates the land for “approximately 1,000 dwellings”. The actual number of dwellings achievable will be explored and tested during the planning application process. The master planners advising on the proposals confirm that the average unit size assumptions and the coverage levels which they generate for each density area (i.e. sq M per Hectare) are reasonable. If dwelling numbers were to reduce below the assumed 1,200 we have utilised for the purposes of our appraisal work, it is likely that average unit sizes would increase, resulting in a similar total Net Sales Area figure. Therefore we are confident that our approach to this particular assumption is robust, whether the final dwelling numbers are 1,000, 1,200 or somewhere in between. 7.4. Non Residential

2298 7.4.1 Office The emerging allocation allows for 12,000 sq M (circa 129,000 sq ft) of gross office accommodation. We have assumed a net to gross ratio of 85% to allow for communal areas, lobbies etc, resulting in a Net Lettable Area of circa 10,200 sq M (110,000 sq ft). 7.4.2 Shopping and ancillary The allocation also allows for up to 1,000 sq M of A1 to A5 space within a shopping parade, as well as ancillary development of A3, A4, C1 or D2 floor space to support the office development on site. At present it is uncertain whether the shopping parade and or ancillary development would sit within or alongside the 12,000 sq M of office accommodation, and in addition the occupier demand and thus value for such accommodation fluctuates more in general than office accommodation – as such for the purposes of our appraisal we have not included any cost or values associated with these proposals – clearly any value arising from this element of the scheme would improve rather than detract from the viability. 7.4.3 Train station car parking It is as yet uncertain as to the delivery and ongoing ownership / management structure of the proposed station car park – as such, we have allowed for the cost of delivery but not any value arising – should any value arise once the details become clearer, this would improve rather than detract from the viability of the development. 7.4.4 Community hub and school The masterplan documentation allows land provision and infrastructure to support delivery of a 1.5 form entry primary school. Costs of delivery are discussed later in this report. 7.4.5 Canal moorings The emerging allocation suggests retention of existing moorings or provision of a marina / canal basis. The master plan documentation as it stands allows for the former – for robustness of our appraisal we have assumed full cost of provision of the canal basin option (which exceeds the likely income generated from it) – retention of existing moorings would improve viability. 7.4.6 Open space Provision of open space as required by the emerging allocation has been included within the master plan proposals – we discuss cost of provision below. 7.4.7 Gypsy and Traveller pitches Provision of Gypsy and Traveller pitches within allocated residential and mixed use sites is a relatively new concept with some ambiguity on what is to be provided and what the ongoing management maintenance and ownership regime would be. As such for the purposes of our report we have assumed a worst case scenario, i.e. the cost of delivery of the pitches would fall to the developer (on site amenity block etc, rather than servicing to periphery only) with no ability extract value from the pitches. Having undertaken market research and discussing with our Residential Development Sales colleagues we have assumed the following average sales values for the purposes of our appraisal, which we are of the opinion are eminently achievable given the excellent location, with direct access to train and road links, proposed provision of a new primary school within the scheme as well as extensive high quality public open space. Current achievable sales values are likely to benefit further from the imminent opening of the Crossrail line. To put these assumptions in context:

2299 The recent Community Infrastructure CIL Viability Assessment undertaken by Dixon Searle Partnership stated average new build selling prices within South Bucks to be between £5,000 and £5,750 per sq M The same document stated that sales prices of between £4,500 and £4,750 per sq M are most relevant for Iver Village – we would comment that average unit sizes within the subject site are likely to be smaller than the average within the CIL VA given the relatively high density assumptions, which would drive values higher, and the subject site is more closely related to the markets within nearby Richings Park which also benefits from direct access to the rail station We have undertaken research into the nearest competitor markets (comparing sale prices from the last 12 months secured from Land Registry with sizing taken from EPC data), showing the following average £ per sq ft sales figures: 8.2. Residential – Affordable Housing The emerging Local Plan requires provision of affordable housing on allocated sites at 40%, with a minimum of 10% of the affordable dwellings being provided as shared ownership, a minimum of 25% of the affordable dwellings being provided as Social Rented tenure and the remainder being Affordable Rented. With uncertainty over the tenure mix until this matter is negotiated and agreed through a S106 agreement, we have assumed a deduction of 40% from market value to reflect the value a Registered Provider would pay a housebuilder to take built affordable housing stock. This is at the upper end of the range of discount to open market value we would expect to see, dependant on the assumed affordable housing tenure mix. 8.3. Residential – Blended Open Market and Affordable Housing Given that at this stage, there is limited certainty on the likely mix of affordable housing to be provided in terms of bedroom numbers / sizing, we have assumed that 40% of the accommodation within any given Density Area would be delivered as affordable rather than open market housing. It could be argued that, once the mix is determined, it is likely that on average an affordable dwelling would be smaller than an average open market dwelling – as such, we have made a robust assumption – once mix is determined it is likely that the scheme will become more rather than less viable. 8.4. Office We have discussed the likely market demand from occupiers and investors for the proposed office accommodation with our South East Office Agency team. There is limited large scale office accommodation in the surrounding area, and we anticipate good demand for office space given this lack of local stock, good rail links, imminent opening of the Crossrail line which Iver station will be linked to, and significant new housing proposed in the immediate area. Analysis of the Slough office leasing market, the nearest local comparator, indicates average rental levels on new or recent build stock to be around £32 per sq ft, with prime rents at £36 per sq ft. We have allowed for a comparable average rent of £32 per sq ft. Transactional evidence is less readily available, however a small number of recent investment purchases, again within Slough, show yields ranging between 5% and 6%. We have applied a yield of 5.75% and allowed for an 18 month rent free period as an incentive. 8.5. Miscellaneous

2300 For the purposes of our appraisal, we have assumed that the master developer acquiring the property once planning permission is granted secures the benefit of: Rent passing – we have assumed that the net annual receipt of circa £3.5m will be retained by the master developer for the first year, winding down over the next two years, with income totalling £7.5m over that period. This could be improved dependant on development phasing etc. Canal basin – we have assumed that circa 20 berths are provided with a capital value of circa £500,000 (£25,000 per berth). 9. Appraisal Assumptions – Costs We have allowed for the following key assumptions – the assumptions are informed by our experience and knowledge of likely costs informed by our associated agency and valuation work, and advice from the wider consultant team where required. Copies of our appraisal summaries are included at Appendix C which provide further information on our assumptions. We have used a residual appraisal tool called ARGUS Developer which is used widely within the industry by surveyors, housebuilders and developers alike. We would be happy to discuss further as and when required. As a general comment you will note that we have assumed lower quartile BCIS figures for baseline build costs. This is in line with our wider experience of selling, valuing and consulting on residential and office development land – and in particular in negotiating land prices under option agreements where the acquiring party and landowner must agree key inputs to residual land appraisals, or take the matter to expert determination if the parties cannot agree. For valuation, agency and option negotiating work, on larger scale projects such as this we almost invariably see agreed or proposed baseline build costs at or around the BCIS Lower Quartile level as the larger developers benefit from economies of scale, buying power and in house capability compared to smaller developers, whose significantly higher build cost rates make up a major part of the BCIS data set and thus skew the median average upwards. Our Master Developer Appraisal assumes that the purchasing Master Developer would secure reserved matters permission for strategic infrastructure, begin delivery of this, and then sell serviced residential and office land to the relevant developer markets. This would include the site access junction, station car park and relief road to theThe Master Developer would also deal with key S106 obligations and financial contributions, leaving the housebuilder to deal with delivery of affordable housing only. We have assumed that the serviced office land will be sold in a single transaction once the initial infrastructure is available, circa 12 months after construction of the infrastructure begins. We have assumed that the Master Developer would provide four serviced residential land parcels to the market, of approximately equal size - the first being sold circa 12 months after the construction of initial infrastructure begins and then a further land sale occurring at 24, 36 and 48 months. This ties in with our assumptions on dwelling delivery rates and number of housebuilder outlets – see comments on delivery later within this report. Our appraisals are attached at Appendix C. The land values generated by the appraisals for serviced residential and office land are: Serviced Residential Land Parcel (1 of 4): £36,916,000 Total Value of Serviced Residential Land: £147,664,000 Serviced Office Land Parcel (1 only): £13,337,000

2301 These values are then fed into the master developer residual appraisal to generate the price expected to be paid for the entire property, with the benefit of planning permission: Total site value, Master Developer Appraisal: £90,930,000 We have appraised the proposed draft illustrative masterplan on the above assumptions in order to understand the economics and viability the proposal. The Benchmark Land Value against which the scheme should be assessed is shown to be in the region of £70,875,000. Our financial appraisal of the proposed development, assuming the land were sold in bulk to a Master Developer once planning permission is secured, demonstrates a land value in the region of £90,930,000 could be achieved. There is a demonstrable, positive “buffer” between the Benchmark Land Value of circa £20,000,000. Therefore the proposed scheme is considered as financially viable, able to meet local planning policy requirements in terms of affordable housing and other community benefits, whilst also providing a suitable return for the landowners to release the land and the developers who will build out the new accommodation. This is a margin which may grow or decrease as more detail becomes available regarding both the scheme itself and any additional costs or values which will be applicable. Additional value would improve viability, and increase the margin/buffer – on the other hand additional costs would adversely affect viability, narrowing the gap between the BLV and Residual Land Value once planning permission is secured. The key unknown cost elements at this stage are: Off site utility network upgrades – utility providers are required to provide for new development and secure payment for upgrades through connection charges (which are allowed for within our build cost assumptions) – however in some cases developers will need to pay for network upgrades to ensure that they are delivered within a timely manner – no such upgrade requirements have currently been identified Off site highways improvements – we understand that currently no significant off site highways works will be required to mitigate the impact of the scheme, whilst the access junction and relief road (which provides benefit to the wider area) have already been allowed for On site ground conditions and contamination – the scheme will require remediation of a former landfill site, no detail on the likely cost is at yet available We would comment that the £20,000,000 buffer between the BLV and RLV is such that this provides protection in the event that significant further costs are identified, with the scheme remaining financially viable and therefore able to be delivered. Additionally, there is scope for uplift in the RLV given: We have made no allowance for value arising from retail and ancillary development within the mixed use area close to the station No allowance made for value arising from rail station parking No allowance for value arising from the Gypsy and Traveller We would also comment that alternative delivery/disposal strategies are open to the landowner to increase their return – acting as master developer for example, or working with an infrastructure provider, taking all or some of the master developer profit element – this would increase further the buffer between BLV and the landowner return, making the scheme even more viable. We would however add a note of caution – the scheme has been appraised utilising the latest understanding of likely

2302 obligations placed on the developer to deliver community and other benefits, through discussions between the landowner, their representatives and the council. The £20,000,000 buffer identified within this report provides the comfort required that the scheme is able to absorb as yet unknown costs. Any additional community benefit requirements sought by the LPA through the planning applications process could therefore jeopardise the viability of the scheme. To put into wider context, it is worth noting that, whilst the £20,000,000 buffer represents an additional circa 28% on top of the Benchmark Land Value, it equates to circa 4% of the combined Gross Development Value of the residential and office accommodation (£485,000,000) – and circa 13% of the total costs allowed for within the Master Developer appraisal. 12.0 DELIVERY RATES We are instructed to consider and comment on the likelihood that the housing element of the scheme will be delivered within the lifetime of the emerging Local Plan i.e. by March 2036, if an allocation and subsequent planning permission is secured. As noted earlier, the emerging masterplan notes that approximately 1,200 dwellings may be achievable once further detailed assessment work is completed. However, given the draft allocation policy comments on approximately 1,000 dwellings, and the local authority’s housing delivery trajectory will respond to this, for the purposes of this section of the report we have focused on the likelihood of delivery of 1,000 dwellings within the plan period. There are a number of delivery routes available to the landowners – for the purposes of our report we have assumed (as with the viability appraisals set out earlier) that the land would be sold in bulk to a Master Developer once an allocation is secured and a planning permission granted. This effectively sets out the “worst case scenario”, as the sale process to a Master Developer could be excluded from the process and the timescale truncated (i.e. if the landowners acted as Master Developer, or if the site was sold to a single developer or consortium of developers who would directly deliver both infrastructure and housing and office space). There are two key elements to consider The planning application timescales from examination of the Plan until first housing completions Housing delivery rates from this point onwards 12.1. Lead In to First Housing Completions The latest Local Development Scheme issued by the LPA in April 2019 anticipated adoption of the Local Plan by the end of 2020. On this basis, we would suggest the following indicative timeframe is achievable: Adoption of Local Plan Dec 2020 Submission of site wide application March 2021 Resolution to Grant Dec 2021 Issue of Planning Permission / S106 Dec 2021 Sale of site to Master Developer Dec 2022 Submission of infrastructure application June 2023 Issue of infrastructure permission Dec 2023 Master Developer begins infrastructure June 2024 Sale of first serviced residential parcel Dec 2024 First housing completions April 2026 Marketing of the complete site could commence prior to issue of the site wide planning permission, provided enough detail on draft conditions and S106 obligations is available once Resolution to Grant is secured – so there is scope for contraction of this timeframe.

2303 The gap between sale of first serviced residential parcel in Dec 2024 and first housing completions in April 2026 (16 months) allows for preparation of the housebuilder’s reserved matters application, determination of the application, mobilisation and circa 6 months of construction. There is scope here also for contraction of timeframe given a selected housebuilder will usually start working up their reserved matters application alongside their due diligence leading into acquiring a serviced land parcel. 12.2. Housing Delivery Rates On the basis of the above, there is a 10 year period between first completions and the end of the plan period. Therefore an average delivery rate of circa 100 dwellings per year is required across the site – circa 60 open market dwellings and 40 affordable dwellings, assuming affordable housing is delivered alongside open market housing (as will likely be required under the S106 agreement) and a 40% affordable housing requirement. Large scale sites such as this will normally comprise a number of housebuilders working alongside each other and delivering market housing from a number of outlets, as well as delivering affordable housing for their selected Registered Providers. Based on our experience elsewhere in the local area, housebuilders will generally build open market homes at the same rate they anticipate being able to sell them into the market, to avoid holding excessive amounts of standing stock, which adversely impacts on their cash flow. Discussions with key housebuilders operating in the south east market indicate that in good locations such as this, they would anticipate sales in the region of 3 to 4 dwellings per month from each outlet – equating to 36 to 48 open market dwellings per annum. A single branded housebuilder will deliver normally from one outlet (unless they are delivering radically different product across their land parcel) – whilst some dual branded housebuilders (for example the Barratt Group which sells under the Barratt and David Wilson brands) will be able to run two outlets at any given time. Affordable housing delivery will normally run alongside the open market housing, providing there is appetite in the Registered Provider sector to take the built stock – with average earnings to house price ratio in South Bucks for 2018 sitting at 18.4 to 1 (ONS data), the seventh highest Local Authority Area in the UK, affordability is very low and therefore we anticipate strong demand from Registered Providers to secure stock in this location. With an extreme lack of affordability in the local area, a large number of Registered Providers would be available to absorb this stock alongside the open market housing. It is worth noting that affordability is a key indicator of market strength for open market housing as well – prices are kept at relative high levels due to strong demand and or lack of stock. On this basis, and linking with the assumptions made within our Master Developer appraisal with a serviced residential land parcel being released each year, we have assumed the following delivery trajectory, based on each housebuilder delivering 40 open market units and 27 affordable units per year: Our assumptions generate a minimum annual delivery rate of 67 dwellings (40 open market) from one outlet, and a maximum of 250 (150 open market) from four outlets – with an annualised average of 143 dwellings (86 open market), which would represent an average of 2.14 outlets delivering units at any given time. We are confident that, given the spread of density areas across the site (equating to very different housing product

2304 in different areas, appealing to different sectors of the market), and the ability to phase and deliver infrastructure in order to release multiple land areas alongside each other, a maximum of four outlets delivering housing at any one time is very sustainable as housebuilders will not be competing for similar buyers in a limited market at the same time. In addition there is increasing appetite from institutional and private investors to deliver large scale, mixed housing sites as Build to Rent, with the properties being retained by the developer and let out in perpetuity – whilst to date this model has largely been applied to apartment schemes in urban centres, there are a number of investors looking to deliver apartment schemes in key well connected urban fringe locations, and follow the trend for “single family rented housing investment” in the United States, where the two key players, Invitation Homes and American Homes For Rent, own and manage 200,000 dwellings. With a strong rental market supported by low affordability rates and good rail connections, it is highly possible that one or more land sales could be made to such investors – as the delivery of private rented housing stock does not conflict with other housebuilders on site offering homes for sale, this gives the opportunity to have an additional outlet running alongside the standard housebuilders, enhancing delivery rates. You will note that our assumptions on delivery rates result in a 3 year “buffer” between the anticipated delivery of the final dwellings (March 2033) and the end of the Plan period (March 2026). This margin allows significant confidence that the scheme can deliver the required 1,000 dwellings before the end of the Plan period – even if delivery rates slip behind the assumptions set out above. In addition to our assessment of the site, informed views on likely take up rates and analysis of collated evidence, we have also considered the evidence presented in a national study of housing delivery published by Nathaniel Lichfield & Partners (NLP), entitled Start to Finish; How Quickly do Large-Scale Housing Sites Deliver? (November 2016). The report makes the following key conclusions regarding housing delivery: Stronger local markets have higher delivery rates; Affordable housing supports higher rates of delivery (circa 40% increase for large sites delivering 30%+ affordable housing compared to those delivering 10%-19%); Large scale greenfield sites come forward more quickly than large scale brownfield sites The average annual build out rate for sites of 1,000-1,499 is 122 units (market and affordable housing combined) (see Figure 8, page 13 of NLP 2016) Addressing each point in turn in relation to the subject site: The site benefits from a number of factors which will lead to strong demand for new homes – access to main line rail services, key motorway road links, a new Primary School and job opportunities generated within the proposed office, retail and leisure accommodation which form a key element of the development. An affordability ratio within the LPA area of more than 18 times average salary supports our confidence in a strong market and resultant take up rates. The scheme proposes 40% affordable housing to be provided which we would expect to accelerate delivery rates significantly compared to an average site Circa 70% of the site is greenfield Even if we ignore the strong local market conditions which would mean delivery rates will be higher than an

2305 average site considered within the NLP study – the delivery rate shown within the NLP study to be an average for a site of this scale would mean full delivery would occur circa Summer 2034, leaving a circa 1.75 year buffer until the end of the Plan period 14. Conclusion – Deliverability The project has support from both the Local Authority and the landowners, and a clear plan is in place to lead in to first housing completions from early in 2026. Given the required minimum delivery rate from 2026 onwards falls well below the anticipated delivery rate – which is supported by example delivery rates on other regional example sites as well as national scale research - we are confident that Land North of Iver Station, Iver will deliver 1,000 dwellings or more in full by the end of the Plan period. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1224537 Full Name Holmer Green Village Society ID 6308 Order 1

2306 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID 1224536 Full Name David Holmes Organisation Details Associate Director Plan-Level: Legally Compliant - Do you consider the Local Plan to Non-Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the 2. Legal Compliance Local Plan is/is not legally compliant, including references to Legal compliance relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. 2.1 We do not consider the Draft Plan to be legally compliant, insofar as it fails to comply with the requirements of the National Planning Policy Framework. Specifically, the Plan does not meet the requirements of paragraph 134, which sets out the purpose of the Green Belt: “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 land” [Authors Emphasis] 2.2 The site falls within Holmer Green, located within the Council’s jurisdiction. The land located to the West of the site falls within Wycombe District Council and falls within the settlement of Hazelmere. The settlements of Holmer Green and Hazlemere are different, they have independent Parish Council’s and functions as separate settlements. The land to the West has recently been allocated by Wycombe District Council for 350 new dwellings. In effect the allocation of this land, when considered against proposed allocation SP BP3 will lead to the merging of the two settlements which raises a direct conflict with Paragraph 134 (b) which is explicit in its sentiments that one fundamental aim of the Green Belt it’s to prevent neighbouring towns merging into one another. The allocation will result in Holmer Green being indiscernible from Hazlemere. The Oxford English Dictionary defines ‘merging’ as the act of combining or joining together. This allocation will essentially join the two settlements, which is in direct conflict with the above. 2.3 The issue is exacerbated when one considers the lack of engagement Policy SP BP3 has with paragraph 134 (b) of the National Planning Policy Framework, insofar as it will lead to the merging of two distinct settlements. The Council have failed to identify a ‘developable area’ and the need to maintain separation between the two settlements, which is a fundamental shortcoming of the proposed allocation. It would appear the Council, in their assessment of capacity have suggested the entirety of the site should be developed, resulting in a density of 20 dwellings per hectare. When one considers the need for a buffer between the developments, which is incorporated into the Wycombe District Council site, the density would have to substantially increase to accommodate this level of residential accommodation. Again, this is further exacerbated when the need for a new school, retention and enhancement of the Travelling Show people site and retention of the Orchard is accounted for, which would suggest a developable area of circa 9ha, resulting of a density of circa 40 dwellings per hectare to result in the number of dwellings proposed on this site. This would result in a development which is out of surrounding with the general townscape of Holmer Green, which typically returns a density of 20-30 dwellings per hectare. 2.4 The only remedy available to ensure the plan is found legally compliant is to remove allocation SP BP3 from the Plan. It is noted that this will create a shortfall in housing delivery. However, it is considered that there are more suitable sites available that will not result in the merging of settlements, which is a key requirement of the Green Belt. 2.4 It is also considered that the evidence base, which seeks to underpin the proposed release of the Green Belt is fundamentally flawed, which will be considered under the assessment of Soundness. Small Sites Requirement

2307 2.5 Paragraph 68 of the National Planning Policy Framework states: Small and medium sized sites can make an important contribution to meeting the housing requirement of an area and are often built-out relatively quickly. In contrast the larger sites upon which the Council is disproportionately reliant are habitually liable to suffer delays in the rate of build out- thus exacerbating the already established deficiency in supply which there is an imperative to redress in the first 5 years of the Plan period rather than over the whole period. It is for these reasons and so as to promote the development of a good mix of sites that local planning authorities should: a) identify, through the development plan and brownfield registers, land to accommodate at least 10% of their housing requirement on sites no larger than one hectare; unless it can be shown, through the preparation of relevant plan policies, that there are strong reasons why this 10% target cannot be achieved; b) use tools such as area-wide design assessments and Local Development Orders to help bring small and medium sized sites forward; c) support the development of windfall sites through their policies and decisions – giving great weight to the benefits of using suitable sites within existing settlements for homes; and d) work with developers to encourage the sub-division of large sites where this could help to speed up the delivery of homes. 2.6 Currently the plan does not allocate any ‘small’ sites for housing and as such does not comply with paragraph 68 of the Framework. It is considered that the removal of the Site SP BP3 presents the Council the opportunity to satisfy paragraph 68 of the National Planning Policy Framework as the removal of some 350 dwellings from the supply, could be captured on smaller sites. This is considered to overcome two ‘legal flaws’ with the plan and will ensure that the plan does not lead to coalescence or indeed fall short of meeting the ‘small’ site requirement. Conclusion on Legal Compliance 2.7 The Plan, in its current form fundamentally conflicts with the National Planning Policy Framework and therefore cannot remotely be considered to be legally compliant. The Council must rectify all of the plans deficiencies before submitting it for examination. In particular it must remove policy SP BP3 from the emerging plan and allocated ‘small’ sites for housing. Small Sites Requirement 2.1 Paragraph 68 of the National Planning Policy Framework states: Small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly. In contrast the larger sites upon which the Council is disproportionately reliant are habitually liable to suffer delays in the rate of build out- thus exacerbating the already established deficiency in supply which there is an imperative to redress in the first 5 years of the Plan period rather than over the whole period. It is for these reasons and so as to promote the development of a good mix of sites that local planning authorities should: a) identify, through the development plan and brownfield registers, land to accommodate at least 10% of their housing requirement on sites no larger than one hectare; unless it can be shown, through the preparation of relevant plan policies, that there are strong reasons why this 10% target cannot be achieved; b) use tools such as area-wide design assessments and Local Development Orders to help bring small and medium sized sites forward; c) support the development of windfall sites through their policies and decisions – giving great weight to the benefits of using suitable sites within existing settlements for homes; and d) work with developers to encourage the sub-division of large sites where this could help to speed up the delivery of homes. 2.2 The Council have not allocated small sites of under 1ha for residential development in the emerging Local Plan. This conflicts with Paragraph 68 of the Framework. Some 382 dwellings have been accounted for, within the brownfield land register, on small sites. However, these all benefit from Planning Permission and are likely to come forward before examination of the plan or have already done so. This falls short of the requirement to provide 10% of the housing requirement on small sites. 2.3 To become legally compliant the Council must seek to allocate smalls sites, such as the one at Union Point, for residential development or explain the ‘strong reasons’ why 10% of the housing requirement cannot be achieved. Failure to identify a suitable supply of housing sites 2.4 The second legal failing of the plan also rests in compliance with paragraph 11(b) of the Framework. The Council have sought to export some 5,687 dwellings, which is over 37% of the total housing requirement (based on the figure forwarded by the plan, not the corrected figure as detailed in the preceding) to Aylesbury Vale. Under Paragraph 11(b)(ii) of the Framework, the Council can seek to not meet the full housing needs where “any adverse impacts of doing

2308 so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole”. 2.5 The Council have been presented with a number of suggested housing sites to accommodate the District’s housing needs. In assessment of these sites the Council have not demonstrated that allocating further sites for residential development would result in adverse impacts that would significantly and demonstrably outweigh the benefits, before looking to Aylesbury Vale District Council (a District that does not share a Boundary with South Bucks) to accommodate un-met needs. Paragraph 11 is explicit in its sentiments that the Council must look within its own boundaries first, before exporting need elsewhere and must do so punctiliously, because for receiving LPAs it is only unmet needs that ‘cannot be met within (their) neighbouring (LPA) areas’ that they have any obligation to absorb. 2.8 To rectify this conflict with National Planning Policy, and produce a legally compliant plan, the Council must allocate the Union Point site (and others) for residential redevelopment, whilst also submitting a clear methodology / assessment of impact and demonstrate that it has been used scrupulously to satisfy the requirement for objective and consistent assessment of all sites submitted to the Council. Conclusion on Legal Compliance 2.09 The Plan, in its current form conflicts with the National Planning Policy Framework and therefore cannot be considered to be legally compliant. The Council must rectify all of the plans deficiencies before submitting it for examination. In particular it must release allocate further small sites for housing, including the site forwarded by this submission. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local 3. Soundness Plan is/is not sound, including references to relevant legislation, 3.1 The Plan is not considered to be sound on the following basis. The Plan does policies and/or regulations. Please be as precise and succinct as not seek to meet, as a minimum, the OAN of the joint Councils, falling some possible. 5000 dwellings short of the actual figures required. Failing to meet this requirement renders the plan unsound. To overcome this the Council must plan for the full OAN. 3.2 Furthermore, the Council are currently planning to meet the exact purported OAN figure, without any contingency. Seeking to meet the exact housing requirements, without a contingency, poses a significant risk to the success of the plan. 4. Conclusions 4.1 The Council appear to have ‘planned to fail’ with their overall approach to housing supply which is underpinned by inaccurate data. The plan, in its current form, will not meet the statutory tests and is demonstrably unsound. 4.2 It is apparent that there are other sites that are deliverable within the first five years of the Plan Period that would assist in meeting the shortfall generated by the under delivery. The Union Point Site does provide a sustainable solution, which would make a significant contribution towards meeting the Council’s Housing needs. The Council must include this, and other sites, to fully meet the housing needs of the District. 6.3 The Plan, in its current form, is not legally compliant and not sound. The Council must reconsider the Emerging Plan, in light of this representation, to achieve submission of a plan capable of progressing through the examination process without being derailed as a result of deficiencies that are entirely capable of being remedied before submission for examination, providing past preconceptions and closed-mindedness are dispensed with. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any

2309 non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1225279 Full Name Mary Blake-Pauley ID 6649 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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

2310 Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local 13 .1 It cannot be right that the South Buckinghamshire district, which is of 87 Plan is/is not sound, including references to relevant legislation, .6% Green Belt policies and/or regulations. Please be as precise and succinct as a possible. and the smallest district in the county, has been targeted in this way. Regrding Policy SP BP9, it is hard to imagine how any mitigation for the potential loss to the Beaconsfield community of this prized land could be brought about given that the remainder of the district is built on and the only other land available is Green Belt. Logic dictates that there would be a net loss to the Green Belt which is contrary to national planning policy guidelines. Compared to the 95% non-Green Belt Vale of Aylesbury district within the county which is some 6½ times larger, the amount of development proposed for Beaconsfield is treble that for its largest near neighbour. That there is a need for housing is not in dispute but previously developed residential and commercial land plus non-Green Belt land should be considered before contemplating the removal of Green Belt status from swathes of open countryside. 13.2 Added to that, there is the potential for substantial profit to be made from the high land r value of the proposed Beaconsfield site. Affordable housing will not be deliveable in meaningful numbers. The development (304 homes subject to a S106 planning agreement) proposed for previously built-on land within the Green Belt area of Wilton Park will be more than enough for the town to absorb. One is left with the impression that the developers are in control, having had the intention to build on the land from the outset with the evidence being customised for the removal of the site from Green Belt land. 13.3 There is no justification whatsoever for the unprecedented scale of what is proposed in Policy SP BP9. Viewed together with the other Policies SP EP3, SP EP4, SP PPl and OM PP 1, if all were to be delivered, the close proximity of each affected area with each other would result in a profoundly negative transformation of the beautiful landscape in the area around Beaconsfield. Years of disruption with incessant building works, road works, heavy lo1Ties and increased traffic leading to further unacceptable levels of traffic congestion, noise and air pollution and the resulting scarring of the Green Belt would deliver a massive body blow to local communities. Loss of Green Belt, as proposed, will destroy habitats, affect health, pollute the air we breathe and contribute to climate change. The outlook, were the Plan to be agreed, would be truly bleak. This is not okay. It is my ardent hope that the proposed development(s) outlined in the foregoing commentary will not be given planning consent. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible.

2311 Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1225340 Full Name Christopher Kelly ID 6655 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 No Soundness?

2312 Soundness mods - Please give details of why you consider this Local As the Local Plan significantly underestimates the actual level of housing required Plan is/is not sound, including references to relevant legislation, across Chiltern and South bucks and by doing so is failing to adequately plan for policies and/or regulations. Please be as precise and succinct as the next 20 years it is unsound. possible. Due to this, there are flaws in the calculation of the five-year housing land supply and this makes the Local Plan unsound. It also fails to take into account unmet housing need from Slough. This Local Plan does not properly recognise that Chiltern and South Bucks are two of the unaffordable authorities for housing in England and a housing uplift is needed. Soundness mods - Are you proposing any modifications to Yes strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to The Local Plan should increase the housing numbers to adequately provide the improve its alignment to this test of soundness. Please be as precise local need within Chiltern and South Bucks, the increased demand from the and succinct as possible. expansion of Heathrow and Slough’s unmet housing need. The Local Plan needs to be modified to increase the number of allocated sites. They should be provide in towns within the two districts where there are larger centres that can cope with increased housing and do not have the traffic problems that exist in Iver. This congestion can only deteriorate with the Heathrow expansion and an allocation for Slough’s unmet housing need. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Not Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the This Local Plan does not take into account Slough’s unmet housing need. Local Plan has met/not met the requirements of the Duty to It states that as no formal requests have been received to meet any unmet Co-operate.Please be as precise and succinct as possible. housing needs of neighbouring areas, the housing strategy of the Local Plan does not require to include the unmet housing need of a neighbour. However, Chiltern and South Bucks District Councils are collaborating with Windsor and Maidenhead and Slough on The Wider Area Growth Study (WAGS) to support future plan making and Duty-to-Co-operate between authorities. The purpose of the study is to identify the potential locations that could accommodate the future housing need growth of the Slough, Windsor and Maidenhead core in line with national policy. This requires that, where a local planning authority cannot meet its housing need in its own area, the resulting unmet need should be accommodated in “neighbouring area…Where it is practical to do so and is consistent with achieving sustainable development.” In short, the study aims to identify alternative locations for people who would normally expect to live in the core places but cannot do so, due to the lack of new housing. The recommendations of the Wags Part 1 are that Slough’s housing need are best met as close to Slough as possible. There would seem to be exceptional circumstances for the release of Green Belt land for some of Slough’s unmet housing need – and it SHOULD be included in this Local Plan. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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.

2313 PAa - Please specify as precisely and 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 1225348 Full Name Mrs Nicola Barrow ID 6663 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 No Soundness? Soundness mods - Please give details of why you consider this Local The whole Local Plan is full of platitudes and is so unsound. Plan is/is not sound, including references to relevant legislation, The Government’s National Planning Policy Framework in February 2019 stated: policies and/or regulations. Please be as precise and succinct as “the planning system should genuinely plan-led. Succinct and up to date plans possible. should provide a positive version for the future of each area, a framework for addressing housing needs and other economic, social and environmental priorities; and a platforms; and a platform for local people to shape their surroundings.” This Local Plan has been so long in its evolution that it does not fully take into account the Heathrow expansion that South Bucks District Council agreed to support last year. Work on this expansion will begin in 18 months and will have very serious implications for South Bucks. Only a few paragraphs in the Local Plan mention the Heathrow expansion, almost as if it is a sideshow of no importance. The NPPF waxes lyrical about a framework of addressing housing needs but this Local Plan does not recognise the true housing needs of the two districts where property prices are amongst the highest in the land and rentals are exorbitant for most people. House prices in Chiltern and South Bucks are at the top of the housing price ladder because it is a beautiful place to live, with most of the land in the Green Belt, relatively close to the M40 junction at Denham and so demand for housing is strong. The Local Plan talks about housing need and yet it is only providing a

2314 minimal annual housing need figure but does not produce a housing requirement figure. The NPPF above talks about economic and social priorities. Laudably the Local Plan wants to see 40 per cent affordable housing across all its allocated sites. If past performance is repeated - only 6 per cent of all housing in South bucks was affordable in recent years – then it will be a great deal lower. Policy SP BP11 is likely to have viability issues because as a brownfield site with landfill it has contamination problems and a potential wildlife site, all of which is likely to hit affordable housing numbers. Forgive me, so often councils allocate land for housing to bump up their housing numbers and the number of affordable housing in their Local Plan and only when the planning applications arrive developers complain that because of all the Section 106 money they cannot afford the level of affordable housing that the local authority would like there is a real risk of this happening with Policy SP BP11. The NPPF also talks about environmental policies and there are plenty of platitudes in the Local Plan on environment. The Local Plan mentions the important of health and the walkability levels for developments close to local centres and yet SP BP11 proposes an allocation where if people want to shop or visit the dentist, doctors etc in Iver High Street they will get in their cars. It also reports on the fact that Iver High Street has one of only three the air quality monitoring points. With news that South Bucks District Council’s latest (2019) Air Quality Annual Status Report reveals that air quality in Iver High Street has further decreased with an increase of 29 per cent in nitrogen dioxide it is of great concern that these levels will increase further because a relief which will only be partially built on land north of Iver Station will create more HGV movements and pollution in Iver High Street. Soundness mods - Are you proposing any modifications to Yes strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to Increase the housing numbers so that there is a sensible housing requirement improve its alignment to this test of soundness. Please be as precise figure. Again platitudes. The Local Plan keeps mentioning how Chiltern and and succinct as possible. South Bucks is a highly expensive area for house purchase and rentals, but it fails to look at cheaper enclaves within this district. Perhaps look again at Chesham, an urban area where house prices are lower than average, certainly compared with Amersham and South Bucks, so they are more affordable to rent and buy. It is highly sustainable as it has a London underground station. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Not Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Since it seems any non-compliance with the Duty-to-co-operate is incapable of Local Plan has met/not met the requirements of the Duty to modification at examination, I would merely say that Slough’s unmet housing Co-operate.Please be as precise and succinct as possible. need will eventually have to be dealt with. With South Bucks being so close to Slough, then some of the unmet housing need will come to the district and this should be allowed in the housing figures. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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.

2315 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 1225360 Full Name Phil Gander ID 6665 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 Yes Soundness? Soundness mods - Please give details of why you consider this Local This Local Plan is seriously underestimating the housing need in its area between Plan is/is not sound, including references to relevant legislation, 2013 and 2036. Circumstances exist to justify an increase in the standard method policies and/or regulations. Please be as precise and succinct as assessment of local housing need for Chiltern and South Bucks area. possible. We are currently three quarters of the way through the consultation on the Heathrow expansion and it is quite clear that this expansion will have a major impact on this rea with not just aircraft noise and pollution from aviation fuel but also traffic on the ground. Anyone visiting the Heathrow expansion roadshow will find that they are planning to use part of the Ridgeway Trading Estate as a construction site (more HGVs and certainly vans and cars for construction workers),. Iver is already a blackspot for congestion of HVS and latest readings on the air quality management station in Iver High Street show a big increase in air pollution. According to South Bucks’ own air quality annual status report the air quality in Iver High Street has declined with a 29% increase in nitrogen dioxide between 2018 and 2019. Chiltern and South Bucks District Council know that these areas area highly popular with house prices storming above other areas in Great Britain. The Government is committed to building more new homes to ensure that the demand and supply is evened up so that with more homes in Britain they will become more affordable. Other councils, who like Chiltern and South Bucks have a concentration of Green Belt land with their areas, have had the vision to dramatically increase their housing numbers as they accept the pent-up demand, saying there is exceptional circumstances to do so. The Evening Standard has had regular reports but how Guildford Borough Council, which has about the same percentage of Green Belt land as Chiltern and South Bucks, has responded to the Government’s demand

2316 for more houses. This, however, proved to unpopular with Guildford voters and in this year’s elections Conservatives lost control of the council. Perhaps Chiltern and South Bucks are worried about such a vision and I don’t want to dwell on politics. Whatever, Chiltern and South Bucks are not responding are not responding to local needs, Slough’s unmet housing need or the Heathrow expansion which will also put additional housing pressures for more homes and more affordable homes. At the moment the Local Plan is only providing the standard method which is the starting point for the minimum need. Soundness mods - Are you proposing any modifications to No strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to With housing demand so great in Chiltern and South bucks, the Local Plan should improve its alignment to this test of soundness. Please be as precise be producing a housing requirement figure so it is above the standard method. and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Not Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Chiltern and South Bucks may say in the Local Plan that no neighbouring authority Local Plan has met/not met the requirements of the Duty to has made a formal request to take some of Slough’s unmet housing need. They Co-operate.Please be as precise and succinct as possible. know Slough has a problem as four councils, Slough, Chiltern, South Bucks and Windsor and Maidenhead have set up The Whether South Bucks like it nor not, it seems some of Slough’s unmet housing need is destined for South Bucks. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1225366 Full Name Ganesh Challa ID 6670 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received:

2317 Duty to Cooperate 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 Yes Soundness? Soundness mods - Please give details of why you consider this Local One of the early pages of the Chilterns and South Bucks Local Plan Publication Plan is/is not sound, including references to relevant legislation, Version are statements of Strategic Objectives and there are four which we policies and/or regulations. Please be as precise and succinct as thoroughly support: possible. 3.5.2 to 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 constraints and opportunities. 3.5.3 to focus new development in accessible locations, reducing the need to travel and increasing opportunities for walking cycling and use of passenger transport. 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 behaviour. 3.5.5 to address existing traffic congestion, capacity limitations, connectivity difficulties and other highway network problems, wherever possible, such as: • Addressing unacceptable HGV movements in and around Iver and Richings Park (We are particularly interested in removing ALL through traffic HGVs in and around Iver and Richings Park) What we do NOT support is that: • The Draft Local Pan identifies a minimum housing need and it does not provide a sensible housing requirement. The Draft Local Plan includes Policy SP BP11 which contravenes all the strategic policy objectives above which we will mention later. Soundness mods - Are you proposing any modifications to No strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to The Draft Local Plan requires to take into consideration of the demand for housing improve its alignment to this test of soundness. Please be as precise in Chiltern and South bucks, the likelihood that both of these councils having to and succinct as possible. help meet Slough’s unmet housing need and the impact on housing demand of the Heathrow expansion. In order to do so, the Draft Local Plan should be modified to include a realistic housing requirement figure which is more than the minimum which could lead to the failure of having a 5 year land supply. Remove Policy SP BP11 from the Draft Local Plan. Without carrying out the above, the Chiltern and South Bucks Draft Local Plan is unsound. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the South Bucks is part of the Slough travel to work area and thousands of South Local Plan has met/not met the requirements of the Duty to Bucks residents work in the town and this is good for the economy of South Co-operate.Please be as precise and succinct as possible. Bucks.

2318 Slough is small in geographical terms and with so many offices and factories, notably Slough Trading Estate, it provides very gainful employment for so we say thousands of South Bucks residents and families. In a time of Climate Change Emergency it is logical to provide housing as close as possible near to homeowners’ work places. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1225379 Full Name Mrs Tina Childs ID 6685 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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

2319 Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local Before stating my vie on why the draft Local Plan is unsound, I would just like Plan is/is not sound, including references to relevant legislation, to point out that many people in Iver feel they are being overwhelmed by policies and/or regulations. Please be as precise and succinct as consultations. We had the Green Belt consultation, where land north of Iver possible. Station was objected to by what I consider was a large number of residents, although South Bucks District Council did not seem to listen to fears about how Iver is besieged by HGVs and how the High Street is high pollution levels. We had the HS2 Consultation and we are having the Heathrow Expansion Consultation, despite the Government voting in favour of the third runway last year. Many people I have spoken to are fed up with so many consultations and feel that these consultations are just box ticking exercises where residents’ views are ignored. However, I consider that this latest consultation is important because the matter will be taken out of the hands of South bucks District Council and will be considered by an independent inspector. The draft Local Plan is unsound because it rites about important issues facing South Bucks in the period between 2013-2036 but really does nothing about them other than giving fine words. South Bucks District council (and Chiltern) know that the district requires more housing in the Plan period but fails to do anything about it. South Bucks District Council (and Chiltern) know that historically there are major problems with large numbers of HGVs travelling through Iver High Street because so many are based here. South Bucks District Council (and Chiltern) know that for years air pollution levels in High Street have been way above the accepted levels set by the EU. Iver has for years the greatest concentration of HGVs in Buckinghamshire and any area surrounding the county. With these HGVs and other vehicles comes in high concentration of vehicle emissions and in some sections of the High Street it has an annual concentration of nitrogen dioxide in excess of the legal limit, as set by the EU as air quality objectives. Perhaps that is why as the Local Plan was being drawn up, Buckinghamshire County Council (the highway authority) produced a report I think it was called the Ivers Traffic Study that concluded that the only way a relief road could be provide for Iver was by development as there was no other funds. Soundness mods - Are you proposing any modifications to Yes strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to More housing should be allocated in the larger centres and it is noticeable that improve its alignment to this test of soundness. Please be as precise both Amersham-on-the-Hill and Gerrards Cross, which both have better shopping and succinct as possible. and community facilities than Iver, do not have any allocated sites. Neither of these places have concentrations of HGVs and resulting high levels of pollution. The large centres are more sustainable than Iver. The draft Local Plan needs to be reviewed. It is drafting has been going on for several years and in the development in Iver to be unacceptable on environmental grounds. The Heathrow expansion is unstoppable, but the amount of housing planned for Iver does not have to go ahead on a site which does not provide a relief road in a timely fashion. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Not Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the By agreeing to the Wider Growth Study (WAGS) South Bucks District Council has Local Plan has met/not met the requirements of the Duty to tried to put off a decision on Slough’s unmet housing need. This seems a delaying Co-operate.Please be as precise and succinct as possible. tactic because South Bucks will have to provide land for Slough’s unmet housing need because in an age where car journey lengths are being encouraged to be shorter, then a northern extension of Slough in South Bucks is almost certain. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible

2320 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 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 1225384 Full Name Derek Cosens ID 6701 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 No Soundness? Soundness mods - Please give details of why you consider this Local Iver, to many of us, has always seemed to be used as a dumping ground for South Plan is/is not sound, including references to relevant legislation, Bucks. There had been gravel extraction, but also large numbers of HGVs have policies and/or regulations. Please be as precise and succinct as been allowed to concentrate on sites of the parish. possible. Previous Local Plans have recognised that Iver parish has a major problem with unacceptable levels of HGVs and all of the pollution this brings to long-suffering residents and it is particularly bad for children (there are four schools either on or near Iver High Street) and the elderly. This Draft Local Plan again seems to accept there is a problem and does really nothing about it. I find it alarming that with air monitoring station in Iver High

2321 Street showing a 29% increase in nitrogen oxide levels, only a few paragraphs are on air quality sine this is one of the council’s responsibilities. Iver has half the allocations in the South Bucks area and the largest one, Policy SP BP11, is too big for the parish. Whilst a brownfield site seems a no brainer, this particular one has many problems. It is likely not be able to provide space for 1000 homes at a time when the districts require more homes because of changing circumstances of Heathrow and Slough’s unmet housing need. The Draft Local Plan therefore requires more than the minimum annual housing need figure but a housing requirement figure that makes the Plan more robust. Without do so, the Plan is unsound. Soundness mods - Are you proposing any modifications to Yes strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to Provide a housing requirement figure that responds to the changing circumstance improve its alignment to this test of soundness. Please be as precise of the Heathrow expansion and the almost inevitable request from Slough and succinct as possible. Borough Council that it needs some help with its unmet housing need. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Not Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Working as I did in Slough Borough Council’s parks department at Wexham from Local Plan has met/not met the requirements of the Duty to 1974 to 2011 I have some sympathy for Slough’s housing problems. Co-operate.Please be as precise and succinct as possible. It has a real problem when it comes to providing actual houses as opposed to a flat. Face with very little open land to build houses on Slough Borough Council decided to sell the parks department nursery. This illustrates how short of land the council was. There are plenty flats being made from office blocks. These do not really provide the family housing that this required by Slough-based residents, particularly affordable homes. Slough is likely to ask for South Bucks’ assistance so the Draft Local Plan should allow for. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1224561 Full Name Denton

2322 Homes ID 7033 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Other Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Denton Homes 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 Review of Sustainability Appraisal and Suitable Alternatives Local Plan is/is not legally compliant, including references to The Sustainability Appraisal (SA) for the Regulation 18 Local Plan consultation relevant legislation, policies and/or regulations. Please be as precise of January 2016 assessed 12 different strategic development options, including and succinct as possible. an Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local Review of Sustainability Appraisal and Suitable Alternatives Plan is/is not sound, including references to relevant legislation, The Sustainability Appraisal (SA) for the Regulation 18 Local Plan consultation policies and/or regulations. Please be as precise and succinct as of January 2016 assessed 12 different strategic development options, including possible. an option for built area extensions to Chesham (Option C). However, the SA for the Regulation 19 consultation of June 2019 only assessed four alternatives. The details given for this decision it that the spatial options were ‘revisited by the plan makers in 2019 and presented as a suite of four options’ (paragraph 5.3.3), however, no explanation has been given as to why different options were ruled out or incorporated into the resultant four options and why others were excluded. The Government’s Planning Practice Guidance section on Local Plans sets out that strategic development alternatives must be ‘realistic and deliverable’. One of these options (Option A) is to do nothing, however this cannot be considered as a reasonable strategic development option. Therefore, there are only three realistic alternatives, all of which involve exporting C&SB’s unmet housing need to Aylesbury Vale (AV). We explain below that we have considerable doubts that AV will be able to accommodate any of C&SB’s unmet housing need, especially given the very advanced stage of their Local Plan preparation. Part b) of the NPPF tests of soundness requires Local Plans to be justified through ‘an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence’. We consider that C&SB District Councils have failed to consider enough reasonable alternative spatial development strategies, therefore the current version of the Local Plan should fail part b) of the tests of soundness. The only pragmatic way to resolve this is for the Councils to consider further reasonable alternatives, in particular urban extensions to the main settlements given the considerable economic, social and economic benefits that they would bring as a strategic development approach. Review of Housing Need In the Memorandum of Understanding (MoU) between AV District Council and C&SB District Councils in relation to the Vale of Aylesbury Local Plan (VALP) of January 2018 it was agreed that the Objectively Assessed Need (OAN) for AV is 19,400 over the plan period (2013-2033), equivalent to 970 dwellings per annum (dpa). It was also agreed that AV can accommodate further housing need from adjacent constrained plan areas within expected development rates,

2323 encompassing 5,725 dwellings of unmet for C&SB, and that the resultant housing need of 27,400 dwellings can be accommodated in AV. The MoU also acknowledged that the VALP is proposing 28,830 homes. However, the Government’s new standard methodology for calculating Local Housing Need (LHN) results in a figure for AV of 1,423 dpa (using the 2014-based Household Projections and 2017 ratio of house price to workplace-based earnings). This is considerably higher than the 970dpa OAN figure, therefore there are considerable doubts as to whether AV can accommodate the unmet need figure of 5,725 from C&SB over the plan period whilst meeting their own housing need. We also note that C&SB District Councils have not produced any further evidence of their Duty to Cooperate with AV since January 2018, nor have they published a Statement of Common Ground, as now required part c) of the tests of soundness. This also raises serious doubts as to whether the C&SB Local Plan 2036 would meet parts a) of the NPPF tests of soundness, in that it needs to be positively prepared, ‘providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development’. The only pragmatic and reasonable way to resolve this is for C&SB District Councils to consider additional sites, such as our client’s sites, in combination with considering an alternative spatial development option that involves area extensions to the main settlements of the Districts, including Chesham. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1226441

2324 Full Name Nicole Burnett ID 6995 Order 1 Number Title Foreword Organisation Details Policy Planner Gladman Developments Limited Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 3.1.1. The Duty to Cooperate (DtC) is a legal requirement established through Local Plan is/is not legally compliant, including references to section 33(a) of the Planning and Compulsory Purchase Act 2004, as amended relevant legislation, policies and/or regulations. Please be as precise by Section 110 of the Localism Act. The DtC requires local planning authorities and succinct as possible. to engage constructively, actively and on an ongoing basis with neighbouring authorities on cross boundary strategic issues through the process of ongoing engagement and collaboration. 3.1.2 The revised Framework has introduced a significant changes on how local planning authorities are expected to cooperate including the preparation of Statement(s) of Common Ground (SOCG) which are required to demonstrate that a plan is based on effective cooperation and has been based on agreements made a neighbouring authorities when cross boundary strategic issues are likely to exist. The revised Framework sets out that local planning authorities should produce, maintain, and update one or more statement(s) of common ground (SOCG), throughout the plan making process. The SOCG should provide a written record of the progress made by the strategic planning authorities during the process of planning for strategic cross-boundary matters and will need to demonstrate the lengths local authorities have taken to ensure cross boundary matters have been considered and what actions are required to ensure issues are proactively dealt with i.e. unmet housing needs. 3.1.3 As demonstrated through the outcome of the Coventry, Mid Sussex, Castle Point and St Albans examinations, if a Council fails to satisfactorily discharge its DtC a Planning Inspector must recommend non-adoption of the Plan. This cannot be rectified through modifications. 3.1.4 Gladman recognise that the DtC is a process of ongoing engagement and collaboration. AS set out in the PPG it is clear that the Duty is intended to produce effective policies on cross boundary strategic matters. In this regard, the council must be able to demonstrate that it has engaged and worked with its neighbouring authorities, alongside their existing joint work arrangements, to satisfactorily address cross boundary strategic issues, and the requirement to meet any unmet housing needs. The DTC shoulder result in effective cooperation to ensure that the Housing Market Areas (HMA’s) housing needs are met in full. Where necessary, a policy mechanism should be built into the Local Plan to demonstrate that unmet housing needs arising from relevant neighbouring authorities and those with a clear function relationship will be met during the plan period. This is of particular relevance for the Chiltern and South Bucks Local Plan. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible.

2325 Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1225231 Full Name Mr Malkiat Singh Jeer ID 6603 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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

2326 Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local Now retired, my career never involved planning but I have had a lifelong interest Plan is/is not sound, including references to relevant legislation, in planning and have commented on earlier consultations in the evolving Draft policies and/or regulations. Please be as precise and succinct as Local Plan, including the release of Green Belt land. possible. I am disappointed that the Draft Local Plan could put the council in difficulty over its 5-year land supply because on the numbers shown there is a risk that land agents could obtain planning permission for speculative schemes because of a lack of a 5 year land supply. There is further disappointment amongst the Iver and Iver Heath communities that the Draft Local Plan has not got to grips with the appalling level of HGVs within Iver High Street and other parts of Iver parish. It seems strange that at the beginning of the Draft Local Plan document councillors emphasise the need for development of “the right scale” and “supported by the necessary infrastructure” and that it should contribute to the overall quality of life.” I will allude to this later. Policy SP BP11 is a at risk of producing lower housing numbers because of the constraints on such a difficult brownfield site to develop. This could put at risk many affordable homes because with extra development costs the site could prove to be unavailable. Cutting affordable housing on the site would be against the council’s Draft Local Plan policy of 40% affordable housing on allocated site. For the reasons above, the Draft Local Plan is unsound. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to Raise the number of homes in the Draft Local Plan so that it meets the needs of improve its alignment to this test of soundness. Please be as precise local demand which is likely to increase between now and 2036 because of the and succinct as possible. expansion of Heathrow and Slough’s unmet housing need. Take out Policy SP BP11 because it risks railing to deliver the number of homes allocated and its viability may because a reduction in affordable housing. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Not Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Having lived in Slough before moving to South Bucks I know the town well. Its Local Plan has met/not met the requirements of the Duty to housing problems are well known because its boundaries make for a narrow Co-operate.Please be as precise and succinct as possible. wedge of solid development sitting between Windsor and Maidenhead and South Bucks. Although the profiles of their residents are quite different, the economies of Slough and South Bucks are intertwined. With so little greenfield land, as commercial development dominates the town, Slough Borough Council has only been able to meet most of its housing need by converting offices into apartments. This has left to an unbalanced community with an influx of the younger generation from particularly West London and these new apartments have not been that popular with existing Slough residents. There is no space for family homes in a town where often families have a larger than average number of children. The four councils who have set up The Wider Area Growth Study will have to address this and I hope their second report will be available for the EiP on this Drat Local Plan Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public?

2327 Attend EiPb - If you wish to participate at the examination in 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 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 1225256 Full Name Mr Paramjit Kaur ID 6624 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 No Soundness? Soundness mods - Please give details of why you consider this Local The draft Local Plan does not reflect the Government’s desire to significantly Plan is/is not sound, including references to relevant legislation, boost the supply of homes because it allocates housing site which over a period policies and/or regulations. Please be as precise and succinct as of 2036 could deliver 763 homes each year. possible.

2328 It does not include additional homes to meet Slough’s unmet housing need and these should be included in the draft Local Plan at this stage. Soundness mods - Are you proposing any modifications to Yes strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to Another 200 homes per year should be built to satisfy the demand for new homes improve its alignment to this test of soundness. Please be as precise in Chiltern and South Bucks. and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Not Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the The Draft Local Plan has not considered all of the requirements of the Duty to Local Plan has met/not met the requirements of the Duty to Co-operate Chiltern and South Bucks asked the Vale of Aylesbury to take some Co-operate.Please be as precise and succinct as possible. of its unmet housing need but has not included any figures for Slough’s unmet housing need. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1225276 Full Name Mr Ian Hoddy ID 6627 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID

2329 Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local I have always been interested in planning as my career, before retirement, was Plan is/is not sound, including references to relevant legislation, in the gravel industry. policies and/or regulations. Please be as precise and succinct as Unlike other local authorities who realise there is a shortage of housing in their possible. areas and have made proper provision of their Local Plans, Chiltern and South Bucks have tried to limit the amount of housing to be provided in the Draft Local Plan. As all residents of Chiltern and South bucks are aware, these districts are amongst the most unaffordable housing areas of the UK. They also suffer from a low provision of affordable housing and latest figures show a worsening in affordability in the two districts. They have included 15250 home in the draft Local Plan and more than 5000 of these are going to the Vale of Aylesbury but have failed to accept Slough’s unmet housing need. Soundness mods - Are you proposing any modifications to Yes strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to The Draft Local Plan identifies the minimum local housing need but does not, improve its alignment to this test of soundness. Please be as precise as the NPPF and PPG guidance advises, have a housing requirement figure, so and succinct as possible. the housing numbers will have to go up. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Not Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Slough in land area is a relatively small borough and has very little land on which Local Plan has met/not met the requirements of the Duty to to build new homes. Therefore, it has considerable unmet housing need and Co-operate.Please be as precise and succinct as possible. South Bucks has been aware of it for many years. However, under realitvely new planning laws the NPPF says that neighbouring authorities must co-operate in helping surrounding councils with this unmet housing need. I can never understand why South Bucks has not been prepared to help because a significant proportion of South Bucks residents rely on livelihoods which are based in Slough. My own wife worked on the Slough Trading Estate for many years and found it more convenient to work here than in London. Having read on the Internet the Wider Growth Area Survey report Part 1, I think there is an inevitability about our council providing land for someo f Soough’s unmet housing need. The WAGS Part 1 has defined an area of search for potential housing areas. This Part 1 report was a fascinating read. In the origins of commuting to core districts, the largest figure commuting to South Bucks came from Slough and this helps our economy bringing workers into a district which has a large number of retirees. Interesting too that the second most popular commute from South Bucks was into the Wycombe district, closely followed by Hillingdon and Chiltern. Commuting into Slough for work over a one year period showed that 5865 came from Windsor and Maidenhead and 3618 came from South Bucks and again these figures probably reflect that more residents are economically active in Windsor and Maidenhead than in South Bucks where there must be a majority who are retired. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public?

2330 Attend EiPb - If you wish to participate at the examination in 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 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 1211087 Full Name Carole Eaden ID 4447 Order 1 Number Title Foreword Organisation Details Great Missenden and Prestwood Revitalisation Group Consultee Type - Please select the type of consultee: Local Interest Group/Amenity Society Date Received - Date Received: 2016-01-21 Duty to Cooperate Body - Is this organisation a Duty to Cooperate No Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to Legally Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the No Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local It is noted that of all the sites proposed in this consultation, there are no site Plan is/is not sound, including references to relevant legislation, allocations for the Parish. policies and/or regulations. Please be as precise and succinct as The Great Missenden and Prestwood Revitalisation Group (GMPRG) questions possible. how are identified local needs to be met?

2331 A refresh of the Market Town Health Check- Community Vision was conducted in 2018 and whilst local residents do not support major changes to the area, there are common themes of requirements- “Affordable housing for our children, so they don’t have to move away.” “A mixed age community.” “There are many people in their 80’s living on their own in 4 bedroom houses because there are few alternatives for them”. “Keep it rural- no major development”. “A wider range of shops and restaurants to sustain those already here and more local employment opportunities”. During the plan period the number of residents aged over 80 in Bucks is due to increase by 44%, therefore there is a great need for down-size and age-restricted properties. Despite the fact that healthcare groups consider it important for the elderly to be able to have care services at home and to enable older people to continue receiving support from their existing infrastructure of family and friends, no suitable accommodation to meet these needs is proposed locally. The plan fails in this respect. Review of GB4 and GB5 areas within the Local Plan Prestwood Within the Local Plan the area of Prestwood, along the A4128 Wycombe Road, to the south of the village is described as not being part of the village settlement. In the Green Belt Settlement Review, the following is stated about this GB5 area- "The identified area covers two rows of housing fronting either side of Wycombe Road. The identified area excludes a pub (the Polecat PH) to the south of the identified area, a garden centre to the south east of the identified area and the church to the north of the identified area. The church is the church which serves Prestwood. However, The main settlement has grown up to the north leaving the church and a few houses isolated from the main settlement. Given the separation from the main settlement it is not considered that this small area can be regarded as part of the main settlement area and it is not considered that it is a village in its own right. The area of housing is more akin to a hamlet. Therefore it is proposed that the infilling designation be removed from this area." This statement is contested. When this area was reviewed in the CDC Delivery DPD it was considered part of the settlement. Historically it is part of the main settlement and local people do not consider this area of housing, the village Church and Hildreth’s garden centre to be a separate 'hamlet'. GB4 and GB5 Areas within the Parish Residents of villages such as South Heath are concerned that removal from Green Belt could lead to disproportionate development spoiling the residential character of the area. Educational site allocation In response to the last consultation it was suggested by GMPRG and the Great Missenden Parish Council that a site on the southern edge of the village, currently in Green Belt, is retained as a potential future "educational site”, rather than housing, as it is the only flat site within the village that could provide school sports pitches etc. As this plan considers development up to 2036, it is feasible that the two currently oversubscribed schools could be moved to the south of the village, within the area previously proposed for development. This in turn would free up land within the built-up area for new housing, additional retail and parking. Please see attached document for further details about these issues and a list of further comments directed at the Local Plan. Soundness mods - Are you proposing any modifications to Yes strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to A Masterplan for Great Missenden Parish needs to be drawn up to consider improve its alignment to this test of soundness. Please be as precise where the necessary developments to provide local housing needs are to be met and succinct as possible. within the plan period, either within the settlement areas or by minor urban extension. Identified needs such as affordable housing for key workers to be provided locally within the District, not sent to Aylesbury, as the high cost of housing in Chiltern is making it difficult to recruit teachers, emergency service workers etc.. For consistency, the GB5 area to the south of Prestwood should be included in the main settlement and excluded from Green Belt, so that Prestwood village church is (as it always has been considered to be) part of the main settlement of Prestwood.

2332 With regard to other GB4 and GB5 areas within the Parish; to address concerns caused by the Green Belt amendments within the plan, it is requested that the following additions to policy 10.2.1, Protected Places, be included: Planning consent for developments in areas previously washed over by the Green Belt must ensure they: • Enhance the local infrastructure for the benefit of the village community. • Do not detract from the openness of the area. • The plot size of developments is in keeping with those of adjacent sites. • Do not cause harm to the character of the area. And lastly, it is suggested that educational site allocations (such as the one suggested in the attached document) be included in the plan, so that (if feasible) new schools can be brought forward within the plan period. Plan-level upload - Please upload any supporting evidence 5467552 Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a Yes modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, GMPRG is concerned that further inappropriate development in the Parish is please outline why you consider this to be necessary (please be as allowed at appeal, due to the lack of a plan for the area, thus causing strain on precise and succinct as possible the infrastructure as has happened in the past. The lack of proposals suggests that it needs representation to provide things the community regards as necessary, whilst having a voice to protect it from harm. 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 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 5467553

Person ID 1225339 Full Name Deborah Kelly ID 6654 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received:

2333 Duty to Cooperate 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 No Soundness? Soundness mods - Please give details of why you consider this Local As the Local Plan significantly underestimates the actual level of housing required Plan is/is not sound, including references to relevant legislation, across Chiltern and South bucks and by doing so is failing to adequately plan for policies and/or regulations. Please be as precise and succinct as the next 20 years it is unsound. possible. Due to this, there are flaws in the calculation of the five-year housing land supply and this makes the Local Plan unsound. It also fails to take into account unmet housing need from Slough. This Local Plan does not properly recognise that Chiltern and South Bucks are two of the unaffordable authorities for housing in England and a housing uplift is needed. Soundness mods - Are you proposing any modifications to Yes strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to The Local Plan should increase the housing numbers to adequately provide the improve its alignment to this test of soundness. Please be as precise local need within Chiltern and South Bucks, the increased demand from the and succinct as possible. expansion of Heathrow and Slough’s unmet housing need. The Local Plan needs to be modified to increase the number of allocated sites. They should be provide in towns within the two districts where there are larger centres that can cope with increased housing and do not have the traffic problems that exist in Iver. This congestion can only deteriorate with the Heathrow expansion and an allocation for Slough’s unmet housing need. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Not Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the This Local Plan does not take into account Slough’s unmet housing need. Local Plan has met/not met the requirements of the Duty to It states that as no formal requests have been received to meet any unmet Co-operate.Please be as precise and succinct as possible. housing needs of neighbouring areas, the housing strategy of the Local Plan does not require to include the unmet housing need of a neighbour. However, Chiltern and South Bucks District Councils are collaborating with Windsor and Maidenhead and Slough on The Wider Area Growth Study (WAGS) to support future plan making and Duty-to-Co-operate between authorities. The purpose of the study is to identify the potential locations that could accommodate the future housing need growth of the Slough, Windsor and Maidenhead core in line with national policy. This requires that, where a local planning authority cannot meet its housing need in its own area, the resulting unmet need should be accommodated in “neighbouring area…Where it is practical to do so and is consistent with achieving sustainable development.” In short, the study aims to identify alternative locations for people who would normally expect to live in the core places but cannot do so, due to the lack of new housing. The recommendations of the Wags Part 1 are that Slough’s housing need are best met as close to Slough as possible. There would seem to be exceptional

2334 circumstances for the release of Green Belt land for some of Slough’s unmet housing need – and it SHOULD be included in this Local Plan. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1225343 Full Name Ashley Kelly ID 6658 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 Yes Soundness?

2335 Soundness mods - Please give details of why you consider this Local For the first time in my life I am completing a planning consultation form. I am Plan is/is not sound, including references to relevant legislation, responding to the Chiltern and South Bucks Draft Local Plan 2036 – Publication policies and/or regulations. Please be as precise and succinct as Version because I love living in Iver and feel it needs improvement which one of possible. the policies in the Plan will definitely not bring to this village only additional dangers of threatening, fast-moving HGVs and increasing levels of pollution. Iver is home to four generators of HGVs at Thorney Business Park, Ridgeway Trading Estate, Court Lane Industrial Estate and Aggregate Industries in Thorney Lane. A fifth generator is the Cape Boards site where the HGVs cannot go over a canal bridge since it has a low weight restriction. So Iver High Street and Langley Park Road are pounded every weekday by HGVs which add to pollution What I cannot understand is that at sometimes these sites would have had to be granted planning permission by either the county council or district council. This problem was allowed to happen when lorries were a good deal smaller and over the years and the weight of the vehicles have increased. So, why aren’t the district council and the county council working together to produce a Local Plan which responds to the strategic objectives mentioned on Page 9 of the Local Plan. One of these objectives writes of “addressing unacceptable HGV movements in and around Iver and Richings Park.” Chiltern and South Bucks councils are under the illusion that ending the present uses of Thorney Business Park will solve the HGV problem and consequent pollution. Policy SP BP11 is in conflict with this policy since it only “assist” providing a relief road on the land north of Iver Station. From what I see, the land north of Iver Station is not providing a relief road it is building a service road for 1000 homes, offices, station car park and community hub. This service road will remain just that and the remainder of the “relief road” is unlikely to be built because the funding will have to come from local taxpayers or national taxpayers who have not been prepared to help in the past. Soundness mods - Are you proposing any modifications to No strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to Delete Policy SP BP11 and have a new allocation for the land south of Iver High improve its alignment to this test of soundness. Please be as precise Street. This will really make a difference to lorry movements in Iver and it will, and succinct as possible. come in two or three years’ time so it would help diver 80% of the existing HGVs and 5000 other vehicles who use the road each week plus all of the extra traffic which will come through the expansion of Heathrow, the Western Link to Heathrow and CEMEX. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Not Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the The landscape of Slough is characterised by offices, factories and logistics centres. Local Plan has met/not met the requirements of the Duty to It helps the economy of South Bucks by providing work for thousands of residents Co-operate.Please be as precise and succinct as possible. living in South Bucks by providing work for thousands of residents living in South Bucks and I and my mother are just two of the thousands of South Bucks council taxpayers who benefit for this town providing with jobs. It also means that in the past South Bucks has not had to worry too much about providing more employment land. That may not last because walking around slough you notice that more and more offices are being converted into apartments. Those buying and renting tend to be, like myself, young people. Many of them are moving into Slough to buy a first time buyer property. This is fine. However, many of them will want to start a family and will require a house with a garden House prices are rising fast in Slough because of the shortage of them and the average two-bedroom semi is touching £400,000. It is obvious that Slough will eventually have an unmet housing need and south Bucks has a moral Duty-to-Co-operate. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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.

2336 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 1225372 Full Name Jonathan Munns ID 6676 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 Yes Soundness? Soundness mods - Please give details of why you consider this Local The world faces a climate change emergency and we are reminded of this every Plan is/is not sound, including references to relevant legislation, day. Iver each day, particularly on weekdays in Iver High Street and Langley Park policies and/or regulations. Please be as precise and succinct as Road, is suffering from its own pollution emergency and the draft Local Plan possible. should be reflecting this but it does not. The draft Local Plan is unsound because it is not positively prepared or justified. The draft Local Plan aims to promote sustainable development, but the allocation of land north of Iver Station may not be delivered for a host of reasons. The number of homes in the draft Local Plan is insufficient because the area will need more homes as Slough’s unmet housing need should be included and the expansion of Heathrow will impact on housing demand in South Bucks, plus local growth. Soundness mods - Are you proposing any modifications to No strengthen the Plan's ability meet the test of soundness?

2337 Policy 1a - Please specify how you would modify this policy to More homes are needed to be included in the draft Local Plan because Chiltern improve its alignment to this test of soundness. Please be as precise and South Bucks has a higher housing need than shown in the document. and succinct as possible. Additional allocations should be included in a modified Local Plan and these should be placed in more sustainable locations than Iver such as the towns of Beaconsfield, Gerrards Cross, Amersham-on-the-Hill and the Chalfonts. These have greater facilities than Iver which only has a local centre. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Not Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the With over 80% of land in Chiltern and South Bucks being within the Green Belt, Local Plan has met/not met the requirements of the Duty to the draft local Plan states on Pages 23 that under the Duty-to-Co-operate the Co-operate.Please be as precise and succinct as possible. two authorities have asked the Vale of Aylesbury to take 5,750 of its unmet housing need, a larger figure than the 5,200 which have site allocations in Chiltern’s and South Bucks’ Green Belt. However, if as is likely, the site north of Iver Station is unable to deliver the quantum of housing suggested, then there are risks to the figure of 5200 being built on Green Belt land. 4.9 on pages 23 of the draft Local Plan states: “Subject to certain caveats, the NPPF sates that strategic policies in local plans, should, as a minimum provide objectively housing and other uses, as well as any needs that cannot be met within neighbouring areas. The legal advice which has been received indicates that the Local Plan is unlikely to be found ‘sound’ at examination unless it provides for the Local Housing need figure of 15,250 homes as a minimum over the Plan period. As no formal requests have been received to meet any unmet housing needs of neighbouring areas, the housing strategy of the Local Plan has been drafted so as to provide 15,260 homes over the period 2013-2036 plus a 10% buffer to allow for potential non-delivery (16,786 homes in total).” This section of the draft Local Plan ignores The Wider Growth Area Study (WAGS) which has been commissioned jointly by Slough, Windsor and Chiltern and South Bucks as part of evidence base to support future plan making and Duty-to-Co-operate work between the authorities. Whilst this Wider Area Study is looking as putting Slough’s unmet housing need in places as far away from Slough as Bracknell, Reading and West Berkshire – is this good for the environment? Adding more pollution from vehicles. The first part of the study is already point towards South Bucks helping Slough out and it states: “Considered in the round, this evidence suggests that the future housing needs of Slough are best met: • As close to Slough as possible • In areas where house prices, or home prices on new developments could be, no higher than Slough • Close to areas that Slough residents commute out to When South Bucks has to take some of Slough’s unmet housing need hopefully there will be 40% affordable housing, as suggested in the draft Local Plan, so that a fair proportion of the housing will include shared ownership housing which is more affordable. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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.

2338 PAa - Please specify as precisely and 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 1219116 Full Name Hayley Keene ID 6798 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 Non-Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the It is not legally compliant because: Local Plan is/is not legally compliant, including references to o It is in breach of the National Planning Policy Framework (NPPF) relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. o The removal of areas SPB7 (the Epilepsy Society site) and SPBP8 (Winkers Field) from the Green Belt is not justified, as they are within an area of high performing Green Belt and fail to demonstrate exceptional circumstances for removal. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local Secondly after attending a meeting regarding the objection I believe that the Plan is/is not sound, including references to relevant legislation, plan is unsound because: policies and/or regulations. Please be as precise and succinct as o It fails to comply with paragraph 84 of the National Planning Policy Framework possible. (NPPF), which emphasises the need to promote a sustainable pattern of development. o The Local Plan states that the two Chalfont St Peter (CSP) sites are in ‘a highly sustainable location’; this is untrue. They are outside the village centre, which is in a valley. The identified sites are at the peak of the adjacent very steep hill making access to and from amenities on foot or cycle extremely difficult. Policy SP SP1 states ‘Development of all sizes and uses must accommodate walking and cycling as a primary means of transport to serve the development’. o Both sites fail to meet the maximum specified sustainable distances to a doctor’s surgery, train station, or hospital. o The sites are particularly unsustainable in relation to transport (no station/adequate bus service). There is poor to no bus service where we live and there is no way as a full time worker I would be able to rely on public transport in this area. It is a very long walk to a local train station where the rates to commute are expensive. o Over 700 dwellings were allocated to CSP under the Core Strategy, which was meant to run until 2021. These have already been built or have planning

2339 permission, putting a significant strain on infrastructure. Further development is unfair and unsustainable. o The 2016 Green Belt assessment is very poorly scored; it is biased, inconsistent and therefore unsound. o No justification has been given for not including the many sites with lower Green Belt scores than the two allocated in CSP. o The need to build houses is not a ground for the removal of the Green Belt. o There are numerous Brown Field and poor performing Green Belt sites in the district that should have been included in preference to the high performing Green Belt sites in CSP. o There are no ‘exceptional circumstances’ or justification for removal of the sites from the Green Belt (the ES site in particular) as it fulfils all five Green Belt purposes. 1 ) To check the unrestricted sprawl of large built up areas. 2) To prevent neighboring towns from merging into one another. § The ES site adjoins the Colne Valley Regional Park with ancient woodlands and provides an essential buffer between CSP, Newlands Park, Chalfont St Giles and Horn Hill. § C&SB have rejected other sites on this basis, showing clear bias and inconsistency. 3) To assist in safeguarding the countryside from encroachment. § The ES site adjoins the Colne Valley Regional Park. Outside the built on areas, the ES site is very rural and the site as a whole is semi rural. This site should have been given a much higher score. 4) To preserve the setting and special character of historic towns. § The awarded score of 0 is totally unjustified. The four listed buildings on the site have been ignored. C&SB have ignored the 2014 Buckinghamshire and Milton Keynes Historic Towns Project (BMHT) and the 2011 Chalfont St Peter Buckinghamshire Historic Towns Assessment, which illustrates the important historical character of the ‘Chalfont Colony’ and states that the site is of ‘high heritage value’. It also denotes that it achieves a high score on historical and commercial values and a medium score for aesthetic values. The BMHT gives the ‘Chalfont Colony’ a ‘high’ heritage value. § The CSP Historical Assessment states ‘Given the historic importance of the Chalfont Colony, it has the potential to be a conservation area in its own right’. 5) To assist in urban regeneration by enforcing the recycling of derelict and other urban land. § C&SB have failed to give prioritised consideration to the many Brown Field sites and other urban land over the Green Belt sites in CSP. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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.

2340 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 1573 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 It is impossible for me as a layman to comment upon legal compliance. The Local Plan is/is not legally compliant, including references to consultnation itself is also too cloaked in jargon and to me it is unforgivebale relevant legislation, policies and/or regulations. Please be as precise that non-techncail version of the consultation is not released whcih allows and succinct as possible. sensible feedback form ordinary people. The consultation document reads "like a closed shop", i.e. only really understandable by those in the know to begin with, which is really unfortunate if the Council expects the public to properly engage. If ordinary members of the public cannot sensibly engage, then personally I would think it ought not to be legally compliant. I note the Plan says it is "sound, evidence-based and will deliver in a sustainable way the necessary outcomes which our communities need". Laudable aims for sure (and fairly ambiguous to be honest), but I am highly doubtful that the plan has or will achieve the stated aims. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to Yes strengthen the Plan's ability meet the test of soundness?

2341 Policy 1a - Please specify how you would modify this policy to The plan is too weak in addressing infrastructure needs to ensure the plan is improve its alignment to this test of soundness. Please be as precise sustainable. A number of areas are lacking in evidence to support the proposition and succinct as possible. ... much reads like a wish list than a practical long term solution. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1220617 Full Name Sarahjane Leary ID 1965 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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.

2342 Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local I can only laugh when I read the "foreword” of the 2036 Local Plan. “We are Plan is/is not sound, including references to relevant legislation, delighted that Chiltern District Council and South Bucks District Council have policies and/or regulations. Please be as precise and succinct as prepared a joint Local Plan. This is a Plan that positively provides for meeting possible. our community’s needs, improving quality of life and opportunities, and will put in place necessary infrastructure to support development whilst also protecting our valued environment and the character of our towns and villages” These current proposals contradict this statement of every front. On an ethical point – surely the residents of Denham especially are suffering enough with the construction of the white elephant that is HS2, without their green belt being squandered unnecessarily. Planners simply need to do their job and find sustainable development sites, and councils need to stop being so damn greedy, and serve their residents. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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.

2343 Policy-level file upload - Please attach any supporting evidence

Person ID 1220702 Full Name Tom Ielapi ID 2115 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 No Soundness? Soundness mods - Please give details of why you consider this Local The Local Plan is unsound and not legally compliant because: Plan is/is not sound, including references to relevant legislation, Not all brownfield sites have been identified. policies and/or regulations. Please be as precise and succinct as possible. A more strategic county-wide view should be taken by the new Unitary Authority before release of any green belt sites. The housing need figures have been over-inflated. Planning consents have been granted for development at higher densities than accounted for in the councils’ housing availability figures which means their figures for housing need are unreliable. Insufficient attention has been paid to previously developed land, both residential and commercial. The councils have merely carried out a request via a “Call for Sites”, inviting landowners and developers to nominate land for development, rather than carrying out their own assessment of land availability. This means, for example, that a large proportion of Beaconsfield green belt has, wrongfully, been nominated rather than previously developed land. This flawed green belt assessment goes against government policy. Previous consultation responses have been ignored. Evidence does not support this green belt release which breaches national policy. Consultation with the communities has been extremely poor. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any

2344 non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1221063 Full Name Mr Damian Sullivan ID 2558 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 Non-Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the The Local Plan is not legally compliant on the basis that there are no statements Local Plan is/is not legally compliant, including references to of common ground documenting cross-boundary issues with other neighbouring relevant legislation, policies and/or regulations. Please be as precise authorities. Without these statements, it is impossible to conclude the Local and succinct as possible. Plan is effective and the Duty to Co-operate has been satisfied. The Duty is a legal compliance point. Moreover, the Local Plan does not address the unmet housing needs of Slough Borough Council. We refer to our representation dated 17th July 2019 for further details. Yes

2345 We would expect up-to-date statements of common ground to demonstrate the duty to co-operate has been satisfied. The Local Plan should increase housing delivery including looking to address the unmet housing needs of Slough Borough Council. The Council should look to sustainable settlements such, as Burnham, Chesham and Chalfont St Giles, to accommodate additional housing growth during the plan period We refer to our representation dated 17th July 2019 for further details. Legally compliant b - Are you proposing a modification to make the No Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local The duty to co-operate is the basis for strategic and cross boundary planning Plan is/is not sound, including references to relevant legislation, across England. The duty is established in legislation which sets out the process policies and/or regulations. Please be as precise and succinct as all LPAs must follow in carrying out the duty to co-operate. However, the possible. legislative framework is also supported by more detailed guidance in both the NPPF (paragraphs 24 to 27) and in the PPG (paragraphs 9-001 to 9-023). No detailed evidence is available to demonstrate how these legal requirements have been addressed. We would have expected the Council to have prepared an up to date Duty to Co-operate statement outlining its activities and the outcomes of those activities. The most recent Duty to Co-operate Statement is dated November 2017. The Council needs to produce the necessary evidence showing how they have co-operated with respect to key cross boundary issues; particularly housing supply. The plan cannot be considered sound as measured against the tests of soundness set out in paragraph 35 in the NPPF without such evidence. The draft Local Plan 2036 confirms that there are 5,200 site allocations which comprise of Green Belt releases. However, this leaves a shortfall of approximately 4,161 dwellings which are expected to be met through the Vale of Aylesbury Local Plan. We consider that the Council should meet its own housing needs without having to rely on other Authorities. The proposed stepped trajectory to housing delivery is not considered sound. Moreover, the Council have not set out in policy the minimum number of homes that will be delivered or a trajectory illustrating how the requirement will be met. Both these are a requirement of planning policy (paragraph 73 of the NPPF) to ensure that the plan can be monitored effectively by both Council, Government, and other stakeholders. We refer to our representation dated 17th July 2019 for further details. Soundness mods - Are you proposing any modifications to Yes strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to The Council should prepare an up to date Duty to Co-operate Statement outlining improve its alignment to this test of soundness. Please be as precise its activities and the outcomes of those activities. and succinct as possible. We consider that an increase in housing land supply is required if the plan is to be consistent with National policy and therefore ‘sound’ with respect to the NPPF. We consider that the Council should look to sustainable settlements such, as Burnham, Chesham and Chalfont St Giles, to accommodate additional housing growth during the plan period rather than relying on the Vale of Aylesbury. This would also allow the Council to bring forward housing more quickly in the early years of the plan period, contributing positively to housing need, and according with the NPPF. There should be no stepped trajectory to housing delivery. The Council should set out in policy the minimum number of homes that will be delivered and to demonstrate how the requirement will be met. We refer to our representation dated 17th July 2019 for further details. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Not Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the The duty to co-operate is the basis for strategic and cross boundary planning Local Plan has met/not met the requirements of the Duty to across England. The duty is established in legislation which sets out the process Co-operate.Please be as precise and succinct as possible. all LPAs must follow in carrying out the duty to co-operate. However, the

2346 legislative framework is also supported by more detailed guidance in both the NPPF (paragraphs 24 to 27) and in the PPG (paragraphs 9-001 to 9-023). No detailed evidence is available to demonstrate how these legal requirements have been addressed. We would have expected the Council to have prepared an up to date Duty to Co-operate statement outlining its activities and the outcomes of those activities. The most recent Duty to Co-operate Statement is dated November 2017. The Council needs to produce the necessary evidence showing how they have co-operated with respect to key cross boundary issues; particularly housing supply. The plan cannot be considered sound as measured against the tests of soundness set out in paragraph 35 in the NPPF without such evidence. We refer to our representation dated 17th July 2019 for more details. Attendance at the EiP - If your representation is proposing a Yes modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, We wish to amplify and expand on the various issues we raise in our please outline why you consider this to be necessary (please be as representation dated 17th July 2019. 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 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 1221321 Full Name Ms Patricia Mallett ID 2978 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 Non-Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the I do not believe that the Measures against which the local plan is tested fit the Local Plan is/is not legally compliant, including references to Habitats Directive and the Conservation of Habitats and Species Regulations

2347 relevant legislation, policies and/or regulations. Please be as precise 2010. Specifically, no mention is made of the globally rare chalk streams habitat. and succinct as possible. This is seriously threatened by over-abstraction. 60% of the chalk streams within the Chilterns AONB are DRY. The drying up of the streams removes globally rare habitat for many different species. Species such as water voles are threatened. This is an environmental emergency. With climate change, we are seeing a reduction in rainfall. Over-abstraction is common now, and is causing the streams to dry up. When more houses are built, the situation is aggravated. More water will be needed, when we are already abstracting too much. In the Measures, only the risk of flood is mentioned. The local plan needs to address the water shortage and the damage to the chalk streams. It is imperative that all housing be fitted with water reduction measures. This should include mandatory greywater recycling, water butts where possible, and a mandatory maximum flow rate on all taps, etc. Legally compliant b - Are you proposing a modification to make the Yes Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) To mandate that all houses are fitted, or retrofitted, with water conservation below:You will need to say why this modification(s) will make the measures, as above. No new housing should be built until the supply of water Local Plan legally compliant/strengthen its legal compliance. Please is assured. Sir James Bevan of the EA gives a series of measures that should be be as precise and succinct as possible. adhered to. an environmental objective – to contribute to protecting and enhancing our natural, built and historic environment; including making effective use of land, helping to improve biodiversity, using natural resources prudently, minimising waste and pollution, and mitigating and adapting to climate change, including moving to a low carbon economy. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local It does not comply with the National Planning Policy Framework. Specifically, Plan is/is not sound, including references to relevant legislation, the environmental objective demands that the plan should contribute to policies and/or regulations. Please be as precise and succinct as protecting and enhancing our natural, built and historic environment; including possible. making effective use of land, helping to improve biodiversity, using natural resources prudently, minimising waste and pollution, and mitigating and adapting to climate change, including moving to a low carbon economy. Soundness mods - Are you proposing any modifications to Yes strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to Water conservation measures, and not increasing housing stock until there is improve its alignment to this test of soundness. Please be as precise adequate water supply. and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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.

2348 Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and 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 1222448 Full Name Colette Browne ID 4059 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 Non-Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the The Local Plan is unsound and not legally compliant because: Local Plan is/is not legally compliant, including references to Not all brownfield sites have been identified. relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. A more strategic county-wide view should be taken by the new Unitary Authority before release of any green belt sites. The housing need figures have been over-inflated and the resident occupancy rate has not been considered - in particular in Beaconsfield where 15% of all housing stock is currently to either rent or buy. Planning consents have been granted for development at higher densities than accounted for in the councils’ housing availability figures which means their figures for housing need are unreliable. Insufficient attention has been paid to previously developed land, both residential and commercial. The councils have merely carried out a request via a “Call for Sites”, inviting landowners and developers to nominate land for development, rather than carrying out their own assessment of land availability. This means, for example, that a large proportion of Beaconsfield green belt has, wrongfully, been nominated rather than previously developed land. This flawed green belt assessment goes against government policy. Previous consultation responses have been ignored. Evidence does not support this green belt release which breaches national policy. Consultation with the communities has been extremely poor. The National Planning Policy states Protecting Green Belt land Paragraphs 133 to 147 133. 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 5 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

2349 (e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land. 135. The general extent of Green Belts across the country is already established. New Green Belts should only be established in exceptional circumstances, for example when planning for larger scale development such as new settlements or major urban extensions. Any proposals for new Green Belts should be set out in strategic policies, which should: (a) demonstrate why normal planning and development management policies would not be adequate; (b) set out whether any major changes in circumstances have made the adoption of this exceptional measure necessary; (c) show what the consequences of the proposal would be for sustainable development; (d) demonstrate the necessity for the Green Belt and its consistency with strategic policies for adjoining areas; and (e) show how the Green Belt would meet the other objectives of the Framework. 136. Once established, Green Belt 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 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. 137. Before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, 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 will be assessed through the examination of its strategic policies, which will take into account the preceding paragraph, and whether the strategy: (a) makes as much use as possible of suitable brownfield sites and underutilised land; (b) 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 transport; and (c) has been informed by discussions with neighbouring authorities about whether they could accommodate some of the identified need for development, as demonstrated through the statement of common ground. 138. When 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. 139. When defining Green Belt boundaries, plans should: (a) ensure consistency with the development plan’s strategy for meeting identified requirements for sustainable development; (b) not include land which it is unnecessary to keep permanently open; (c) where necessary, identify areas of safeguarded land between the urban area and the Green Belt, in order to meet longer-term development needs stretching well beyond the plan period; (d) make clear that the safeguarded land is not allocated for development at the present time. Planning permission for the permanent development of safeguarded land should only be granted following an update to a plan which proposes the development; (e) be able to demonstrate that Green Belt boundaries will not need to be altered at the end of the plan period; and (f) define boundaries clearly, using physical features that are readily recognisable and likely to be permanent. 140. If it is necessary to restrict development in a village primarily because of the important contribution which the open character of the village makes to the openness of the Green Belt, the village should be included in the Green Belt. If, however, the character of the village needs to be protected for other reasons,

2350 other means should be used, such as conservation area or normal development management policies, and the village should be excluded from the Green Belt. 141. Once 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. 142. The National Forest and Community Forests offer valuable opportunities for improving the environment around towns and cities, by upgrading the landscape and providing for recreation and wildlife. The National Forest Strategy and an approved Community Forest Plan may be a material consideration in preparing development plans and in deciding planning applications. Any development proposals within the National Forest and Community Forests in the Green Belt should be subject to the normal policies for controlling development in Green Belts. Proposals 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 considerations. 145. A local planning authority should regard the construction of new buildings as inappropriate in the Green Belt. Exceptions to this are: (a) buildings for agriculture and forestry; (b) the provision of appropriate facilities (in connection with the existing use of land or a change of use) for outdoor sport, outdoor recreation, cemeteries and burial grounds and allotments; as long as the facilities preserve the openness of the Green Belt and do not conflict with the purposes of including land within it; (c) 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; (d) the replacement of a building, provided the new building is in the same use and not materially larger than the one it replaces; (e) limited infilling in villages; (f) limited affordable housing for local community needs under policies set out in the development plan (including policies for rural exception sites); and (g) limited infilling or the partial or complete redevelopment of previously developed land, whether redundant or in continuing use (excluding temporary buildings), which would: not have a greater impact on the openness of the Green Belt than the existing development; or not cause substantial harm to the openness of the Green Belt, where the development would re-use previously developed land and contribute to meeting an identified affordable housing need within the area of the local planning authority. 146. Certain other forms of development are also not inappropriate in the Green Belt provided they preserve its openness and do not conflict with the purposes of including land within it. These are: (a) mineral extraction; (b) engineering operations; (c) local transport infrastructure which can demonstrate a requirement for a Green Belt location; (d) the re-use of buildings provided that the buildings are of permanent and substantial construction; (e) material changes in the use of land (such as changes of use for outdoor sport or recreation, or for cemeteries and burial grounds); and (f) development brought forward under a Community Right to Build Order or Neighbourhood Development Order. 147. When located in the Green Belt, elements of many renewable energy projects will comprise inappropriate development. In such cases developers will need to demonstrate very special circumstances if projects are to proceed. Such very special circumstances may include the wider environmental benefits associated with increased production of energy from renewable sources. This plan proposed does not meet the National Planning Policy Guidelines in green Belt in any way . The "any policy is better than no policy" didn't work for Theresa May - Don't let it work here please.

2351 Legally compliant b - Are you proposing a modification to make the Yes Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) The plan needs a correct consultation prior to be ing drawn up. All brownfield below:You will need to say why this modification(s) will make the sites need to be considered as does all applicable other sites in the entire area, Local Plan legally compliant/strengthen its legal compliance. Please not just Alylesbury and Beaconsfield and Little Chalfont. be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local Policy SP BP9 Plan is/is not sound, including references to relevant legislation, This policy is unsound for many reasons. Beaconsfield green belt is not a policies and/or regulations. Please be as precise and succinct as sustainable location because it is too far from the new town supermarkets, shops possible. and services and too far from the railway station. This site should be retained as green belt as it performs the 5 green belt purposes strongly. To release it is not consistent with national policy. Traffic is already heavily congested in the town with many junctions already operating over capacity. The impact on traffic if Beaconsfield green belt is released for development would be severe. The ideas for traffic mitigation lack sufficient detail and have not been modelled to take into account all planned development within the surrounding area. The Jacobs’ report confirms traffic congestion in the town would become far worse. Beaconsfield cannot accommodate any more traffic. Construction of the Beaconsfield relief road has been started by BCC but a dispute with Inland Homes (who have planning permission for Wilton Park) has meant that completion of the relief road has been delayed. This relief road would just become an access road to a huge housing estate and business park if our green belt is released. The relief road would not offer any relief. HS2 lorry movements and Heathrow expansion have not been factored into traffic assessments. Pedestrian and cycle access to the Option 9 areas is dangerous due to the busy roads. Cycling is not a safe option in this area. It is unrealistic to think people will walk or cycle to the New Town from Option 9 because it is too far and the roads too dangerous. Bus services are very limited and infrequent. The many roundabouts, zebra crossings, traffic lights and railway bridge across the town mean that traffic is not free-flowing before factoring any more development. Beaconsfield is not a “principal settlement”, it is a small market town, smaller than many of its neighbours. It sits on the boundary with Wycombe district which means that the population and traffic from thousands more homes will affect our roads and infrastructure. The amount of development proposed for Beaconsfield is unsustainable. It is disproportionate. Air pollution will only get worse. The level of car ownership in this area is one of the highest in the country. The Air Quality Management Area around the M40 area makes this an unsuitable and unsustainable area for development, being close to the M40 and adjacent to the M40 spur, A40 and A355 which are all heavily congested traffic routes. Increasing retail development in the new town would only increase traffic trying to reach it. Although there are several empty retail units in the town, so there is no need for more. Building retail development on Altons carpark would remove a nursery school and a car park which is usually at capacity during week days and on a road with queueing traffic already at peak times. Building retail development on the Mercedes site would be unsustainable next to Davenies Pre-prep and Prep School leading to dangerous traffic and pollution levels. This policy is not effective because this land is among the most expensive land in the country meaning it cannot produce truly affordable housing in any meaningful numbers. All that would result is more expensive housing which would not solve the housing crisis. Profits would line the pockets of a few at a huge cost to the town in terms of worsening traffic congestion, strain on infrastructure and services. The policy is ineffective due to its location being unsustainable, leading to more traffic congestion and pollution. To remove this site from green belt would be to remove the green lungs of the town.

2352 These fields have been used by dog walkers and for recreation for decades and their loss would result in Beaconsfield itself losing over 60% of its green belt. This is extreme, disproportionate, inconsistent with national policy and unjustified. Beaconsfield has little park land and these fields are one of its most important natural resources and provide important green infrastructure which cannot be replaced. The green belt site selection has been erroneous. This is the worst possible and least sustainable site on what is supposed to be our relief road which we have been waiting for since the 1970s. The selection of this site is contrary to national policy, in particular Para. 136 of the National Planning Policy Framework. No exceptional circumstances have been shown for its release. Housing need itself is not “exceptional circumstances.” Development of this site would result in urban sprawl and a huge urban expansion of what is a small market town. Part of the site is in a Conservation area and there are listed buildings on the site. The town’s population would grow by around one third which is unsustainable. 1600 more homes plus 20,000 sq metres of employment space would lead to thousands more car journeys in the town every day. The development planned just across the district boundary with Wycombe district (including a further 1,000 homes on the Gomm Valley site near Tylers Green) means around a further 3,000 homes and thousands more cars using our roads and town from these sites too. There has been no joined up thinking. Beaconsfield is right on the border with Wycombe district. Geographically therefore, it is unsustainable to add c. 1600 more homes into an area right next to an area in Wycombe district thousands more homes are planned. This land will not deliver meaningful affordable housing. Developers locally have been avoiding affordable housing provision on site for years due to high costs and high land value. It is undeliverable on site in the required numbers. Removal of this site from green belt would result is loss of a huge proportion of the town’s accessible countryside, crossed by public rights of way. Evidence is being retro-fitted for removal of this green belt site. This site plays an important role in preserving the “openness” of the green belt which is the first thing one notices when one approaches the town. This site is important in framing the Old Town Conservation Area. It is near junction 2 of the motorway and our green belt mitigates against the poor air quality along the Air Quality Management Area of the M40 corridor. Making air quality worse goes against government policy. This site provides green infrastructure, agricultural land and includes ancient woodland which would be threatened by urbanisation, pollution and traffic. Release of this site from green belt for development would create severe stress on Burnham Beeches SAC by virtue of it lying within the 5K buffer zone. This site plays the important role of preventing coalescence with Seer Green. This site is home for many threatened species such as bees, deer, bats and newts. The housing need figures have been over-inflated by the government. All housing need can be accommodated on non-green belt land. There are no exceptional circumstances to justify this green belt release; it is unjustified and contrary to national policy. Release of this green belt site would mean other nearby sites would not be re-generated. It is wasteful use of land. There is no local A & E dept. at Wycombe Hospital. GPs’ surgeries and hospitals are under severe stress. Schools are at capacity. There are no boys’ schools in the town meaning that boys who pass the 11 plus must travel out of town to Wycombe to attend school, adding more traffic to the roads. The distance admission policy means that boys are disadvantaged as more and more development takes place between Beaconsfield and Wycombe. This is unsustainable. This site performs strongly the green belt purposes. Exceptional circumstances for its release have not been demonstrated. This Plan is unsound. Policy SP EP4 This policy is unsound and not legally compliant. Reference to 20,000 sq. metres of economic floor space on Beaconsfield green belt should be deleted. This would generate an unsustainable amount of traffic in an already severely congested area. Air quality would suffer. The evidence does not show a need for this type of use and it would prevent the letting of empty employment space in the vicinity. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness?

2353 Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 3697 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 Legally Compliant be legally compliant/non-compliant.

2354 Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the No Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local In regards to the Beaconsfield development, in the sustainability report each of Plan is/is not sound, including references to relevant legislation, the sites that cumulatively form the area (1.13, 1.13A, 1.14 , 1.14A, 1.14B) each policies and/or regulations. Please be as precise and succinct as score in the major impact category in between 2-6 categories, yet you have possible. proposed doing all of them. This does not seem reasonable or proportionate. Soundness mods - Are you proposing any modifications to Yes strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to Reduce size of suggested development in Beaconsfield to a sustainable level. improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1213664 Full Name Ms Dawn Fleming ID 6860

2355 Order 1 Number Title Foreword Organisation Details Clerk Iver Parish Council Consultee Type - Please select the type of consultee: Parish Council Date Received - Date Received: 2016-04-06 Duty to Cooperate Body - Is this organisation a Duty to Cooperate No Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local General Comments Plan is/is not sound, including references to relevant legislation, As well as our objections to, and proposed modifications of, specific PVLP policies policies and/or regulations. Please be as precise and succinct as addressed in points 2 - 6 below, we have a number of more general concerns possible. that do not lead to an obvious modification of any one policy. These general concerns may be broadly described as follows; the overall scale and intensity of new development proposed in the Ivers, the lack of any clarity about the 'Iver Relief Road' and significant flaws in the assessment of need for, and supply of, pitches for gypsies and travellers Overall scale and intensity of new development The overall scale and intensity of new development proposed by the PVLP in the Ivers is unprecedented and unsustainable. From several consultation events held by TIPC on the local plan and the emerging INP, it is clear that local residents are very worried about the impact that 3,500 or so additional residents will have on the social fabric and the overall amenity of our villages, particularly Iver and Richings Park. The Ivers Parish and in particular the villages of Iver and Richings Park are choked by HGV and other traffic and the inevitable consequences of that; unacceptable traffic congestion, harmful pollution, high noise levels and increased hazards to all highway users including pedestrians. The sheer intensity of development proposed over such a small area will not only exacerbate these problems but will generate a multitude of equally serious environmental impacts such as increased flood risk, loss of green space, adverse landscape impacts and a reduction in wildlife and biodiversity. The level of development proposed in The Ivers quite obviously undermines the objectives of The Chiltern and South Bucks Business Plan 2019/20 set out at PVLP paragraph 3.1 and the means of achieving them. Business cannot flourish or the economy of the area grow if it is overwhelmed by wholly unacceptable levels of traffic and traffic congestion. The Strategic Objectives of the PVLP at paragraphs 3.5.3, 3.5.4, 3.5.5 and 3.5.9 are also undermined by, and thoroughly inconsistent with, the scale of development proposed. The PVLP cannot on any analysis be considered to comply with the presumption in favour of sustainable development for plan making set out in Paragraph 11, NPPF because the adverse impacts of the development proposed for the Ivers would significantly and demonstrably outweigh the benefits, when assessed against the policies in the NPPF. We maintain that for these reasons alone the PVLP is unsound and that the Inspector must address this albeit difficult issue. Lack of clarity on the 'Iver Relief Road' We address in more detail below, and with regard to specific PVLP policies, why an Iver Relief Road must be delivered early in the plan period in an attempt to at least offset the inevitable traffic impacts of any further development. However, irrespective of how and when any relief road is built, there appears to be real confusion as to what form an Iver Relief Road will take. Supporting

2356 documents for the Local Plan indicate that the relief road to be provided in connection with proposed site allocations is an east-west road from Thorney Lane North to Mansion Lane. This creates a problem as the connection onto Mansion Lane will be between the railway and the canal. HGVs will not be able to use this road as the railway bridge is too low and the canal bridge has a weight restriction on it. Therefore such a scheme would not fulfil the purpose of a relief road. The intention seems to be that the additional north-south elements of the relief road will be funded by other infrastructure projects such as the Western Rail Link to Heathrow and Heathrow expansion. However, the delivery of such infrastructure will be far too late in the plan period to address the urgent imperative for the Iver Relief Road, prior to or at least more or less simultaneously with PVLP proposed developments. Given that the Iver Relief Road is so fundamental (see The Chiltern and South Bucks Business Plan 2019/20 objectives at 3.1.2 and Strategic Objectives at 3.5.5), the confusion and lack of clarity over what the project even involves amounts to a major flaw in plan-making which should be addressed by the PVLP examination. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1213740 Full Name Nicola Thomas ID 6085 Order 1 Number

2357 Title Foreword Organisation Details Partnership Manager Bucks & Milton Keynes Natural Environment Partnership Consultee Type - Please select the type of consultee: Natural Environment Partnership Date Received - Date Received: 2016-04-07 Duty to Cooperate Body - Is this organisation a Duty to Cooperate Yes Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Section Policy Number: Local Plan is/is not legally compliant, including references to Foreword (Page i) relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Very little focus on the environment except for communities of high quality...”which will generate conservation of the future” and putting into place necessary infrastructure to “protect our valued environment”. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) Section Policy Number: below:You will need to say why this modification(s) will make the Foreword (Page i) Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Modifications Include in the foreword explicit recognition of the strategic and local importance of the environment as a pre-requisite to a thriving economy and health and well-being of residents. Linked to that, the need to ensure the environment and its habitats and wildlife are not only protected, but enhanced, extended and maintained over the long-term to generate services such as pollination, water and air quality improvements and risk reduction such as flooding and the impacts of climate change. Explicit mention of the need for net biodiversity gain as a result of development would be welcomed here too as an example of how this recognition of the importance of the environment is being converted to action. Vale of Aylesbury Local Plan (Reg 19 version) Spatial Vision (at 2.4a) includes: “Environmental, heritage and cultural assets will be protected and, where possible, enhanced...” (2.4d) “…Growth will be accompanied by the delivery of infrastructure, services, and facilities in the right places at the right time, to bring maximum benefits to new and existing communities. This includes improving…green and blue infrastructure…” And Strategic Objective 6 states: “The Council will manage development in a way that ensures the protection and enhancement of the district’s built, natural and historic environment, landscape and biodiversity. Planning positively for biodiversity and green infrastructure, the overall approach will minimise development on high-quality agricultural land, conserve and enhance areas of sensitive landscape including the Chilterns AONB and designated local landscapes and achieve high-quality design and building at appropriate densities.” • Plan:MK 2016 – 2031 – Strategic Objectives 16 and 17 refer to the importance of GI and Biodiversity • Plan:MK 2016 – 2031 – Strategic Objectives 16 and 17 refer to the importance of GI and Biodiversity Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness?

2358 Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1213773 Full Name Mr Byron Thorne ID 4195 Order 1 Number Title Foreword Organisation Details Owner The Park Consultee Type - Please select the type of consultee: Individual/Resident Date Received - Date Received: 2016-04-18 Duty to Cooperate Body - Is this organisation a Duty to Cooperate No Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID 1210943 Full Name Mr Bob Newell Organisation Details

2359 Plan-Level: Legally Compliant - Do you consider the Local Plan to Non-Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the For the reasons stated herein, the Local Plan is: not positively prepared; not Local Plan is/is not legally compliant, including references to justified; not effective; and it is not consistent with National Policy. It has failed relevant legislation, policies and/or regulations. Please be as precise to make a proper assessment of the availability of previously developed sites and succinct as possible. within the Green Belt. Legally compliant b - Are you proposing a modification to make the Yes Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) A large part of the evidence base requires rewriting, particularly Part 2 - Green below:You will need to say why this modification(s) will make the Belt Assessment, Options Appraisal and Exceptional Circumstances Report. The Local Plan legally compliant/strengthen its legal compliance. Please Councils have effectively ignored both the potential of previously developed be as precise and succinct as possible. sites in the Green Belt, and their surroundings to provide Housing. We represent such a site that has clearly not been considered, despite consistent submissions. This is The Park, long-redundant former Football Stadium and adjacent land, Wexham Road, Wexham, Bucks SL2 5QR. The inclusion of such sites is essential in terms of legal compliance. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local The plan is NOT POSITIVELY PREPARED for the following reasons: Plan is/is not sound, including references to relevant legislation, · The plan is not sufficiently informed by agreements with other authorities so policies and/or regulations. Please be as precise and succinct as that unmet need from neighbouring areas is accommodated where it is practical possible. to do so and is consistent with achieving sustainable development. Specifically, it should have accommodated the unmet needs of Slough - a large town directly on the border of the plan area. The proposals should include, as an example, the Football Stadium and adjacent land, Wexham Road, Wexham, Bucks SL2 5QR. This is mainly previously developed land, and literally on the boundary with Slough. · The plan should have reviewed Green Belt to consider the longer term requirements of Slough rather than defer this decision to a future plan. · The plan does not provide a strategy which meets area’s objectively assessed needs due to errors in its calculation of housing land supply. The Plan is NOT JUSTIFIED because reasonable alternatives have not been taken into account. · The approach of the Councils has been to assume the export of unmet need to Aylesbury Vale despite agreeing that the need would only be exported if it were impossible to find within the plan area. · The plan does not accommodate housing need from Slough, despite Slough’s request for it to do so. · The plan does not demonstrate that the development sites, and thus the overall spatial strategy, has been selected for inclusion in the plan on a robust, consistent and objective basis. Potential sites have been rejected and sites have been selected without adequate evidence and reasoning. · The influence of the town of Slough, adjoining the southern border of the plan area, has not sufficiently influenced the spatial strategy. In particular, sustainable settlements close to Slough are not given sufficient consideration for growth, based on this proximity. · The influence of the transport nodes into London has not sufficiently influenced the spatial strategy. In particular, the new Elizabeth Line into London is not given sufficient recognition in terms of opportunities for growth. The Plan is NOT EFFECTIVE because · The plan is not based upon adequate joint working on a critical cross-boundary strategic matter. The development needs of Slough is a cross-boundary strategic matter and a request from Slough Borough Council to assist with meeting this need has been rebuffed. A joint Growth Study has recently been commenced but this is not taken account of in the Publication Plan. It defers the housing needs of Slough and the associated Green Belt implications. The plan is INCONSISTENT WITH NATIONAL POLICY, as it conflicts with the National Planning Policy Framework (“the NPPF”), which is national policy and advice that the Councils must have regard to when preparing their plan (Section 19(2) of the Planning and Compulsory Purchase Act 2004), in that: · It does not deliver sustainable development, which is the NPPF’s core concept and is set out in NPPF Paragraphs 7 and 8, particularly in terms of providing sufficient numbers of homes and sufficient land of the right type and in the right place. · It does not meet NPPF paragraphs 136-138 that alteration of Green Belt boundaries are not fully evidenced and justified (having regard to their intended permanence in the long term so they can endure beyond the plan period) and in terms of promoting sustainable patterns of development, particularly in relation to the town of Slough and transport nodes into London.

2360 · The plan is not sufficiently informed by agreements with other authorities so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development. Specifically, it should have accommodated the unmet needs of Slough - a large town directly on the border of the plan area. · The plan should have reviewed Green Belt to consider the longer term requirements of Slough rather than defer this decision to a future plan. · The plan does not provide a strategy which meets area’s objectively assessed needs due to errors in its calculation of housing land supply. The approach of the Councils has been to assume the export of unmet need to Aylesbury Vale despite agreeing that the need would only be exported if it were impossible to find within the plan area. · The plan does not accommodate housing need from Slough, despite Slough’s request for it to do so. · The plan does not demonstrate that the development sites, and thus the overall spatial strategy, has been selected for inclusion in the plan on a robust, consistent and objective basis. Potential sites have been rejected and sites have been selected without adequate evidence and reasoning. · The influence of the town of Slough, adjoining the southern border of the plan area, has not sufficiently influenced the spatial strategy. In particular, sustainable settlements close to Slough are not given sufficient consideration for growth, based on this proximity. · The influence of the transport nodes into London has not sufficiently influenced the spatial strategy. In particular, the new Elizabeth Line into London is not given sufficient recognition in terms of opportunities for growth. . Obvious areas for inclusion - for example: The Park former Football Stadium and adjacent land, Wexham Road, Wexham, Bucks SL2 5QR have been ignored. The plan is not based upon adequate joint working on a critical cross-boundary strategic matter. The development needs of Slough is a cross-boundary strategic matter and a request from Slough Borough Council to assist with meeting this need has been rebuffed. A joint Growth Study has recently been commenced but this is not taken account of in the Publication Plan. It defers the housing needs of Slough and the associated Green Belt implications. It does not meet NPPF paragraphs 136-138, in that alteration of Green Belt boundaries are not fully evidenced and justified (having regard to their intended permanence in the long term so they can endure beyond the plan period) and in terms of promoting sustainable patterns of development, particularly in relation to the town of Slough and transport nodes into London. Soundness mods - Are you proposing any modifications to Yes strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to As part of rectifying the issues above, we believe that the Football Stadium and improve its alignment to this test of soundness. Please be as precise adjacent land, Wexham Road, Wexham, Bucks SL2 5QR should be included in and succinct as possible. the Housing and Green Belt proposals. The area is not even considered in 11 - Building Places, and this should be amended accordingly, due to its immediate proximity to Slough, with significant build development adjacent. This inclusion would clearly impact upon other areas of the Plan, such as 5 - Living Places, and 10 - Protected Places. A large component of the evidence base needs rewriting, particularly the Part 2 Green Belt Assessment, Options Appraisal and Exceptional Circumstances Report. The Park former Football Stadium and adjacent land, Wexham Road, Wexham, Bucks SL2 5QR should be included in the component for Housing, as per this submission. Suitable and sufficient joint working is required. Suitable and sufficient joint working is required, and a strategy which meets the needs, and is logical. A large component of the evidence base needs rewriting, particularly the Part 2 Green Belt Assessment, Options Appraisal and Exceptional Circumstances Report. The Park former Football Stadium and adjacent land, Wexham Road, Wexham, Bucks SL2 5QR should be included in the component for Housing, as per this submission. Suitable and sufficient joint working is required. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Not Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination

2361 Duty to Co-operate a - Please give details of why you consider the The plan is not sufficiently informed by agreements with other authorities so Local Plan has met/not met the requirements of the Duty to that unmet need from neighbouring areas is accommodated where it is practical Co-operate.Please be as precise and succinct as possible. to do so and is consistent with achieving sustainable development. Specifically, it should have accommodated the unmet needs of Slough - a large town directly on the border of the plan area. The approach of the Councils has been to assume the export of unmet need to Aylesbury Vale despite agreeing that the need would only be exported if it were impossible to find within the plan area.The influence of the town of Slough, adjoining the southern border of the plan area, has not sufficiently influenced the spatial strategy. In particular, sustainable settlements close to Slough are not given sufficient consideration for growth, based on this proximity. Attendance at the EiP - If your representation is proposing a Yes modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, Besides the fundamental nature of the deficiencies with the Plan, the omission please outline why you consider this to be necessary (please be as from the Plan of The Park former Football Stadium and adjacent land, Wexham precise and succinct as possible Road, Wexham, Bucks SL2 5QR is a fundamental error, given its previously developed nature, its location on the boundary with Slough, its close proximity to developed land and facilities, and its appropriate infrastructure. Due to the fundamental nature of hits error, it is important that the proposers are represented. 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 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 1214841 Full Name Mrs Juliette Payne ID 6565 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Individual/Resident Date Received - Date Received: 2016-12-12 Duty to Cooperate Body - Is this organisation a Duty to Cooperate No Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID 1224201 Full Name Jon Wright Organisation Details

2362 Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local In its current form the Local Plan is unsound on the grounds that it has not been Plan is/is not sound, including references to relevant legislation, positively prepared, effective or consistent with national planning policy. The policies and/or regulations. Please be as precise and succinct as Local Plan is not meeting the area’s objectively assessed need as a minimum possible. and is only explicitly identifying 11 sites for residential development, despite relying on many more sites through the HELAA assessment to meet its objectively assessed need. Soundness mods - Are you proposing any modifications to Yes strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to In order to make the Local Plan sound, there should be greater signposting of improve its alignment to this test of soundness. Please be as precise sites that are and succinct as possible. considered suitable, and sites should be identified through land use designations, associated tables, maps and policies. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 5500978

Person ID 1213996

2363 Full Name Unknown ID 4778 Order 1 Number Title Foreword Organisation Details Hyde Heath Village Society Consultee Type - Please select the type of consultee: Local Interest Group/Amenity Society Date Received - Date Received: 2016-06-21 Duty to Cooperate Body - Is this organisation a Duty to Cooperate No Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to Non-Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the We believe the Plan has been an Iterative process which has been complicated Local Plan is/is not legally compliant, including references to by District Council Merger, Unitary Authority creation and a significant number relevant legislation, policies and/or regulations. Please be as precise of documents which are fragmented and fail to allow all members of Hyde Heath and succinct as possible. to participate. Legally compliant b - Are you proposing a modification to make the Yes Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) We believe the entire Local Plan process should be stopped. We believe the below:You will need to say why this modification(s) will make the Unitary Authority should take ownership of the emerging plan and produce a Local Plan legally compliant/strengthen its legal compliance. Please holistic document covering the whole Authority. We believe the work done to be as precise and succinct as possible. date is no longer valid since the Unitary Authority would be implementing an emerging plan it has not considered or had assessed at Unitary level from the entire authority as a whole. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local The needs assessment has not considered needs in the context of a Unitary Plan is/is not sound, including references to relevant legislation, Authority but rather as a group of separate authorities. We believe the level of policies and/or regulations. Please be as precise and succinct as consideration and cooperation between neighbouring authorities did exist but possible. would be far more accommodating to areas such as the AONB if the location was considered as a Unitary Authority. Soundness mods - Are you proposing any modifications to Yes strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to The entire plan process requires a housing assessment and greenbelt assessment improve its alignment to this test of soundness. Please be as precise review as a holistic Unitary Authority. and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Not Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the S110 of the Localism Act places a duty to ensure development is sustainable. Local Plan has met/not met the requirements of the Duty to We do not believe removing Hyde Heath from the Greenbelt to encourage Co-operate.Please be as precise and succinct as possible. development is sustainable since there is little to no public transport in Hyde Heath and furthermore, the plan did not consider Hyde Heath in the context of its infrastructure needs or indeed the effect any further development would have on our existing infrastructure. Attendance at the EiP - If your representation is proposing a Yes modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, The purpose of the Localism Act was to hand power to the Local people to please outline why you consider this to be necessary (please be as influence planning in their local area. The consultation has made clear that it precise and succinct as possible intends to ignore the wishes of the people as regards planning in their local area and despoil the greenbelt within an Area of Outstanding Natural Beauty. To comply with the terms of the Localism Act, the emerging plan would have to prove or establish in what way it has accommodated the wishes of the local

2364 people and allowed them to influence planning in their local area. If the plan cannot establish such a thing, then only an examination in public could allow this matter to be discussed in more detail. 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 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 1214042 Full Name Paul Jennings ID 4346 Order 1 Number Title Foreword Organisation Details River Chess Association Consultee Type - Please select the type of consultee: Local Interest Group/Amenity Society Date Received - Date Received: 2016-07-25 Duty to Cooperate Body - Is this organisation a Duty to Cooperate No Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the We would resist any lifting of Green Belt Status as part of this plan. We wish to Local Plan is/is not legally compliant, including references to reiterate and remind you the purposes of the Green Belt. relevant legislation, policies and/or regulations. Please be as precise Purpose 1: To check unrestricted sprawl of large built-up areas. and succinct as possible. Purpose 2: To prevent neighbouring towns merging into one another. Purpose 3: To assist in safeguarding the countryside from encroachment Purpose 4: To preserved the setting and special character of historic towns Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Engagement with Water Companies Plan is/is not sound, including references to relevant legislation,

2365 policies and/or regulations. Please be as precise and succinct as Overall the Local Pan does not address infrastructure issues in details especially possible. the key areas of water and wastewater management We understand that there is a need to increase the housing stock in Chiltern District but are keen to ensure that this is done in way that does not have a detrimental affect on the Rivers Chess. We therefore encourage Chiltern District to engage with both Thames Water and Affinity Water to investigate alternative sources of water to meet existing and incremental demand resulting from this plan. Thames Water operate sewage management and processing within Chiltern District. Affinity Water are responsible for supplying drinking water for the District. In addition Thames Water abstract water from the aquifer underlying Chiltern District for supply elsewhere. Only through dialogue with these water companies will we ensure the River Chess is not subject to further stress and deterioration in quality. 3. Water Supply Water supply is flagged at various points in the Local Plan but as yet we cannot see any indication as to how this issue is going to be resolved without doing further harm to the River Chess. The Chess catchment is over abstracted and any increase in water demand coming from new housing needs to come from alternative sources. We also believe that abstraction needs to be reduced from current levels, if this does not happen we will continue to see frequent river drying events in Chesham as we did in 2011, 2012, 2015, 2016, 2017, 2018, and 2019. The drying event in 2015 caused thousands of fish to be killed and the almost complete disappearance of invertebrates in the river, in more recent drying events there was no evidence of fish in the river as there has been insufficient flowing water for the ecosystem to recover. We are working on a joint study with the Environment Agency, Buckinghamshire County Council and the Water Companies to address this problem. The Upper Chess Low Flow Study has established that abstraction is having a detrimental impact on flows in the Chess. In their latest Business Plans and Water Resource Management Plans both Affinity and Thames have provided for shutting down abstraction from Chesham, Chartridge and Hawridge in the AMP period 2020 to 2025. This must be highlighted and provided for in the in Local Plan as it places a constraint on water use and the ability to build new houses. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to Engagement with Water Companies improve its alignment to this test of soundness. Please be as precise We would like to see the establishment of a formal forum where the water and succinct as possible. companies and the District Council planners meet with stakeholders to ensure water supply and sewage treatment issues are addressed. Water Supply We would like to see a commitment in the Local Plan supporting the reduction of abstraction in the Chess Catchment in order to reduce low flow and drying events in the River Chess. Sewage Treatment Infrastructure Ensure Thames Water are made aware of plans that will impact on the Chesham Sewage Treatment Works Road, Urban and Agricultural Runoff We would like to see detailed sustainable road and urban drainage plan included in the Local Plan to address existing issues and cope with new housing. Green Belt Under Threat While appreciating that there are new housing requirements encroachment on Green Belt should be resisted. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible

2366 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 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 1215146 Full Name Mr Robert Taylor ID 5218 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Individual/Resident Date Received - Date Received: 2016-12-10 Duty to Cooperate Body - Is this organisation a Duty to Cooperate No Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the No Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local The plan does not start from a proper starting point. A more appropriate place Plan is/is not sound, including references to relevant legislation, would be to consider the previous plan, its critical objectives and the policies and/or regulations. Please be as precise and succinct as achievements and failings on these. This should have been coupled with an possible. analysis of these achievements and failings, how/why they were achieved or failed. This should be followed by a detailed profile of provision complemented by what is assessed is the need in each use class (and within classes, for example for housing split between 1, 2, 3, 4, and 5+ bedrooms etc.).This should have been

2367 supported by data. Insufficient consideration of impacts of plan (eg infrastructural demands) Soundness mods - Are you proposing any modifications to Yes strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to Resubmission of plan with the suggested approach so that it is evident why improve its alignment to this test of soundness. Please be as precise need is considered and what its impacts are (and how they will be resourced). and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1222969 Full Name Mr Malcolm Smith ID 6811 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name

2368 Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to Legally Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the • I am 100% in support of the draft Local Plan and find it to be legal and sound. Local Plan is/is not legally compliant, including references to • It is of utmost importance that the plan is protecting the Green Belt land under relevant legislation, policies and/or regulations. Please be as precise Section 10 of the Plan and succinct as possible. • I am utterly dismayed that that Paradigm Housing in association with their Planning Agent, Pegasus Group are going to challenge the existing designated Green Belt land , specifically the land off High View. I wish to inform you of my strongest objection to this challenge. • Chiltern District Council fully supports this land as Green Belt land and this land is not mentioned in the draft Local Plan as one of the 15 sites which are potential development areas for new housing. This challenge can only be viewed as speculative. • I note that 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 • This land has been left as meadow land for over 40+years and supports vast ecosystems including wildlife habitats for; badgers, bats, deer, fox, red kite and a plethora of birds, small mammals and birds. There are also very many wildflower species and associated insects. These all require the protection of the Green Belt status. • Geologically the chalk bedrock in this area has succumbed to significant subsidence in the form of many sink holes. The nearby fields and Stylecroft road have numerous deep depressions where sink holes have appeared. An entire house in Valentine way is now suspended over a sink hole that appeared overnight a few years ago. The land is therefore not fully suitable for development. • Any development on this site reduces the open space that is enjoyed by many particularly as the Chiltern way runs past the site. • Traffic congestion and pollution due to more traffic is a serious concern. The site is located on the top of a steep hill which is impassable on icy days. Already it is very difficult to access the A413 due to increase of traffic numbers using the road. More development will only lead to more difficulties for all in the area. • Development at the top of this steep hill far from the school, doctor and local amenities makes it totally unsuitable for young children or the elderly to access services. Pushing a pram to the village is impossible due to the gradient, poor paths and dangerous A413. The result is isolation of residents and an increase in car journeys thus adding to pollution and congestion. Legally compliant b - Are you proposing a modification to make the No Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Yes Soundness? Soundness mods - Please give details of why you consider this Local I believe that the draft Local Plan is sound. Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to No strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible.

2369 Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 5501507

Person ID 1222859 Full Name Mrs Jasmine Russell ID 6815 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 Legally Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the I support the Chalfont St Giles Neighbourhood Plan and Chiltern & S Bucks Local Plan is/is not legally compliant, including references to District Plan and I support the draft Local Plan and find it to be legal and sound. relevant legislation, policies and/or regulations. Please be as precise I am also relieved to see that Green Belt land is protected under Section 10 of and succinct as possible. the plan and would object to any company trying to reclaim Green Belt for financial gain through housing. Green belt land needs to be protected to ensure that they are free from pollution and development thus protecting the local wildlife and allowing them to thrive in their natural habitats. I would consider it irresponsible to build on Green Belt. In addition the local infrastructure would not cope with the addition to this number of houses. The narrow lanes are already congested, the trains are full at our “end of line “ stations and parking has become a problem at many of the local shops which discourages people to use them.

2370 Schooling is also a problem. We have not been able to get our children into our local school despite being less than 2 miles away from it. Our children now travel by car to a school within a neighbouring village. Legally compliant b - Are you proposing a modification to make the No Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Yes Soundness? Soundness mods - Please give details of why you consider this Local We believe that the draft Local Plan is sound. Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to No strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a No modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1222895 Full Name Dr Wayne Philpott ID 6836 Order 1

2371 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 Legally Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the I consider it essential to preserve the Green Belt across the UK. Otherwise Local Plan is/is not legally compliant, including references to unwanted development can be pushed through by any organisation, whether relevant legislation, policies and/or regulations. Please be as precise unscrupulous or not. and succinct as possible. Open spaces in this area in particular are much used and valued. Local amenities need to be preserved and not stretched beyond breaking point by unnecessary development. Legally compliant b - Are you proposing a modification to make the No Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Yes Soundness? Soundness mods - Please give details of why you consider this Local I consider it essential to preserve the Green Belt across the UK. Otherwise Plan is/is not sound, including references to relevant legislation, unwanted development can be pushed through by any organisation, whether policies and/or regulations. Please be as precise and succinct as unscrupulous or not. possible. Open spaces in this area in particular are much used and valued. Local amenities need to be preserved and not stretched beyond breaking point by unnecessary development. Soundness mods - Are you proposing any modifications to No strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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

2372 Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and 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 5501499

Person ID 1222950 Full Name Mrs Jennine Loader ID 6812 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 Legally Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the I support the draft Local Plan and think it is legal and sound. I am pleased that Local Plan is/is not legally compliant, including references to Green Belt land is protected under this plan as this was a major factor in my relevant legislation, policies and/or regulations. Please be as precise family choosing to live here. and succinct as possible. I understand that Paradigm Housing and Pegasus Group intend to challenge the Green Belts assessment of the land off High View and I object to this in the strongest possible terms. I have lived here since 2004 and since my daughter was about 1 year old, we have taken her to this plot of land to meet the horses. It is so close to our home, so quiet and peaceful and a wonderful place for wildlife to flourish in this small suburban area. I do not understand how Paradigm and Pagasus could possible want to challenge the green belt status of this land which I understand has been designated green belt for over 60 years. This area of land was not mentioned in the draft Local Plan as one of the 15 sites which were potential development areas for new housing so why are Paradigm after this specific plot? Why can they not apply to build on one of the designated areas for new housing? I understand a similar application in Chesham Green Belt land in Chesham (Planning Application Reference is CH/2018/0659/OA) was rejected and I sincerely hope CDC continue to follow the National Planning Policy Framework regarding Green Belt and throw Paradigms proposal where it belongs….in the trash for recycling. From a business perspective I can see why Paradigm want to build houses…this would be a HUGE revenue earner for the company, however the negative impact on the ancient village of Chalfont st giles is not worth the cost to it’s residents. More residents means • even longer waiting times to see a local GP. It is already over 2 weeks to see a GP.

2373 • Significantly more traffic along a small road (Kings Road and Stylecroft) with significant impact accessing the A413 which is already a treacherous junction at the best of times. • Destruction of open spaces and loss of a valuable wildlife habitit where I have seen deer, foxes, munkjack and where I understand badgers and bats also reside. Legally compliant b - Are you proposing a modification to make the No Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) No I am not proposing a modification to the Local Plan, for some reason Paradigm below:You will need to say why this modification(s) will make the are wanting to change the plan. If anything at all the plan should be bolstered Local Plan legally compliant/strengthen its legal compliance. Please to protect the precious green spaces we have around us. be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Yes Soundness? Soundness mods - Please give details of why you consider this Local I believe that the draft Local Plan is sound, however at this late time I do not Plan is/is not sound, including references to relevant legislation, have time to include reference etc in this submission. policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to No strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 5501503

Person ID 1223255 Full Name The Chalfonts Christian Trust ID 6511

2374 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Charity/Religious Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: The Chalfonts Christian Trust Person ID 1223253 Full Name Ian Gillespie Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local Spatial Vision – Section 3.4 Plan is/is not sound, including references to relevant legislation, Strategic Objectives – Section 3.5 policies and/or regulations. Please be as precise and succinct as possible. Please fill in the form below if you believe this policy does not meet the four tests of Soundness; positively prepared, justified, effective and compliant with the National Planning Policy Framework Feb 2019. We believe the Local Plan is unsound, because it has not been positively prepared, does not represent the most appropriate strategy (when considered against reasonable alternatives) and because there are significant concerns over deliverability. We also raise concerns in relation to compliance with the NPPF Feb 2019. The Spatial Vision is very generic and isn’t very spatial. It does not explain the reasoning for the proposed distribution of development across the two Districts, with reference to the hierarchy of settlements. The Spatial Vision does refer to meeting needs locally (i.e. within Chiltern and South Bucks) but if this is not possible, the authorities will work with adjacent Local Plan areas (i.e. Aylesbury Vale District Council) to meet these needs elsewhere as part of sustainable development proposals. There is clearly a matter of planning balance here, with significant weight to be attached to the benefits of meeting housing need where it arises, not least to avoid unsustainable travel patterns. We do recognise also the importance to be attached to focusing new development in accessible locations (JLP para 3.5.3); protecting and enhancing the local environment (JLP para 3.5.8); maximising the provision of affordable housing (JLP para 3.5.10); conserving the landscape and scenic beauty of the Chilterns Area of Outstanding Natural Beauty, (JLP para 3.5.9); and the need for a strong Green Belt policy (JLP para 3.5.7). In relation to this last Strategic Objective, the JLP references the importance of establishing a Green Belt boundary that will endure beyond 2036. This is an appropriate Strategic Objective, which fits with national Green Belt policy. The issue is that having undertaken a full Green Belt Assessment, looking at all of the opportunities to meet the needs of Chiltern and South Bucks locally, why is there reference in the JLP (paragraph 3.5.7) to the need for further consideration of the Green Belt boundary to the north of Slough, with the clear inference that there may need to be further amendments to the Green Belt boundary in this area prior to 2036. It seems perverse to countenance further Green Belt releases in the JLP area prior to 2036 to meet an adjoining authority’s unmet housing needs, but not to propose such releases to meet the existing needs of Chiltern and South Bucks District Councils.

2375 If there are opportunities to accommodate further development in Chiltern and South Bucks to the north of Slough (or indeed anywhere else in the JLP area) these opportunities ought to be taken forward as part of the current JLP, in the interests of good planning and to accord with the Memorandum of Understanding (July 2017), which requires that each authority does everything it possibly can to meet their own housing needs locally. Soundness mods - Are you proposing any modifications to Yes strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to We believe that it is possible for Chiltern and South Bucks Districts to identify improve its alignment to this test of soundness. Please be as precise additional sites for development in the Districts now (rather than in a Local Plan and succinct as possible. review), which would reduce the level of unmet housing need to be accommodated in Aylesbury Vale, and increase the likelihood of the housing requirement figures for both Chiltern and South Bucks Districts, and the wider Buckinghamshire HMA, being delivered in the period to 2036. We do not believe that the publication version JLP has struck the right planning balance. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1222959 Full Name Avtar Kudhail ID 6810 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee:

2376 Date Received - Date Received: Duty to Cooperate 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 Legally Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the 1. I support the draft Local Plan and find it to be legal and sound Local Plan is/is not legally compliant, including references to 2. The land off High View has been in the Green Belt for more than 60 years relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. 3. The land off High View is highly regarded by the Chiltern District Council as Green Belt land 4. Strongly object to Paradigm Housing intending to challenge the Green Belt assessment of a plot of land off High View 5. Traffic congestion and pollution due to more traffic. Environmental issues (ideas): carbon foot print / carbon emissions /global warming 6. Inevitable felling of trees/shrubbery during the development 7. Loss of wildlife habitat. Badgers, bats, deer, birds all reside in the land off High View 8. Geological concerns. Area is historically known for being prone to subsidence and sink holes 9. Loss of open spaces. Less green areas for everyone to enjoy 10. Increased waiting times at your Medical Centre to see a GP/Consultant/Dentist 11. More competition for a child place at your local school Legally compliant b - Are you proposing a modification to make the No Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Yes Soundness? Soundness mods - Please give details of why you consider this Local I√ believe that the draft Local Plan is sound. Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to No strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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

2377 PP 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 5501506

Person ID 1223285 Full Name James Latham ID 4797 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 Non-Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Is not compliant as does not have proper regard to National Policy. Local Plan is/is not legally compliant, including references to There is no sustainability appraisal which has been developed in line with NPPF. relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. The Head of Policy at South Bucks DC who has a key role in the development of this Joint Plan has conflicts of interest which have not been addressed. Legally compliant b - Are you proposing a modification to make the Yes Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) Removal of swathes of Green Belt in South Bucks in particular does not comply below:You will need to say why this modification(s) will make the with National Policy in terms of meeting 'exceptional circumstances'. No evidence Local Plan legally compliant/strengthen its legal compliance. Please is provided to support this through a thorough sustainability appraisal. be as precise and succinct as possible. Review of the role of the Head of Policy for South BC in the development of the Local Plan Reference to key local housing supply and demand analysis and not inflated Government housing Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local An assessment of local housing needs and its profile needs to be carefully Plan is/is not sound, including references to relevant legislation, considered before anything else in the assessment of demand for housing. The policies and/or regulations. Please be as precise and succinct as NPPF figures are not reliable. possible. Soundness mods - Are you proposing any modifications to Yes strengthen the Plan's ability meet the test of soundness?

2378 Policy 1a - Please specify how you would modify this policy to All non-Greenfield options in this Local Plan and other available options on improve its alignment to this test of soundness. Please be as precise brownfield sites and sites to the north of Bucks should be considered under the and succinct as possible. new Bucks Unitary Authority when in place. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a No modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1223065 Full Name Barry Moxley ID 4715 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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.

2379 Legally compliant a - Please give details of why you consider the This is the first time I have attempted to respond to a consultation. For many Local Plan is/is not legally compliant, including references to reasons if it is designed to encourage comments rather than prevent them it is relevant legislation, policies and/or regulations. Please be as precise extremely badly designed including: and succinct as possible. • Plan is complicated and not written in plain English. • Online submission is not reliable. After filling in the form for an hour I received the following message: An error occurred while submitting the form. [REPM101] Representation can't be created for this event and consultee I and others will not take the time to repeat the exercise. • Serious health and safety issues appear to have been ignored in preparing the plan. There is no evidence that risk assessments have been completed to safeguard in particular school children. Finalisation and agreement of the plan without doing so could be considered negligent on the part of counsellors and those preparing the plan, rendering them liable to potential prosecution in the event of accidents. • Consultation is flawed for the reasons above. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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.

2380 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 1223101 Full Name John Spencer ID 4702 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 Legally Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the No Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Yes Soundness? Soundness mods - Please give details of why you consider this Local I strongly agree that the draft local plan is legal and sound and I am very happy Plan is/is not sound, including references to relevant legislation, that the Green Belt land is being protected for the next generation of Chalfont policies and/or regulations. Please be as precise and succinct as St Giles villagers possible. I am now very aware that Paradigm Housing are intending to challenge this green belt assessment for land off of High View and I very strongly object to it. This is being done in the guise of affordable housing but it is very clear that this is being used to try and swerve round the green belt allocation. I find it abhorrent that people can try and change green belt just for profit As everyone is aware that this particular piece of green belt is highly regarded and has not been mentioned in the local draft plan as one of 15 potential sites so why is this now being thought of as a possible development? I was very happy to hear that Chiltern district council are following the National Planning Policy Framework guidelines as I believe 99 houses were rejected for a plot of green belt in Chesham which is very similar to High View Not only would this development impact on loss of open spaces and wildlife but this particular area is certainly not suitable for the huge disruption and huge change in traffic that would inevitably happen if this site is developed The traffic congestion alone would be unsustainable as Stylecroft Road would never be able to cope with it and this has to go down as speculative development If this area was developed the impact on schools and doctors waiting times would of course be huge I am hugely against this and strongly oppose it Soundness mods - Are you proposing any modifications to No strengthen the Plan's ability meet the test of soundness?

2381 Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a No modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 5502320

Person ID 1223112 Full Name Clare Yabsley ID 4665 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 Non-Compliant be legally compliant/non-compliant.

2382 Legally compliant a - Please give details of why you consider the The Local Plan should be dismissed as it does not reflect the wider economic Local Plan is/is not legally compliant, including references to needs of Buckinghamshire. It should be reviewed as part of the new Unitary relevant legislation, policies and/or regulations. Please be as precise Authority . and succinct as possible. The Portfolio Holder for Planning and Economic Development, South Bucks DC has conflicts of interest in his dealing with the development of the Local Plan which have not been addressed. Legally compliant b - Are you proposing a modification to make the Yes Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) The Local Plan should be dismissed but the contents reviewed as part of a wider below:You will need to say why this modification(s) will make the Unitary Authority assessment. Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local It does not reflect the changing nature of local housing needs. Plan is/is not sound, including references to relevant legislation, Considerable Green Belt land earmarked for release around Beaconsfield has policies and/or regulations. Please be as precise and succinct as not been justified or demonstrated to be an 'exceptional circumstance'. possible. Soundness mods - Are you proposing any modifications to Yes strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to The contents of the Local Plan should be reviewed in light of the policies and improve its alignment to this test of soundness. Please be as precise views of a wider Unitary Authority. and succinct as possible. Remove any reference to removal of Green Belt land around Beaconsfield except Wilton Park which is developable land in the Green Belt. The rest of the development of Green Belt land is not sustainable. There is too much congestion - rail and road which is at capacity. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a No modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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

2383 Full Name Mrs Estelle Foster ID 5205 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 Legally Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Yes Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) The local plan needs to strengthen compliance by stating details about how below:You will need to say why this modification(s) will make the public Transport could be improved in the Chesham and Amersham, e.g. by Local Plan legally compliant/strengthen its legal compliance. Please recommending park and ride, and improved bus stops -access and space for be as precise and succinct as possible. buses. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local Policy regarding ensuring impact upon green belt is minimised is unclear. Just Plan is/is not sound, including references to relevant legislation, saying that impact must be mitigated as far as possible is insufficient. It policies and/or regulations. Please be as precise and succinct as applications comply. possible. Soundness mods - Are you proposing any modifications to Yes strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to Identify specific areas where new trees could be planted in the N East of Chesham. improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the This is difficult to appraise. The consultation form demands knowledge which Local Plan has met/not met the requirements of the Duty to the average resident doesn't have. therefore the consultation itself is unsound. Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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.

2384 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 1223254 Full Name Gold Hill Baptist Church ID 6510 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Charity/Religious Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Gold Hill Baptist Church Person ID 1223253 Full Name Ian Gillespie Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local Spatial Vision – Section 3.4 Plan is/is not sound, including references to relevant legislation, Strategic Objectives – Section 3.5 policies and/or regulations. Please be as precise and succinct as possible. Please fill in the form below if you believe this policy does not meet the four tests of Soundness; positively prepared, justified, effective and compliant with the National Planning Policy Framework Feb 2019. We believe the Local Plan is unsound, because it has not been positively prepared, does not represent the most appropriate strategy (when considered against reasonable alternatives) and because there are significant concerns over deliverability. We also raise concerns in relation to compliance with the NPPF Feb 2019. The Spatial Vision is very generic and isn’t very spatial. It does not explain the reasoning for the proposed distribution of development across the two Districts, with reference to the hierarchy of settlements.

2385 The Spatial Vision does refer to meeting needs locally (i.e. within Chiltern and South Bucks) but if this is not possible, the authorities will work with adjacent Local Plan areas (i.e. Aylesbury Vale District Council) to meet these needs elsewhere as part of sustainable development proposals. There is clearly a matter of planning balance here, with significant weight to be attached to the benefits of meeting housing need where it arises, not least to avoid unsustainable travel patterns. We do recognise also the importance to be attached to focusing new development in accessible locations (JLP para 3.5.3); protecting and enhancing the local environment (JLP para 3.5.8); maximising the provision of affordable housing (JLP para 3.5.10); conserving the landscape and scenic beauty of the Chilterns Area of Outstanding Natural Beauty, (JLP para 3.5.9); and the need for a strong Green Belt policy (JLP para 3.5.7). In relation to this last Strategic Objective, the JLP references the importance of establishing a Green Belt boundary that will endure beyond 2036. This is an appropriate Strategic Objective, which fits with national Green Belt policy. The issue is that having undertaken a full Green Belt Assessment, looking at all of the opportunities to meet the needs of Chiltern and South Bucks locally, why is there reference in the JLP (paragraph 3.5.7) to the need for further consideration of the Green Belt boundary to the north of Slough, with the clear inference that there may need to be further amendments to the Green Belt boundary in this area prior to 2036. It seems perverse to countenance further Green Belt releases in the JLP area prior to 2036 to meet an adjoining authority’s unmet housing needs, but not to propose such releases to meet the existing needs of Chiltern and South Bucks District Councils. If there are opportunities to accommodate further development in Chiltern and South Bucks to the north of Slough (or indeed anywhere else in the JLP area) these opportunities ought to be taken forward as part of the current JLP, in the interests of good planning and to accord with the Memorandum of Understanding (July 2017), which requires that each authority does everything it possibly can to meet their own housing needs locally. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to We believe that it is possible for Chiltern and South Bucks Districts to identify improve its alignment to this test of soundness. Please be as precise additional sites for development in the Districts now (rather than in a Local Plan and succinct as possible. review), which would reduce the level of unmet housing need to be accommodated in Aylesbury Vale, and increase the likelihood of the housing requirement figures for both Chiltern and South Bucks Districts, and the wider Buckinghamshire HMA, being delivered in the period to 2036. We do not believe that the publication version JLP has struck the right planning balance. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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.

2386 PAa - Please specify as precisely and 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 1223665 Full Name Ian Mortimer ID 6837 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 Legally Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the We are in support of the Local Plan and its housing strategy both of which appear Local Plan is/is not legally compliant, including references to to follow legal guidance. relevant legislation, policies and/or regulations. Please be as precise As the local housing demand has been met in the Local Plan we see no reason and succinct as possible. why Paradigm Housing should need to be seeking to use green belt land. Better for Paradigm to work with the council to better use the council designated land for housing and/or brownfield sites. We believe that the housing demand can be met for many years if the Local Plan is followed and identified brown field sites are used in preference to Green Belt lands. The loss of Green Belt land will significantly adversely affect the local ecology. It will also greatly reduce the “green lung” giving recreational space for local residents. Once lost to developers Green Belt lands and all the benefits they bring can never be reclaimed. Legally compliant b - Are you proposing a modification to make the No Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Yes Soundness? Soundness mods - Please give details of why you consider this Local We believe that the draft Local Plan is sound Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to No strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence

2387 Plan-Level: Duty to Co-operate - Do you consider the Local Plan to Met have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a No modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 5501502

Person ID 1224417 Full Name DLA Town Planning ID 6865 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID 1224416 Full Name Simon Andrews Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance?

2388 Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local Summary Plan is/is not sound, including references to relevant legislation, 2.2.1 The export of unmet housing need to Aylesbury Vale is not justified, either policies and/or regulations. Please be as precise and succinct as by the evidence on available alternatives within the Plan area or by the reasonable possible. alternatives considered through the Sustainability Appraisal process; Commentary 2.2.2 The Councils’ approach to meeting housing need in the two districts is set out in the Strategic Objectives, in Table LPb and in Policy SP LP1. In essence, the approach proposes: • Development of existing sites and commitments; • Development of Green Belt review recommended sites; • Exporting remaining unmet need to Aylesbury Vale. 2.2.3 The contribution from each source of housing is set out in Table 1 below. The total housing planned to be delivered in the Chiltern and South Bucks areas combined equates to 10,417. This conflicts with the calculations in Table LPb in the draft Local Plan, which appears to contain some arithmetical errors. Table 1: Sources of housing supply Source No. of homes % of homes Completions and committed sites 2,976 18.48% Assumptions about future windfall and site delivery 2,241 13.92% Development of Green Belt review recommended sites 5,200 32.29% Exporting remaining unmet need to Aylesbury Vale 5,687 35.31% Total 16,104 100% 2.2.4 Paragraph 59 of the NPPF emphasises the importance of meeting housing need, stating: “To support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed, that the needs of groups with specific housing requirements are addressed and that land with permission is developed without unnecessary delay.” (emphasis added) 2.2.5 Meeting housing need is not just a numbers game but is about providing homes for local people. Exporting one-third of the housing need (and over half of all new proposed allocations) across Chiltern and South Bucks to Aylesbury Vale is a substantial strategic policy-making decision and one with profound social, environmental and economic implications. 2.2.6 The Memorandum of Understanding between Chiltern, South Bucks and Aylesbury Vale includes reference to the “surplus” of housing currently included within the Vale of Aylesbury Local Plan (VALP). The VALP provides around 57% of housing around Aylesbury town itself, with almost 20% around the villages of Buckingham, Haddenham, Winslow and Wendover. 2.2.7 While Chiltern technically falls within the same “best fit” Housing Market Area as Aylesbury Vale, South Bucks was found to fall within the Reading and Slough Housing Market Area. Irrespective of where Housing Market Area boundaries are drawn, the decision to move households from one district to another, often over quite a distance, will have significant consequences. 2.2.8 While parts of Chiltern district are relatively close to Aylesbury, Amersham – the largest settlement in Chiltern district – is around 15 miles and 30 minutes by car from Aylesbury. Gerrards Cross is around 22 miles and 40 minutes by car from Aylesbury. Some of the “surplus” housing will be provided in Buckingham, in the north of Aylesbury Vale, which is considerably further way from where the housing need is arising. 2.2.9 The consequences of not meeting housing need where it arises has not been adequately considered, or considered at all, as reasonable alternatives through the Sustainability Appraisal process. The most recent assessment in 2019 provided a suite of four options: • Do nothing; • Export all housing need to Aylesbury Vale; • Use all non-Green Belt sites and export remaining housing to Aylesbury Vale; • Use all non-Green Belt sites and recommended Green Belt sites and export remaining housing to Aylesbury Vale. 2.2.10 It can be seen from these four options that a strategy of accommodating all housing need within Chiltern and South Bucks has not been assessed as a reasonable alternative. Given the potential social, environmental and economic

2389 consequences of relocating 5,687 households from within Chiltern and South Bucks to neighbouring Aylesbury Vale, the failure to assess this option as part of the sustainability appraisal process is a fundamental flaw in the draft Local Plan. 2.2.11 The soundness tests in Paragraph 35 of the NPPF requires a local plan to be “justified” i.e. “an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence”. 2.2.12 It cannot be disputed that exporting housing need to a neighbouring district is a sub-optimal strategy for development. As a general principle, it is better to accommodate housing need where it arises. The Councils’ position appears to be that the Green Belt prevents this. However, in determining whether exporting housing need is an appropriate strategy it is vital to understand, firstly, the nature and extent of harm to the Green Belt and, secondly, the wider implications of the relocation of housing need. A balancing exercise is then required weighing up the costs and benefits of the strategy. This exercise has not been undertaken and the Inspector cannot therefore be confident that the strategy is sound. 2.2.13 The Councils’ chosen strategy was assessed through the Sustainability Appraisal but the findings concluded a “major positive impact” in respect of housing. Paragraph E.3.11.1 states: “It is assumed that the provision of 5,200 homes within this policy would satisfy the housing need for Chiltern and South Bucks over the Plan period and would therefore have a major positive impact on the local housing provision.” 2.2.14 5,200 homes would manifestly not satisfy the housing need in Chiltern and South Bucks over the plan period. Satisfying the housing need requires a further 5,687 homes to be delivered in Aylesbury Vale. Accommodating 10,887 homes in Chiltern and South Bucks would satisfy the housing need and would justify a “major positive impact”. Accommodating just 5,200 would result in a “minor positive impact” but would also result in negative impacts, particularly social and economic, as housing need is not being met where it arises, but also environmental impacts, for example from increased travel. 2.2.15 The Councils’ Sustainability Appraisal framework defines 12 Objectives against which the draft Local Plan has been assessed. The relocation of housing need outside the Councils’ areas may have a number of sustainability impacts that relate to these objectives, as described below: • Increased travel – while homes may be provided in Aylesbury Vale, reality suggests that residents’ jobs will remain within the Local Plan area. The export of housing need could therefore result in extended journeys to work as residents commute from Aylesbury and Buckingham to employment locations within Chiltern and South Bucks. Increased travel will have a negative impact on objective 4 (Climate change mitigation), objective 7 (pollution) and objective 9 (Transport and accessibility, which specifically aims to reduce the need to travel); • Housing – as described above, accommodating housing need 15-30 miles from where it arises is sub-optimal and doing so would have negative consequences in terms of sustainability objective 10 (Provide affordable, environmentally sound and good quality housing for all); • Health and social well-being – relocating households can often have social consequences as households are removed from social circles and end up further from family and friends • Economy - The Councils need to ensure there is broad alignment between the number of homes planned and the jobs forecast. The last assessment of the balance was undertaken in the 2016 HEDNA update. This concluded that 315 workers per year would be needed in Chiltern district and 320 workers per year in South Bucks. While there may be a broad balance between jobs and homes if housing need was being met in full, there does not appear to be an assessment of the balance resulting from the strategy to export unmet housing need to Aylesbury Vale. The strategy is likely to have negative economic consequences (SA objective 12 – Economy) and these have not been assessed. 2.2.16 The lack of consideration and assessment of these issues is highlighted in the Councils’ assessment of spatial option B (exporting almost all of the area’s housing need to Aylesbury Vale). This option scored a “minor positive impact” in terms of housing, despite the vast majority of housing not being met where it arises. The impact on housing should be negative under this option. Similarly, the impact of this option on the local economy was also “minor positive”, whereas the impact of only providing a fraction of the homes needed locally should surely result in a negative economic impact. The impacts on increased travel (objective 9) and the resulting climate change (objective 4) and pollution (objective 7) implications were simply not acknowledged in the SA process. This illustrates the lack of understanding by the Councils of the negative impacts of exporting housing need to Aylesbury Vale. 2.2.17 In summary, the negative social, environmental and economic consequences of relocating households from Chiltern and South Bucks districts to Aylesbury Vale district have not been fully assessed. The option of not relocating households in this way and meeting housing need in full where it

2390 arises has not even been assessed as a potential option. This option is clearly a “reasonable alternative” against which the NPPF requires the chosen option to be tested. In the absence of such testing, the draft Local Plan cannot be found sound. Soundness mods - Are you proposing any modifications to Yes strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to The Local Plan needs to accommodate more of the unmet housing need within improve its alignment to this test of soundness. Please be as precise Chiltern and South Bucks, rather than exporting the unmet need to Aylesbury and succinct as possible. Vale. The evidence base needs to be revisited. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 5503433

Person ID 1224512 Full Name Chesham & District Natural History ID 6870 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty 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

2391 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 will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Deletion of Policy NC3 Plan is/is not sound, including references to relevant legislation, We regret the deletion from the existing local plan of Policy NC3 – creation of a policies and/or regulations. Please be as precise and succinct as Local Nature Reserve at Weirhouse Mill. Although the site has deteriorated due possible. to lack of management, we believe that the Local Plan should encourage the designation of a LNR here or elsewhere on the River Chess to identify the importance of this river to the wildlife of the area and to local residents. In fact rather than a specific nature reserve, the whole valley of the River Chess should be designated as a Special Area of Conservation (SAC) as the river is one of the best, if not the best, of the chalk streams in the Chilterns and needs to be subject to conservation measures to maintain and improve its status and quality. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why

2392 Policy 3a - Please specify as 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 1224589 Full Name Farmglade ID 6295 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID 1224588 Full Name Brendan Joy Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local Plan Level: Soundness Plan is/is not sound, including references to relevant legislation, Farmglade considers the Consultation Draft Local Plan (the Plan) to be unsound policies and/or regulations. Please be as precise and succinct as in its present form but believes it could be made sound by the amendment of possible. sections as stated in this detailed representation. Statement on Soundness Submissions were previously made by Farmglade to earlier consultation as follows: - Initial Consultation and Call for Sites, April 2015. - Call for Sites process, January 2018. Farmglade `act as agents for other Group companies which own the freeholds of the relevant sites. Specifically in relation to this Plan, Farmglade make comments in relation to landholdings at: 1. Longbottom Lane, Beaconsfield - Learmount Castle Developments Ltd are owners of 27 acres of land to the east of the junction with Amersham Road. This land is currently open space within the Green Belt, with an existing structure on part of the site. It has a planning permission for a recreational use (6 hole golf course). 2. Tatling End – Capswood Investments Ltd are owners of the site of Phoenix House. The Consultation draft of the Chiltern and South Bucks Local Plan (The Plan) covers the 20 years to 2036, during which time, it will seek to deliver 15,026 new homes. 11,000 of these are intended to be within the Plan area and 5,750 in Aylesbury Vale. The Plan states that Chiltern and South Bucks have worked with Aylesbury Vale District Council (AVDC) in the preparation of this consultation draft Plan. As

2393 such, Chiltern and South Bucks have an agreement to deliver part of their housing requirement through the AVDC Local Plan. The level of growth in the Chiltern and South Bucks Consultation draft Plan will require a delivery rate of 763 new homes per annum for the next 20 years in Chiltern and South Bucks. This is a challenging rate and level of growth for this area in the context of recent delivery rates, which have been below this level. The focus of this growth is intended to be driven by development in built up areas and on previously developed land. It should make efficient use of land and permitted development already in place. This is in accordance with national policy in the NPPF (paragraph 117). 87-88% of the Chiltern and South Bucks area lies within the Green Belt. In this context, Farmglade supports the approach of seeking to release areas of Green Belt to deliver the growth needed in this Plan period, in accordance with the Council’s Green Belt review. This approach to review and release of Green Belt land is in accordance with paragraph 136 of the NPPF. Farmglade therefore support the Spatial Vision of the Plan at 3.4. In terms of the Strategic Objectives at 3.5; Farmglade supports these and in particular notes the intention to: - Address traffic issues at the A355 Corridor in Beaconsfield (at Longbottom Lane) - Reconsider the Green Belt boundary. Farmglade represents companies with landholdings in Beaconsfield directly to the south east of the junction on the A355 at Longbottom Lane, which are not allocated in this Plan, but which are believed to offer a future development opportunity in this area and which would expand upon the development and growth to the East of Beaconsfield and could assist in the delivery of upgraded infrastructure to facilitate this. Farmglade supports the overall aims of the Plan, and, as a housebuilder and developer with land in the area both within the built up areas and within the Green Belt, is well placed to assist in the delivery of much needed homes within this Plan period and in accordance with the stated strategy of this Plan. In terms of economic growth; it is noted that there are over 2,000 businesses in the area and that the Council seeks to promote sustainable economic growth. Farmglade support this and the means of promoting sustainable growth at page 5 of the Plan. It is however considered that this must be achieved in the context of the delivery also of much needed homes and recognising that employment and economic growth would be held back without adequate homes. Economic and employment growth should be focussed in approrpiate locations and not at the expense of residential development. Farmglade’s position in relation to this Plan is therefore as follows: 1. Strategic Objectives – Farmglade overall support the Strategic Objectives of the Plan as set out at 3.5. 2. Housing – The delivery of new homes is imperative. This is an area with significant housing need and where demand is having a direct impact on raising house prices. This Plan has a strategy for delivering new homes, but it is heavily reliant on Aylesbury Vale District Council (AVDC) for achieving this. Whilst there is an agreement in place with AVDC for this, this is reliant on their delivering a challenging target to achieve this. In this context, it is considered Chiltern and South Bucks could do more and identify further areas of land for housing delivery during this Plan period in order to make this Plan sound. This could have been further progressed through the work of the Berkshire Strategic Housing Market Assessment (SHMA) and it is not clear why this has not formed part of the ongoing Plan work for South Bucks. 3. Employment – The Plan also recognises that it is imperative to support and grow employment and the economy in this area. The Plan seeks to do this through focussing growth around existing employment locations and transport hubs. It is believed that this is a suitable strategy, but that there are sites identified for this growth, such as at Tatling End, which whilst representing an existing employment area are not fulfilling these aspirations – they are not in an EZ or near any transport hubs. These areas could therefore make an alternative equally valuable residential contribution, whilst focussing employment on more suitable locations such as Uxbridge and Slough. 4. Green Belt – The release of Green Belt land to assist with housing provision is supported in appropriate locations. Specifically, at Tatling End for example, release in this area has been supported by Farmglade in previous representations. However, it is not clear as to why the Phoenix House site should only be released for employment use and why this was not assessed for residential use in the Green Belt review and Sustainability Appraisal. Furthermore, at Beaconsfield, there is scope to look at further Green Belt release for housing and to assist in the delivery of junction improvement work at the A355/Ledborough Lane/Longbottom Lane junction. This is a key transport interchange location, which currently relies on its delivery based on a single land allocation. By identifying additional land for development in this area which could further contribute to this infrastructure, this would reduce the risk in terms of its delivery,

2394 but any such land should be identified now as part of the Local Plan process, in accordance with paragraph 136 of the NPPF. Soundness mods - Are you proposing any modifications to Yes strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to Modifications to policy to meet the tests of soundness. improve its alignment to this test of soundness. Please be as precise We have set out proposed modifications to ensure the soundness of the Plan in and succinct as possible. the context of the issues set out above in relation to the specific policies of the Plan. Overall it is deemed however that the Plan is unsound as follows: The strategy of reliance on Aylesbury Vale to deliver a significant proportion of the known housing need is unsound. Not only does this place reliance on an area with an already challenging growth figure, it will not reduce the pressure of demand for homes in South Bucks and will not provide housing to support the employment growth around Slough, Uxbridge, the Thames Valley and West London. Further work should be undertaken to look at further sites which are available within the Plan period and in the area of Chiltern and South Bucks which could deliver more of this need in the Plan period. This could include areas such as: - Farmglade’s land at Longbottom Lane, which could form a logical and sustainable extension to the allocation East of Beaconsfield, and - At Tatling End, where an employment designation is proposed, but which could assist in meeting vital housing need as opposed to employment, for which there are more suitable locations in existing centres such as Slough and Uxbridge and around transport hubs. The Plan would be more effective in reconsidering these matters. The Plan should be reconsidered to ensure that the locations for employment growth reflect the objectives of the Plan in terms of the location and nature of growth. For example, Tatling End could make a sustainable location for housing delivery but does not necessarily fulfil the criteria in terms of employment growth locations. Further consideration is required in this regard to ensure that the Plan is justified and is capable of meeting its delivery requirements in terms of housing need. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why

2395 Policy 3a - Please specify as 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 1224143 Full Name Land and Partners ID 5919 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty 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 Non-Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the The Plan is not consistent with national policy as it conflicts with Local Plan is/is not legally compliant, including references to the National Planning Policy Framework (“the NPPF”), which is national relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. policy and advice that the Councils must have regard to when preparing their Plan (Section 19(2) of the Planning and Compulsory Purchase Act 2004). The Plan is not consistent with the NPPF in the following ways: • It does not deliver sustainable development, which is the NPPF’s core concept and is set out in Paragraphs 7 and 8 of the NPPF, particularly in terms of providing sufficient numbers of homes and sufficient land of the right type and in the right place. • It does not meet NPPF paragraphs 136-138 that alteration of Green Belt boundaries are not fully evidenced and justified (having regard to their intended permanence in the long term so they can endure beyond the Plan period) and in terms of promoting sustainable patterns of development, particularly in relation to the town of Slough and transport nodes into London and Heathrow. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local 1.1. The Local Plan does not comply with Section 20(5)a of the Planning Plan is/is not sound, including references to relevant legislation, and Compulsory Purchase Act 2004 (the Act). Specifically, the Plan policies and/or regulations. Please be as precise and succinct as possible. does not have regard to the National Policy issued by the Secretary of State as required by Section 19(2)a of the Act. 1.2. Paragraph 26 of the NPPF states that effective and on-going joint working is integral to plan making. The Plan is not based on effective and on-going joint working with Slough Borough Council (BC), where there is a strategic cross-border issue that the Plan does not address. The unmet housing need within Slough BC has been brought to the attention of Chiltern and South Bucks throughout the Plan-making

2396 process, but has not been taken into account in the spatial strategy. 1.3. Paragraph 27 of the NPPF states that in order to demonstrate effective and on-going joint working, strategic policy- making authorities should prepare and maintain one or more statements of common ground, documenting the cross-boundary matters being addressed and progress in co-operating to address these. There is no statement of common ground with Slough BC supporting this Plan. 1.4. The Plan has not had regard to paragraph 136 of the NPPF which states: “Strategic policies should establish the need for any changes to Green Belt boundaries, having regard to their intended permanence in the long term, so they can endure beyond the plan period.” 1.5. At paragraph 3.5.7 the Plan refers to a review of the Plan which considers further the Green Belt Boundary north of Slough. The new boundaries’ endurance beyond 2036 is conditional on this potential further consideration. The Plan is therefore in conflict with the NPPF as the proposed new boundaries are not permanent in the long term without further consideration. 1.6. These matters also relate to the duty to co-operate and the tests of soundness of the Plan. They are explained in greater detail in the relevant sections. 2.2. The Plan is not positively prepared for the following reasons: • The Plan is not sufficiently informed by agreements with other authorities so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development. Specifically, it should have accommodated the unmet needs of Slough - a large town directly on the border of the plan area. • The Plan should have reviewed Green Belt to consider the longer term requirements of Slough rather than defer this decision to a future plan. • The Plan does not provide a strategy which meets area’s objectively assessed needs due to errors in its calculation of housing land supply. 2.6. Table LPb on page 53 of the Plan is incorrect. The Total Supply in (K) sets out the housing requirement for the Plan area of 11,099. This is derived from (O) Overall supply needed minus (Q) Requirement needed from Vale of Aylesbury Local Plan. However, the components of supply are 682 homes short as only 10,417 is identified: (B) Completions (1,217) (D-F) Commitments (1,759) (H) Other HELAA sites (1,791) (I) Windfalls (450) (J) Site Allocations (5,200) 2.7. Also completions should actually be 1,217 according to Table LPa on page 51 of the Plan, giving a requirement for a further 46. 2.8. Therefore, the Plan does not provide a strategy which meets the area’s objectively assessed needs due to errors in its calculation of housing land supply. This means that its strategy is not deliverable over the Plan period. By not providing sufficient numbers of homes, the Plan will not deliver sustainable development as required by Paragraphs 7 and 8 of the NPPF. The South Bucks and Chiltern Plan preparation has proceeded on the basis of only addressing the housing needs of Buckinghamshire and to ignore those in Berkshire. They were clearly aware of the all the evidence of Slough’s unmet need throughout 2017 and RBWM’s stated inability to accommodate it, yet did not factor this in to their planmaking process at all. Slough BC had formally requested that South

2397 Bucks accommodate some of its unmet need in 2016, as set out in the Duty to Co-operate section below, but there was no political will to do so. • The approach of the Councils has been to assume the export of unmet need to Aylesbury Vale despite agreeing that the need would only be exported if it were impossible to accommodate within the Plan area. • The Plan does not accommodate housing need from Slough, despite Slough’s request for it to do so. • The Plan does not demonstrate that the development sites, and thus the overall spatial strategy, has been selected for inclusion in the Plan on a robust, consistent and objective basis. Potential siteshave been rejected and sites have been selected without adequate evidence and reasoning. • The influence of the town of Slough, adjoining the southern border of the Plan area, has not sufficiently influenced the spatial strategy. In particular, sustainable settlements close to Slough are not given sufficient consideration for growth, based on this proximity. • The influence of the transport nodes into London has not sufficiently influenced the spatial strategy. In particular, the new Crossrail/Elizabeth Line into London is not given sufficient recognition in terms of opportunities for growth. • Heathrow and its planned expansion has not sufficiently influenced the spatial strategy. The new Crossrail/Elizabeth Line link to this major employment location has not been considered. • The errors in the Plan’s calculation of housing land supply in the Plan means that its strategy is not deliverable over the Plan period. • The Plan is not based upon adequate joint working on a critical cross-boundary strategic matter. The development needs of Slough is a cross-boundary strategic matter and a request from Slough BC to assist with meeting this need has been rebuffed. A joint ‘Wider Area Growth Study’ has recently been commenced but this is not taken account of in the Publication Plan. It defers the housing needs of Slough BC and the associated Green Belt implications. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to 1.1. In order to demonstrate the Plan has had regard to paragraphs 26 improve its alignment to this test of soundness. Please be as precise and 27 of the NPPF, it needs to be based upon effective joint working and succinct as possible. on cross-border issues. The cross-border issue of Slough’s housing needs should be addressed within the Plan period and a statement of common ground between the neighbouring authorities should be produced. 1.2. In order to demonstrate that regard has been had to paragraph 136 of the NPPF, the Plan cannot rely on a review to ensure Green Belt Boundaries can endure beyond the Plan period. Therefore, the Green Belt Part Two Assessment, Green Belt Development Options Appraisal and associated allocations require rewriting based upon ensuring that the revised Green Belt boundary will endure beyond the Plan period. 1.3. The cross border issue of Slough’s housing needs is also a duty to co-operate issue which is addressed in the relevant section. The duty to co-operate relates to the preparation of the Plan so it cannot be rectified post-submission Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any

2398 non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1224202 Full Name BMO Real Estate Partners ID 6294 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Employer Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: BMO Real Estate Partners Person ID 1224201 Full Name Jon Wright Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to Legally Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the The Local plan is not legally compliant as the councils have not allocated sufficient Local Plan is/is not legally compliant, including references to sites suitable for residential development in order to meet the objectively relevant legislation, policies and/or regulations. Please be as precise assessed needs and these are not clearly identified on the Proposals Map as and succinct as possible. required by NPPF Paragraph 23. With regards to affordable housing, the plan is unduly prescriptive and fails to create any opportunity for different forms of affordable housing as defined in Appendix B of the NPPF.

2399 Legally compliant b - Are you proposing a modification to make the Yes Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) Sufficient major development sites such as the site at PerkinElmer, Chalfont below:You will need to say why this modification(s) will make the Road, Seer Green need to be allocated in order to meet objectively assessed Local Plan legally compliant/strengthen its legal compliance. Please needs. be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Yes Soundness? Soundness mods - Please give details of why you consider this Local In its current form the Local Plan is unsound on the grounds that it has not been Plan is/is not sound, including references to relevant legislation, positively prepared, effective or consistent with national planning policy. The policies and/or regulations. Please be as precise and succinct as Local Plan is not meeting the area’s objectively assessed need as a minimum possible. and is only explicitly identifying 11 sites for residential development, despite relying on many more sites through the HELAA assessment to meet its objectively assessed need. The Local Plan is unduly restrictive in terms of affordable housing provision and it has not been demonstrated that sites will be viable with the prescribed tenure mixes. It also currently fails to reflect the requirements of the Self-Build and Custom Housebuilding Act 2015, the implications of which are clearly set out in National Planning Practice Guidance. Soundness mods - Are you proposing any modifications to Yes strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to In order to make the Local Plan sound, there should be greater signposting of improve its alignment to this test of soundness. Please be as precise sites that are considered suitable through the HELAA process, and sites should and succinct as possible. be identified through land use designations, associated tables, maps and policies. A fresh review of HELAA sites should be undertaken, with a commitment to review the HELAA annually, with explicit policy support required to be given to sites identified as suitable in the HELAA. A mixture of affordable housing tenures should also be sought and determined by the characteristics of each site and residential scheme rather than the currently unduly restrictive policies. Furthermore, the Plan could be made sound by broadening the strategy for self-build to encompass sites for exclusively self-build housing. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why

2400 Policy 3a - Please specify as 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 1225807 Full Name Patrick Kelly ID 6807 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate 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 Legally Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the I fully support the Chalfont St Giles Neighbourhood Plan and Chiltern & South Local Plan is/is not legally compliant, including references to Bucks District relevant legislation, policies and/or regulations. Please be as precise Plan. and succinct as possible. I have recently been advised by Paradigm Housing that they intend to apply for Rural Exemption on the land off High View, Stylecroft Road, Chalfont St Giles, that has been in the Green Belt for over 60 years. I strongly object to this application and recommend that Rural Exemption Planning should be formally rejected for the following reasons • The Chalfont St Giles Neighbourhood Plan was approved via a referendum by 92% of the village. • The Green Belt land is protected under Section 10 of that plan. • The Neighbourhood Plan was approved by the Chiltern District Council • The Land off High View is regarded as Green Belt by Chiltern District Council • The National Planning Policy Framework Guidelines describes Rural Exception sites as “small sites suitable for Affordable Housing …. The application for High View is for c.90 houses which cannot be described as small. • A development of this nature would have serious implications for traffic congestion on Stylecroft/Kings Road and more specifically access to the already extremely busy A413. • The infrastructure surrounding the village would be unable to cope with this additional development. • Severe and increased pressure will be placed on School places in the local school as well as further increased waiting times at the Doctor's Surgery Legally compliant b - Are you proposing a modification to make the No Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible.

2401 Plan-Level: Soundness - Do you believe this plan meets the tests of Yes Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to No strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1224276 Full Name Startland Developments Limited ID 6877 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body?

2402 Agent on behalf of - Consultee is an agent on behalf of: Person ID 1223271 Full Name Paul Airey Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of No Soundness? Soundness mods - Please give details of why you consider this Local Soundness. I consider that the Plan is not sound for the following reasons: Plan is/is not sound, including references to relevant legislation, 1. The Plan has not been positively prepared in that while an agreement has policies and/or regulations. Please be as precise and succinct as been made with the neighbouring authority at Aylesbury Vale District Council possible. to accommodate 5725 units out of the total housing requirement for Chiltern and South Bucks, there has no similar agreement with Slough despite that authority preparing proposals for the northern expansion of Slough into the Borough. In these circumstances it is not possible to be certain that the calculated housing need and spatial strategy in the plan is sound. 2. The Plan is not justified because the housing strategy has underestimated the overall housing requirement in the Borough. It is noted that the table LP b (Homes Requirement and supply) shows in row N that the figures include an additional 10% to account for potential non-delivery of homes. This percentage, which generates a figure of 1,526, has been copied from the figure used in the draft proposal in the Vale of Aylesbury Local Plan. The figure was however questioned in the Inspectors Interim findings (29/08/2018). 17) At the time the evidence base was prepared there was no definitive guidance on what level of uplift for affordability is appropriate. Reference is made to professional judgments made by other examining Inspectors such as at Eastleigh and comparisons made between affordability in Eastleigh and affordability in the Central Buckinghamshire Housing Market Area to arrive at a recommendation for the Central Buckinghamshire HMA. Comparisons are also made within the Buckinghamshire HMA to arrive at different recommendations for Aylesbury Vale and for the rest of the HMA. 18) But, if these recommendations are tabulated, it becomes clear that the uplift recommended for VALP in comparison with Eastleigh is too low: Location Affordability ratio National comparison Uplift recommended England 7x Eastleigh 8.6x 20% higher 10% Aylesbury Vale 10.4x 50% higher 10% Bucks HMA 12.1x 75% higher 15% Rest of HMA 13.9x 100% higher 20% 19) The disconnect between the affordability ratio, the national comparison and the uplift recommended for Aylesbury Vale is obvious. An affordability ratio for Eastleigh 20% higher than the national average leads to a recommendation for a 10% uplift. An affordability ratio for Aylesbury Vale 30% higher still leads to no further recommended uplift yet an affordability ratio for the Buckinghamshire HMA only 25% higher leads to an uplift 5% higher as does the increase in the affordability ratio for the rest of the HMA excluding Aylesbury Vale. Even if the 20% uplift for the rest of the HMA is correct, the uplift for VALP should be 15% to be in proportion with that recommended for Eastleigh and that for the whole HMA should be about 17-18%. Moreover, more recent evidence shows the differences between Aylesbury Vale and the rest of the Housing Market Area decreasing which suggests that the uplift for VALP should more likely be 20% than 15%. On the basis of the above, it would appear that the housing requirement for the Plan area has been underestimated. If the 10% uplift is changed to 20% as it appears it should be, then the uplift adjustment will increase from 1526 to 3052. This will increase the overall shortfall (row P) to 7213 units. The agreement with

2403 Aylesbury Vale allows for only 5725 units which means that the Plan under-provides by 1488 housing units. Under these circumstances there is a need for significant additional housing provision within the Plan. 3. The Plan is not effective because it does not properly deal with cross-boundary strategic housing matters and does not provide sufficient housing allocations to meet the OAN, as detailed above. 4. The Plan is also not consistent with government policy. NPPF paragraph 67 requires the Council to identify a supply of: a) specific, deliverable sites for years one to five of the plan period; and b) specific, developable sites or broad locations for growth, for years 6- 10 and, where possible, for years 11-15 of the plan The Plan does not allocate sufficient sites or broad locations for growth to meet the requirement and as a result this is contrary to current Government Policy. It is also considered that at least one of the housing allocations made (SB BP 11) is not necessarily deliverable in the required timescales. Further details of this are considered below in respect of specific policy considerations. Soundness mods - Are you proposing any modifications to Yes strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to To help meet the shortfall in housing allocations a site (HELAA ref 0299) to the improve its alignment to this test of soundness. Please be as precise east of Richings Park is put forward to be considered as a new allocation. This and succinct as possible. site has previously been submitted to the LPA as part of the plan making process, but has not been included in the Plan despite representations being made at both the Local Plan Reg 18 stage and the Green Belt Preferred Options consultation in 2016. The site, which is referred to as SBO299 in the HELAA and is under a single ownership, is approximately 5.77 ha in size and lies between Thorney Lane, South and the M25. It is bounded on the north by the main rail line to London. The site is immediately adjacent to the settlement boundary for Richings Park but is currently in designated greenbelt. Planning permission has recently been granted for a commuter car park at the north west corner of the site, to serve the soon to be upgraded railway station at Iver (Crossrail). A considerable amount of work has been undertaken to demonstrate that the site is both available and deliverable and the following documents are submitted in support of the site. 1. A draft layout plan of the site providing for 136 two storey houses on the site ranging from 2 to 5 bedrooms. A relatively high density of development is proposed due to the sustainability of the site and the proximity of the rail station. The layout has been guided by the results of the other surveys undertaken particularly the archaeological assessment (see below). 2. A Phase 1 Ecology Survey which concluded that it was considered unlikely that there will be any overarching ecological constraints to developing the site. 3. A Landscape and Visual Impact Assessment and a critique of the Green Belt Review process that was undertaken by the Council, by Lizard Landscape Design and Ecology. The LVIA incorporates a Capacity Study in line with assessment criteria within the 2017 Terra Firma produced Landscape Capacity Study for Green Belt Development Options (2017), and informed by a desktop study, site visit and photographs from publicly accessible land. The site is provided with a comparable level of assessment to justify its removal from the Green Belt. This report is significant as it firstly questions the basis of the Council commissioned assessment which included the land as part of a much wider area of land to the south of Richings Park (site 99) but then failed to undertake a more detailed assessment of this discreet and isolated area of land, despite having done so for another site within the wider area. Secondly, the study concludes that the site is consistent with the general suitability of areas for development identified by Terra Firma for alternative sites within the Study Area. 4. An Archaeological Assessment and Geophysical Report confirming the presence of Archaeological remains on part of the site, but questioning the exact location of the Scheduled Ancient Monument. 5. A site survey confirming the features and contours of the site. The site is within Flood Zone 1 and it is considered that there are a range of options for dealing with run-off within the site. It is also considered that there is likely to be adequate service provision within the area for a development of this size. The site’s primary benefits are its location adjacent to the railway station at Iver and the community facilities at Richings Park. It is considered that these factors should have been afforded much greater weight during the site selection process. In addition the Green Belt Assessment was flawed in respect of this site. Plan-level upload - Please upload any supporting evidence

2404 Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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 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 1225851 Full Name Ciaran Nagle ID 6840 Order 1 Number Title Foreword Organisation Details Consultee Type - Please select the type of consultee: Individual/Resident Date Received - Date Received: Duty to Cooperate 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 Legally Compliant be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the I am writing this submission on my own behalf. But whilst engaging and speaking Local Plan is/is not legally compliant, including references to with many people in my village I discovered that my concerns were shared by relevant legislation, policies and/or regulations. Please be as precise almost every one of them. This submission therefore has the tacit backing of a and succinct as possible. large segment of the local population. There is nil/negligible support for any change in status of the Green Belt.

2405 I am aware that some organisations stand to gain a significant pecuniary advantage if the land off High View (HV) is developed. I believe such a proposed development a) is wrong, b) is unnecessary, c) is harmful and d) does not have the support of the village. I believe the Local Plan is correct and does not need changing. I wish to make the following points in defence of the Local Plan: 1. The Green Belt Assessment of 2016 commissioned by C&SB DC was completed and is available online. The Neighbourhood Plan and the Local Plan refer to this document in Section 10: Protected Places so we are to assume that the Local Plan is based on the 2016 Assessment. 2016 is only three years ago which means that it is current and up to date. We can not accept any suggestion that any of these documents – or their contents – are out of date. 2. If any potential developer argues that the HV site was ‘incorrectly assessed’ then they are questioning the professional expertise of the Planning Inspector(s) who carried out the assessment. 3. If any potential developer successfully argues that the HV site was ‘incorrectly assessed’ then they are setting up exactly the conditions that would encourage further challenges not just to the assessment of the HV site, but to every conclusion arrived at in the Assessment and also the Neighbourhood and Local Plans. Once weakened, all of these planning documents will become susceptible to challenges from more and more developers who will be able to argue that if one assessment was incorrect, maybe other assessments are incorrect. CDC will need to allocate time and resources to bolstering the correctness of all their other conclusions. 4. The North-East boundary of HV contains a row of poplar trees and hedging. Pegasus, acting on behalf of Paradigm, mentioned at their Design Workshop on 20 July (to which at most 500 affected homeowners were invited) that the ‘hybrid poplars along NE boundary of HV site are coming to the end of their natural lives’. If the Green Belt boundary is moved to this tree line and development is allowed on HV, then when these hybrid poplars do fail (as Pegasus’ ‘tree’ advisors have indicated to them) this will leave a very weak Green Belt boundary to the open fields beyond. There will inevitably be a domino effect as Paradigm and other developers rush to exploit the breach and open up further land for development. This will result in the joining up of the parishes of CSG and CSP into one ‘Chalfont City’, exactly the type of outcome that Green Belt legislation is intended to hinder. This is one reason why it is imperative to keep the Green Belt boundary where it is now. 5. Developers aiming to build on HV have reportedly stated that HV should be viewed as a natural infill and that the Green Belt should be moved to the North East edge of the field where it would form one long line with the rest of the Green Belt. However this argument should be ignored. Even a cursory look at any local English map will show that there are few, if any, straight lines anywhere in the country. The precedent for parish, district, county and Green Belt boundaries is that they are irregular and rarely straight. That is the way the residents of Chalfont St Giles want to keep them in the case of the Green Belt covering HV. 6. In 1934 the boundary of Chalfont St Giles Parish was moved to its current location. We understand that property developers may wish to challenge this decision. It might suit their interests if the boundary was still in its previous location (prior to 1934) on the north east edge of the field. But we see no justification in reversing a decision made for the right reasons 85 years ago. If someone can challenge a decision made 85 years ago then anyone can challenge any decision made since then. That would render anything and everything completely fluid and remove any certainty about any boundaries or planning decisions made about anything in the last hundred years. 7. In any event, Green Belt boundaries are not associated in any way with Parish boundaries. They are entirely different and separate, as we understand. 8. From Chiltern & SB District Council website: quote re Local Plan: “It protects us from speculative development which can sometimes happen without sufficient benefit to local communities.” The village community of Chalfont St Giles sees no benefit in any development of HV, as evidenced by the reported 336 signatories to a petition garnered in just 6 hours last Saturday by a protest group. More significantly, the local communities in Stylecroft Road, Gorelands Lane and Kings Road not only see no benefit, they see a huge downside that would result from increased pressure on roads, water and sewage infrastructure. All three roads were built only for light traffic and the access to HV is through an even narrower bottleneck. There would be a significant effect on the standard of life of the local community if this bottleneck was opened to the kind of traffic that would result from 80-90 new houses literally in their backyard. This is why such a development was not included in the Local Plan and why the Local Plan must be respected. 9. HV is a considerable distance from the shops and amenities of CSG. It is high on a hill with steep roads leading to the village. It is an unsuitable location for the elderly or unfit. It is entirely unsuitable for those without cars and therefore

2406 a housing development would require at least 1-2 vehicles per household. The level of traffic that this would engender is unsustainable by the road infrastructure. 10. There are currently 128 trees growing throughout the HV site. A CDC estimate in the District Plan states that the district’s carbon footprint will increase by 21% over the next 10 years. CDC is targeted with reducing this as far as possible. Development of HV will require cutting down all or most of the128 trees. This will only increase our carbon footprint, not decrease it. How will CDC be able to get on track to decrease the district’s carbon footprint whilst actually cutting down trees which are carbon gatherers? 11. There is currently only one – and rather narrow – access road into the HV field. This is dangerous as Emergency Vehicles cannot get in if that route is blocked. There is another ancient single carriageway track into HV which is currently grown over and impassable. But that track is not wide enough to accommodate 2-way vehicular traffic. This ancient track gives onto a particularly narrow section of Gorelands Lane which would be an extremely dangerous place to create a new junction. This impassable track is not viable as a regular vehicular access route into HV, even if tarmacked. Thus HV is left with only one viable, though narrow, access. Legally compliant b - Are you proposing a modification to make the No Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Yes Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to No strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in 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.

2407 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

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