VALP Summer 2016 Consultation Responses - Chapter 5 Housing

ID Respondent Name Comment VALP16-07-14-00208 Bill Russell Policy H1 - If the Vale is to encourage teachers and health & social care staff to live and work locally we need to have affordable housing for these groups of workers. VALP16-08-05-00263 David Theobald Policy H5 - On the 14th of July 2016 in the Friars Square Shopping Centre I talked to Mr Richard Shaw about self build I custom builds sites in the local plan and the ones in Winslow. Mr Richard Shaw asked if I could send you a letter outlining my questions and the options I know of for self-build I custom builds. Mr Richard Shaw also said, that the government as set out plans for self-build I custom build plots and that there is no standards for doing these as of yet. Please can you answer the following questions for me? 1. Will there be Self-build I custom build sites in the Local Plan? 2. Where will these sites be? 3. When will any self-build I custom build site be ready 4. In what form will they come in (see options below)? I also talked to Mr Richard Shaw about three different options that I know have been tried for which I have listed below the pros and cons as far as I can see them.

VALP16-08-05-00263 David Theobald Option 1 The Stoke-on-Trent option. http://www .selfbu ild porta l.org. u k/ stoke-serviced-plots This option is where the council buys the land and puts in services for the plots. Pros 1. Council gets to sell to local people first then opens up to national wide. 2. Council can make sure the land only goes' to self-build I custom builds and sell any land to building companies that they can't sell. 3. Money raised can go towards the 1.1 million shortfall from the government. 4. Can start off small to test and made larger. 5. Government funding 1 https://www.gov.uk/government/publications/ custom-build-serviced-plots-loan-fund Cons 1. Council needs to pay for the land and put in services. 2. Harder to put in affordable housing.

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ID Respondent Name Comment VALP16-08-05-00263 David Theobald Option 2 The Graven Hill option http://gravenhill.eo.uk/ This is where the council buys the land and a new large development is setup by working with the nacsba (National Custom & Self Build Association). Pros 1. Council gets to sell to local people first then opens up to national wide. 2. Council can make sure the land only goes' to self-build I custom build. 3. Money raised can go towards the 1.1 million shortfall from the government. 4. Affordable housing can be included. 5. Working with people that know self-build I custom build. 6. Government Funding https:l lwww.gov.uklgovernmentlpublicationslcustom-build-serviced-plots-loan-fund Cons 1. Council needs to pay for the land and put in services. 2. Needs to be a larger development. 3. Cherwell District Council as the first to try this as far as I know.

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ID Respondent Name Comment VALP16-08-05-00263 David Theobald Option 3 Private investment or groups buy land to put on their self-build I custom build houses option. This is where one or groups of people buy land around Aylesbury and then submit planning for a group of houses on the land. Pros 1. Council only need to do planning permission. 2. Council works with groups so their buy in the right areas 2 Cons 1. A lot of small developments. 2. People buying land that may not be in the council planned area for building. 3. More work for the council in the long run. 4. No money from the plots go to AVDC. I do know there are 20 self-build I custom build plots in Winslow by Bloor homes one of which I am looking at but, this is throwing up some red flags for me. Some ofthese red flags are 1. They do not want builds that do not work for them on the site. 2. They want to know what houses are going up and they prefer house frames they have on their books. 3. They want to build the houses. 4. They cannot say if we can claim the vat back on the self-build I custom build. 5. They will not sell the land without planning permission. 6. They cannot give a price on the land right now. All the above gives the self-build I custom build sites in Winslow a greater chance of failing giving AVDC a bad taste about self-builds, which we all do not want. Please note I have registered on the Aylesbury self-build register. VALP16-08-05-00266 Graham Winwright Policy H6 - The need for specialist elderly accommodation aged 75+ of 1,160 is not included within the overall objectively assessed (Chiltern and South housing need figure but is in addition to this. The draft VALP expects all larger developments in strategic developments (Aylesbury, Bucks District Councils) Buckingham, Haddenham, Wendover and Winslow) to provide an element of self-contained extra care dwellings as part of the overall housing mix, or an equivalent amount in an alternative location if this is agreed to be more appropriate. This approach is supported and clarification on how this issue is to be addressed in the new VALP would be welcomed.

VALP16-08-08-00273 Sheila Cotton Policy H2 - Pleased to see that no further housing is recommended for Bierton due to the large development already taking place in this parish (Kingsbrook) VALP16-08-10-00284 Roz Owens Policy H1 - Housing should also have to be sold as a priority to local people to fulfil their housing needs, otherwise developments in places such as Haddenham, Aylesbury and Wendover are all liable to help ease the housing shortages in London but push up prices making housing unaffordable for local people with lower average wages.

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ID Respondent Name Comment VALP16-08-10-00291 Andrew Dean (Global Policy H1 - Affordable housing must be controlled and is more suited to larger settlements with greater employment opportunities manufacturer) and greater facilities. Affordable housing in more premium villages and towns is not appropriate; either for those being housed (as smaller villages/towns do not offer the employment opportunities) or for local residents. My voice is shared by everyone I've spoken to in Winslow. VALP16-08-10-00291 Andrew Dean (Global Policy H6 - Maintain identities of protected, more 'premium' smaller towns and villages such as Winslow by carefully controlling manufacturer) affordable housing schemes. VALP16-08-11-00302 Janice Hammons Policy H6 - I would like AVDC to consider the mix of housing allocated within Cheddington. The need for affordable housing is more preferable to 4/5 bed houses as it allows young local residents to have a chance of buying a property. VALP16-08-17-00361 Ella Jones (Wendover Policy H5 - Wendover Parish Council supports the encouragement of self builders. Parish Council) VALP16-08-17-00361 Ella Jones (Wendover Policy H6 - Wendover Parish Council supports a mixture of house design, size and innovative features. Parish Council) VALP16-08-18-00363 Charlotte Newman Policy H1 - Housing should be built so people have the opportunity to afford to rent or even buy; one or two bedroom apartments first time renters or buyers. Important that smaller properties are built in villages, not just four/five bedroom houses. I would like to stay living in my home village. I don't like the idea that people can buy affordable housing association houses/flats as they are not replaced. VALP16-08-20-00400 jim woolgar Policy H7 - What utilities are expanding?

VALP16-08-22-00417 Diane Phillips Policy H1 - Piecemeal development = no requirement for any affordable if under 12 dwellings (see latest application r/o Shakespeare Orchard). The village is full of expensive / large houses which are not selling; the community needs affordable housing to assist both young and old and to reflect the changing population needs (e.g. divorce increase / aging population); 25-3-% affordable homes (including social residential accommodation) would be a huge benefit to the community and would mean children could afford to stay in the village thus keeping a thriving and caring community together. VALP16-08-23-00446 Arthur Evans Policy H1 - should be a priority. Suitable accommodation for the elderly is also important.

VALP16-08-23-00446 Arthur Evans Policy H2 - Vey much to be encouraged.

VALP16-08-25-00496 Michael Tippen Policy H4 - The additional houses proposed for Ickford ( 50 houses - SHLICK005/6) will cause an additional burden on the already overloaded sewage system (which has overflowed on previous occasions and backed up into the house). The village school is already full and additional traffic (up to100 cars) will cause further congestion on some roads at peak times. It is now difficult to get out of our driveway at certain times.The character of this small village will be further spoiled for ever. The village only has some amenities because, through their own endeavours, the village people have provided village facilities such as the village hall and grants and loans to support the shop and post office. Furthermore the adjacent villages of Worminghall and Shabbington (of similar size) are drawn to Ickford because of these amenities and yet have less houses proposed (11 houses) That causes an additional burden on the roads The village is prone to flooding at certain times and further concreting of land for houses will provide less land for flood water to soak away. Since we have been in this small rural village there has been continual building. 50 houses is far too many for this small village.

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ID Respondent Name Comment VALP16-08-25-00512 Richard Hills Policy H6 - In Winslow there is an imbalance of 3,4, & 5 bed detached houses up to 50 yrs old occupied by one or two elderly people unable to move and release quality family houses, due to lack of suitable property for the elderly. Elmfields is in danger of becoming an old peoples ghetto ! There are perhaps no more than a dozen children left on this estate. We, the retired, OUTNUMBER employed residents. My wife and I in our mid 80s are stuck in a fine but too large house due to the imbalance of previous housing policy. This needs addressing in the future, though no doubt too late for us. VALP16-08-25-00528 Fiona Lippman Policy H5 - would like to see this extended to all schemes, not just larger developments. (Buckland Parish Council) VALP16-08-25-00528 Fiona Lippman Policy H6 - Support this, but would like to see the addition that the housing mix of a new development should be based initially on (Buckland Parish local need, not district need. Council) VALP16-08-25-00529 Lucy Murfett (Chilterns Policy H1 - The policy should be amended to secure affordable housing contributions on smaller sites in AONBs and Designated Conservation Board) Rural Areas, in line with the latest guidance (See Government Planning Practice Guidance on Planning Obligations para 017). Suggested new asterisked section to the policy: "* except in the Chilterns AONB and Designated Rural Areas where affordable housing at 31% will be required on sites of 6 or more dwellings."

The smaller site provisions apply to rural areas designated under s157 of the 1985 Housing Act, including National Parks, AONBs and Designated Rural Areas, which includes many parishes in Aylesbury Vale (see lists available here http://www.legislation.gov.uk/uksi/1997/625/schedule/1/made of whole parishes covered eg Ivinghoe, Edlesborough, and here http://www.legislation.gov.uk/uksi/1997/625/schedule/2/made of mapped part parishes including Haddenham, Aston Clinton, Wendover etc. VALP16-08-25-00529 Lucy Murfett (Chilterns Policy H2 - The Chilterns Conservation Board supports this policy. The Board has supported and will continue to support rural Conservation Board) exceptions schemes to meet identified local housing needs. However, changes are needed to Policies D5, D6 and D7 or else there are very unlikely to be any rural exceptions sites in larger, medium or small villages. As currently written D5, D6 and D7 allow new greenfield housing to be located "within or adjacent to the existing developed footprint of the village". By allowing market greenfield housing on sites adjacent to the edge of villages, potential rural exceptions sites will go for market housing. For a rural exceptions policy to work, there has to be strict policy control on greenfield village expansions, which the RES is then an exception to.

VALP16-08-28-00548 Nicola Page Policy H6 - Housing should fit in with the environment, but under 3 stories in rural locations. I was pleased with the comment re garages and alternative space being required for parking, this makes sense but we also need planned provision for the elderly. This could also help out on transport. Retired people don't commute. Why not take advantage of this and place retirement communities on the busy roads which are struggling? VALP16-08-30-00562 Andrew Bateson (AB Policy H1 - The proposal to accommodate at least 31% affordable housing on all allocated development sites (including those Planning & Development identified at Policy D3) is supported by the Dagnall House Bletchley landowner, who would be aiming to provide 13 of the 39 new Ltd) houses on its land (@33.33%) as affordable dwellings.

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ID Respondent Name Comment VALP16-08-30-00562 Andrew Bateson (AB Policy H6 - In accordance with the results of the HEDNA survey, the proposed housing mix suggested in policy H6 is supported by Planning & Development the Dagnall House Bletchley landowner. Accordingly, the landowner would be aiming to provide five of the proposed thirteen Ltd) affordable dwellings as 2-bed houses, five more as 3-bed houses and one each of 1-bed and 2-bed flats and a 4-bed house. Likewise, the twenty-six open market houses on the site would aim to be provided as 1 x 1-bed flat, 1 x 2-bed flat, 3 x 2-bed houses, 13 x 3-bed houses, 6 x 4-bed houses and 2 x 5-bed houses, all in accordance with the proposed policy.

VALP16-08-31-00568 Graham Tyack Policy H6 - HVS Comments – paras 5.58-5.67: (Haddenham Village Social Housing: The requirement for social housing should be higher and should make an explicit allowance for additional social Society) housing for rental and shared ownership. Areas such as Haddenham are already essentially parts of the London housing area, with further pressure from Oxford, and this is already pricing many local young people out of the market. This situation will worsen unless developers are required to provide a mix of dwellings, for both purchase and rent and unless local authorities and housing associations are involved in providing far more social housing.

Housing for the Elderly: Haddenham has a high proportion of elderly residents and the Village Society supports any policy which requires developers to make provision for both independent and dependant housing for the elderly. The situation is being made worse by the piecemeal conversion of bungalows into two-storey dwellings and, if this cannot be prevented, it is essential that provision of accessible dwellings of various sizes should be incorporated in housing developments in compensation for this loss of suitable housing. VALP16-08-31-00568 Graham Tyack This also requires that section 106/CIL allocations should incorporate expenditure to enhance transport, pedestrian and other (Haddenham Village infrastructure to meet the needs of an ageing population. Society) Employment: The Haddenham Neighbourhood Plan, supported by the Village Society, identified the need for small-scale starter units for local entrepreneurs who have begun their business activities but need space for expansion. Unless this need is addressed, economic growth will be stifled and areas such as Haddenham will be colonised by commuters. It is therefore crucial that the VALP addresses the nature, rather than just the area, of employment land and develops policies to meet the actual needs of local communities. VALP16-08-31-00569 Paul Moss Policy H1 - Allocation of a housing quota to small villages must include low cost starter homes and social rent homes. AVDC must not allow these provisions to be watered down in the development stage. The villages need affordable homes. VALP16-08-31-00580 Fiona Lippmann Policy H5 - This should be extended to all schemes, not just the larger developments.

VALP16-08-31-00580 Fiona Lippmann Policy H6 - Mix is often inappropriate to local needs. Please respect the needs of the locality as well as the district.

VALP16-08-31-00581 Fiona Lippmann (Halton Policy H5 - Would like to see this extended to all schemes, not just larger developments. Parish Council) VALP16-08-31-00581 Fiona Lippmann (Halton Policy H6 - Housing mix within a new development, should be based initially on local need, not district need. Parish Council) VALP16-08-31-00583 Roger Kemp (Kemp's Policy H1 - Paras 5.13 and 5.14. Again the Ford site I propose could satisfy the need for affordable housing. Farm)

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ID Respondent Name Comment VALP16-09-01-00613 Denise McClellan Policy H1 - H1 - I believe it is important to allow for an appropriate % of affordable housing in any development , especially in villages in order to "keep them alive". VALP16-09-01-00613 Denise McClellan Policy H2 - H2 page 115 I support this policy in principle, but how can this work in practice? All landowners/developers believe that their sites shouls all be "open market" sites where houses are sold at full market value. VALP16-09-01-00637 Viv Lynch (Wingrave Policy H1 - Para 5.4 - Affordable housing needs to be dispersed throughout the development and not clustered into a single area. with Rowsham Parish Council) VALP16-09-01-00637 Viv Lynch (Wingrave Policy H6 - 5.59 For Wingrave with Rowsham where there is an excess of larger homes the percentages in this table should not be with Rowsham Parish exceeded. Council) VALP16-09-02-00641 Christopher Matthews Policy H1 - Paragraphs 5.1 to 5.12 - I agree with the provision of affordable housing, including ‘starter homes’ but steps must be taken to ensure that homes are available that first time buyers can afford. There are many young people in Haddenham who are unable to buy a property here because prices are too high. However, it should be noted that having trains to London from Haddenham station has led to higher house prices and attracts purchasers currently living in London. Will ‘starter homes’ be affordable for local people, particularly first time buyers? It is important to take into account the needs of local young people and require developers to provide a mix of dwellings, for both purchase and rent, and local authorities and housing associations provide far more social housing within the same total of housing numbers. VALP16-09-02-00641 Christopher Matthews Policy H6 - Paragraphs 5.60 to 5.64 Housing for older people Bungalows are in high demand for older people in Haddenham. I understand why they cannot easily be built because of land requirements but it is very important that planning permission is refused for changing current bungalows into two-storey family homes as has happened to three bungalows in my road. Availability of bungalows enables older residents to downsize. We know many older people who are looking to downsize in Haddenham but are unable to find a suitable property to buy. This has an effect on the rest of the housing chain as larger family homes remain occupied by an older couple rather than being available for purchase by a family.

VALP16-09-02-00642 Adele Berthet Policy H6 - 1.The housing development figures for Worminghall - it states 11 with commitments and completed totallig 8 leaving (Worminghall Parish 3. 5 of the houses within this committed total were refused at planning although there is an appeal in process for this as well as an Council) alternative plan for 3 houses. Worminghall also has a planning application awaiting decision for 12 houses. The result of this was due 31/8/16 but we have not yet heard as to whether this will be approved or not. If this is approved, then this will immediately take the figures to almost double the total of 11 that are in the draft plan. Any new housing should fit with the needs of the community, which currently is for smaller and therefore more affordable dwellings. VALP16-09-02-00643 Angela Matthews Policy H1 - Paragraphs 5.1 to 5.12 - I agree with the provision of affordable housing, including ‘starter homes’ but steps must be taken to ensure that homes are available that first time buyers can afford. There are many young people in Haddenham who are unable to buy a property here because prices are too high. However, it should be noted that having trains to London from Haddenham station has led to higher house prices and attracts purchasers currently living in London. Will ‘starter homes’ be affordable for local people, particularly first time buyers? It is important to take into account the needs of local young people and require developers to provide a mix of dwellings, for both purchase and rent, and for local authorities and housing associations to provide far more social housing within the same total of housing numbers.

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ID Respondent Name Comment VALP16-09-02-00643 Angela Matthews Policy H6 - Paragraphs 5.60 to 5.64 Housing for older people Bungalows are in high demand for older people in Haddenham. I understand why they cannot easily be built because of land requirements but it is very important that planning permission is refused for changing current bungalows into two-storey family homes as has happened to three bungalows in my road. Availability of bungalows enables older residents to downsize. We know many older people who are looking to downsize in Haddenham but are unable to find a suitable property to buy. This has an effect on the rest of the housing chain as larger family homes remain occupied by an older couple rather than being available for purchase by a family.

VALP16-09-02-00648 Paul Edwards Policy H1 - Section 5 affordable housing With the average price of a property in Marsworth in excess of £540,000 how will the affordable housing price be achieved as this is well out of reach for many first time buyers or even second or third move buyers, will it mean that the build will consist of 1 bedroom houses or flats or even studio apartments in order to reach this target, and for this area what do you classify as a price range for affordable housing. Or will it become a 100% affordable housing site as mentioned in section 5.17

As we all know it is essential to provide an adequate stock of new build housing in the area but this does not need to be done at the detriment to the already established communities by building around them why not try to intersperse the build throughout the entire community rather than just concentrating on one area.

If we are forced to have just this one large site within the village then I request that the following is built into the plan and agreed upon before commencement of any development work All properties abounding the development are given the right to increase their land by a minimum of 10 metres from their existing boundary at current land cost prior to planning permission being granted That a boundary of 10 metres is provided between the new development boundary and the existing properties boundary (even after the extension of boundary as above) to provide a buffer in order to help stop the original dwellings from being overlooked by the new development. As mentioned earlier many of the current residents purchased the property due to the open views over the countryside, and like ourselves did not want to be overlooked by a sprawling development of housing. VALP16-09-02-00653 Quainton Parish Council Policy H3 - H3 Rural Workers' dwellings - The PC agree that strict rules should be adhered to in the granting of permanent rural workers' dwellings. The PC agree with agricultural ties as many farm properties slip into residential use. Buckinghamshire needs its farmers and their workers. VALP16-09-02-00654 Tom Hutchinson (Land Policy H5 - Policy H5 should make clear that the policy requirement for all larger developments to provide a percentage of serviced and Partners Ltd) dwelling plots for sale to self/custom builders it to be subject to evidence of sufficient demand. Also 'larger developments' should be defined. VALP16-09-02-00654 Tom Hutchinson (Land Policy H6 - In Policy H6 'Larger residential development schemes' should be defined. and Partners Ltd) VALP16-09-02-00654 Tom Hutchinson (Land Policy H7 - It is not clear why Policy H7 is proposing to include the Government's national Technical Housing Standards as a and Partners Ltd) mandatory requirement within the Local Plan area. Technical standards are best dealt with via Building Regulations.

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ID Respondent Name Comment VALP16-09-02-00655 Frances Durkin Policy H1 - The VALP must take into account the nature of existing property in an area. Cheddington is already full of larger 4 bedroom properties are there is insufficient, smaller and affordable properties for those who have grown up in the village to be able to afford to stay. The percentage of affordable properties must be in proportion to the village as a whole and not just to the new builds. Younger people need the opportunity to buy their own homes and not be priced out by more larger new builds.

VALP16-09-02-00661 Robert Love (Davidsons Policy H1 - Policy H1 requires residential development of 11 or more dwellings to provide a minimum of 31% affordable homes on Developments Ltd) site. It is reasonable to suggest that Policy H1 of the Draft Plan should consider an 'up to' percentage figure for affordable housing as not all development will be capable of delivering the full requirement subject to viability. It is also relevant to note that affordable housing policy should be subject to a Supplementary Planning Document as this is capable of regular review and can be updated to reflect current affordable housing needs and potential changes to Government policy including the initiative on Starter Homes identified in the Housing and Planning Act. The Housing and Planning Act gained Royal Assent on 13 May 2016 and includes a requirement for councils to provide a minimum of 20% of new housing as discounted starter homes for first-time buyers. The outcome from the ‘Technical consultation on implementation of planning changes’ that ran from 18 February to 15 April 2016 is pending. It is expected that the definition of affordable housing will change to include starter homes, and that planning proposals for qualifying sites will need to include a percentage of starter homes in order to obtain consent. In view of the above, it is reasonable to suggest that the Draft Plan should consider housing growth above projections if deliverable because of the potential for increased economic growth in the District. The HEDNA considers it unlikely that house prices will adjust sufficiently to enable many of the households who are unable to afford their housing costs from moving away from the area. It is therefore reasonable to suggest the Council should be considering additional housing in response to market signals and to widen the opportunities for home ownership. It is considered relevant to identify the potential for additional housing through Starter Homes should the necessary provisions be in place and the definition of affordable housing is amended in the NPPF to include Starter Homes. VALP16-09-02-00661 Robert Love (Davidsons Policy H5 - No view - However, there are a number of challenges in delivering self-build as part of a larger allocation e.g. services, Developments Ltd) S106 obligations, master planning. VALP16-09-02-00661 Robert Love (Davidsons Policy H6 - It is considered that Policy H6 is satisfactory in principle but must reflect market demands. Developments Ltd) VALP16-09-02-00664 Ken Trew (Cuddington Policy H1 - Para 5.5 Policy H1 sets a threshold of 11 dwellings, or more, for affordable housing target of 31%. There should be a Parish Council) requirement where 10 or less trigger a requirement for affordable housing when considered cumulatively with other small scale developments in the same settlement. This could take the form of a negotiation with AVDC and local social landlords to contribute to affordable housing, maybe through the CIL process? VALP16-09-02-00666 Kate Curry (Aston Policy H1 - This section does not give a definition of what “Affordable Housing” actually means. How will affordable housing be Abbotts Parish Council) guaranteed for the future / in perpetuity? Is it possible for the total housing allocation in a small village (say 4 houses) to be all affordable? VALP16-09-02-00666 Kate Curry (Aston Policy H3 - a) Existing need must be proven, not the sort of ‘spin’ used in recent years. Abbotts Parish Council)

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ID Respondent Name Comment VALP16-09-02-00667 Robert Barnes Policy H1 - All should recognise the need for Affordable Housing and be the means by which a village can evolve. It is not a reason to mass development on rural communities VALP16-09-02-00671 David Child Policy H1 - Para 5.13 There is no point in building affordable houses where the occupants are unable to get to a full range (shift work etc) of employment. It would be better to take the 30% in cash and build the affordable dwellings where high quality infrastructure is available. VALP16-09-02-00673 rod phillips Policy H2 - Rural exception sites have too many obstacles to overcome before they are accepted, these often petty rules need removing, to allow more sites to be used. The rural exception sites policy needs to accommodate more categories, not just affordable housing etc, but elderly downsizers. VALP16-09-02-00673 rod phillips Policy H5 - This policy seems to concentrate on providing self/build plots on the larger sites this misses the whole point of self build, most self builders are not looking for custom build sites, in fact most self builders look for single sites to build on, so this approach of using larger sites is no help to self builders, and should be re worked to accommodate smaller sites, perhaps using the rural exception policy. VALP16-09-02-00675 Mr and Mrs Hudson Policy H3 - The reasons for these developments to take place i.e. would not be permitted under normal circumstances i.e. Agricultural Occupancy Ties Should be up-held. VALP16-09-02-00677 Steven Mitchell Policy H1 - Support. Number or percentage must not be relaxed on village sites. VALP16-09-02-00677 Steven Mitchell Policy H6 - Support. But does the chart in paragraph 5.59 mean that within the town centre only 23% (4% + 4% + 9% + 6%) of new-build dwellings can be flats? So the rest must be houses. Chart permitted development offices to flats developments mix may be adjusted to allow houses rather the flats VALP16-09-02-00677 Steven Mitchell Policy H7 - Support.

VALP16-09-03-00715 Roderick floud Policy H1 - Para. 5.4 - 31% is too low. There is an urgent need for truly affordable homes and for social housing provision, to avoid settlements such as Haddenham becoming extensions of north London, without a diverse population mix. VALP16-09-03-00720 Ruth Scott (Scott Travel Policy H2 - All landowners/developers believe their sites should all be ‘open market’ sites where houses are sold at full market value. Ltd) Speculators will sit on investments until they get their way!! VALP16-09-03-00726 Richard Dorrance Policy H1 - I agree with the proposals. However the smaller villages, like mine, will only have developments of 10 or less houses and so under paragraph 5.5 there will be no pressure on developers to provide affordable housing in these smaller villages. This seems to be wrong to me. VALP16-09-03-00726 Richard Dorrance Policy H6 - I agree with the proposals

VALP16-09-04-00738 Linda Kemp (Kemp's Policy H1 - Paras 5.13 and 5.14. Again the Ford site proposed by my husband could satisfy the need for affordable housing. Farm)

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ID Respondent Name Comment VALP16-09-04-00739 Pierre & Wendy Hibble Policy H2 - Paragraphs 5.13 and 5.17 The requirement to provide affordable rural housing is fully supported and endorsed. However when confronted with Policies such as D7 which pre-determines the number of houses to built at Whaddon then how is the Policy H2 to be enforced? Developers will always seek full value, market housing? How will affordable properties be developed and how will the continuous built form of the village be protected from dispersed developments? Yet again the Vale Plan presents objectives with incomplete arguments and no basis of how the ideals will be enforced. VALP16-09-04-00740 John Gavan Policy H1 - The availability of affordable housing is a great issue in this area. even the smallest houses are too expensive. We therefore need not only affordable housing but AVDC needs to be proactive in reestablishing community rentable housing for young people. This may require going to goverment and petitioning for changes to the law. VALP16-09-04-00742 Carolyn Cumming Policy H7 - I support the policy but what does “built-in” mean? I have assumed bedroom cupboards but, if so, there must be further storage capacity specifically for recycling. VALP16-09-04-00750 Colin Read (Aston Policy H2 - There should be small cottages built in the AONB of the Chilterns and Wycombe. They need not be overpowering if built Clinton parish planning) in sympathy with their surroundings and kept on a small scale in each village. This would however use up some brownfield land in small villages. It would not put undue pressure on community services bout would provide some much needed smaller rural dwellings . VALP16-09-04-00750 Colin Read (Aston Policy H3 - As per paragraph above these could be utilised for rural workers. Clinton parish planning) VALP16-09-04-00750 Colin Read (Aston Policy H7 - These need to be contained within our parish to smaller dwellings as there is a great need for house local people. Large Clinton parish planning) houses on green field sites are totally unacceptable. We are inundated with them. VALP16-09-04-00753 Alan Branch Policy H1 - Paragraph 5.1 Provisions to ensure that affordable homes remain at affordable prices should, in my opinion, be reinforced in law. Further provisions should be made to limit property sales to a single person to two to stop "Landlords" from purchasing property for private rental. VALP16-09-04-00780 Linda Fisher Policy H1 - There is a desperate need for affordable housing but it's not just about housing - commuter costs are astronomical - people won't use the station car park as its too expensive so this will simply mean that the surrounding area will be a very large car park. The railway will benefit if these plans go ahead but they are giving nothing from their side. Even if affordable houses are built by definition these people will need to commute to get to work and if travel is expensive they will simply take to their cars

VALP16-09-04-00788 David Dinsdale Policy H6 - Most of the plans seem to include a very high level of housing for affluent people and potential commuters from Princes Risborough and Haddenham. This is not creating a balanced local demographic. VALP16-09-04-00790 rachel baker Policy H1 - Greatly needed. Most small houses have been extended/re-developed and turned into larger houses. Most recent developments of smaller houses (built approx 30 years ago!) are of poor quality and unafordable. VALP16-09-04-00790 rachel baker Policy H5 - Smaller developments of self build would help to preserve the rural character of the village

VALP16-09-04-00790 rachel baker Policy H6 - Little stock available for single / elderly people e.g. bungalows.

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ID Respondent Name Comment VALP16-09-05-00799 John Mole (Oakley Policy H2 - Within villages, we are seeing many children of 'village families' having to move from their home village to buy cheaper Parish Council) houses in small market towns (e.g. Bicester and Thame). Whilst for larger settlements there is no communal loyalty and moving away is often expected, within the traditional small Bucks village the local people wish to stay here with their offspring like they have done for centuries. Only by increasing affordable housing is this going to be possible. VALP16-09-05-00802 Ruth Hewitt (Admiral Policy H1 - Houses should have a priority for local 'children' Costumes) VALP16-09-05-00806 Jeff_ Deacon Policy H4 - More pressure to remove people from the countryside and place them in towns.

VALP16-09-05-00806 Jeff_ Deacon Policy H7 - Judging by what AVDC has recently permitted, maximum has the same meaning as minimum. And with the 30 dwellings per hectare requirement it is no wonder that all the new developments are cramped, even when compared with Northern mill towns of the Victorian era. VALP16-09-05-00820 Christine Yates (EDaN Policy H1 - We need houses for our young people wishing to stay in the village who cannot afford the larger houses which are in (Edlesborough, Dagnall excess in the village. & Northall) community projects) VALP16-09-05-00830 Manlet Group Holdings Policy H1 - Policy H1 Affordable Housing - Draft Policy H1 seeks provision of 31% affordable housing on site for developments of 11 or more dwellings. Manlet Group question how the figure of 31% was calculated, as this proportion will be difficult to provide on- site for smaller developments in particular. As such, Manlet Group supports draft Policy H1 which allows for an open book financial appraisal of the development to be provided for an site which is unviable at this level of affordable housing particularly where it makes a positive contribution to the social infrastructure of the settlement. Manlet Group also supports the acceptance in draft Policy H1 that affordable housing may be provided off-site or by a financial contribution. However, it is unnecessary to require this in ‘exceptional circumstances’ and it is therefore suggested that Draft Policy H1 is amended to read: “c. the council may agree to the affordable housing being provided off-site or a financial contribution in lieu….”

VALP16-09-05-00832 Jake Collinge (Jake Policy H6 - There should be flexibility in the Policy wording to allow weight to given to the general Collinge Planning characteristics of the area when determining the appropriate housing mix. Consultancy Ltd) VALP16-09-05-00833 Tim Smee Policy H2 - Inappropriate development.

VALP16-09-05-00840 Jake Collinge (Jake Policy H6 - There should be flexibility in the Policy wording to allow weight to given to the general characteristics of the area when Collinge Planning determining the appropriate housing mix. Consultancy Ltd) VALP16-09-05-00847 Jake Collinge (Jake Policy H6 - There should be flexibility in the Policy wording to allow weight to given to the general characteristics of the area when Collinge Planning determining the appropriate housing mix. Consultancy Ltd)

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ID Respondent Name Comment VALP16-09-05-00853 Suzanne Lindsey Policy H1 - POLICY H1 AFFORDABLE HOUSING (Whaddon Parish Affordable housing should be provided at a minimum of 35% - if not 40% - of all development sites over 6 units. (therefore a six Council) house site – wherever it may be - must provide at least 2 affordable homes) Otherwise the acute shortage of affordable homes will continue to grow (especially in rural areas) and the situation for young and old who want a proper and affordable ‘roof over their head’ will become more acute. It is not sustainable to continue building larger 3 and 4 bedroomed ‘for sale’ houses without providing the desperately required homes for those in need, in special circumstances, on low incomes or simply those that prefer or can only afford rent.

VALP16-09-05-00853 Suzanne Lindsey Policy H2 - POLICY H2 RURAL EXCEPTION SITES (Whaddon Parish Whilst WPC strongly supports this policy, it remains very difficult to see how it can work in practice because any sites that are within, Council) or adjoin settlements are seen as ‘fair game’ for the development industry, especially whilst AVDC do not have a justifiable and strong 5 year supply. Similarly, benevolent land owners are very few and far between nowadays, so the opportunities are going to be very rare, and will probably only come forward after land owners and developers have totally exhausted the application/appeal process and realised there is little chance of success in getting a planning consent for ‘open market sale housing’. WPC sees the only way of overcoming this is by fixing realistic and defensible village development boundaries with the help of communities and Parish Councils, and thereafter sticking rigidly to such planning boundaries. Any sites falling outside these firm village boundaries would become candidates for Rural Exception Sites. VALP16-09-05-00853 Suzanne Lindsey Policy H4 - POLICY H4 REPLACEMENT HOUSES IN THE COUNTRYSIDE (Whaddon Parish Whilst generally supporting this policy it seems illogical not to have a maximum redevelopment or extension limit. Whilst Council) understanding the ‘does not cause significant harm to the site or it’s surroundings’ rule, it would seem sensible to have an additional clause limiting the permitted size to say twice that of the existing footprint area. Otherwise the situation could lead to pressure for sub-division, unless a similar ‘no sub-division’ clause is added. VALP16-09-05-00860 John Careford Policy H1 - I don't think that for new developments that a socially engineered community by diverse housing stock arrangements is a good idea. You can't make community like this, and far too often there is nothing to help this process from the outset. Community centres should be first in, not last in!

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ID Respondent Name Comment VALP16-09-05-00863 David Peck Policy H2 - 1.The overall plan seems to be a drastic solution and a more thoroughly thought through solution appears to be needed. 2.The proposal seems to be to convert Haddenham from a village into a small town. Which will have very negative impacts on a number of areas, if not properly planned from square one in the proposed development, including: a.Transport, many new roads would be needed and access and parking at the station could become intolerable. The current village roads are not capable of taking any real increase in traffic. b.Doctors’ surgery is currently unable to handle for the 4500ish residents and will be unlikely to handle many additional thousands without significant enhancements. c.The schools are currently almost at capacity and new schools would be needed, including a local secondary school rather than making many more journeys to Waddesdon, Aylesbury and Thame. d.With the other planned developments in South Oxfordshire, especially near to Thame, the services in Thame would be overwhelmed. e.By basing the developments in and around Haddenham that will consume significant quantities of high-grade agricultural land. f.There is a great need in Haddenham for a high quality retirement home area and in any plan to develop Haddenham this is an essential item.

VALP16-09-05-00863 David Peck 3. The proposal to develop near Haddenham does not appear to take due account of the other available brownfield sites in Buckinghamshire, especially those at Wescott and Winslow’s nearby old airfield. In the not too distant future Winslow will be connected to the new railway line between Oxford and Cambridge making the Winslow area are very attractive transport hub. 4. Further it does not take account of the possibility of generating a completely new town on the railway line between Haddenham and Bicester. 5. The north of the county is wanting development and new homes, whilst this plan seems to further increase the congestion in the southern part of Buckinghamshire. 6. Haddenham is already accepting many hundreds of extra houses within its general boundaries and hence assisting the AVDC to meet its housing objectives. Hence consideration should be given to additional housing in the AVDC area going elsewhere. 7. There is great concern that AVDC is taking on housing requirements from the surrounding district councils, especially Wycombe. Also it is understood that the density of housing proposed for the Wycombe area is far lower than that proposed new developments around Haddenham. This seems totally unreasonable and further detailed assessment of Wycombe’s plans are needed before AVDC except more houses from other authorities. 8. Further, little consideration seems to have been made for the local employment of the new residents, hence exacerbating the transport system by adding to the commuter pool.

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ID Respondent Name Comment VALP16-09-05-00867 Susan Peck Policy H2 - 1.The overall plan seems to be a drastic solution and a more thoroughly thought through solution appears to be needed. 2.The proposal seems to be to convert Haddenham from a village into a small town. Which will have very negative impacts on a number of areas, if not properly planned from square one in the proposed development, including: a.Transport, many new roads would be needed and access and parking at the station could become intolerable. The current village roads are not capable of taking any real increase in traffic. b.Doctors’ surgery is currently unable to handle for the 4500ish residents and will be unlikely to handle many additional thousands without significant enhancements. c.The schools are currently almost at capacity and new schools would be needed, including a local secondary school rather than making many more journeys to Waddesdon, Aylesbury and Thame. d.With the other planned developments in South Oxfordshire, especially near to Thame, the services in Thame would be overwhelmed. e.By basing the developments in and around Haddenham that will consume significant quantities of high-grade agricultural land. f.There is a great need in Haddenham for a high quality retirement home area and in any plan to develop Haddenham this is an essential item.

VALP16-09-05-00867 Susan Peck 3. The proposal to develop near Haddenham does not appear to take due account of the other available brownfield sites in Buckinghamshire, especially those at Wescott and Winslow’s nearby old airfield. In the not too distant future Winslow will be connected to the new railway line between Oxford and Cambridge making the Winslow area are very attractive transport hub. 4. Further it does not take account of the possibility of generating a completely new town on the railway line between Haddenham and Bicester. 5. The north of the county is wanting development and new homes, whilst this plan seems to further increase the congestion in the southern part of Buckinghamshire. 6. Haddenham is already accepting many hundreds of extra houses within its general boundaries and hence assisting the AVDC to meet its housing objectives. Hence consideration should be given to additional housing in the AVDC area going elsewhere. 7. There is great concern that AVDC is taking on housing requirements from the surrounding district councils, especially Wycombe. Also it is understood that the density of housing proposed for the Wycombe area is far lower than that proposed new developments around Haddenham. This seems totally unreasonable and further detailed assessment of Wycombe’s plans are needed before AVDC except more houses from other authorities. 8. Further, little consideration seems to have been made for the local employment of the new residents, hence exacerbating the transport system by adding to the commuter pool.

VALP16-09-05-00868 Jake Collinge (Jake Policy H6 - There should be flexibility in the Policy wording to allow weight to given to the general characteristics of the area when Collinge Planning determining the appropriate housing mix. Consultancy Ltd)

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ID Respondent Name Comment VALP16-09-05-00869 Jake Collinge (Jake Policy H6 - There should be flexibility in the Policy wording to allow weight to given to the general characteristics of the area when Collinge Planning determining the appropriate housing mix. Consultancy Ltd) VALP16-09-05-00871 Mary Hunt (Aylesbury Policy H1 - It is essential that the Council use forms of housing provision where affordability can be guaranteed irrespective of the Vale Green Party) wider market conditions, such as social and co-operative housing, and encourage self-build and custom-build that directly meets peoples’ needs while empowering the builders/occupants. Mutual retirement housing and specialist retirement co-housing should be included in the Plan.

We believe that the Council should require Housing Associations to set rents at levels that ensure genuine affordability for those on low incomes.

Significantly more affordable housing should be provided because house prices are so high here. Para.5.1 states ‘To enable the council to meet a proportion of the identified need it will seek to secure a minimum of 31% affordable housing on qualifying development sites’. The requirement needs to be clarified. Identified need should be fully met not just a ‘proportion’. The percentage should be adjusted upwards if necessary. VALP16-09-05-00871 Mary Hunt (Aylesbury Policy H5 - Aylesbury Vale Green Party welcomes the allocation of self/custom build housing. It is to be hoped that the Vale Green Party) supplementary planning document will be ready to inform the final VALP. We urge AVDC to consider what proportion of this land can be made available to widen opportunities for home ownership. VALP16-09-05-00871 Mary Hunt (Aylesbury Policy H6 - Para. 5.64 It is important that extra care accommodation is provided on almost all developments and essential that the Vale Green Party) Plan does not limit its threshold to only ‘large’ developments. It is important that villages continue to grow their provision for the elderly and extra-care needs as much as other areas. VALP16-09-05-00873 Jake Collinge (Jake Policy H6 - There should be flexibility in the Policy wording to allow weight to given to the general characteristics of the area when Collinge Planning determining the appropriate housing mix. Consultancy Ltd) VALP16-09-05-00879 Jon Hobbs (Vale of Policy H1 - It is pleasing to see the priority for affordable housing recognised in the VALP as the 2nd Strategic Objective and we Aylesbury Housing support the overall vision and strategic objectives detailed in the plan. We support the plans targets for growth and its Trust) acknowledgment that all settlements need to accommodate new homes at a rate of growth in proportion to their size.

It is unfortunate that the plan appears to state that AVDC have currently only identified 3.9 years of land supply against a target of 5 years and we would hope this is not a barrier to the plan gaining the necessary approvals.

The Trust strongly supports the plan’s intent to secure 31% affordable housing on all developments of 11 units or more. This will increase the supply of low cost including on smaller sites. This policy may also help regulate the land value of smaller sites.

We accept the guidance on the application of Starter Homes being as affordable housing is in abeyance at the time of writing. The Trust supports the National Housing federation’s call for Government to allow local Authorities such as AVDC to set their own delivery targets for this product based on local housing need.

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ID Respondent Name Comment VALP16-09-05-00879 Jon Hobbs (Vale of Policy H2 - The inclusion of Rural exception policy (H2) in the plan is welcome and the emphasis on retaining a high percentage of Aylesbury Housing housing affordable is commendable in providing low cost housing as well as regulating land values. We welcome the proposal that Trust) private sector homes may be permitted on an open book basis and this is capped at 50%. The removal of Government grants and rising construction costs now mean building of homes for sale may be required to support many affordable housing schemes.

We note the housing mix tables generated from the Buckinghamshire housing and Economic Development Needs Assessment (HEDNA) and hope that these principles can be practically applied to produce a sustainable property market.

We welcome the drive to ensure that 10% of private sector homes and 15% of affordable homes within schemes are Accessible and Adaptable. We trust that such a policy will be applied pragmatically on a case by case basis so as not to inadvertently rule out affordable housing developments.

VALP16-09-05-00879 Jon Hobbs (Vale of Policy H7 - We support Policy H7 requiring all new units to meet the nationally described space standard. This provides clarity and Aylesbury Housing supports a consistent approach. This policy will help ensure that new homes are provided not only to meet the immediate growing Trust) demand for housing but remain fit for propose in the future.

We note the reliance on windfall sites for delivery of the plan and the concerns of AVDC regarding delivery of affordable rented homes following implementation of Starter Homes as a prescribed affordable housing tenure. As owners of a number of such small windfall sites, some of which are in rural locations, we hope AVDC planning and the members of the Council will take a universally positive stance on the development of such schemes and support such planning applications.

Overall the Trust supports the plans strategy for expansion providing that a sufficient number of affordable homes of all tenures can be built to continue to address Aylesbury Vale’s housing need. We are pleased to see the plan recognises the different tenures of ‘affordable housing’ which provides for the needs of different client groups. We are aware that AVDC remain committed to rented homes and hope that delivery of this important tenure for many low income households is not forgotten by the Government’s home ownership aspirations. VALP16-09-05-00892 Jake Collinge (Jake Policy H6 - There should be flexibility in the Policy wording to allow weight to given to the general characteristics of the area when Collinge Planning determining the appropriate housing mix. Consultancy Ltd) VALP16-09-05-00897 tim dorsett Policy H1 - Should not be sold off

VALP16-09-05-00904 Christopher Wayman Policy H1 - H1 p114Proposes 31% affordable homes on a (new) site containing 11 or more dwellings. BNDP (Policy HP5) currently (Buckingham Town requires 35% affordable homes on sites for 25 or more dwellings, or sites of 1 hectare or more, albeit subject to viability. There is no Council) conflict with VALP on the housing mix. VALP16-09-05-00904 Christopher Wayman Policy H2 - H2 p115 Nothing to conflict with BNDP. (Buckingham Town Council)

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ID Respondent Name Comment VALP16-09-05-00904 Christopher Wayman Policy H3 - H3 p120 Nothing to conflict with BNDP (Buckingham Town Council) VALP16-09-05-00906 Jake Collinge (Jake Policy H6 - There should be flexibility in the Policy wording to allow weight to given to the general characteristics of the area when Collinge Planning determining the appropriate housing mix. Consultancy Ltd) VALP16-09-05-00913 Jake Collinge (Jake Policy H6 - There should be flexibility in the Policy wording to allow weight to be given to the general characteristics of the area when Collinge Planning determining the appropriate housing mix. Consultancy Ltd) VALP16-09-05-00913 Jake Collinge (Jake Policy H6 - There should be flexibility in the Policy wording to allow weight to given to the general characteristics of the area when Collinge Planning determining the appropriate housing mix. Consultancy Ltd) VALP16-09-05-00928 Tim Northey (Rectory Policy H1 - The proposed affordable housing policy seeks to lower the existing affordable housing threshold to residential Homes Limited) developments of 11 or more dwellings. Within the draft plan, it states that this threshold has been identified to accord with the threshold introduced into the NPPG. However, this was not intended to be a national threshold but its intention was to facilitate the delivery of smaller sites burdened by planning obligations in areas where low affordable housing thresholds existed. Effectively, this guidance seeks to set out a minimum national threshold with Local Planning authorities still required to justify their affordable housing thresholds at the local level. The proposed policy threshold is not therefore considered sufficiently justified with further full assessment required by the Council to ensure that such a threshold would not threaten future development viability in the district.

VALP16-09-05-00928 Tim Northey (Rectory Policy H6 - Support the flexible approach that the housing mix is not prescribed in policy, but allows for agreement at the time of an Homes Limited) application given current evidence. VALP16-09-05-00928 Tim Northey (Rectory Policy H7 - Given the lifetime of the plan, it would be a concern if minimum design standards were prescribed in policy as these Homes Limited) standards typically change on a regular basis. The policy therefore should be sufficiently flexible to allow for amendments to national standards. VALP16-09-05-00929 Sue Severn (Berryfields Policy H1 - 1. Housing needs for the forseeable future are fully met in the parish of Berryfields. Parish Council & Stoke 2. Policing must be considered to ensure it is adequate for the size of the area. Hammond Parish 3. The PC agrees in principle that the housing requirement within Aylesbury is correct. Council) 10. Specific housing for the elderly must include sheltered housing both for rental and sale.

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ID Respondent Name Comment VALP16-09-05-00934 Debbie Edwards Policy H1 - Section 5 affordable housing With the average price of a property in Marsworth in excess of £540,000 how will the affordable housing price be achieved as this is well out of reach for many first time buyers or even second or third move buyers, will it mean that the build will consist of 1 bedroom houses or flats or even studio apartments in order to reach this target, and for this area what do you classify as a price range for affordable housing. Or will it become a 100% affordable housing site as mentioned in section 5.17

As we all know it is essential to provide an adequate stock of new build housing in the area but this does not need to be done at the detriment to the already established communities by building around them why not try to intersperse the build throughout the entire community rather than just concentrating on one area. If we are forced to have just this one large site within the village then I request that the following is built into the plan and agreed upon before commencement of any development work All properties abounding the development are given the right to increase their land by a minimum of 10 metres from their existing boundary at current land cost prior to planning permission being granted. That a boundary of 10 metres is provided between the new development boundary and the existing properties boundary (even after the extension of boundary as above) to provide a buffer in order to help stop the original dwellings from being overlooked by the new development. As mentioned earlier many of the current residents purchased the property due to the open views over the countryside, and like ourselves did not want to be overlooked by a sprawling development of housing.

VALP16-09-05-00951 Charles Robinson (DLP Policy H1 - The flexibility towards the provision of affordable housing is necessary and welcomed. Planning Limited) VALP16-09-05-00955 Jonathan Clover Policy H1 - I believe the emphasis should be on affordable housing ie starter homes, shared ownership, self build, and social housing. There is likely to be a need for a greater proportion of these than 31%. Again the siting of these will depend on the location of the new settlements and where need arises in Aylesbury and the larger villages. More work is needed on this both in the Neighbourhood Plans and this Plan,s supplementary document. I defer further comment till then. VALP16-09-05-00955 Jonathan Clover Policy H5 - I agree this policy if it can be shown to encourage self build on a suitable basis.

VALP16-09-05-00955 Jonathan Clover Policy H6 - I accept that for Wendover suitable provision must be made for those with special needs of all kinds but these homes should be provided on suitable sites only determined by the Neighbourhood Plan, and not on land properly forming part of the Green Belt. VALP16-09-05-00955 Jonathan Clover Policy H7 - H7: again has research been done or considered in assessing dwelling size requirements as to the experience of people living in new housing in Aylesbury with similar standards. I note a viability study is underway. Will this canvass people's views and will this be published? Heela: I understand that the sites shown on the map had been brought forward following the call for sites or through a planning application. Is that correct? VALP16-09-05-00981 Michael Crockett Policy H1 - The number of houses planned is too high, especially considering that we should not be accommodating more than 10,000 houses from other places like Wycombe and South Bucks.

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ID Respondent Name Comment VALP16-09-05-00984 Phillippa Martin-Moran Policy H1 - 31% if Molly’s Folly and Field are allocated for a maximum of 100 units more affordable would be delivered, this will be (Optimis Estates) critical given new starter homes as well as more traditional affordable tenures. On our illustrative layout of 93 units at 31% the total of affordable units achieved by the Council that would exceed the 22 units ‘committed’ and total 29 units. VALP16-09-05-00987 Jonathan Glasspool Policy H6 - 4.62 The proposed developments at Haddenham will effectively create a doughnut ring of new development around the existing village. The character of the village will change substantially, turning a rural conurbation into a small dormitory town, with few, if any, services for those who live on the periphery of the village, and no proposed improvements of any significance to the facilities in the centre of the village.

The proposal to build an additional 200 houses to the north of the village (HA07) ignores its adjacency to the conservation area on Rosemary Lane. Development on this land was rejected by BCC within the past 15 years for many good reasons. See my points later concerning heritage. VALP16-09-05-00988 Sue Barber Policy H1 - All housing needs to provide adequate parking. Affordable housing needs to be closed to schools for all ages, transport links, bus and rail and within a reasonable distance from employment sites. VALP16-09-05-00988 Sue Barber Policy H6 - Needs to reflect the area not just built to meet a need. Smaller houses not just for first time buyers but for older people to downsize. Gardens are vital for all houses, it's a proven good activity for health and mental wellbeing. Green belt needs to be maintained to enable people to have good areas for walking to keep fit and healthy. No one wants to catch a bus or drive to find an area for a walk. VALP16-09-05-00988 Sue Barber Policy H7 - Must meet the needs of the local area and provide adequate parking.

VALP16-09-05-00992 Helen Hyre Policy H6 - Para 5.67 I agree that suitable accessible housing will be needed in towns and villages to meet the needs of older people. VALP16-09-05-00998 Charlotte Beadle Chapter 5 Housing - All paragraphs: I do not support this draft plan for 33000 new homes in Aylesbury Vale. VALP16-09-05-01005 Andrew Phillips Chapter 5 Housing This email is specifically centred around the expansion plans for Haddenham, either by this village growing or a "new town" on its outskirts. Haddenham is a historic settlement with no natural commercial centre. It is a small residential area with one key selling point = which is the railway station. We have two oversubscribed infant schools and one primary school. We are some distance from any secondary school with the nearest in a neighbouring county and no right to send our children there. We have no shops of note other than a corner shop and minor mini market (McColls). We have four pubs and minimal eateries. To expand this village would be a major failing of AVDC. We have poor village roads which are already overcrowded and often accident blackspot (Staybridge Rd jnt Woodways). The S.E part of the village floods yearly and parking around the railway station is already blocking the residential roads. Princes Risborogh is also adding housing as is Thame (In Oxfordshire). These in conjunction with Haddenhams already approved housing will put a strain on the existing infrastructure and no additional resources. From attending the open days and seeing your reports. Winslow is the only viable option. VALP16-09-05-01008 John Mortimer Policy H1 - Any development has to offer a range of housing options, but the provision of affordable housing has to be a prime objective.

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ID Respondent Name Comment VALP16-09-05-01008 John Mortimer Policy H2 - This policy has to be supported, but making it work in reality is difficult. Every single landowner/developer believes his or her site should all be ‘open market’ sites where housesare sold at full market value. Added to which, farmers close to developments are clouding the picture. Sensing that development is encroahing ever closer to the farms, they are only too aware that for every acre of land on which they can obtain planning permission they are likely to receive £1,000,000. ONE MILLION POUNDS. Not surprisingly, farmers close by AVDC and Milton Keynes are applying for planning permission. This is eroding the nation's stock of green belt. VALP16-09-05-01008 John Mortimer Policy H6 - There has to be a mix of housing. In particular, preference should be given to including bungalows in the new developments, including WDA001, in order to cater for elderly or inffirm inhabitants. Bungalows represent the worst nightmare for developers as they occupy too much land. But these desires should be stifled at birth as IT IS THE NEEDS OF THE COMMUNITY which come first. After all, the community provides the income for AVDC and others to do their work; indeed pays wages. Put more succinctly pays the salaries of the planners who should be working for THEIR community, NOT cow-towing to Government needs.

VALP16-09-05-01028 Warren Whyte (AVDC) Policy H5 - Welcome the provision of this policy, albeit without much detail at this stage.

VALP16-09-05-01028 Warren Whyte (AVDC) Policy H6 - There seems to be no mention of student housing - a big issue for Buckingham given the success of the university. This has an impact in the private rental sector and a clause or policy is needed to ensure a suitable provision of student accommodation is provided, and releasing family homes and flats to the domestic market. VALP16-09-05-01030 Derek Town Policy H1 - Para 5.13 Affordable homes are required and it is good to see there is a positive policy to support this requirement but will it be enforced ? There is potential for developers to work around this requirement by staging development or other devious means, will enforcement be made clear during planning approvals? VALP16-09-05-01030 Derek Town Policy H6 - Para 5.58 Do the planning authority have the power to influence the design of developments to specify dwelling types?

VALP16-09-05-01037 Janette Eustace Policy H1 - We believe it is important that when establishing the affordable housing requirement Neighbourhood Plans and Housing (Stewkley Parish Need Surveys should be referred to at an early stage. This requirement should be incorporated into policy. Council)

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ID Respondent Name Comment VALP16-09-05-01037 Janette Eustace Policy H6 - The demographics of the nation, county, district and parish clearly show we have an ageing population with one third of (Stewkley Parish the population being over 55 years and prospects of them living longer. More needs to be planned for in the VALP to cater for this Council) situation. Equally there is insufficient about homes and infrastructure for the disabled. The word 'disabled' only appears five times in a total of 222 pages, whilst three quarters of the growth in population in the district it is estimated, will be over the age of 65 years. Such people although not disabled will inevitably by less physical mobile. No emphasis has been placed on the community demographic and associated need. Stewkley has conducted a very detailed survey of the community with over 80% response. It shows a key need (over 60%) for 2 bed (mixed single and 2 storey) dwellings for start ups and down sizing. It also shows that a large number of 4 and 5 bed houses will be vacated to downsize. AVDC’s developer house type mix does not meet our village need and will place more pressure on Stewkley to build even more housing than allocated as AVDC will only view developer’s proposals on their VALP criteria rather than the community sustainable need. The VALP needs to be changed and to reflect this. The 5 year housing supply strategy is ‘developer driven’. The VALP highlights a typical % housing type mix for developments. If the allocated dwelling numbers to each village is ‘ideological’ based on the community need then the housing type mix should surely reflect this and not what makes a developer the most profit? VALP16-09-05-01037 Janette Eustace Policy H7 - AVDC has a large number of reasonably wealthy residents. They occupy large well kept properties and as they age they (Stewkley Parish will be seeking to down size. They will require quality, single floor properties, still with two garages, two en suite bedrooms and good Council) size living area. By providing these type of properties it frees up the large properties for the next generation.

VALP16-09-07-01153 Sylvie Eames Policy H1 - H1 Affordable Housing –recent changes relating to affordable housing not being required on sites of 10 or less should be amended in rural areas. In villages like Newton Longville there is urgent need for affordable housing. Youngsters starting on the housing ladder cannot afford to live in the village as there is nothing that is affordable. There is nothing about Starter Homes in VALP The demographics of the area reveal that the average age of the villagers is increasing and need for sheltered housing should be considered. This should be in detail in policy H6 Housing Mix. VALP16-09-07-01159 Mandy Cliffe (Great Policy H1 - H1 Affordable Housing Horwood Parish Council) GHPC notes that the Written Ministerial Statement of 28 November 2014 (which introduced the 10-dwelling threshold for affordable housing contributions mentioned in paragraph 5.5) combined this with a size threshold of a maximum combined gross floor space of 1,000 square metres GHPC considers that the size threshold should also be included in Policy H1. GHPC also considers that the phrase “a minimum of 31% affordable homes on site” in the policy should be replaced by a minimum of 31% affordable homes on site, unless a policy in a made neighbourhood plan covering all or part of the site specifies a greater percentage.

VALP16-09-07-01159 Mandy Cliffe (Great Policy H2 - H2 Rural Exception sites Horwood Parish Council) GHPC considers that this policy should incorporate the wording Proposals for these rural exception sites must accord with the Plan’s design policies and reinforce the distinctive character of the villages in which they are located from saved AVDLP Policy GP4. GHPC also considers that the maximum proportion of market housing to be included in a rural exception scheme should be 30% rather than 50% in order to preserve the essential nature of the scheme. This modification to policy H2 would make it consistent with paragraph 54 of the NPPF, which refers to “some market housing” in contrast to “significant additional affordable housing”; the present policy with a maximum of 50% would not be consistent with paragraph 54.

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ID Respondent Name Comment VALP16-09-07-01159 Mandy Cliffe (Great Policy H3 - H3 Rural Workers dwellings - In the itemised lists within the policy it is not clear why items (b) and (c) for permanent Horwood Parish Council) dwellings are worded differently from the corresponding items (i) and (j) for temporary dwellings. If these two pairs of items are indeed supposed to be equivalent then GHPC suggests a single itemised list for both types of dwelling, with a “fork” in the list to provide items (e) and (f) for permanent dwellings, and item (l) for temporary dwellings. VALP16-09-07-01159 Mandy Cliffe (Great Policy H4 - 5.4.1 GHPC suggest that the phrase “is considered acceptable in principle” in the policy be replaced by “will be Horwood Parish Council) permitted”, and that a suitably modified version of the sentence about increases in size from paragraph 5.54 be incorporated in the policy itself. VALP16-09-07-01159 Mandy Cliffe (Great Policy H5 - 5.5.1 GHPC supports the inclusion of a quantified policy for the provision of plots for self/custom build housing on large Horwood Parish Council) development sites.

VALP16-09-07-01159 Mandy Cliffe (Great Policy H6 - 5.6.1 GHPC considers that the second and third paragraphs of this policy should be quantified, giving targets for the Horwood Parish Council) proportions of specialist housing to be provided in developments of different sizes, with a requirement to present open-book viability evidence for any proposals where it is claimed that such targets cannot be attained. 5.6.2 It would be helpful to provide a full reference to Approved Document M, indicating that it is a guidance document relating to the Building Regulations 2010. VALP16-09-07-01159 Mandy Cliffe (Great Policy H7 - 5.7.1 GHPC notes that a policy requiring compliance with the Technical Housing Standards document would, with the Horwood Parish Council) provision of viability evidence, be in conformity with paragraphs 173 and 174 of the NPPF, but suggests that in any event a policy requirement that applicants provide a schedule of floor areas for each type of unit proposed would be of help to decision takers. VALP16-09-07-01160 Dave Norris Policy H1 - H1 Affordable Housing –recent changes relating to affordable housing not being required on sites of 10 or less should be amended in rural areas. In villages like Newton Longville there is urgent need for affordable housing. Youngsters starting on the housing ladder cannot afford to live in the village as there is nothing that is affordable. There is nothing about Starter Homes in VALP The demographics of the area reveal that the average age of the villagers is increasing and need for sheltered housing should be considered. This should be in detail in policy H6 Housing Mix. VALP16-09-07-01171 Nick Osgerby (Steeple Policy H6 - SCPC believes that there should be a significant shift in emphasis to housing developments proposed in the village to Claydon Parish Council) provide homes suitable for its aging population.

VALP16-09-07-01172 Simon Proctor (Proctor Policy H1 - 5.8 and H1 cOffsite provision is to be encouraged. Surveyors (Stoke Hammond)) H1 dClarity is required as to what is meant by “larger developable area” and “could be developed as a whole”. For example separate ownership or lease restrictions may preclude a larger site being brought forward for development as a whole, further it may be more appropriate to the scale and character of a settlement for a smaller development. VALP16-09-07-01172 Simon Proctor (Proctor Policy H5 - This policy should be pursued with caution. Self-build plots can significantly impact on the delivery of housing numbers Surveyors (Stoke and the attractiveness of a site / development to purchasers. Personal economic factors can have a significant bearing on the Hammond)) standard of work or indeed completion of the development. Enforcement or remediation may incur significant expense to the authority.

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ID Respondent Name Comment VALP16-09-07-01172 Simon Proctor (Proctor Policy H6 - It is important to remain flexible with regard to mix which should reflect need and market factors. Surveyors (Stoke Hammond)) VALP16-09-07-01172 Simon Proctor (Proctor Policy H7 - It is important to remain flexible with regard to floor areas which should reflect need and market factors. Surveyors (Stoke Hammond)) VALP16-09-08-01205 Mark Rose (Define (on Policy H1 - The Draft VALP states that to meet identified affordable housing needs a minimum of 31% is required on qualifying sites. behalf of Bovis Homes)) However, viability is a critical issue in the determination of affordable housing targets and the tenure mix. That has most recently been highlighted in the letter from Brandon Lewis MP to all of the Local Authority Leaders dated 9th November 2015, that seeks to encourage local authorities to act quickly and constructively in renegotiating Section 106 requirements to address viability issues. However, in plan making the key is of course to establish requirements that are deliverable in the first instance (NPPF paras 173- 174). That should be clearly demonstrated before a minimum target is set, and there does not appear to be any evidence to that effect at this point in time. The Governments’ Starter Homes Initiative will also need to be taken into account in due course. However, as highlighted above the NPPG asks plan makers to consider increasing their housing requirement in order to help meet affordable housing needs. VALP16-09-08-01205 Mark Rose (Define (on Policy H6 - BHL would be concerned if the proposed policy in relation to housing mix was unduly prescriptive as that can have behalf of Bovis Homes)) significant implications for the viability of strategic sites that needs to be carefully considered. Furthermore, the policy only refers to housing need rather than demand. However, the NPPF clearly states (2nd bullet para 50) that demand is the key consideration when identifying “the size, type, tenure and range of housing that is required”. It is essential that the difference between need and demand is recognised, as whilst the need arising from smaller households might be for smaller properties, the actual demand is commonly still for larger properties. That is not surprising as the benefits to smaller households of having more flexible living accommodation in both the short and long terms are clear, and ultimately more sustainable if it means that residents can stay in their home if their household grows or their circumstances change.

VALP16-09-08-01207 Michael Knott (Barton Policy H1 - Policy Hl -Affordable Housing. We welcome the provision of on-site affordable housing, subject to viability. The suitability Willmore (on behalf of of any affordable housing policy is reliant entirely on the development needs of the District and the appropriateness of the affordable Manlet Group Holdings housing thresholds, which in the case of the Preferred Options document is set at 31% of dwellings on sites of a net gain of 11 or Limited)) more dwellings. It is considered that the policy should allow for developers to negotiate on the level of affordable housing to be provided, particularly on schemes where viability is an issue and the benefits of providing a scheme with a lower level of affordable housing would outweigh any adverse impacts of lowering the supply of housing in the District. requirement. Clearly, the Council could seek to increase the supply of affordable housing by increasing the overall supply of housing in the District.

VALP16-09-08-01209 Tim Coleby (Peter Brett Policy H1 - BA supports the policies in chapter 5 ‘Housing’. Associates LLP on The Aylesbury Woodlands proposals will provide a substantial boost for housing supply in the district and help the Council in its behalf of efforts to demonstrate a five year supply of deliverable housing sites, as is required by the NPPF. Buckinghamshire Policies H1 Affordable Housing and H6 Housing Mix 5.2 Advantage) In respect of the Aylesbury Woodland planning application proposals, the affordable housing and housing mix requirements of these policies are noted and will be the subject of further discussions with the Council.

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ID Respondent Name Comment VALP16-09-08-01209 Tim Coleby (Peter Brett Policy H5 - 5.3 Associates LLP on In accordance with this policy, the Aylesbury Woodlands housing offer is distinguished by its custom build element, as follows. behalf of As part of the housing offer for the site, an element of Custom Build housing will be provided. The Custom Build sector aims to Buckinghamshire reduce the reliance on large scale house builders and reduce the housing shortfall. Custom Build on the Woodlands site will involve Advantage) a builder or developer being contracted by BA and could offer a number of benefits, including; affordable bespoke-designed market housing; promotes design quality; environmental sustainability; drives innovation in building techniques; can offer opportunities to smaller builders and contractors; and create local jobs and contribute to local economies.

VALP16-09-08-01225 Frazer Hickling (Phillips Policy H1 - In regards to the chapter on housing, it is noted that the policies set a threshold and proportions for delivery of affordable Planning Services housing, dwelling sizes and mixes as well as criteria which will be applied to proposals for rural exceptions site, rural worker’s Limited) dwellings and, self-build replacement dwellings. Para 2.30 - It is considered that the chapter covers all expected ‘housing-related’ policy matters, and we have no comments to make. VALP16-09-08-01242 Louise, Thomas & Eleri Policy H3 - Following on from our experience of obtaining planning permission for a rural workers dwelling, we would like to make Hosking some comments about paragraph 5.53 ‘Rural Workers Dwellings.’ You state ‘applicants must provide sufficient information to enable the council to determine any application for an occupational dwelling. The council may also seek the advice of agricultural or other consultants to give a technical appraisal of the case being put forward.’ We fully support this paragraph but ask that you use agricultural and other consultants that are the best in their field. For example, farm business consultants to assess a farm business case for a dwelling, because while Acorus are surveyors, they are not business consultants, and do not have the experience in working with developing farm businesses over a period of time, and do not have that perspective of seeing how those businesses may look marginal to start with, but are capable of growing sustainably. Having had personal experience in obtaining planning permission for a rural workers dwelling we had the absolute misfortune to be appraised by Laura Wall from Acorus who was anything other than the best in her field. This therefore led to us having to be present at three planning committee meetings to discuss our case – a massive waste of everyone’s time and energy and at huge cost all because Laura Wall did not know much, if anything, about agriculture even though she is purported to the council’s expert. We are just very thankful that the District Councillors that sit on the planning committee grasped our case and unanimously supported our application.

VALP16-09-08-01245 Deborah O’Brien Policy H1 - H1 The affordable housing distribution patterns proposed in the Plan are too rigid. We would wish to see ‘ghetto-ising’ of (Padbury Parish Council) affordable housing in developments being avoided. In addition, we would wish to see a firm commitment to provide a minimum of 35% affordable homes in developments. VALP16-09-08-01245 Deborah O’Brien Policy H6 - 5.58 et seq and H6, H7 We welcome the intention to set appropriate mixes of houses (in terms of size) on (Padbury Parish Council) developments, particularly for the more rural settlements. Historically, larger homes have tended to be built and this has changed the demographics of the villages (and ultimately their sustainability) due to lack of affordability.

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ID Respondent Name Comment VALP16-09-08-01273 Adam Ross (Nexus Policy H1 - We reserve our comments on this policy for the time being on the basis that, as is rightly recognised at footnote 25 of the Planning Ltd (on behalf VALP, Policy H1 is likely to need to be amended following the publication of the Regulations on Starter Homes as outlined in the of Gleeson Housing and Planning Act 2016. Developments Limited, The inter-relationship between Starter Homes and other affordable housing is key to the soundness and, importantly, the viability of the Ernest Cook Trust, this policy but at this point in time it is impossible to determine whether the requirement for a minimum of 31% affordable housing the Trustees of Lord including, we assume, provision for Starter Homes, is reasonable or viable. Carington’s 1963 Settlement and the Change Sought Pearce Family)) We reserve our position in terms of the content of Policy H1 pending the publication of the Starter Homes Regulations and greater clarity on the soundness and viability of the policy. VALP16-09-08-01273 Adam Ross (Nexus Policy H5 - We do not object to the principle of making available an appropriate proportion of development in the district as self-build Planning Ltd (on behalf / custom build housing, which accords with the NPPF objective to deliver a wide range of high quality homes. of Gleeson However, we reserve our right to comment further on this policy when ‘flesh has been added to the bone’. It is this detail that will be Developments Limited, key to the soundness and viability of the policy. It is of course not only the proportion of self / custom build housing sought, but also the Ernest Cook Trust, the practicality and viability of delivering such provision, which depends to a large extent on the size and nature of a development the Trustees of Lord site. Carington’s 1963 Settlement and the Change Sought Pearce Family)) We reserve our right to comment on this policy when the detail has been added in terms the proportion of self / custom build housing sought and its delivery, having regard to issues of practicality and viability. VALP16-09-08-01273 Adam Ross (Nexus Policy H7 - We do not object, in principle, to the Council’s proposal to require minimum dwelling sizes based upon the government’s Planning Ltd (on behalf published ‘Technical Housing Standards’ in 2015. The viability of doing so is, however, key and we note that a viability study is of Gleeson currently under way. As such we must reserve our right to comment fully when this is available. Developments Limited, However, we do object to the fact that the Council appears to have moved straight to the issue of the viability of such provision but the Ernest Cook Trust, without carrying out the first step of the process – identifying the need to adopt these minimum standards in the context of Aylesbury the Trustees of Lord Vale District. Carington’s 1963 The government’s internal space standards are optional i.e. it is at the discretion of the local authority as to whether to set these Settlement and the additional technical requirements. ID 56-020 of the PPG is clear that before considering the issue of viability it is first necessary for Pearce Family)) the Council to consider, and identify, that there is a need for internal space standards and then ‘provide justification for requiring internal space policies.’ No such justification is provided in Policy H7 and as such, the policy is contrary to national policy in this regard.

Changes Sought Policy H7 is contrary to national policy as it provides no justification for the need to introduce internal space standards in Aylesbury Vale, or any work to demonstrate that it would be viable. The policy should either be deleted or amended to address these issues, and we reserve our right to comment further in due course.

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ID Respondent Name Comment VALP16-09-08-01283 Simon Proctor (Proctor Policy H1 - 5.8 and H1 cOffsite provision is to be encouraged. Surveyors (Stoke Hammond 2)) H1 dClarity is required as to what is meant by “larger developable area” and “could be developed as a whole”. For example separate ownership or lease restrictions may preclude a larger site being brought forward for development as a whole, further it may be more appropriate to the scale and character of a settlement for a smaller development. VALP16-09-08-01283 Simon Proctor (Proctor Policy H5 - This policy should be pursued with caution. Self-build plots can significantly impact on the delivery of housing numbers Surveyors (Stoke and the attractiveness of a site / development to purchasers. Personal economic factors can have a significant bearing on the Hammond 2)) standard of work or indeed completion of the development. Enforcement or remediation may incur significant expense to the authority. VALP16-09-08-01283 Simon Proctor (Proctor Policy H6 - It is important to remain flexible with regard to mix which should reflect need and market factors. Surveyors (Stoke Hammond 2)) VALP16-09-08-01283 Simon Proctor (Proctor Policy H7 - It is important to remain flexible with regard to floor areas which should reflect need and market factors. Surveyors (Stoke Hammond 2)) VALP16-09-08-01291 Martin Small (Historic Policy H2 - Policy H2 – we would like to see a criterion in Policy H2 that small-scale developments for affordable housing may be England) permitted only if there is no adverse impact on the historic environment/heritage assets, or at least a requirement that such development proposals conform with other policies of the Plan as part of the positive strategy for the conservation and enjoyment of, and the clear strategy for enhancing, the historic environment required by the NPPF.

(Although outside our remit, we do query whether or not it is appropriate to say “may be permitted” in a policy, given that paragraph154 of the HPPF states “Only policies that provide a clear indication of how a decision maker should react to a development proposal should be included in the plan.” “May” is not a “clear indication”). VALP16-09-08-01291 Martin Small (Historic Policy H3 - we would like to see a criterion in Policy H3 that rural workers’ dwellings be permitted only if there is no adverse impact England) on the historic environment/heritage assets, or at least a requirement that such development proposals conform with other policies of the Plan, as part of the positive strategy for the conservation and enjoyment of, and the clear strategy for enhancing, the historic environment required by the NPPF.

Paragraph 6.2 – we welcome the requirement that “Development should not, either on its own or cumulatively, (in combination with other established or proposed developments in the vicinity), significantly adversely affect the area’s landscape, heritage and built environment…”, as part of the positive strategy for the conservation and enjoyment of, and the clear strategy for enhancing, the historic environment required by the NPPF.

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ID Respondent Name Comment VALP16-09-08-01301 Aston Clinton Sarl Policy H1 - 2.19 Policy H1 of the VALP states that the type, size, tenure and location of affordable housing will be agreed with the (Nexus Planning Ltd) Council, taking into account the most up to date evidence. We do however note that paragraph 5.9 of the VALP states this will be negotiated on a site by site basis. Aston Clinton Sarl support this but consider that it should be specifically referenced in the policy wording, rather than supporting text. Market conditions and evidence will of course change over the course of the Plan period and it is therefore important that the policy is suitably flexible to respond to such changes and variances. 2.20 Aston Clinton Sarl welcome the acknowledgement that Starter Homes are likely to be included in the definition of affordable housing, which we understand might be clarified later this year. The VALP will of course need to respond to any new legislation / guidance that arises on this matter. 2.21 Notwithstanding the above, we note that paragraph 5.7 of the VALP states that affordable homes will be expected to be groups of no more than 18 homes. Aston Clinton Sarl are aware that affordable housing providers seek larger clusters for management reasons and as a result, rigidly apply such a requirement could deter said providers. Aston Clinton Sarl would therefore suggest that this cluster limit is increase or greater flexibility applied to the wording. Changes Sought: 2.22 Policy H1 wording is amended to include confirmation that the type, size, tenure and location of affordable housing will be agreed with the Council on a site by site basis, that the policy is amended following publication of imminent Starter Homes legislation / guidance and that the affordable housing cluster limit is increased or at least flexibility increased.

VALP16-09-08-01301 Aston Clinton Sarl Policy H7 - 2.23 Policy H7 proposes to implement the Government’s internal space standards, subject to the outcome of a viability (Nexus Planning Ltd) study, the results of which are not know at this stage. Whilst Aston Clinton Sarl has no objection in principle to applying these standards, the NPPG is clear that local planning authorities should provide justification for requiring internal space policies. 2.24 Until the above evidence has been provided, which Aston Clinton Sarl is not aware has be done, the implementation of internal space standards is not justified. Changes Sought: 2.25 The policy should be removed from the Plan until such time that a full needs and viability assessment has been carried out.

VALP16-09-09-01315 Neil Tiley (Pegasus Policy H1 - Paragraph 5.3 identifies that according to the HEDNA there is a need for 6,580 affordable homes from 2013 to 2033. Group (on behalf of The Local Plan identifies a housing requirement for 33,300 homes in total and so it can be calculated that 19.8% of housing should Jeremy Elgin)) be provided as affordable units according to the evidence of the Council. However, Policy H1 requires that a minimum of 31% of homes are affordable. This Policy therefore places an onerous obligation on residential developments which is not fairly or reasonably related in kind or scale and which is therefore contrary to both paragraph 173 of the NPPF and to the CIL tests. The total affordable need would have to be far greater in order to justify this Policy, which in itself would justify an uplift to the housing requirement (and thereby reduce the percentage of affordable housing sought on each site); or the percentage requirement must be 19.8%.

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ID Respondent Name Comment VALP16-09-09-01315 Neil Tiley (Pegasus Policy H5 - Policy H5 requires that all larger developments will provide a percentage of serviced dwelling plots for sale for Group (on behalf of self/custom build. This Policy is intended to be detailed within a SPD, but the details of this SPD will be critical to the soundness of Jeremy Elgin)) the Policy and so this information should be provided within the Local Plan. Furthermore, awaiting the production of a SPD will only serve to delay the delivery of larger developments which will further undermine the already precarious five-year land supply position. The requirement for self-build plots would need to be justified by a demand for such provision. However, the HEDNA identifies that “…this represents only a very limited number of people and an exceptionally small proportion of the overall housing need identified each year.” Based on the available evidence of demand, there is no justification for requiring provision on larger developments. The provision of self-build plots within larger developments may adversely affect deliverability, as there is no certainty of the timescales and demand for such sites. Indeed, each plot would normally be sold individually and so a number of different purchasers would be required which may take time, then each would develop to their own timescales. Furthermore, self-builders tend to prefer smaller sites rather than components of large development sites and so on-site provision is unlikely to respond to the demand.

VALP16-09-09-01315 Neil Tiley (Pegasus Policy H6 - seeks to provide for a mix of housing as identified in the HEDNA or more recent evidence. However, this will not be Group (on behalf of applicable to all sites (such as the redevelopment of a building to flats) and so there needs to be sufficient flexibility within the policy Jeremy Elgin)) wording to allow for alternative mixes. Policy H6 also requires that larger development schemes provide for self-contained extra-care accommodation. This Policy will need to be demonstrated to be viable and that it responds to an identified need. Finally, Policy H6 also seeks to apply the optional accessibility standards. This can only be applied where this is justified by an evidenced local need and where it would not compromise the viability of development. The justification within the HEDNA is not locally specific, but reflects the national rate of wheelchair use. The current justification is therefore insufficient to meet the requirements. Furthermore, no viability assessment has been undertaken and so the effects on viability are entirely unknown. Until and unless these pieces of work are undertaken the optional standards cannot be applied in Aylesbury Vale.

VALP16-09-09-01315 Neil Tiley (Pegasus Policy H7 - 6.10 See response to Policy H6. Policy H7 seeks to apply the optional space standards which would need to be justified Group (on behalf of by evidenced local need and where it would not compromise the viability of development. Neither of these have been demonstrated Jeremy Elgin)) and so these optional standards cannot be required at present. 6.11 The optional space standards require larger homes, which will reduce the density of developments and thereby will generate a need for additional areas of land to be allocated for development to achieve the housing requirement. It is also likely to increase the cost of housing which will be counter-productive given the affordability issues which already exist in Aylesbury Vale, and will present further barriers to the accessibility of housing.

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ID Respondent Name Comment VALP16-09-09-01389 Amy Stone Policy H1 - Affordable Housing We reserve comment on this policy for the time being on the basis that, as is rightly recognised at footnote 25 of the VALP, Policy H1 is likely to need to be amended following the publication of the Regulations on Starter Homes as outlined in the Housing and Planning Act 2016. The inter-relationship between Starter Homes and other affordable housing is key to the soundness and importantly, the viability of this policy but at this point in time it is impossible to determine whether the requirement for a minimum of 31% affordable housing including, we assume, provision for Starter Homes, is reasonable or viable. Change Sought We reserve our position in terms of the content of Policy H1 pending the publication of the Starter Homes Regulations and greater clarity on the soundness and viability of the policy. VALP16-09-09-01389 Amy Stone Policy H5 - Self / Custom Build Housing We do not object to the principle of making available an appropriate proportion of development in the district as self-build / custom build housing, which accords with the NPPF objective to deliver a wide range of high quality homes. However, we reserve our right to comment further on this policy when ‘flesh has been added to the bone’. It is this detail that will be key to the soundness and viability of the policy. We note particularly that it is not only the proportion of self / custom build housing sought, but also the practicality and viability of delivering such provision which depends to a large extent on the size and nature of a development site. Change Sought We reserve our right to comment on this policy when the detail has been added in terms the proportion of self / custom build housing sought, and detail in terms of its delivery having regard to issues of practicality and viability.

VALP16-09-09-01389 Amy Stone Policy H7 - Dwelling Sizes We do not object, in principle, to the Council’s proposal to require minimum dwelling sizes based upon the government’s published ‘Technical Housing Standards’ in 2015. The viability of doing so is, however, key and we note that a viability study is currently under way. As such we must reserve our right to comment fully when this is available. However, we do object to the fact that the Council appears to have moved straight to the issue of the viability of such provision but without carrying out the first step of the process – identifying the need to adopt these minimum standards in the context of Aylesbury Vale District. The government’s internal space standards are optional i.e. it is at the discretion of the local authority as to whether to set these additional technical requirements. ID 56-020 of the PPG is clear that before considering the issue of viability it is first necessary for the Council to consider, and identify, that there is a need for internal space standards and then „provide justification for requiring internal space policies.‟ No such justification is provided in Policy H7 and as such, the policy is contrary to national policy in this regard. Change Sought As drafted, Policy H7 is contrary to national policy as it provides no justification for the need to introduce internal space standards in Aylesbury Vale, or any work to demonstrate that it would be viable. The policy should either be deleted or amended to address these issues, and we reserve our right to comment further in due course.

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ID Respondent Name Comment VALP16-09-09-01399 Cllr Phil Yerby Policy H1 - We support the policy aim but strongly disagree with point b. In effect major housing developments resist the need for affordable homes. It is extremely likely that significant on- and off-site infrastructure levies will be needed in order to deliver the minimum level of required infrastructure. Thus it is probable that in most cases of major development this policy will not be delivered, which is unacceptable. The policy needs to be re-written to state, “development of 11 dwellings or more will be required to provide a minimum of 25% affordable housing in addition to any other required infrastructure contributions”. Point b. should be removed. This will ensure a far greater delivery of the vitally-needed affordable homes than does the current proposed policy.

VALP16-09-09-01399 Cllr Phil Yerby Policy H2 - “Small scale” needs to be defined. Whilst it states in the body of the text (bullet point 5.4) that they “often provide fewer than 12 dwellings” this needs to be made clear in the policy. We recommend the policy be changed to state clearly that no sites will be considered of over 12 dwellings including any market housing incorporated in any scheme. It would also be helpful to define “rural” in the context of the VALP definitions. We do not consider medium villages or above to be rural. The policy should state that only “smaller villages and below will be considered as rural for the purposes on the policy.

VALP16-09-09-01399 Cllr Phil Yerby Policy H3 - We make no comment on the policy but note that the text accompanying the policy is considerably longer than the whole of the Aylesbury Transport Strategy. VALP16-09-09-01399 Cllr Phil Yerby Policy H6 - We support these policies.

VALP16-09-09-01399 Cllr Phil Yerby Policy H7 - We support these policies.

VALP16-09-09-01399 Cllr Phil Yerby Polyc H5 - Policy H5 Self/custom build housing - We support the policy aim but it needs to be SMART. It is appropriate to define “larger”. Suggested size of larger development should be above 10. VALP16-09-09-01407 Simon Handy (Strutt & Policy H1 - Policy H1 – ‘Affordable housing’ Parker LLP (Stoke We do not have any objections to the wording of this policy. Our development proposals would help deliver much needed affordable Mandeville)) housing and would comply with Policy H1 by meeting the 31% requirement. VALP16-09-09-01427 Phil Yerby (Hampden Policy H1 - We support the policy aim but strongly disagree with point b. In effect major housing developments resist the need for Fields Action Group) affordable homes. It is extremely likely that significant on- and off-site infrastructure levies will be needed in order to deliver the minimum level of required infrastructure. Thus it is probable that in most cases of major development this policy will not be delivered, which is unacceptable. The policy needs to be re-written to state, “development of 11 dwellings or more will be required to provide a minimum of 25% affordable housing in addition to any other required infrastructure contributions”. Point b. should be removed. This will ensure a far greater delivery of the vitally-needed affordable homes than does the current proposed policy.

VALP16-09-09-01427 Phil Yerby (Hampden Policy H2 - Policy H2 Rural exception sites Fields Action Group) “Small scale” needs to be defined. Whilst it states in the body of the text (bullet point 5.4) that they “often provide fewer than 12 dwellings” this needs to be made clear in the policy. We recommend the policy be changed to state clearly that no sites will be considered of over 12 dwellings including any market housing incorporated in any scheme. It would also be helpful to define “rural” in the context of the VALP definitions. We do not consider medium villages or above to be rural. The policy should state that only “smaller villages and below will be considered as rural for the purposes on the policy.

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ID Respondent Name Comment VALP16-09-09-01427 Phil Yerby (Hampden Policy H3 - We make no comment on the policy but note that the text accompanying the policy is considerably longer than the whole Fields Action Group) of the Aylesbury Transport Strategy. VALP16-09-09-01427 Phil Yerby (Hampden Policy H5 - Policy H5 Self/custom build housing - We support the policy aim but it needs to be SMART. It is appropriate to define Fields Action Group) “larger”. Suggested size of larger development should be above 10. VALP16-09-09-01427 Phil Yerby (Hampden Policy H6 - We support these policies. Fields Action Group) VALP16-09-09-01427 Phil Yerby (Hampden Policy H7 - We support these policies. Fields Action Group) VALP16-09-09-01451 Geoff Culverhouse Policy H1 - Para 5.1 - Affordable housing should be provided a minimum rate of 35% of all relevant developments. The strongest (North Bucks Parishes possible action should be taken to ensure that this requirement is met in all cases. Within AVDC’s area there are numerous Planning Consortium) communities which are defined as ‘rural areas’ by Statutory Instrument 1997 No. 625 (referred to at para 5.15 of VALP). The recent change to PPG relating to affordable housing not being required on sites of 10 or less would therefore not apply on sites within these ’rural areas’. Policy H1 needs to be amended to reflect this. Para 5.2 - We believe it is important that when establishing the affordable housing requirement Neighbourhood Plans and Housing Need Surveys should be referred to at an early stage. This requirement should be incorporated into policy. Para 5.3 - Affordable housing ‘clusters’ should reflect the scale of the overall development and not be set at a specific number. Where developments are completed in phases no affordable housing cluster should be permitted adjacent to a cluster on an earlier phase of the development. These matters should be incorporated into the policy and not left to be reliant on the supporting text.

VALP16-09-09-01451 Geoff Culverhouse Policy H2 - We suggest that ‘may be permitted’ in the first line of this policy should be replaced with ‘will be encouraged’. (North Bucks Parishes Planning Consortium) VALP16-09-09-01451 Geoff Culverhouse Policy H3 - Policy H3 Rural workers dwellings - This policy is supported. (North Bucks Parishes Planning Consortium) VALP16-09-09-01451 Geoff Culverhouse Policy H4 - Replacement dwelling in the countryside - Add to this policy. Replacement dwellings should occupy no more than twice (North Bucks Parishes the footprint of the existing dwelling. Planning Consortium) VALP16-09-09-01451 Geoff Culverhouse Policy H5 - Self/custom build housing - This is already being explored in respect of a site at Winslow. Meetings with the developers, (North Bucks Parishes interested self-builders, AVDC planners and Winslow Town Council (WTC) representatives have established that there is much work Planning Consortium) to be done on this as yet. There is clearly strong evidence of the need and therefore the development of a clear SPD will be important. WTC would be happy to contribute to discussions on the development of a suitable SPD. VALP16-09-09-01451 Geoff Culverhouse Policy H6 - Housing Mix - Generally this is supported. Additionally, Neighbourhood Plans and Housing Need Surveys, where (North Bucks Parishes available, must be referred to when establishing housing mix on developments. Planning Consortium) VALP16-09-09-01451 Geoff Culverhouse Policy H7 - Dwelling sizes - This policy is noted. (North Bucks Parishes Planning Consortium)

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ID Respondent Name Comment VALP16-09-09-01468 Sarah Hamilton-Foyn Policy H1 - Paragraph 5.3 identifies that according to the HEDNA there is a need for 6,580 affordable homes from 2013 to 2033. (Pegasus Group (Revera The Local Plan identifies a housing requirement for 33,300 homes in total and so it can be calculated that 19.8% of housing should Limited on behalf of be provided as affordable units according to the evidence of the Council. However, Policy H1 requires that a minimum of 31% of M&G Property Limited homes are affordable. This Policy therefore places an onerous obligation on residential developments which is not fairly or Partnership)) reasonably related in kind or scale and which is therefore contrary to both paragraph 173 of the NPPF and to the CIL tests. The total affordable need would have to be far greater in order to justify this Policy, which in itself would justify an uplift to the housing requirement (and thereby reduce the percentage of affordable housing sought on each site); or the percentage requirement must be 19.8%.

VALP16-09-09-01468 Sarah Hamilton-Foyn Policy H5 - Policy H5 requires that all larger developments will provide a percentage of serviced dwelling plots for sale for (Pegasus Group (Revera self/custom build. This Policy is intended to be detailed within a SPD, but the details of this SPD will be critical to the soundness of Limited on behalf of the Policy and so this information should be provided within the Local Plan. Furthermore, awaiting the production of a SPD will only M&G Property Limited serve to delay the delivery of larger developments which will further undermine the already precarious five-year land supply position. Partnership)) The requirement for self-build plots would need to be justified by a demand for such provision. However, the HEDNA identifies that “…this represents only a very limited number of people and an exceptionally small proportion of the overall housing need identified each year.” Based on the available evidence of demand, there is no justification for requiring provision on larger developments. The provision of self-build plots within larger developments may adversely affect deliverability, as there is no certainty of the timescales and demand for such sites. Indeed, each plot would normally be sold individually and so a number of different purchasers would be required which may take time, then each would develop to their own timescales. Furthermore, self-builders tend to prefer smaller sites rather than components of large development sites and so on-site provision is unlikely to respond to the demand.

VALP16-09-09-01468 Sarah Hamilton-Foyn Policy H6 - Policy H6 seeks to provide for a mix of housing as identified in the HEDNA or more recent evidence. However, this will (Pegasus Group (Revera not be applicable to all sites (such as the redevelopment of a building to flats) and so there needs to be sufficient flexibility within the Limited on behalf of policy wording to allow for alternative mixes. M&G Property Limited Policy H6 also requires that larger development schemes provide for selfcontained extra-care accommodation. This Policy will need Partnership)) to be demonstrated to be viable and that it responds to an identified need. Finally, Policy H6 also seeks to apply the optional accessibility standards. This can only be applied where this is justified by an evidenced local need and where it would not compromise the viability of development. The justification within the HEDNA is not locally specific but reflects the national rate of wheelchair use. The current justification is therefore insufficient to meet the requirements. Furthermore, no viability assessment has been undertaken and so the effects on viability are entirely unknown. Until and unless these pieces of work are undertaken the optional standards cannot be applied in Aylesbury Vale.

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ID Respondent Name Comment VALP16-09-09-01468 Sarah Hamilton-Foyn Policy H7 - 6.9 See response to Policy H6. Policy H7 seeks to apply the optional space standards which would need to be justified (Pegasus Group (Revera by evidenced local need and where it would not compromise the viability of development. Neither of these have been demonstrated Limited on behalf of and so these optional standards cannot be required at present. M&G Property Limited 6.10 The optional space standards require larger homes, which will reduce the density of developments and thereby will generate a Partnership)) need for additional areas of land to be allocated for development to achieve the housing requirement. It is also likely to increase the cost of housing which will be counter-productive given the affordability issues which already exist in Aylesbury Vale, and will present further barriers to the accessibility of housing. VALP16-09-09-01477 Jane Eden (Aylesbury Policy H1 - Ownership of new homes - Even in leafy Buckinghamshire there are residents who need to live in social housing, Town Council.) therefore this provision must be maintained and increased, there are several thousand people on the waiting list for social housing within Aylesbury and the wider vale, historically the % of social housing on developments has been 30%, Aylesbury Town Council sees no reason why that should be lowered. Social housing provision must be increased as part of the forthcoming developments, Aylesbury Town Council planning & Licensing committee reiterates that in our view a minimum 30% of new developments should be available on this basis. VALP16-09-12-01514 Simon Proctor (Proctor Policy H1 - 5.8 and H1 c Offsite provision is to be encouraged. Surveyors (Gawcott)) H1 d Clarity is required as to what is meant by “larger developable area” and “could be developed as a whole”. For example separate ownership or lease restrictions may preclude a larger site being brought forward for development as a whole, further it may be more appropriate to the scale and character of a settlement for a smaller development. VALP16-09-12-01514 Simon Proctor (Proctor Policy H5 - This policy should be pursued with caution. Self-build plots can significantly impact on the delivery of housing numbers Surveyors (Gawcott)) and the attractiveness of a site / development to purchasers. Personal economic factors can have a significant bearing on the standard of work or indeed completion of the development. Enforcement or remediation may incur significant expense to the authority. VALP16-09-12-01514 Simon Proctor (Proctor Policy H6 - It is important to remain flexible with regard to mix which should reflect need and market factors. Surveyors (Gawcott)) VALP16-09-12-01514 Simon Proctor (Proctor Policy H7 - It is important to remain flexible with regard to floor areas which should reflect need and market factors. Surveyors (Gawcott)) VALP16-09-12-01515 Cameron Austin-Fell Policy H1 - The policy requires a ‘minimum of 31%’ affordable homes. There appears to be limited justification for the 31% figure (RPS Planning & and also its treatment as a minimum requirement, therefore until this is appropriately evidenced based, this element of the policy is Development (on behalf not considered to be justified. Whilst paragraph 5.6 allows for a reduced element of affordable housing provision, based on viability of Richborough Estates considerations (which is supported), it is not clear why a cap of grouping affordable homes of no more than 15-18 units has been Site - Churchway, provided. This should be removed and the circumstances of the site dictates the level of grouping of affordable housing, which may Haddenham)) be significantly different depending upon the size of the site and its characteristics. Criterion D states that where a site is part of a larger developable area that could be developed as a whole, the council will seek affordable housing provision appropriate to the larger area. This is considered inappropriate in relation to strategic allocations which, given their very nature, will be under different landownerships and will inevitably come forward at different stages. The policy should be amended to allow for this or the policy element removed completely. The independent consultant cannot be independent if chosen solely by the Council; it must be chosen by the Council and Applicant, from a selected shortlist.

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ID Respondent Name Comment VALP16-09-12-01515 Cameron Austin-Fell Policy H5 - This policy requires a percentage of all larger developments to be provided as serviced plots for sale to self/custom (RPS Planning & builders. This policy wording should be made more flexible and not require all larger sites (however defined) as this might in many Development (on behalf instances be unworkable with existing land agreements and characteristics of the site. The policy should say consideration only of Richborough Estates should be given to providing serviced plots for sale. Site - Churchway, Haddenham)) VALP16-09-12-01515 Cameron Austin-Fell Policy H6 - Paragraph 5.64 states it will be expected that all larger developments should provide an element of self-contained extra (RPS Planning & care dwellings as part of the over mix. Whilst this might be possible on very large sites (500+), this would/may not be possible or Development (on behalf appropriate on sites below this general level of site and should either therefore be clarified or omitted from the plan. of Richborough Estates Concern is raised in relation to the requirement for all residential developments to meet Category 2 standards for adapted homes Site - Churchway, with 10% of market homes meeting Category 3 standards. The evidence base for such specific requirements appear limited and the Haddenham)) justification appears lacking, particularly the viability implications of imposing such stringent requirements.

VALP16-09-12-01515 Policy H7 - Providing minimum gross floor areas for all dwellings (as Table 9 does) is inappropriate. This is not based on appropriate viability considerations and would hinder the ability of the market to deliver both the amount of housing required and the type of accommodation required from future occupants. The policy should be removed and dealt with through building control requirements if justified. VALP16-09-12-01521 Sean Carolan (Winslow Policy H1 - Para 5.7 -the simple statement that affordable homes should be in groups of no more than 15 to 18 is totally Town Council) unacceptable, another instance AVDC where one size does not fit all. At 31% affordable homes contribution, a 48 home development would/could have a single cluster of 15, clearly a single cluster for such a site would not constitute the spirit and principle of the original guidance, by Government of seamless distribution. For a 480 home development it would be 10 x cluster of 15 and for a 2,400 homes development it could be 41 x clusters of 18. This is not the way to achieve ‘seamless distribution of affordable homes throughout a development.’ Cluster sizes need to reflect the scale of the development, not have a blanket cluster size irrespective of the scale of the development. For the 48 home development a cluster size of 5 would be reasonable, for 480 perhaps 10 and for 2,400 why not 30? The oft used excuse that the Housing Associations insist on this large cluster size is not correct. They do not want pepper potting but are amenable to cluster sizes that reasonably relate to the size of the development.

VALP16-09-12-01521 Sean Carolan (Winslow Policy H4 - Policy H4 requires some qualification on the size of a replacement dwelling to be permitted. We suggest a footprint no Town Council) larger than twice the size of the existing dwelling. VALP16-09-12-01521 Sean Carolan (Winslow Policy H5 - There is clear evidence from discussions in Winslow (between aspiring self-builders, WTC, AVDC and developers) that Town Council) there is a need for the development of a SPD for self/custom build housing.

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ID Respondent Name Comment VALP16-09-12-01521 Sean Carolan (Winslow Policy H6 - Housing mix – There is a justified perception that too often AVDC has simply approved the housing mix proposed by Town Council) developers, even when these are in direct conflict with the needs of the district and the community and this is still happening. Recently, an application for over 40 homes in a medium sized village with a made Neighbourhood Plan, which included a Housing Needs Survey which identified the housing mix that community needed, firstly had confirmation that AVDC had approved what was described at the call-in Public Inquiry as a “good housing mix,” when all the market housing was to be 4 and 5 bed homes, in direct contravention of an up to date Housing Needs Survey. Then the application was approved, hence the call-in. In July of this year, Winslow was informed that for the largest site for new homes detailed in their Neighbourhood Plan, AVDC had approved the following housing mix for the largest and most important site for housing identified in the NP:- Type Aff. Rent Aff. Part Ownership Market 18 x 1 Bed Flats 18 0 0 39 x 2 Bed Flats 18 21 0 41 x 2 Bed Houses 11 0 30 58 x 3 Bed Houses 16 0 42 85 X 4 Bed Houses 0 0 85

VALP16-09-12-01521 Sean Carolan (Winslow This represents 68% of the affordable homes as flats when the recommendation is 15%. There are no market 1 and 2 bed homes Town Council) when the recommendation is 22%. 54% of the market housing would therefore be for 4 bed homes when the recommendation for 4 and 5 bed market homes is 27.5%. Clearly these examples are unacceptable, particularly when the premier planning document of the Development Plan in both instances is a made Neighbourhood Plan and it appears no regard was paid to these by the relevant Officers. The very worrying fact is that currently AVDC is supposed to be operating an approval system for the housing mix for a development very similar to that identified in H6, yet these appalling housing mixes continue to be foisted on communities. Obviously, the Policy needs significant improvement to ensure that it functions to ensure the Vale generates the housing mix it requires, based on Housing Needs Surveys and not what developers prefer. One immediate improvement that should be instituted is that where there is a made Neighbourhood Plan, AVDC should be obliged to consult with the relevant Parish or Town Council at an early stage, regarding the proposed housing mix in a new application for their comments. For Policy H6, for developments above a certain size, proportionate to the size of the community, 5% perhaps, the proposed housing mix for all such applications should be referred to all Parish and Town Councils for their comments. Who is in the best position to advise on the specific needs for housing in a community other than the Parish or Town Council? One realises that Officers need to take the bigger, pragmatic view on the needs of the wider District but it can surely be agreed that there is a place for the truly local input here.

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ID Respondent Name Comment VALP16-09-12-01523 Cameron Austin-Fell Policy H1 - The policy requires a ‘minimum of 31%’ affordable homes. There appears to be limited justification for the 31% figure (RPS Planning & and also its treatment as a minimum requirement, therefore until this is appropriately evidenced based, this element of the policy is Development (on behalf not considered to be justified. Whilst paragraph 5.6 allows for a reduced element of affordable housing provision, based on viability of Richborough Estates considerations (which is supported), it is not clear why a cap of grouping affordable homes of no more than 15-18 units has been Site - Lower Road, provided. This should be removed and the circumstances of the site dictate the level of grouping of affordable housing, which may be Aylesbury)) significantly different depending upon the size of the site and its characteristics. Criterion d states that where a site is part of a larger developable area that could be developed as a whole, the council will seek affordable housing provision appropriate to the larger area. This is considered appropriate in relation to strategic allocations which, given their very nature, will be under different landownerships and will inevitably come forward at different stages. The policy should be amended to allow for this or the policy element removed completely. The independent consultant cannot be independent if chosen solely by the Council; it must be chosen by the Council and Applicant, from a selected shortlist. VALP16-09-12-01523 Cameron Austin-Fell Policy H5 - This policy requires a percentage of all larger developments to be provided as serviced plots for sale to self/custom (RPS Planning & builders. This policy wording should be made more flexible and not require all Development (on behalf larger sites (however defined) as this might in many instances be unworkable with existing land agreements and characteristics of of Richborough Estates the site. The policy should say consideration only should be given to providing serviced plots for sale. Site - Lower Road, Aylesbury)) VALP16-09-12-01523 Cameron Austin-Fell Policy H6 - Paragraph 5.64 states it will be expected that all larger developments should provide an element of self-contained extra (RPS Planning & care dwellings as part of the over mix. Whilst this might be possible on Development (on behalf very large sites (500+), this would/may not be possible or appropriate on sites below this general level of site and should either of Richborough Estates therefore be clarified or omitted from the plan. Concern is raised in relation to the requirement for all residential developments to Site - Lower Road, meet Category 2 standards for adapted homes with 10% of market homes meeting category 3 standards. The evidence base for Aylesbury)) such specific requirements appear limited and the justification appears lacking, particularly the viability implications of imposing such stringent requirements. VALP16-09-12-01523 Policy H7 - Providing minimum gross floor areas for all dwellings (as Table 9 does) is inappropriate. This is not based on appropriate viability considerations and would hinder the ability of the market to deliver both the amount of housing required and the type of accommodation required from future occupants. The policy should be removed and dealt with through building control requirements if justified.

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ID Respondent Name Comment VALP16-09-12-01538 Jon Gateley (Savills (on Policy H1 - CSP object to this policy (H1) in its requirement for a minimum 31% of affordable homes to be provided on site, as it is behalf of Crest Strategic not justified or positively prepared in respect of NPPF paragraph 182. We also note that a study concerning the viability of affordable Projects)) housing has yet to be completed (draft VALP, paragraph 5.2). CSP recognise that Policy H1 will need to be updated when the details of the Government’s starter homes initiative are known. CSP would however like to note the potential inconsistency of the VALP with the evidence base. Paragraph 5.3 of the draft plan states that the Housing and Economic Development Needs Assessment (HEDNA, January 2016) identifies a need for up to 6,580 additional affordable homes. The figure 31% appears to have been derived as a percentage of the District housing requirements (6,580/21,300 = 31%). However, the assessment figure of 6,580 is a “maximum” or “higher range figure” as per the evidence base. (See paragraph 4.116 and Table 79, HEDNA, January 2016). Paragraph 7.95 of the HEDNA notes the affordable housing requirement of 10,500 dwellings in the Bucks HMA which, set against the overall OAN of 50,000 dwellings, is circa 20% This figure is much closer to the bottom end of the range set out in Table 79. The equivalent pro rata figure for Aylesbury Vale would be approximately 4,600 additional affordable dwellings. Using the same methodology as is presumed to be used in the plan (affordable housing OAN as a direct proportion of the overall housing provision for Aylesbury Vale), this leads to a figure of 22% provision (4,600/21,300 = 22%). CSP therefore consider the provision of 31% as, at best, a target. Instead the policy may be better expressed as a range, 20-30%, negotiated on a site-by-site basis. Modifications to Policy H1 sought by CSP The policy should refer to a ‘target’ rather than a ‘minimum’. This would be more consistent with paragraph 5.9 which refers to negotiation on a site-by-site basis. In addition, the Policy should be consistent with the evidence base, and thus refer to a range 20-30%. VALP16-09-12-01538 Jon Gateley (Savills (on Policy H5 - Policy H5 outlines that large developments should provide “a percentage” of serviced plots for self/custom builders. We behalf of Crest Strategic comment that as drafted, this policy lacks clarity and definition and is not supported by local evidence. Potentially, it could undermine Projects)) the deliverability and viability of larger sites, when taken together with other planning obligations, and delivery should ultimately rest on site-specific considerations, referring to need. VALP16-09-12-01538 Jon Gateley (Savills (on Policy H6 - Policy H6 outlines that a mix of housing types and sizes should be provided to meet current and future housing needs. behalf of Crest Strategic The principle of offering flexibility based on the council’s evidence of market conditions is supported by CSP. However we object to Projects)) the prescriptive nature of the final paragraph, relating to the provision of Accessible and Adaptable Dwellings. It is essential to ensure that this integrates fully with viability evidence, currently under preparation by AVDC, and that this is responsive to the scale and nature of individual sites. Modifications to Policy H6 sought by CSP Delete the final paragraph: (STRIKETHROUGH) All new residential development should meet Category 2 (Accessible and Adaptable Dwellings) of Approved Document M: Volume 1, 10% of market housing should meet Category 3 of Approved Document M: Volume 1, and 15% of affordable housing should meet Category 3.

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ID Respondent Name Comment VALP16-09-12-01538 Jon Gateley (Savills (on Policy H7 - 3.43. Paragraph 5.70 of the draft VALP states that a viability study required in relation to the government’s Technical behalf of Crest Strategic Housing Standards is currently underway, which is to consider whether it would be viable to apply the government’s standards in all Projects)) new development in the District. It states that ‘should the viability study conclude that the above standards are viable, the proposed submission plan will include a policy requiring that the above standards (or the latest version) are applied to all new developments, subject to comments received at this stage’. 3.44. In the National Planning Practice Guidance (PPG), Paragraph: 002 Reference ID: 56-002-20160519, it is stated that: Local planning authorities have the option to set additional technical requirements exceeding the minimum standards required by Building Regulations in respect of access and water, and an optional nationally described space standard. Local planning authorities will need to gather evidence to determine whether there is a need for additional standards in their area, and justify setting appropriate policies in their Local Plans 3.45. In the absence of the evidence of need as well as viability required at this stage, CSP objects to the inclusion of this policy.

VALP16-09-12-01567 Laura Tilston (Gladman Policy H1 - Policy H1 sets an affordable housing requirement of 31%, Gladman raise no objections with the provision of this scale of Developments) affordable housing. Notwithstanding the above support Gladman objects to Policy H1(d) which states “where a site is part of a larger developable area that could be developed as a whole, the Council will seek affordable housing provision appropriate to the larger area.” It is unclear how this element of the policy will work in practice and from our reading of this element of the policy would mean providing affordable housing in relation to sites/schemes that may never be progressed. This clearly cannot be a sound or fair approach. Further, the Council have a preference for pepper potting their affordable housing provision across sites. This would not tie in with Policy H1(d) which would result in all of the affordable housing provision for much wider schemes being delivered within phase 1 of any development.

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ID Respondent Name Comment VALP16-09-12-01567 Laura Tilston (Gladman Policy H5 - Policy H5 relates to the provision of Self/Custom housing. Gladman welcome the addition of a policy in relation to self- Developments) build housing within the Local Plan. This would be in line with current government thinking and objectives. It is key that the development industry is able to understand the implications of any such policy requirement, to assist with the design of schemes and the consideration of financial viability. Policy H5 refers to the fact that it may be appropriate to set a specific threshold for what is meant by ‘larger developments’ as these will be expected to provide a percentage of serviced plots for sale to self/custom builders. The policy then goes on to state that further work will be done to determine what this threshold should be. Gladman submit that this type of detail is needed within the policy as the development industry needs clarity over what is expected. As it stands consultation on this policy is somewhat meaningless as the detail has not yet been provided. This further work needs to be completed and further consultation on this policy should then take place. Gladman recommend that any policy requirement in relation to self-build housing has an element of flexibility built in to allow for negotiation over self-build plots on the basis of viability to ensure that site delivery is not delayed or prevented from coming forward. Any specific requirement to include self-build plots should be tested through the Council’s viability assessment of the Local Plan policies to ensure that the cumulative impacts of all proposed local standards and policy requirements do not put the implementation of the Plan as a whole at risk (paragraph 174 of the Framework). Further to this, Gladman urge the Council to ensure the policy has added flexibility as there is no guarantee that these units will be delivered and there may be situations when they are difficult to deliver which may result in the non-delivery of otherwise sustainable land for housing. Therefore Gladman recommend that any policy specific requirement needs to include a mechanism whereby if the self-build plots are not taken up within a given time period then these revert back to market housing to be provided as part of the wider scheme. This would provide flexibility and help to ensure that the required housing is delivered.

VALP16-09-12-01567 Laura Tilston (Gladman Policy H6 - Policy H6 requires that “new residential development should provide a mix of housing types and sizes to meet current Developments) and future housing needs. The housing mix will be agreed taking into account the Council’s most up to date evidence on housing need and any evidence available regarding local market conditions.” Gladman support this element of policy H6 as it suggests that housing mix will be determined on a site by site basis depending on the most up to date evidence and local circumstances. This is supported as it is not overly prescriptive and allows developments to respond to the particular needs at that point in time. Policy H6 sets a requirement that “larger residential development schemes in strategic settlements will be expected to provide an element of self-contained extra care dwellings as part of the overall mix, or an equivalent amount in an alternative location if this is agreed to be more appropriate.” Gladman query what is meant by ‘larger residential development scheme’ as this detail is not currently provided within the policy.

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ID Respondent Name Comment VALP16-09-12-01567 Laura Tilston (Gladman Policy H7 - 5.4.1 Policy H7 refers to a table of minimum internal floor areas and requires that these standards (or the latest version) Developments) are applied to all new developments. Gladman note that a caveat needs to be added to this policy stating that this will be dependent on viability. 5.4.2 The Written Ministerial Statement (WMS) dated 25th March 2015 confirms that “the optional new national technical standards should only be required through any new Local Plan policies if they address a clearly evidenced need, and where their impact on viability has been considered, in accordance with the NPPG”. Furthermore, with particular reference to the nationally described space standard the PPG (ID: 56-020-20150327) confirms “where a need for internal space standards is identified, local planning authorities should provide justification for requiring internal space policies”. If the Council wishes to adopt this standard it should be justified by meeting the criteria set out in the PPG including need, viability and impact on affordability. The Council has not provided sufficient evidence to justify adoption of these proposed standards. 5.4.3 Gladman note that §5.70 refers to a viability study currently underway and that this will conclude whether it would be viable to apply the government standards in all new development. Again, consulting on this policy prior to the additional work being undertaken to inform the policy and conclude whether or not it is viable and justified within the VALP is futile. VALP16-09-12-01622 Christopher Roberts Policy H1 - 2.20 The wording of Draft Policy H1 proposes to set a minimum contribution of 31% affordable homes. It is considered (Turley.co.uk on behalf that inclusion of the word ‘minimum’ will not provide developers with clarity as to the actual quantum of affordable provision needed of Cala Homes Ltd) to design a policy compliant scheme. Indeed, it is possible to interpret the semantics of this policy as inferring that developments shall be expected to provide affordable housing beyond the 31% level, with the upper limit simply being the threshold of viability. To reduce the potential for misinterpretation, we would recommend that the policy be reworded to clarify that residential developments (of 11 or more dwellings) will be required to provide 31% affordable homes on site, unless the applicant advises that a proposal is unviable in the light of the above policy requirement (as supported by an open-book assessment). 2.21 We would also advise that the proposed affordable housing requirement should be considered in the context of a wider assessment of viability across the District. This should consider cumulative viability issues arising from affordable housing, other developer contributions and (future) CIL levy rates, and should include sensitivity testing in different parts of the District7.(7 In addition, we note the Council’s remarks regarding forthcoming secondary legislation, to be made in relation to ‘starter home’ provision. The impact of such provision, in lieu of affordable housing, should form part of a broader consideration of the cumulative impacts of developer contributions and inform any subsequent revision to Draft Policy H1.) comprehensive understanding of financial viability constraints affecting the local residential sector.

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ID Respondent Name Comment VALP16-09-12-01622 Christopher Roberts 2.22 In the absence of further analysis and assessment, it is not possible to ascertain the potential impact of the proposed 31% (Turley.co.uk on behalf affordable housing requirement. In turn, it is not possible to determine if Draft Policy H1 meets the relevant tests of soundness, of Cala Homes Ltd) particularly in terms of justification and likely effectiveness. The above concerns also invite us to question if the draft policy can be said to satisfy the requirements of NPPF Paragraphs 173 and 174. These paragraphs require that LPA’s shall (in plan-making and decision-taking) give full consideration to viability, taking into account the cumulative effect of “all existing and proposed local standards, supplementary planning documents and policies that support the development plan, when added to nationally required standards”. We further note Paragraph 175 of the Framework encourages LPAs to work up and test proposed CIL charges, alongside the preparation of the Local Plan. Therefore, we would encourage the Council to progress this stream of work, such that the viability implications of the emerging Development Plan can be comprehensively considered and understood.

VALP16-09-12-01622 Christopher Roberts Policy H6 - Housing Mix (Turley.co.uk on behalf Draft Policy H6 indicates that larger residential developments, in Strategic Settlements, will be expected to provide an element of self- of Cala Homes Ltd) contained extra care dwellings. We submit that this aspect of the proposed policy is all-encompassing and inflexible, in both its wording and conception. The ‘blanket’ requirement to provide extra care dwellings discourages effective consideration of the specific needs of the locality, and has no regard to the suitability of a particular site or its capacity to accommodate extra care units. We advise that extra care developments often require a large building footprint and introduce large blocks of apartments. Such developments are unlikely to be suitable in locations where this would (for example) contrast with development density in the surrounding locality. Furthermore, we consider that the policy also fails to acknowledge the market drivers in the extra care sector, with site operators / registered providers having very specific site requirements, which vary greatly. This invites the question; ‘what if there is no market demand from extra care operators in any given location and at a given time?’. Indeed, the Draft Policy affords no consideration to development viability and the subsequent impact that the provision of extra care dwellings may have on the overall deliverability of a scheme or the provision of affordable homes. In view of the above concerns, we submit that Draft Policy H6 is not properly justified, unlikely to be effective and has the potential to impede to delivery of strategic sites. Consequently, the Draft Policy (as currently configured) is not considered sound.

VALP16-09-12-01636 Oliver Taylor (Gleeson Policy H1 - Policy H1 Affordable housing - Gleeson/Linden reserve our comments on this policy for the time being on the basis that, Strategic Land on behalf as is rightly recognised at footnote 25 of the VALP, Policy H1 is likely to need to be amended following the publication of the of Linden Homes) Regulations on Starter Homes as outlined in the Housing and Planning Act 2016. The inter-relationship between Starter Homes and other affordable housing is key to the soundness and, importantly, the viability of this policy but at this point in time it is impossible to determine whether the requirement for a minimum of 31% affordable housing including, we assume, provision for Starter Homes, is reasonable or viable.

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ID Respondent Name Comment VALP16-09-12-01636 Oliver Taylor (Gleeson Policy H5 - Policy H5 Self/custom build housing Strategic Land on behalf Gleeson/Linden are not against the principle of making available an appropriate proportion of development in the district as self-build of Linden Homes) / custom build housing, which accords with the NPPF objective to deliver a wide range of high quality homes; however, we reserve our right to comment further on this policy when ‘flesh has been added to the bone’. It is this detail that will be key to the soundness and viability of the policy. It is of course not only the proportion of self / custom build housing sought, but also the practicality and viability of delivering such provision, which depends to a large extent on the size and nature of a development site.

VALP16-09-12-01641 MICHAEL KNOTT Policy H1 - We welcome the provision of on-site affordable housing, subject to viability. The suitability of any affordable housing (Gallagher Estates) policy is reliant entirely on the development needs of the District and the appropriateness of the affordable housing thresholds, which in the case of the Preferred Options document is set at 31% of dwellings on sites of a net gain of 11 or more dwellings. It is considered that the policy should allow for developers to negotiate on the level of affordable housing to be provided, particularly on schemes where viability is an issue and the benefits of providing a scheme with a lower level of affordable housing would outweigh any adverse impacts of lowering the requirement. Broadly-speaking, we consider that the District should seek to increase the affordable housing supply by increasing the overall supply of housing in the district to meet objectively assessed housing need.

VALP16-09-12-01641 MICHAEL KNOTT Policy H6 - Gallagher Estates agree that new residential development should provide a mix of housing types and sizes to meet (Gallagher Estates) current and future housing needs. It is also agreed that the housing mix agreed will take into account the council's most up to date evidence on housing need and any evidence available regarding local market conditions. Gallagher Estates support the provision of a suitable mix of housing, to be agreed on a case by case basis, subject to viability, and based on the most up to date evidence.

VALP16-09-12-01641 MICHAEL KNOTT Policy H7 - Gallagher Estates welcome the introduction of the Government's Technical Housing Standards (March 2015) and (Gallagher Estates) support proposed policy H7 (dwelling sizes), subject to viability. However, it is considered that the policy should allow for developers to negotiate on the dwelling size standards to be provided, particularly on schemes where viability is an issue and the benefits of providing a scheme with smaller dwelling sizes outweigh any adverse impacts of lowering the requirement.

VALP16-09-13-01672 Derek Bromley Policy H5 - Whilst the provision of plots for sale to self/custom builders may seem a reasonable planning policy objective it ignores unfortunately the practicalities and interaction with other legislation. The lead developer will have overall responsibility for a site under health and safety legislation and for security. Self-builders working on the site would have great difficulties in achieving 'safe site'. In addition, there needs to be provision for welfare etc. Developers would need some control over the period of time of any self-build projects so as not to impact upon the main site. Rather than self-build plots a better solution may be that opportunities are provided for a purchaser of shell dwellings thereby enabling them to buy at a reduced price and limit its exposure to health and safety issues.

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ID Respondent Name Comment VALP16-09-13-01675 Mike Taylor (Chilmark Policy H1 - Introduction Consulting Ltd. (on 1. Chilmark Consulting Ltd. (CCL) are instructed by and write for and on behalf of Barwood Land and Estates Ltd. (BLEL) with behalf of Barwood Land respect to the Vale of Aylesbury Local Plan: Draft Plan, Summer 2016 (VALP) published for consultation by Aylesbury Vale District and Estates Ltd. Council (AVDC). This representation is concerned with Policy H1 (Affordable Housing) and supporting evidence set out in the (BLEL))) Central Buckinghamshire HEDNA Consultation Draft (January 2016). This representation must be read in conjunction with the other representations submitted by BLEL dealing with related matters. Nature of Representation Affordable Housing Target Proportions Chapter 5 of the Draft VALP deals with matters of affordable housing provision. Policy H1 (Affordable Housing) identifies that residential developments of 11 or more dwellings will be required to provide a minimum of 31% affordable housing. It is of concern that such a fundamental matter as affordable housing provision, which in turn forms part of the underlying analysis necessary to establish the comprehensively supported by the necessary evidence. It is understood from paragraph 5.2 that there is a forthcoming Affordable Housing Viability Study, but at the time of writing, this has not been published. Similarly, the Draft VALP makes reference to a forthcoming Affordable Housing Supplementary Planning Document (SPD) but that too has not yet been published.

VALP16-09-13-01675 Mike Taylor (Chilmark The NPPF is clear that plan-making involves the front-loading of technical work and ensuring that there is an adequate and complete Consulting Ltd. (on evidence base to underpin the plan’s policies (NPPF paragraph 158) and to ensure meaningful engagement (paragraph 155). The behalf of Barwood Land NPPF also requires Local Plan’s to ensure that they are viable and deliverable as paragraphs 170 – 177 set out. This requires that and Estates Ltd. the evidence on matters of development viability. In this case, the necessary housing viability evidence is not available and the (BLEL))) deliverability implications of this cannot therefore be evaluated. This represents a clear deficiency in the VALP’s preparation process. BLEL are therefore deeply concerned that the proportion of affordable housing set out in policy H1 is not supported by specific evidence as to how the 31% target has been derived, whether this level of contribution is viable and what the policy or implications arising from the provision of Starter Homes in the District is to be in accordance with the Housing and Planning Act, 2016 (at Part 1, Chapter 1, paragraph 4). Until this information is provided it is not possible to conclude whether policy H1 will be an effective and sound response to meeting affordable housing needs. In the same manner, policy S2 and the OAHN evidence base in the CB HEDNA must be equally considered unsound until the necessary evidence is presented in complete and final form. Calculation of Affordable Housing Needs Paragraph 5.3 sets out that this provision will be to meet the assessed need for 6,580 affordable dwellings (329 dpa) over the plan period. The calculation of affordable housing need is set out in the CB HEDNA report Consultation Draft (January 2016). The results of the CB HEDNA calculation of affordable housing are set out in Figure 77 where the assessed need for affordable housing in the District is 4,381 dwellings over the 2013-33 period (219 affordable dwellings per annum). A higher range figure is also expressed at Figure 79 of 6,580 dwellings (329 per annum) based on affordable housing for all households renting privately with housing benefit support.

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ID Respondent Name Comment VALP16-09-13-01675 Mike Taylor (Chilmark It is clear from BLEL’s review that the CB HEDNA modelling has: Consulting Ltd. (on • failed to account for the number of households already on the District Council’s Housing Register as being in need of behalf of Barwood Land accommodation, effectively ignoring the existing backlog of needs; and and Estates Ltd. • a different interpretation of the definition of affordable housing needs to that in the Aylesbury Vale HEDNA or used widely (BLEL))) elsewhere. The CB HEDNA takes a narrow, ‘welfare’ based definition of affordable housing need The CB HEDNA approach is therefore ignoring a large number of households that AVDC has a statutory duty to house and which are found on its housing register. Existing Backlog of Affordable Housing Needs The CB HEDNA does not appear to make any allowance or inclusion of existing households in need in its calculations despite identifying a total housing waiting list of 5,204 households (1,209 in reasonable preference) in April 2014 at Figure 67. Figure 66 provides a longer-term view of the housing waiting list and clearly identifies a growing housing waiting list every year from 2009 onwards (and, bar a small dip in 2008-2009, an increasing trend over the period from 2001 to 2008). Paragraph 4.90 et seq. set out how future needs of existing households are projected but does not take account of the existing backlog. These paragraphs identify that there are 480 established households falling into need each year in the HMA as a whole but does not present a breakdown of this figure for each of the constituent local authority areas. It also identifies that established households’ situations can improve over time and as such it calculates at paragraph 4.93 that there is an average net reduction of 234 households (in the HMA) needing affordable housing each year.

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ID Respondent Name Comment VALP16-09-13-01675 Mike Taylor (Chilmark The analysis presented therefore concludes that there is a reducing level of future need arising from existing households against a Consulting Ltd. (on backdrop, recorded in the previous Aylesbury Vale HEDNA of significant existing and rising levels of affordable housing need. behalf of Barwood Land As BLEL set out in its submissions to the VALP Issues and Options Consultation previously, the conclusion in the CB HEDNA that and Estates Ltd. there is a reduction in existing affordable housing need appears counter to the housing market dynamics in Aylesbury Vale. (BLEL))) Reliance on Welfare Reform and Housing Benefits to Measure Affordability The CB HEDNA takes an approach to calculating affordable housing needs that derives the number of households in need from those claiming housing benefit. The affordable housing needs model identifies that the level of households drawing housing benefit in, is set as a constant over the plan period. There is no guidance in the NPPG that requires a narrow, welfare based assessment to be used rather than a more standard, accepted practice that models household income distributions and examines those in housing need drawing from the Council’s Housing Register. While many households choose to live in private rented accommodation with housing benefit support, other households may prefer an affordable tenancy, but are unable to access one due to unavailability of existing or new affordable rented stock. To reduce the number of households claiming housing benefit, more affordable housing would need to be provided. Without sufficient affordable housing, there will be continued pressure on the private rented sector and associated need for additional housing benefit support for households otherwise unable to afford local housing costs. BLEL therefore object to the CB HEDNA’s methodology for measuring those in affordable housing need based on a housing benefit welfare model. Policy H1 is flawed in relying upon the evidence of the CB HEDNA’s approach using housingwelfare benefits data when there is a clear Government policy to reduce welfare payments including a focus on reductions to housing benefits. The Government has signalled its intentions to introduce further changes to the welfare system as (November 2015).

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ID Respondent Name Comment VALP16-09-13-01675 Mike Taylor (Chilmark The Housing and Planning Act now sets out further reform to housing delivery and this is likely to impact significantly on the need for Consulting Ltd. (on and supply of affordable housing in England. The Act introduces Starter Homes in order to support greater home ownership. It also behalf of Barwood Land supports the Government’s stated objectives to introduce Right to Buy to tenants of Registered Providers. In addition, local and Estates Ltd. authorities will be expected to dispose of higher value vacant council housing to release funds to extend Right to Buy, reducing the (BLEL))) supply of social housing available to those in housing need. The CB HEDNA has an explicit recognition of this significant limitation and under-estimate at paragraph 4.72, stating: “The affordability assessment used by the Model is relatively stringent insofar as it is only households that would be eligible for welfare support that are counted within the identified affordable housing need. There are likely to be other households who are spending more than 25% of their gross income (and sometime much more than this proportion), but who are not eligible for welfare support in relation to their housing. The Model’s assessment therefore focusses on those households with the most acute needs, and a broader affordability assessment would probably identify a greater number of households needing affordable housing. The Model therefore identifies a minimum level of affordable housing need”. [Our emphasis]. BLEL concludes that the measures put in place by Government to reduce welfare costs and particularly housing benefits will lead to an increasing need for affordable housing, including social rent and that an affordable housing needs model based on housing benefit claimant analysis fails to correctly estimate the scale of need arising.

VALP16-09-13-01675 Mike Taylor (Chilmark Conclusions Consulting Ltd. (on The following conclusions are drawn with respect to policy H1 and the available evidence set out in the CB HEDNA: behalf of Barwood Land • the approach taken in the CB HEDNA is inconsistent with the standard and industry accepted approach to the definition and and Estates Ltd. calculation of affordable housing needs in accordance with the NPPG and practice (BLEL))) elsewhere; • the ongoing Government programme of welfare reforms could significantly impact on the level and size of affordable housing need in Aylesbury Vale and the available supply of social housing. This could have a direct impact altering the assessed balance between supply and demand and the implied level of backlog and particularly future need; • the deliberate reliance on a narrow welfare definition (explicitly recognised as such by the CB HEDNA’s authors) of affordable housing need fails to recognise the Government’s objectives to reduce housing benefits as part of wider welfare finance reform; and • the CB HEDNA’s method and approach significantly under-estimates the level of affordable housing needs in Aylesbury Vale. It is not therefore a full estimate of housing needs. The recent Aylesbury Vale HEDNA provides a valuable benchmark to the level of affordable housing need and its methodology is aligned to and consistent with the NPPG’s and therefore is preferable to that contained in the CB HEDNA. Policy H1 is therefore unsound as it is not: • Justified or effective – for the reasons already highlighted the proposed affordable housing requirement does not represent the full affordable housing need for the District. The policy will not be effective in meeting affordable housing needs. • Consistent with national policy – the policy is not positively prepared or sufficiently proactive and essentially undermines the delivery of adequate levels of affordable housing. It is therefore inconsistent with national policy and practice in the NPPF and the NPPG.

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ID Respondent Name Comment VALP16-09-13-01688 James Stevens (Home Policy H1 - We appreciate that Policy H1 will need to be updated when the details of the government’s starter homes initiative are Builders Federation Ltd) known.

Paragraph 5.3 of the draft plan states that the HEDNA identifies a need for up to 6,580 additional affordable homes. Indeed it is assumed that it is this figure which is applied to the overall housing provision within the District to give the Policy requirement for the curiously precise requirement for a “minimum of 31% affordable homes on site” (6,580/21,300 = 31%). However, the assessment figure of 6,580 is a “maximum” or “higher range figure” (Ref: paragraph 4.116 and Table 79, HEDNA, Jan 2016).

Paragraph 7.95 makes it clear that, in concluding that the overall housing provision for the Bucks HMA is 50,000 dwellings it includes (their emphasis) an OAN for affordable housing of 10,500 dwellings. This figure is much closer to the bottom end of the range set out in Table 79. The equivalent pro rata figure for Aylesbury Vale would be approximately 4,600 additional affordable dwellings. Using the same methodology as is presumed to be used in the plan (affordable housing OAN as a direct proportion of the overall housing provision for Aylesbury Vale) the “correct” figure, using the evidence from the HEDNA, is just 22% rather than the stated 31% (4,600/21,300 = 22%).

VALP16-09-13-01691 Roy van de Poll Policy H1 - Policy H1 advises that Residential developments of 11 or more dwellings gross will be required to provide a minimum of 31% affordable homes on site. I am aware of other LPAs specifying figures as high as a 50% contribution. With the acknowledged very high need for particularly rested affordable homes, a higher figure than 31% is surely required. The fact that the figure is a minimum is irrelevant because all the evidence is that no builder or developer will volunteer to provide a higher figure than that which is specified.

In 5.7, the simple statement that affordable homes should be in groups of no more than 15 to 18 is totally unacceptable, another instance where, AVDC, one size does not fit all. At 31% affordable homes contribution, a 48 home development would/could have a single cluster of 15, clearly a single cluster for such a site would not constitute the spirit and principle of the original guidance, by Government of seamless distribution. For a 480 home development it would be 10 x cluster of 15 and for a 2,400 homes development it could be 41 x clusters of 18. This is not the way to achieve ‘seamless distribution of affordable homes throughout a development.’ Cluster sizes need to reflect the scale of the development, not have a blanket cluster size irrespective of the scale of the development. For the 48 home development a cluster size of 5 would be reasonable, for 480 perhaps 10 and for 2,400 why not 30? The oft used excuse that the Housing Associations insist on this large cluster size is not correct. They do not want pepper potting but are amenable to cluster sizes that reasonably relate to the size of the development.

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ID Respondent Name Comment VALP16-09-13-01691 Roy van de Poll Policy H6 - Policy H6 Housing mix – There is a justified perception that too often AVDC has simply approved the housing mix proposed by developers, even when these are in direct conflict with the needs of the District and the community and this is still happening. Recently, an application for over 40 homes in a medium sized village with a made Neighbourhood Plan, which included a Housing Needs Survey which identified the housing mix that the community needed, firstly had confirmation that AVDC had approved what was described at the call-in Public Inquiry as a “good housing mix,” when all the market housing was to be 4 and 5 bed homes, in direct contravention of the up to date Housing Needs Survey. Then the application was approved, hence the call-in. In July of this year, Winslow was informed that for the largest site for new homes detailed in their Neighbourhood Plan, AVDC had ‘approved’ the following housing mix for the largest and most important site for housing identified in the NP:-

[table removed for formatting purposes - see attachment]

VALP16-09-13-01691 Roy van de Poll This represents 68% of the affordable homes as flats when the evidence suggests a level of 15%. There are no market 1 and 2 bed flats when the recommendation is 22%. 54% of the market housing would therefore be for 4 bed homes when the recommendation for 4 and 5 bed market homes is 27.5%. Clearly these examples are unacceptable, particularly when the premier planning document of the Development Plan in both instances is a made Neighbourhood Plan and it appears no regard was paid to these by the relevant Officers. The very worrying fact is that currently AVDC is supposed to be operating an approval system for the housing mix for a development very similar to that identified in H6, supposedly using evidence very similar to that provided by VALP, Which had been compiled for VAP, yet these appalling housing mixes continue to be foisted on communities. Obviously, the Policy needs significant improvement to ensure that it functions to ensure the Vale generates the housing mix it requires, not what developers prefer. One immediate improvement that should be instituted is that where there is a made Neighbourhood Plan, AVDC should consult with the relevant Parish or Town Council at an early stage, regarding the proposed housing mix in a new application for their comments. For Policy H6, for developments above a certain size, proportionate to the size of the community, – 5% perhaps, the proposed housing mix for all such applications should be referred to all Parish and Town Councils for their comments. Who is in the best position to advise on the specific needs for housing in a community other than the Parish or Town Council?! One realises that Officers need to take the bigger, pragmatic view on the needs of the wider District but it can surely be agreed that there is a place for the truly local input here.

VALP16-09-13-01696 Mark Owen (Barton Policy H1 - In line with the NPPF, we agree that AVDC should provide affordable housing as part of residential developments, Willmore (on behalf of subject to viability, and therefore support the principle of Draft Policy H1 (Affordable Housing). Hampden Fields Consortium)) VALP16-09-13-01696 Mark Owen (Barton Policy H5 - We agree with the inclusion of Draft Policy H5 (Self/Custom Build Housing) and consider that a threshold should be Willmore (on behalf of introduced to understand when these serviced plots should be provided. Hampden Fields Consortium))

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ID Respondent Name Comment VALP16-09-13-01696 Mark Owen (Barton Policy H6 - We support Draft Policy H6 (Housing Mix) that new residential development should provide a mix of housing types and Willmore (on behalf of sizes to meet current and future needs including extra care, specialist housing for older people. It should be noted that the Hampden Hampden Fields Fields proposal provides a mix of housing types and sizes including a 60 bed care home/extra care facility for the elderly. Consortium)) VALP16-09-13-01697 Jodi Stokes (Persimmon Policy H1 - Housing Mix Homes Midlands) Paragraph 5.9 of the Aylesbury Vale Draft Local Plan states that “The type, size, tenure and location of the affordable homes will be negotiated on a site-by-site basis”. The Council are going to require 31% Affordable Housing for any scheme over 11 dwellings. Scheme viability can be affected through the total amount and tenure of affordable housing that needs to be delivered. Without a plan-wide viability assessment, it is impossible at this stage to gauge whether the need for affordable housing will be met in its entirety. This information should be presented alongside or before the next consultation on the plan, and if necessary the overall housing requirement may need to be increased to assure the viable delivery of the full need for affordable housing. Paragraph 5.59 of the Aylesbury Vale Draft Local Plan states that “the Buckinghamshire Housing and Economic Development Needs Assessment (HEDNA)(2016) provides conclusions on the required mix of market and affordable housing need by house type and size for the VALP period”. Housing mix should be considered on a site by site basis using the HEDNA as the evidence base combined with market signals. Any requirements regarding the provision of housing to meet specific needs such as those for older people should be supported by evidence from the HEDNA. Paragraph 5.68 of the Aylesbury Vale Draft Local Plan states that “the government introduced the Technical Housing Standards in March 2015. The Council currently have a viability study underway to see where this is feasible as a standard to apply to all new development in the district”. The evidence base for viability work needs to be consulted on and opportunity afforded for duly made representations.

VALP16-09-13-01702 Derek Bromley Policy H1 - To ensure the reasonableness of costs. The applicant should be able to require the Council obtain not less than 3 quotes (Bidwells) for an independent financial assessment with the applicant selecting from the choice of quotes. VALP16-09-13-01702 Derek Bromley Policy H5 - Whilst the provision of plots for sale to self/custom builders may seem a reasonable planning policy objective it ignores (Bidwells) unfortunately the practicality and interaction with other legislation. • Health & Safety- The lead developer will have overall responsibility for a site under health and safety and security. Self-builders working on the site would have great difficulties of achieving 'safe site'. In addition, there needs to be provision for welfare etc. • Developers would need some control over the appearance and timing of any self-build projects so as not to impact upon the main site. • Rather than self-build plots a better solution may be that opportunities are provided for a purchaser of shell dwellings thereby enabling them to buy at a reduced price.

VALP16-09-13-01703 Merilyn Munson Policy H2 - We are supportive of this policy. With the threshold of 11 dwellings below which affordable housing will not be delivered through cross subsidy from market housing it is likely that, in order to meet future affordable housing needs (based on accurate local needs assessment not yet undertaken) rural exception sites will be one of the few tools available to areas such as Brill for the delivery of any additional affordable housing.

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ID Respondent Name Comment VALP16-09-13-01707 Richard Walker Policy H1 - Affordable Housing OAN and the affordable requirement - We submit that the Plan should include a numerical target for (Pegasus Group) the amount of affordable housing to be delivered within the Plan period. On the basis of the current HEDNA this is 4,600 dwellings for Aylesbury Vale, supplemented by a figure emanating from overspill unmet affordable need in adjoining authorities. We observe from the Draft VALP and Figure 124 of the HEDNA that the overall provisional unmet need requirement to be accommodated in Aylesbury Vale is 12,000 (which represents 39.7%) of the overall requirement for the other authorities. Therefore, of the 6,100 affordable need in these areas, 2,422 should be added to the baseline affordable target for Aylesbury. The overall affordable target of the Plan would therefore be around 7,022 (351 per annum). The need for affordable housing impacts on the nature of housing supply that needs to come forward at villages where growth is identified. Growth needs to be on sites that are above the affordable housing threshold and where provision viable. These figures will need some adjustment based on the need to revise the HEDNA. The only place in the Draft Plan that this affordable housing analysis is made is at paragraph 5.3 where it is said that “The (draft) Buckinghamshire Housing and Economic Development Needs Assessment 2015 (HEDNA) identifies a need in Aylesbury Vale district for up to 6,580 additional affordable homes between 2013-33, equating to 329 affordable homes a year”. The November 2015 study has now been superseded and this analysis should be updated to square with our analysis above. Furthermore, this analysis should be lifted into the bulleted list of policy requirements in Policy S2 (Spatial Strategy for Growth). It should be part of the spatial strategy itself and not reduces solely to supporting text to affordable housing policy.

VALP16-09-13-01718 Craige Burden Policy H1 - The policy is non specific requiring a minimum of 31% affordable housing. This needs to be clarified; and allow for the (Persimmon Homes) viability of schemes to be tested. The policy makes no reference to the provision of Starter Homes within the affordable housing strategy, despite the Ascension of the Housing and Planning Act 2016. VALP16-09-13-01718 Craige Burden Policy H5 - It is not appropriate for all larger developments to be expected to cater for self / custom builders. The creation of this (Persimmon Homes) restriction upon the larger sites will impact upon the rate of delivery and will cause potential impacts upon the phasing of developments. VALP16-09-13-01718 Craige Burden Policy H6 - The policy should not place the unfair requirement to only rely upon the Council's evidence for housing mix. The policy (Persimmon Homes) should also not require larger residential developments to provide self contained extra care dwellings. Extra Care providers have very specific requirements and some sites may not meet the market requirements. In addition there may be individual sites better suited to the provision of such facilities.

The requirements to meet Part M of the building regulations has not been considered in terms of the impact upon the viability of the scheme. The policy is also unclear and poorly worded in relation to the technical guidance from Government. There should be no split between the mix of affordable and market housing on the sites.

Policy H7 requires space standards to be met within the District. This appears to be no support for this policy based on the impact on viability. The creation of minimum space standards in an area where there is a high need for housing will falsely inflate prices, as these will be based on the square meterage created. VALP16-09-13-01722 Sarah James Policy H1 - There is no affordable housing now,we have looked to.move on many occasions and the prices are way to high.

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ID Respondent Name Comment VALP16-09-13-01722 Sarah James Policy H7 - Like most new housing estates,they seem.to be small high rise builds.with limited gardens and narrow roads,how with this.fit in with the local housing of all local villages VALP16-09-13-01770 E. A. Lock Policy H1 - The price of housing in Haddenham is quite high with a typical 3 bed semi being sold for in excess of £500,000. Developers will not build huge numbers of houses in a hurry as that will depress the prices and hence their profits. Any development will be phased very deliberately to attain maximum return and will keep prices high. AVDC should look for areas in the north of the county which are affordable for young families. VALP16-09-13-01817 Simon Proctor (Proctor Policy H1 - 5.8 and H1 cOffsite provision is to be encouraged. Surveyors (Newton Longville)) H1 dClarity is required as to what is meant by “larger developable area” and “could be developed as a whole”. For example separate ownership or lease restrictions may preclude a larger site being brought forward for development as a whole, further it may be more appropriate to the scale and character of a settlement for a smaller development. VALP16-09-13-01817 Simon Proctor (Proctor Policy H5 - This policy should be pursued with caution. Self-build plots can significantly impact on the delivery of housing numbers Surveyors (Newton and the attractiveness of a site / development to purchasers. Personal economic factors can have a significant bearing on the Longville)) standard of work or indeed completion of the development. Enforcement or remediation may incur significant expense to the authority. VALP16-09-13-01817 Simon Proctor (Proctor Policy H6 - It is important to remain flexible with regard to mix which should reflect need and market factors. Surveyors (Newton Longville)) VALP16-09-13-01817 Simon Proctor (Proctor Policy H7 - It is important to remain flexible with regard to floor areas which should reflect need and market factors. Surveyors (Newton Longville)) VALP16-09-19-01834 Martha Simpson Policy H1 - I agree with affordable housing but I do not agree with council or housing association houses being sold on unless they are replace like for like. It is important for young people to be able to continue to live in the village or town they grew up in - if they want to. VALP16-09-19-01839 Robert Skinner Policy H1 - I agree that afforable housing is needed as youngsters cannot afford to live in the village they grew up in. I would like such housing to be available for local people to have first choice. Two and three bedroom houses are more suitable.

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ID Respondent Name Comment VALP16-07-28-00232 Anita Blackhall Policy E2 - The occupation of the former gas reception site on Bletchley Road by the haulier First Class Transport has led to an unacceptable impact on the village and in particular, the Conservation Area, by HGVs. A larger impact, on the road safety and road structure by this class of vehicle arises from the use of Whaddon Road and Stoke Road as a short cut to the south of Milton Keynes (a 'Sat-Nav bypass'). Whilst the principle of additional employment land within the village area is acceptable, I believe that this should not be allowed unless and until a new relief road, skirting the landfill site to link Bletchley Road with the A4146 is provided. A high-speed Broadband service also needs to be provided to the whole of the village of Newton Longville before offering land for employment. VALP16-07-29-00239 Mr Jan Blackhall Policy E2 - The occupation of the former gas reception site on Bletchley Road by First Class Transport, a haulier, has led to an unacceptable impact on the village and in particular, the Conservation Area, by HGVs. A larger impact, on the road safety and road structure by this class of vehicle arises from the use of Whaddon Road and Stoke Road as a short cut to the south of Milton Keynes (from my observation a 'Sat-Nav bypass'). Whilst I find the principle of additional employment land within the village area acceptable, I am of the view that this should not be allowed unless and until a new relief road, skirting the landfill site to link Bletchley Road with the A4146 is provided. VALP16-08-05-00257 Helen Harris Policy E1 - All four Royal Mail sites are well established, having operated successfully for a number of years, serving a wide (Cushman&Wakefield catchment area. Due to the nature of use, operations extend well beyond the normal working day, including associated vehicular (on behalf of Royal Mail movements. The potential juxtaposition of alternative, possibly sensitive land uses particularly residential uses adjacent or within Ltd)) close proximity to the sites is of direct concern to our client. Given the business functions of Royal Mail, operations often take place in sensitive hours in the early mornings and late evenings which sees delivery times and the constant movement of delivery vehicles and could therefore result in significant amenity issues should sensitive land uses, particularly new dwellings, be located nearby. Royal Mail are supportive of the policy wording to Draft Policy E1 (Protection of Key Employment Sites) which is considered to be sufficiently robust to safeguard those Royal Mail properties which are located within designated areas against the implementation of residential development or other insensitive land uses which would be contrary to, and do not provide direct, ongoing support to, existing business operations.

VALP16-08-05-00257 Helen Harris Policy E2 - Similarly, Royal Mail are supportive of the policy wording to Draft Policy E2 (Other Employment Sites), specifically (Cushman&Wakefield wording which stipulates that “alternative employment use which will not normally be permitted where it will prejudice the efficient and (on behalf of Royal Mail effective use of the remainder of the employment area”. This is considered to be sufficiently protective to those Royal Mail properties Ltd)) which fall outside of designated areas and which can, therefore, be slightly more susceptible to insensitive uses. This approach accords with adopted Government guidance set out in the NPPF which advises that local planning authorities should help achieve economic growth by planning proactively to meet the development needs of business and support an economy fit for the 21st century. The NPPF also advises that local planning authorities should support the existing business sectors, taking account of whether they are expanding or contracting. VALP16-08-11-00299 Andrew Cole Policy E4 - It is essential that new housing areas are provided with future proof technology. Fairford Leys still has areas that cannot receive high speed internet connections which hamper residents ability to work effectively from home. VALP16-08-17-00361 Ella Jones (Wendover Policy E4 - Wendover is a home to a large number of home workers. They need good communications connectivity and sustainable Parish Council) transport links. Additional development could put increased strain on the services that these business' rely on.

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ID Respondent Name Comment VALP16-08-17-00361 Ella Jones (Wendover Policy E9 - Agriculture is at the heart of Wendover. It helps to shape our environment. Taking land out of agricultural production for Parish Council) house building and large infrastructure projects like HS2 threatens the viability of farms in their traditional role. That may require farmers to develop new business ideas on their land. Wendover Parish Council is broadly supportive of allowing sympathetic and small scale developments of his kind. VALP16-08-19-00374 Simon Milliken (National Policy E7 - The Council will promote a growing, sustainable tourism sector, and support proposals. Proposals for new or expanded Trust, Waddesdon tourism, visitor or leisure facilities will be supported within or adjacent to settlements. Elsewhere, the nature of the proposed Estate and Hartwell development must justify a countryside location and minimise environmental impacts, and avoid unacceptable traffic impact on the House) local road network’

Comment: WE/NT/HHH support in principle Policy E7 which promotes the tourism sector, subject to the proviso that the Council exercise sufficient flexibility to enable key visitor attractions like Waddesdon Manor, Hartwell House and Stowe to meet the ever changing needs of its business operation VALP16-08-19-00374 Simon Milliken (National Policy E8 - New tourist accommodation in the rural area Trust, Waddesdon Finite market demand for tourist accommodation means that the proposals for new tourist accommodation in the rural area should Estate and Hartwell continue to be strictly controlled and subject to a market demand viability study. There should be continued policy support for existing House) hotel uses in the rural area. VALP16-08-20-00400 jim woolgar Policy E9 - Removing agricultural land VALP16-08-25-00529 Lucy Murfett (Chilterns Policy E1 - This policy states that applications for B1 (light industrial), B2 (general industrial), B8 (storage and distribution) will be Conservation Board) permitted at key employment sites. Given that the list of key employment sites includes sites which are visible from the escarpment of the Chilterns AONB (e.g. Arla/ Woodlands, Pitstone Green Business Park and Triangle Business Park) a restriction 'subject to meeting other policies in the plan' could usefully be added. This would help safeguard from adverse impacts on the AONB (eg visual impacts or increases in traffic generation through the AONB), and require careful design (e.g. green roofs, reductions in height and bulk of individual buildings). VALP16-08-25-00529 Lucy Murfett (Chilterns Policy E7 - The tourism section should refer to the Chilterns AONB in paragraph 6.20. Conservation Board) VALP16-08-25-00529 Lucy Murfett (Chilterns Policy E9 - In paragraph 6.34 a second reference could be added as follows: Conservation Board) "AVDC Design Guide for New Buildings in the Countryside, and in the AONB, to the Chilterns Buildings Design Guide" VALP16-08-25-00530 Eric Sergeant Policy E5 - Strongly agree and should be especially adhered to in the countryside. i. the design of buildings will not detract from the character or appearance of the site or the surrounding area VALP16-08-25-00530 Eric Sergeant Policy E9 - Strongly agree especially in relation to diversification and industrialisation

b. not overlarge in relation to the holding VALP16-08-28-00547 Bob LEWIS Policy E2 - Where are your proposals for work for all these extra people? VALP16-08-28-00548 Nicola Page Policy E1 - My question is why Just protect sites, why are there no dedicated sites for employment on the new roads which would be too busy and noisy and polluted for attractive dwellings when more employment sites are needed. Near the HS2/New Ring Road is the obvious candidate. The more employment we get near the accommodation, the more chance that there is one less commuter and a local participating occupant in the economy.

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ID Respondent Name Comment VALP16-08-31-00569 Paul Moss Policy E2 - No new employment sites are planned for the developments adjacent to Milton Keynes WHA01, NLV01 leaving planning dependant on Milton Keynes and or requiring further as yet unplanned transport infrastructure developments to improve travel to the Aylesbury and the South of the Vale. VALP16-08-31-00580 Fiona Lippmann Policy E8 - Small community infrastructure must not be overloaded. VALP16-08-31-00581 Fiona Lippmann (Halton Policy E8 - The building of tourist accommodation should not impact on small communities and put a strain on infrastructure. Parish Council) VALP16-08-31-00607 Eleanor Dolley Policy E1 - 6.2 - The development of the sites adjacent to Milton Keynes would directly conflict this point. Overall, considering how many new houses are planned - the employment plans are woefully insufficient. VALP16-09-01-00622 Lachlan Robertson Policy E1 - Para 6.6 - Contrary to the statement made here, the Aylesbury Vale Employment Land Review Update (2012) did not (Savills on behalf of identify 16 key employment sites in the district. It identified 16 existing employment sites. Whilst it may be appropriate to identify key Aylesbury Vale Estates) employment areas, this should be more clearly undertaken via a methodology that demonstrates their importance. It must be demonstrated why the normal provisions for allowing their re-use as previously developed land into other uses (in accordance with the NPPF) should be disregarded. It is especially important that these sites are adequately identified in maps that can be clearly related to named sites. This will allow for an appropriate level of public consultation and thus strengthen the soundness of the Plan.

Policy E1 Notwithstanding our comments on para 6.6, we are concerned that a blanket policy of preventing the re-use of employment land for other purposes is not compliant with NPPF policy. Whilst the test for releasing such land into other uses may be stricter than for other non-key employment areas, nevertheless, this requires clearer justification than is available to this Plan. We would therefore recommend a viability test of appropriate rigour is introduced as a criteria e.

VALP16-09-01-00622 Lachlan Robertson Policy E2 - Para 6.8 We support the principle of seeking the information suggested for considering alternative non-employment (Savills on behalf of based uses. However, it should be made clear that the test should be applied to both land and buildings. Policy E2 Unfortunately, Aylesbury Vale Estates) policy E2 does not logically follow through from para 6.8. The policy can be made sound by omitting the word employment in line 2.

VALP16-09-01-00637 Viv Lynch (Wingrave Policy E4 - 6.11 For rural homeworkers to effectively work in the digital economy age it is essential to have fibre to the home to with Rowsham Parish ensure effective broadband speeds. Council) VALP16-09-02-00641 Christopher Matthews Policy E1 - Paragraphs 6.1 to 6.6 - I agree that key employment sites should be protected. However, it should be noted that units within Haddenham Business Park remain vacant. To encourage employment opportunities in Haddenham it is important that the costs of facilities are comparable to alternative local sites such as Thame and Long Crendon Business Parks. In addition to protecting existing business sites it is important to ensure that that these are affordable, including rent and business rates. Haddenham Neighbourhood Plan, supported by the Village Society, identified the need for small-scale starter units for local entrepreneurs who have begun their business activities but need space for expansion. Unless this need is addressed, economic growth will be stifled and areas such as Haddenham will be colonised by commuters. It is therefore crucial that the VALP addresses the nature, rather than just the area, of employment land and develops policies to meet the actual needs of local communities.

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ID Respondent Name Comment VALP16-09-02-00641 Christopher Matthews Policy E7 - Paragraphs 6.20 to 6.25 - Haddenham is a popular tourist destination and attracts coach parties, particularly those on the ‘Midsummer Murders’ trail. Part of the attraction is the quintessential English village shown at Church End, with church (Grade 1 listed building), pond, green and old houses. Unfortunately, this important area is already being spoilt by high numbers of cars, both parked and driving through the area. New housing outlined in VALP, especially the 280 houses planned for the land at the south of the village by Aston Road, will generate a large increase in traffic with the potential to ruin the whole essence of the village that tourists come to see. VALP16-09-02-00643 Angela Matthews Policy E1 - Paragraphs 6.1 to 6.6 - I agree that key employment sites should be protected. However, it should be noted that units within Haddenham Business Park remain vacant. To encourage employment opportunities in Haddenham it is important that the costs of facilities are comparable to alternative local sites such as Thame and Long Crendon Business Parks. In addition to protecting existing business sites it is important to ensure that that these are affordable, including rent and business rates. Haddenham Neighbourhood Plan, supported by the Village Society, identified the need for small-scale starter units for local entrepreneurs who have begun their business activities but need space for expansion. Unless this need is addressed, economic growth will be stifled and areas such as Haddenham will be colonised by commuters. It is therefore crucial that the VALP addresses the nature, rather than just the area, of employment land and develops policies to meet the actual needs of local communities.

VALP16-09-02-00643 Angela Matthews Policy E7 - Paragraphs 6.20 to 6.25 - Haddenham is a popular tourist destination and attracts coach parties, particularly those on the ‘Midsomer Murders’ trail. Part of the attraction is the quintessential English village shown at Church End, with church (Grade 1 listed building), pond, green and old houses. Unfortunately, this important area is already being spoilt by high numbers of cars, both parked and driving through the area. New housing outlined in VALP, especially the 280 houses planned for the land at the south of the village by Aston Road, will generate a large increase in traffic with the potential to ruin the whole essence of the village that tourists come to see. VALP16-09-02-00653 Quainton Parish Council Policy E1 - The PC agree with policies E1, 2, 3 and 4. Working from home is a growth area and hours of business and extra parking that might be needed should be looked at. VALP16-09-02-00653 Quainton Parish Council Policy E7 - Policies E7 and E8 The PC agree with these policies provided infrastructure is in place.

VALP16-09-02-00653 Quainton Parish Council Policy E9 - The PC agree with this policy

VALP16-09-02-00669 Sean Carolan Policy E5 - The concept of a settlement boundary, conformity with the NP, and a statement that the development will not allow infill are needed. Placing an out of town development on the edge of a small town could create disproportionate amounts of infill land if the policy isn't crystal clear. VALP16-09-02-00677 Steven Mitchell Policy E1 - Support. VALP16-09-02-00677 Steven Mitchell Policy E2 - Support. VALP16-09-02-00677 Steven Mitchell Policy E5 - Support. VALP16-09-03-00679 Samita Kirve (Bucks Policy E7 - We lack places to spend a day out. I suggest we earmark a place around a lake/ reservoir to develop a Lido/ leisure spot. NHS Trust) This would be a good place to relax for residents. It will also attract tourists from neighbouring counties.

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ID Respondent Name Comment VALP16-09-03-00715 Roderick floud Policy E1 - Paras 6.5-6.6 A significant omission from this policy is the provision of starter units for small business use, which may comprise mixed office/retail developments. The Haddenham neighbourhood plan identified the lack of such business premises as a major factor causing migration from the area, as small businesses sought premises into which to expand. VALP16-09-03-00726 Richard Dorrance Policy E1 - I'm not sure where to say this comment. In Table 10 which lists the key employment areas, none of them are near Edlesborough and Northall. This is more evidence that Aylesbury Vale District Council doesn't care about us and assumes that we will travel to Leighton Buzzard or Dunstable to find work. This seems so short-sighted. The villages can accommodate small start-up employment opportunities, eg the business at SparrowHall Farm at Edlesborough. VALP16-09-04-00742 Carolyn Cumming Policy E2 - Where is the Policies Map? I have not found one for either E1 or E2 within the body of the Draft Consultation Document.

VALP16-09-04-00742 Carolyn Cumming Policy E4 - Paragraph 6.11 This is essential to encourage but, given the need for fast Broadband in all developments, some reference to the section on Telecommunications and the policy outlined in Paragraphs 11.37, 11.38 and 11.41 should be given here. VALP16-09-04-00750 Colin Read (Aston Policy E5 - We see the Woodlands development as a necessary evil within our parish. We do see the advantage of funding for a Clinton parish planning) ring road but it will bring it's own problems with traffic through our village. In conjunction with Hampden Fields it could overwhelm our roads and serious traffic mitigation is required to preserve the village. VALP16-09-04-00750 Colin Read (Aston Policy E7 - There is scope for this with the closeness of the Chilterns however it needs to be low key and we are in agreement with Clinton parish planning) the small scale accommodation provision that is proposed. VALP16-09-04-00788 David Dinsdale Policy E7 - Building a 7,000 house Garden Village is not compatible with how this area of outstanding national beauty. VALP16-09-05-00798 Santosh Kirve (NEC Policy E4 - Working from home is an emerging trend for which we need real fibre-to-home connections at affordable rates. At the Europe Ltd) moment only Virgin is providing this service, but it is very expensive. I understand that this is a national issue, but we should press the government for it. VALP16-09-05-00798 Santosh Kirve (NEC Policy E5 - We should think of probably having big tech parks/ business parks once we have a good road/ rail network in place. We Europe Ltd) need good employment opportunities near our place of residence. Otherwise Aylesbury will develop from a commuter town to a commuter city! Need to look at successful towns like Reading, Milton Keynes etc. VALP16-09-05-00806 Jeff_ Deacon Policy E9 - I thought that AVDC's policy (as shown by its cavalier approach to Haddenham) is to build on prime agricultural land

VALP16-09-05-00807 Angela Truesdale Policy E7 - Haddenham is on the 'Midsomer Murders' coach tour as we have had 12 Midsomer Murders films on location. Haddenham has also been the location of 'Rosemary & Thyme' and 'Inspector Lynley'. Apart from coaches visiting Church End Green most days, there has been no tourist development but there is scope for promoting tourists to stay in B&Bs in the village and enjoy the beautiful village conservation area (assuming that it isn't spoilt by the increased housing or by having a new settlement imposed). VALP16-09-05-00812 Simon Russell Policy E2 - The evidence base for the emerging LP should ensure that it is consistent across sectors. Any sites lost to employment (Amethyst Planning) uses by way of implemented consents should no longer be identified as available or appropriate for B class uses to ensure that the LP evidence base is robust and the LP is sound.

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ID Respondent Name Comment VALP16-09-05-00841 Sara Jones (Delta Policy E2 - Support is given to the identification at paragraph 6.8 that where there is no reasonable prospect of an employment site Planning on behalf of being used for employment purposes, alternative uses may be considered. In particular land at Buckingham Road Winslow should Crevichon Properties be reallocated for residential use. Ltd) VALP16-09-05-00853 Suzanne Lindsey Policy E1 - Whilst this is not a subject that WPC feels confident to comment on in detail, Councillors are generally supportive of the (Whaddon Parish policies, but are amazed that so little information is provided, especially for the WHA001 site – if indeed this site continues to feature Council) in the VALP. No attempt appears to have been made to calculate employment growth for the area – or indeed how much employment land, if any, will need to be allocated on this particular site. Sustainability is a ‘key aim’ of any strategic site and/or Plan, and this appears to be lacking in both WHA001 and VALP, and must be corrected before any Government Inspector finds the plan unsound. It is simply not sustainable to allocate such large housing areas without some employment within it, unless AVDC simply want the WHA001 residents to cross the boundary and work in MK, thereby supporting their economy to the detriment of AVDC.

VALP16-09-05-00871 Mary Hunt (Aylesbury Policy E4 - Working at home should be positively encouraged as it enables people who could not otherwise work, for a variety of Vale Green Party) reasons, to be gainfully employed. We support this wherever there is no impact on the environment. AVDC could lead the way for larger employers to promote home working, at least for part of the week. A policy to support home working more proactively should be included here. VALP16-09-05-00874 Philip Morley Policy E1 - Paragraph 6.6 Table 10 lists key employment sites. None are in Wendover. Once again, the provision of housing should be located close to key employment sites to encourage sustainable transportation. VALP16-09-05-00904 Christopher Wayman Policy E1 - 6.6 p129 The Aylesbury Vale Employment Land Review of 2012 identified 16 key employment sites in the district, (Buckingham Town including B1, B2 and B8 and other employment sites. Three of them – at Silverstone, Westcott Venture Park and Wendover Council) Woodlands - have been given proposed ‘Enterprise Zone’ status. Buckingham Industrial Park is another of the 10 key sites, along with Network 421 at Gawcott.

BNDP policies EE1 and EE2 have already earmarked additional land for employment over and above VALP’s requirement, in particular Site Q* on the southern side of Buckingham Industrial Park. “This employment site should be aimed at the high-quality jobs principally in office/business use and in hi-tech office/industrial use, which would complement the developments taking place at Silverstone. Uses other than B8 (storage or distribution) will be preferred.” This once again demonstrates the BNDP’s forward- thinking. (* Site Q is the one which AVDC planning manager Peter Williams believes to have been withdrawn, although is clearly shown in the made BNDP approved by his own council). E1 p130VALP envisages 12 key employment sites, including three adjacent to Buckingham – Buckingham Industrial Park, Silverstone Circuit, and Network 421 at Gawcott.

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ID Respondent Name Comment VALP16-09-05-00904 Christopher Wayman Policy E2 - E2 p131VALP seems content to permit the redevelopment of all other (i.e. non-“key”) employment sites (albeit with a (Buckingham Town number of caveats). It also identifies (para 6.7) the importance of Aylesbury town centre and Stoke Mandeville Hospital, but identifies Council) no other “sub-key” sites in the Vale. What about the other towns?

Apart from supporting redevelopment of “non-key” employment sites, the draft Policy paradoxically identifies a need for an extra 22 hectares of new employment land, but fails to identify where these are to be located. Presumably, the most favoured location(s) will be in the vicinity of the larger development(s) and/or near suitable transport links. This needs to be clarified.

VALP16-09-05-00904 Christopher Wayman Policy E3 - E3 p132Nothing to conflict with BNDP (and should be supported!) (Buckingham Town Council) VALP16-09-05-00966 Michelle Kidd (Area Policy E5 - This should have an additional point within the wording of the policy dealing with the protection and enhancement of Sustainable Places biodiversity/ecological value, natural features, green and blue infrastructure etc. Team The Environment Agency) VALP16-09-05-00966 Michelle Kidd (Area Policy E9 - There should be additional wording in this policy dealing with the protection and enhancement of natural features and Sustainable Places biodiversity/ecological value. Team The Environment Agency) VALP16-09-05-00988 Sue Barber Policy E3 - carefully planned employment sites to provide suitable facilities VALP16-09-05-00988 Sue Barber Policy E4 - good internet connections for all. Good road access as even home workers need to travel at some point. VALP16-09-05-00988 Sue Barber Policy E7 - This should include not removing green belt and maintaining AONB for tourists to visit. If you destroy the countryside what is there for tourist to visit. Halton and Wendover are historic and beautiful, loved by walkers and tourists in general, this must be maintained otherwise it's just becomes another town VALP16-09-05-00988 Sue Barber Policy E9 - E9 any accommodation for tourists must be near shops, trains, buses and not in rural settlements where facilities and roads are too limited to provide for the needs of tourists i.e. Halton and Wednover VALP16-09-05-00992 Helen Hyre Policy E4 - Para 6.11 Working at home should be permitted as long as it doesn't have a serious impact on the neighbours. VALP16-09-05-00998 Charlotte Beadle Chapter 6 Economy - All paragraphs: I do not support this draft plan for 33000 new homes in Aylesbury Vale.

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ID Respondent Name Comment VALP16-09-05-01005 Andrew Phillips Policy E2 - This email is specifically centred around the expansion plans for Haddenham, either by this village growing or a "new town" on its outskirts. Haddenham is a historic settlement with no natural commercial centre. It is a small residential area with one key selling point = which is the railway station. We have two oversubscribed infant schools and one primary school. We are some distance from any secondary school with the nearest in a neighbouring county and no right to send our children there. We have no shops of note other than a corner shop and minor mini market (McColls). We have four pubs and minimal eateries. To expand this village would be a major failing of AVDC. We have poor village roads which are already overcrowded and often accident blackspot (Staybridge Rd jnt Woodways). The S.E part of the village floods yearly and parking around the railway station is already blocking the residential roads. Princes Risborogh is also adding housing as is Thame (In Oxfordshire). These in conjunction with Haddenhams already approved housing will put a strain on the existing infrastructure and no additional resources. From attending the open days and seeing your reports. Winslow is the only viable option.

VALP16-09-05-01008 John Mortimer Policy E3 - There is no hint of what provision will be made for employment on many of the proposed housing developments. Or indeed how the two will be interfaced. In the case of WDA001, some provision should be made for industrial units, but it is most likely that the majority of those living in WDA001 will find employment in Milton Keynes. Buckingham and Ayesbury are too far away. Milton Keynes is an obvious magnet. This again is the hypocracy of the proposals. Residents will find all their needs met in Milton Keynes, even to the point of the need for the CREMATORIUM!!!!!! But AVDC will be extracting Council Tax. So what will be given in return to satisfy and placate the Milton Keynes councillors? VALP16-09-05-01008 John Mortimer Policy E4 - Some people will work from home and will expect high quality Wifi to be provided. VALP16-09-05-01008 John Mortimer Policy E6 - Provision will have to be made for local centres in the manner provided by Milton Keynes. No mention is made in the 200- plus page DRAFT report of local centres, especially in developments such as WDA001 and others. VALP16-09-05-01028 Warren Whyte (AVDC) Policy E1 - I do not agree that Buckingham is a good location to promote B8 uses - this tends to be distribution: large sheds with high transport requirements but limited employment opportunities. B8 uses should only be promoted in areas of excellent transport connections, such as Arla EZ

E1c must be robust - the growth of out of town retail uses in Buckingham has been to the detriment of the town centre, generates more car journeys, and reduces the availability of B1/2 units from new businesses VALP16-09-05-01028 Warren Whyte (AVDC) Policy E5 - Without a town centre policy for Buckingham, this policy (especially E5e) provides an open door for a retailer who doesn't want the difficulties of development in a town centre location. We must have a policy that helps to enable retail investment in difficult market town locations so to discourage retail from out-of-town locations. VALP16-09-05-01037 Janette Eustace Policy E1 - Existing employment sites must be protected from development and new employment sites identified as the population (Stewkley Parish moving into the area to occupy the newly built houses will require employment. Council)

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ID Respondent Name Comment VALP16-09-06-01059 Ken Goodman Policy E2 - Employment Land Development. The volume of traffic through the village at present stands at 144,000vehicles per month travelling east to west and 104,00 north to south. More development will only cause a major increase in these figures which the village cannot possibly cope with. Already on the site of the former gas reception site on Bletchley Road a road haulier has moved in and this has led to an unacceptable impact on the village and in particular the conservation area by the HGV’s. The road is also used as a short cut to the south of Milton Keynes, which has a large impact on Whadden road and Stoke road in respect of road safety and road deterioration. If employment in this area is to develop then alternative routes should be made to keep the integrity of the village ethos.

VALP16-09-06-01062 Sheila Goodman Policy E2 - Employment Land Development. The volume of traffic through the village at present stands at 144,000vehicles per month travelling east to west and 104,00 north to south. More development will only cause a major increase in these figures which the village cannot possibly cope with. Already on the site of the former gas reception site on Bletchley Road a road haulier has moved in and this has led to an unacceptable impact on the village and in particular the conservation area by the HGV’s. The road is also used as a short cut to the south of Milton Keynes, which has a large impact on Whadden road and Stoke road in respect of road safety and road deterioration. If employment in this area is to develop then alternative routes should be made to keep the integrity of the village ethos.

VALP16-09-07-01134 Matthew Dawber (Savills Policy E2 - Policy E2 – Other Employment Sites (on behalf of Berryfields The Developer is supportive of the pragmatic approach demonstrated in Policy E2 with regard to non-key employment sites. This is Developers)) reflective of the approach outlined in paragraph 22 of the NPPF. However, in light of the housing land shortfall and employment land surplus circumstances for a change of use between these should be outlined in Policy. This could be done within Policy E2, as it is most likely to affect the non-key employment sites, or through a new policy. If the Council decides not to accommodate this within policy specific sites should be identified for the change of use from employment to residential uses to address the issue.

VALP16-09-07-01153 Sylvie Eames Policy E1 - E1 Protection of key employment sites and E2 – covered by comments for D9. The policy as worded makes it easy to convert employment land into housing. There is already serious shortages of local employment and people having to commute.

VALP16-09-07-01153 Sylvie Eames Policy E3 - I agree with policies E3and E4 VALP16-09-07-01153 Sylvie Eames Policy E4 - I agree with policies E3and E4 VALP16-09-07-01153 Sylvie Eames Policy E5 - E5 Development outside town centres would be stronger if worded “are met” VALP16-09-07-01159 Mandy Cliffe (Great Policy E1 - 6.1 E1 Protection of key employment sites Horwood Parish Council) 6.1.1 This policy is consistent with paragraph 21 of the NPPF. However paragraph 22 of the NPPF includes a requirement that land allocations (in the context of employment land) should be regularly reviewed, and indeed the number of key employment sites was reduced from 16 to 12 between 2012 and 2016. GHPC considers that this policy should include a reference to a review mechanism to allow for modifications in the list of key employment sites during the plan period. VALP16-09-07-01159 Mandy Cliffe (Great Policy E2 - 6.2 E2 Other employments sites Horwood Parish Council) 6.2.1 This policy is consistent with paragraphs 21 and 22 of the NPPF.

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ID Respondent Name Comment VALP16-09-07-01159 Mandy Cliffe (Great Policy E3 - 6.3 E3 Provision of complementary facilities for employees Horwood Parish Council) 6.3.1 GHPC considers that the first instance of the word “appropriate” in this policy should be replaced by the word “permitted”. VALP16-09-07-01159 Mandy Cliffe (Great Policy E4 - 6.4.1 This policy is a rewritten version of lapsed AVDLP Policy GP7. Horwood Parish Council)

VALP16-09-07-01159 Mandy Cliffe (Great Policy E5 - 6.4.2 The first part of this policy is a slightly modified version of 24 of the NPPF. Horwood Parish Council) 6.4.3 GHPC considers that, to clarify that this policy is consistent with paragraphs 26 and 27 of the NPPF, the second paragraph should be modified so that after the second comma it reads …, will be refused unless it can be demonstrated that ... VALP16-09-07-01159 Mandy Cliffe (Great Policy E6 - 6.6.1 This policy is consistent with the third bullet point of paragraph 23 of the NPPF, and is a rewritten version of various Horwood Parish Council) saved policies from AVDLP applying to the shopping frontages in individual strategic settlements.

VALP16-09-07-01159 Mandy Cliffe (Great Policy E7 - 6.7.1 GHPC considers that the first sentence of this policy, ending in the word “… and support proposals”, is is of too Horwood Parish Council) general a nature, contradicts the remainder of the policy, and should be deleted. The second sentence should be amended to read Proposals for new or expanded tourism, visitor or leisure facilities will be supported within or adjacent to settlements, subject to compliance with other policies in the Development Plan.

VALP16-09-07-01159 Mandy Cliffe (Great Policy E8 - 6.8.1 The second paragraph of this policy, “Proposals … as a going concern.”, concerning proposals to reduce tourist Horwood Parish Council) accommodation, is inappropriately positioned. GHPC considers that it would be better placed at the end of the policy. 6.8.2 The remainder of the policy is broadly consistent with the third bullet point of paragraph 28 of the NPPF. 6.8.3 The term “medium tier of the settlement hierarchy”, used in the first bullet point of this policy, is not defined anywhere in the draft VALP; nor is it defined in the draft Settlement Hierarchy (July 2016). There are no logical connectives joining the three bullet points in the policy, and so the meaning of this part of the policy is ambiguous. Furthermore, the second bullet point and list item (c) appear to cover the same contingencies, as do the third bullet point and list item (d). 6.8.4 GHPC considers that the middle part of this policy should be completely rewritten in order to clarify its intended meaning. GHPC would also suggest that the rewritten version should be stated to apply to those non-strategic settlements in the Settlement Hierarchy described as “villages” rather than “other settlements”, so that the existing list item (b) should become Tourist accommodation in other settlements will not generally be supported. 6.8.5 The final part of the policy, concerning camping and touring caravan sites, is essentially a rewrite of saved AVDLP Policy GP73.

VALP16-09-07-01159 Mandy Cliffe (Great Policy E9 - 6.9.1 This policy is generally consistent with the second bullet point of paragraph 28 of the NPPF. Horwood Parish Council) 6.9.2 GHPC considers that there should be a further sentence at the end of the policy, along the lines of Proposals should provide evidence that the design of such buildings is consistent with the AVDC Design Guide for New Buildings in the Countryside. 6.9.3 GHPC also considers that, for clarity, the policy should state explicitly whether it applies to retail outlets related to agriculture, such as farm shops and garden centres.

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ID Respondent Name Comment VALP16-09-07-01160 Dave Norris Policy E1 - E1 Protection of key employment sites and E2 – covered by comments for D9. The policy as worded makes it easy to convert employment land into housing. There is already serious shortages of local employment and people having to commute.

VALP16-09-07-01160 Dave Norris Policy E3 - I agree with policies E3and E4 VALP16-09-07-01160 Dave Norris Policy E4 - I agree with policies E3and E4 VALP16-09-07-01160 Dave Norris Policy E5 - E5 Development outside town centres would be stronger if worded “are met” VALP16-09-07-01166 Andrew Marsh (Central Policy E2 - Employment Bedfordshire) In relation to employment, we note that the Buckinghamshire HEDNA highlights an oversupply of employment land in the district compared to the predicted need for employment land, and therefore that further detailed assessment is to be undertaken of employment sites to determine if they can be put to other uses, including for housing. We welcome this approach and would appreciate being given the opportunity to discuss options with you and comment on future studies in relation to this.

VALP16-09-07-01171 Nick Osgerby (Steeple Policy E4 - Steeple Claydon has a significant number of residents working from home and supports the proposed policy E4 Claydon Parish Council)

VALP16-09-07-01171 Nick Osgerby (Steeple Policy E9 - Steeple Claydon has a history of agricultural development and employment. SCPC supports the proposed policy E9 Claydon Parish Council)

VALP16-09-07-01172 Simon Proctor (Proctor Policy E2 - This policy appears confused. Does it in fact relate to alternative uses (other than employment sites)? Surveyors (Stoke Hammond)) VALP16-09-07-01174 Sarah Churchard Policy E1 - Paragraph 6.4 (Robinson & Hall LLP We agree that sustainable economic growth should be supported, but there is no evidence in Chapter 6 that this is the case. There (Whitehouse Farm, are no figures or forecasts set out which aspire to what level of employment growth would be suitable, or in general areas. This is a Winslow)) significant down fall of the plan, which needs to be rectified in subsequent versions. We cannot see that the Plan could go forward without the evidence base or sites being allocated.

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ID Respondent Name Comment VALP16-09-08-01209 Tim Coleby (Peter Brett Policy E1 - 6.3.1 BA supports the identification of the ARLA/Woodlands Enterprise Zone as a Key Employment Site under policy E1, Associates LLP on subject to: it being revised slightly to allow a proportion of key employment sites to be developed for non-employment uses eg behalf of residential, where this is required to facilitate effective delivery of employment uses on the remainder of the site; or the policy map Buckinghamshire accompanying policy E1 excluding that part of the ARLA/Woodlands Enterprise Zone which is proposed for non-employment use in Advantage) the current planning application. Strategic Importance of Aylesbury Woodlands 6.3.2 Aylesbury Woodlands is a key strategic employment site for Aylesbury Vale district and Buckinghamshire. The vision for the site is that it will become a new Gateway in Buckinghamshire that will bring much needed infrastructure and a transformational employment offer for the region. It is identified as a priority project by Buckinghamshire Thames Local Enterprise Partnership (LEP) and has, along with Silverstone and Westcott Venture Park, been awarded Enterprise Zone status. Due to its strategic importance in supporting the economic growth aspirations of the district it is therefore important that the site is protected under Policy E1 of the emerging Local Plan. It is also important to note that, in awarding Enterprise Zone status, central Government acknowledged that Aylesbury Woodlands would incorporate residential and other non-employment uses within the Enterprise Zone boundary. 6.3.3 The Aylesbury Vale Enterprise Zone is aimed at attracting and developing new business investment; speeding up the growth and development of local enterprise; and helping to address the business critical infrastructure needs of the three strategic sites within it (Silverstone, Westcott Venture Park and Arla/Aylesbury Woodlands). Given its position at the heart of the ‘Golden Triangle’ and at the centre of the ‘Oxford to Cambridge Arc’ the LEP want the Enterprise Zone to challenge internationally as a major new employment location over the coming years. 6.3.4 BA is promoting a scheme for Aylesbury Woodlands that comprises up to 100,000 sq m of high quality employment floorspace that will leverage the industry leading, high tech food manufacturing capability at Arla and attract ambitious, growth-oriented companies, particularly in the LEP’s priority sectors described above in para 6.2.5. This B space will be provided in a mixed use strategic development area to the east of Aylesbury alongside housing and an associated local centre to serve the day to day shopping needs of residents and workers, as well as a sports village. Once built and occupied, the employment uses being planned on site have the potential to support almost 5,495 gross direct, indirect and induced jobs in total. It is estimated that 2,634 of these jobs will be new to Aylesbury Vale district (i.e. net additional). These net additional jobs are estimated to have the potential to add approximately £152.3 million Gross Value Added to the local economy per annum.

6.3.5 The quantum and mix of B space proposed in the Aylesbury Woodlands scheme responds to identified current business needs and forecast employment growth. The Buckinghamshire HEDNA identifies that although there are 8% and 9% B space vacancy rates recorded across Buckinghamshire and Aylesbury Vale respectively, approximately 70% of vacant stock is classified as second hand Grade B, which is unlikely to be attractive to new investors. 6.3.6 Paragraph 5.44 of the HEDNA goes on to state that ‘views expressed at the employment land consultation workshop also suggested that ‘although Aylesbury Vale has a number of safeguarded employment sites, local agents considered that many of these sites are not suitable for development for employment uses as a result of their lack of adequate transport connections and other services and facilities’.

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ID Respondent Name Comment VALP16-09-08-01209 Tim Coleby (Peter Brett It is therefore highly questionable as to whether the 73 ha supply of employment land identified in Figure 133 of the Buckinghamshire Associates LLP on HEDNA is deliverable and/or attractive to inward investors. With this in mind it is essential that new sites are allocated in appropriate behalf of locations if the area is to realise its aspirations of attracting inward investment from higher value sectors. Buckinghamshire Locational and Sustainability Benefits Advantage) 6.3.7 It is entirely appropriate that a strategic employment allocation of the status of Aylesbury Woodlands, which has the potential to attract the types of high value sectors being targeted by the LEP, should be located on the eastern fringe of Aylesbury. Importantly, with regard to Policy D9, the site will be easily accessible from the A41, and the motorway network beyond, and will therefore be highly attractive to the types of large employers that the District Council and LEP are looking to attract. Furthermore, taking note of the principles of sustainable development set out in the NPPF, it is important that a suitable amount of employment land is delivered on the eastern fringe of Aylesbury alongside a large proportion of the district’s planned housing provision. This in turn will help to reduce daily out flows of district residents to other areas and reduce pressure on the wider road network within Aylesbury.6.3.8 The importance of this approach is highlighted by the Buckinghamshire Thames Valley LEP Strategic Economic Plan (SEP) Refresh consultation document which states that ‘given that Buckinghamshire is already the most porous LEP area in the country, with London, Oxford, Reading and Milton Keynes acting as a significant pull for people who live in the county, it is vitally important we invest in the creation of suitable employment sites locally to ensure Buckinghamshire develops sufficient, suitable jobs for its growing population’. 6.3.9 It goes on to state that ‘going forward, given that much of our infrastructure is already at breaking point, we are particularly keen to see employment sites being brought forward that are located close or near to linked housing growth and that can offer high value employment to the large number of people that are currently out commuting’. It is for these reasons that the LEP has committed significant funding support towards the Aylesbury Eastern Link Road (South) in order to unlock the land for development.

Conclusions 6.3.10 In summary, BA supports the protection and promotion of Aylesbury Woodlands as an employment site under draft Policy E1. It is a key strategic employment site for Buckinghamshire as a whole, with the capability of attracting the types of higher value businesses and jobs that the District Council and LEP are looking to bring to the area to facilitate the diversification of the economy. The viable delivery of employment uses at Aylesbury Woodlands and other sites is however dependant on linked housing development within a mixed use strategic development area. 6.3.11 It is for this reason that the Enterprise Zone boundary includes a substantial proportion of the whole Aylesbury Woodlands development boundary, incorporating housing and other uses. BA therefore recommends that the text of Policy E1 reflects the requirement for linked employment and housing growth, in order to comply with the sustainable development principles set out in the NPPF and ensure that employment generating uses are delivered. VALP16-09-08-01225 Frazer Hickling (Phillips Policy E1 - It is noted that the policies set out in this chapter relate to protection and provision of employment sites of all types, as Planning Services well as the provision of ‘complementary facilities’, and supporting the development of businesses compatible with residential areas, Limited) as well as retail, tourism and agriculture. It is considered that the expected ‘employment’ policy related matters have been covered in this chapter and we have no specific comments to make on policy. We would take this opportunity to highlight that consideration should be given to identifying new employment sites, where they can contribute to the mix of land use within the expansion areas.

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ID Respondent Name Comment VALP16-09-08-01242 Louise, Thomas & Eleri Policy E9 - We would also ask that as covered in Policy E9: Agricultural development, ‘The development of new agricultural Hosking buildings or extensions of existing buildings will be permitted where the development is necessary for the purposes of agriculture on the unit or locally where facilities are shared, not over large in relation to the holding and there are no existing buildings on the unit which are capable of re-use’ and that this is appraised by an agricultural expert. There have been far too many cases of agricultural buildings being granted planning permission which should not have been, for example an alpaca house (hardly a sustainable agricultural enterprise), a machinery store and workshop on a holding of five acres (is that likely to be necessary?), two buildings for hay and machinery storage that have lain empty since, and a sheep shed that is many times larger than it need be for the size of flock proposed, on a holding with a large number of horses. This then puts the council in a weaker position when such holdings then want a rural workers dwelling. The two parts should be very much joined up. We trust you will take our comments on board and we hope that the new settlement is removed from the final plan.

VALP16-09-08-01245 Deborah O’Brien Policy E1 - We welcome the undertaking that ‘Local and village centres will also be encouraged to grow and loss of essential (Padbury Parish Council) facilities and businesses such as local shops, pubs and post offices will not be supported.’ However, in many villages the erosion of essential facilities and businesses occurred some time ago, and it is difficult to see how this will be effectively remedied/enforced.

Is there an economic foundation to the Plan? We remain unconvinced that this is the case, and in particular we see no evidence for employment growth within the vale or a target to meet the same.

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ID Respondent Name Comment VALP16-09-08-01262 Geoff Gardner Policy E5 - Housing and Economic Needs (Gardener Planning Ltd 2.4 Housing needs calculations are based upon the Housing and Economic Development Needs Assessment (HEDNA) carried out on behalf of Arnold by ORS and published in October 2015. However, two HEDNAs were published in 2015, the other being by GL Hearn: Aylesbury White Estates Ltd) Vale Housing & Economic Development Needs Assessment (July 2015). 2.5 The matter of two dissenting HEDNAs and OANs was raised in response to the Issues and Options (I&O) consultation in 2015. However, there is no response in the DP or any of the background documents. It is therefore repeated in this Report as it is fundamental and materially affects the ‘robust evidence base’, which impacts on soundness. It will be an issue when the Plan is eventually examined. 2.6 A critical difference is that GLH calculate that the Objectively Assessed Need (OAN) for housing is “that taking account of baseline forecasts and the impacts of planned investment which will support economic growth, delivery of 1,326 homes per annum would be needed” . 2.7 There is no comparison of the two HEDNAs in the Issues And Options Consultation Document (I&OCD) apart from an attempt at explaining the preference of ORS over GLH, but what is needed is much more explanation than appears in the I&O consultation (there is none in either the ORS HEDNA or the DP)(emphasis added): Aylesbury Vale’s housing need: The Housing and Economic Development Needs Assessment (HEDNA, 2015) for Central Buckinghamshire local authorities suggests the district has an OAN for 21,000 dwellings (net) (21,300 rounded to the nearest thousand) over the plan period (1,050 per annum). This figure is less than in the Aylesbury Vale HEDNA, (July 2015) due to a different methodology which follows more recent advice and takes into account other factors, such as unattributable population change. 2.8 This confusion should be clarified and the discrepancies identified and explained. Two Reports come to different conclusions in the space of 4 months. The GLH Report calculates the OAN to be 1,326 homes p.a. . The ORS Report finds that the OAN for AV District is 1,065 homes p.a. . This is a substantial difference of 25%. 2.9 The GLH Report arrives at the higher figure of 1,326 homes p.a., for the District only, as follows:

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ID Respondent Name Comment 1.20 The report has considered potential future economic performance as well as commercial property market dynamics. Three separate forecasts – from each of the main forecasting houses (Cambridge Econometrics, Oxford Economics and Experian) – have been considered. Neither forecast is inherently ‘better.’ For the purposes of providing a baseline/ trend-based assessment future economic performance, GL Hearn considers that it would be sensible to take the average of the three forecasts on a sector basis to provide a Synthesis Forecast. A Synthesis Baseline Forecast sees net growth of 15,600 jobs between 2013-33 in the District. 1.21 This Synthesis Forecast represents expected growth in employment of 0.8% per annum. This is consistent with past trends (albeit that the precise growth rate varies depending on what period is studied and dataset used). Provision of 1,192 homes per annum is modelled as being required to support this (including adjustments to improve affordability). 1.22 The exact relationship between growth in jobs and housing need will be sensitive to the relationship between jobs and people (as some people hold down more than one job), to changes in employment rates and the extent to which people work longer in the future, and to commuting dynamics. The report has sought to make reasonable estimates of the impact of these issues based on the evidence currently available. 1.23 GL Hearn’s analysis suggests that there are however some committed investment projects which are likely to support stronger employment growth than is modelled in the Synthesis Baseline Scenario. In drawing conclusions, GL Hearn has taken account of the potential impacts of investment in infrastructure including delivery of East-West Rail; and of major development projects which can be expected to support stronger employment growth in some sectors than shown in the Synthesis Baseline Forecast. This results in forecast growth of 1.0% per annum in employment, with net growth of 19,000 jobs between 2013-33 in the District. This is modelled to require 1,326 homes per annum.

VALP16-09-08-01262 Geoff Gardner 2.10 What GLH does, therefore, is to take an average of 3 studies (which is 1,192 homes p.a.) then adds 134 homes p.a. for (Gardener Planning Ltd “stronger employment growth”, taking account of known indicators, to arrive at its final figure of 1,326 homes p.a. as the OAN. on behalf of Arnold Although the ORS figure of 1,065 is roughly comparable with the GLH figure of 1,192, ORS seems to make no additional allowance White Estates Ltd) which recognises the ‘stronger economic growth’ factor. 2.11 The potential for stronger economic growth for Aylesbury Vale has been recently reinforced by the proposal for a Cambridge - MK - Oxford Growth Arc, of which the Terms of Referencinclude: “The aim of this review is to provide the Government with proposals and options for the long-term infrastructure priorities to unlock growth, jobs and housing within the Cambridge-Milton Keynes-Oxford corridor over the next 30 years. Together with Northampton, the area contains four of the UK’s fastest growing, and most productive, places. It encompasses global centres of research expertise in Oxford and Cambridge and advanced manufacturing and logistics in Milton Keynes. The review will make recommendations to maximise the potential of the area as a single, knowledge-intensive cluster that competes on a global stage, whilst both protecting the area’s high quality environment and securing the homes, and jobs, the region needs.” VALP16-09-08-01283 Simon Proctor (Proctor Policy E2 - This policy appears confused. Does it in fact relate to alternative uses (other than employment sites)? Surveyors (Stoke Hammond 2)) VALP16-09-08-01291 Martin Small (Historic Policy E2 - Policy E2 – should the first sentence of the Policy read “..the redevelopment of other existing employment sites to an England) alternative non-employment use…” ?

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ID Respondent Name Comment VALP16-09-08-01291 Martin Small (Historic Policy E5 - Policy E5 – we welcome criteria a. and i. of Policy E5, although we would also like to see a reference to “historic England) significance” in criterion i., as part of the positive strategy for the conservation and enjoyment of, and the clear strategy for enhancing, the historic environment required by the NPPF. VALP16-09-08-01291 Martin Small (Historic Policy E7 - Policy E7 – we welcome criterion a. of Policy E7, although we would like to see “historic significance” included, as part of England) the positive strategy for the conservation and enjoyment of, and the clear strategy for enhancing, the historic environment required by the NPPF. VALP16-09-08-01291 Martin Small (Historic Policy E8 - Policy E8 – we are concerned that clause d. of the policy would encourage the loss of existing rural buildings that may be England) of architectural or historic interest – vernacular and traditional farm buildings are generally under-represented in the statutory list of buildings of special architectural and historic interest.

We consider therefore that this clause should exempt buildings of special architectural or historic merit (whether listed or not) and that the policy should contain a general criterion requiring the historic environment and significance of any heritage assets to be conserved and enhanced, as part of the positive strategy for the conservation and enjoyment of, and the clear strategy for enhancing, the historic environment required by the NPPF. VALP16-09-08-01291 Martin Small (Historic Policy E9 - Policy E9 – we would welcome the addition of a reference to the historic environment in criterion e. of this policy, as part England) of the positive strategy for the conservation and enjoyment of, and the clear strategy for enhancing, the historic environment required by the NPPF. VALP16-09-09-01315 Neil Tiley (Pegasus Policy E5 - Policy E5 sets the requirement for a sequential test for town centre uses outside of an existing centre. It then identifies Group (on behalf of the criteria against which retail proposals outside of these existing centres will be assessed. However, this does not make provision Jeremy Elgin)) for any town centre uses or retail floorspace which may be required as part of a new settlement. The application of a sequential test to such proposals would be overly onerous and would be contrary to paragraph 26 of the NPPF which allows for town centre uses in locations which are in accordance with the Local Plan. The policy wording should be adjusted to accommodate town centre uses of an appropriate scale within the new settlement.

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ID Respondent Name Comment VALP16-09-09-01317 James Yeoman (Savills Policy E5 - Housing and Economic Land Availability Assessment (HELAA) on behalf of Mr D and Proposed Site – MGB009 Mrs G Hearn) The Council has assessed our client’s land interest under HELAA site reference MGB009. MGB009 extends to cover an area of circa 2.3ha east of Clement’s Lane. The HELAA concludes that the site would be unsuitable for residential development, owing to biodiversity constraints and its location adjacent to the Marsh Gibbon Conservation Area. AVDC outline that development of the site would likely have adverse impacts. Notwithstanding this, it is noted that the site is well positioned to accommodate the residual housing requirements for development delivery to Marsh Gibbon, with the Council’s initial concerns regarding the impact of development able to be sufficiently mitigated by relevant technical inputs, including ecological surveys as may be required. The site is well related to existing development and the facilities of Marsh Gibbon. These include a primary school, a village hall, public houses, churches, bus services, and a number of local businesses. Adequate access can be obtained via Clements Lane. The site lies opposite the Marsh Gibbon Village Hall, and development at the site would represent a proportionate and appropriate continuation of the existing built form of the settlement. The site represents a logical extension to the built form of Marsh Gibbon and occupies a gateway location to the southern extent of the village. Whilst the site lies adjacent to the designated Marsh Gibbon Conservation Area, development in this location could be sensitively designed to appropriately respond to this adjoining heritage designation. The enclosed plans provides an Illustrative Site Layout outlining the potential form of residential development at the site. This particular layout demonstrates a capacity of 20 units. The scheme provides for on-site parking and garaging, with access taken directly from Clements Lane. The Layout is provided as an approximate capacity testing exercise. A lower quantum of development (e.g. 5 to 10 units) could be delivered on the site, depending on the approach of the VALP and any future revision to the Marsh Gibbon Neighbourhood Plan to allocating sites at Marsh Gibbon. The purpose of this submission is to demonstrate the flexible nature of the site and its potential to deliver a high quality residential scheme to meet local housing need.

VALP16-09-09-01399 Cllr Phil Yerby Policy E1 - Policy E1 Protection of key employment sites 97.105. We oppose the proposal of ARLA/Woodlands as a key employment site, protected employment site or, for the avoidance of doubt, any employment site. At paragraph 1.15 of the draft plan it states: “Employment need is usually met by new allocations to satisfy the forecast requirement. However the forecast requirement for the district is 22ha whilst the Council has a supply of over 70ha (not including the Arla/Woodlands part of the new Enterprise Zone). The Council is therefore considering which employment sites it can reallocate to other uses including housing.” 98.106. The Woodlands element of the Arla site does not pass any sequential testing requirements as regards to flooding and the Council has not adequately demonstrated that suitable employment land has been identified. Woodlands cannot be justified as an employment site within the VALP. (see comments on flooding) VALP16-09-09-01399 Cllr Phil Yerby Policy E4 - We support the policy. VALP16-09-09-01399 Cllr Phil Yerby Policy E5 - 108. Retail sites should have been developed and consulted on as part of the plan. Ad hoc allowing of supermarket locations, as this policy does, will lead to many future applications outside of the Town Centres. The policy needs to make it clear that design will be a consideration at outline planning stage and not a reserved matter. VALP16-09-09-01399 Cllr Phil Yerby Policy E7 - 109. It should be made clear within the policy that development of any sort within the AONB will not be permissible under any circumstances.

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ID Respondent Name Comment VALP16-09-09-01399 Cllr Phil Yerby Policy E8 - 109. It should be made clear within the policy that development of any sort within the AONB will not be permissible under any circumstances. VALP16-09-09-01413 Michelle Thompson Policy E7 - Also look at the quality of new development as well as engaging with heritage style sites - go for architectural outstanding areas with green spaces capable of capturing people's imagination, getting them to enjoy the area regularly/for longer spells at a time. If promoting sites - parking, toilets, roads, paths, hospitalisty and cafes on main roads to aid flow of trafiic at busy times

VALP16-09-09-01427 Phil Yerby (Hampden Policy E1 - We oppose the proposal of ARLA/Woodlands as a key employment site, protected employment site or, for the avoidance Fields Action Group) of doubt, any employment site. At paragraph 1.15 of the draft plan it states: “Employment need is usually met by new allocations to satisfy the forecast requirement. However the forecast requirement for the district is 22ha whilst the Council has a supply of over 70ha (not including the Arla/Woodlands part of the new Enterprise Zone). The Council is therefore considering which employment sites it can reallocate to other uses including housing.” The Woodlands element of the Arla site does not pass any sequential testing requirements as regards to flooding and the Council has not adequately demonstrated that suitable employment land has been identified. Woodlands cannot be justified as an employment site within the VALP. (see comments on flooding)

VALP16-09-09-01427 Phil Yerby (Hampden Policy E4 - We support the policy. Fields Action Group) VALP16-09-09-01427 Phil Yerby (Hampden Policy E5 - 108. Retail sites should have been developed and consulted on as part of the plan. Ad Fields Action Group) hoc allowing of supermarket locations, as this policy does, will lead to many future applications outside of the Town Centres. The policy needs to make it clear that design will be a consideration at outline planning stage and not a reserved matter. VALP16-09-09-01427 Phil Yerby (Hampden Policy E7 - 109. It should be made clear within the policy that development of any sort within the AONB will not be permissible under Fields Action Group) any circumstances. VALP16-09-09-01427 Phil Yerby (Hampden Policy E8 - 109. It should be made clear within the policy that development of any sort within the AONB will not be permissible under Fields Action Group) any circumstances. VALP16-09-09-01451 Geoff Culverhouse Policy E1 - 6.1 The list of key employment sites should be extended to include any employment sites specifically referenced in (North Bucks Parishes Neighbourhood Plans. It is important to recognise that in some locations even a small employment site could be classed as ‘key’ to Planning Consortium) development in that area. Furthermore it is vital that employment opportunities are created in all areas where significant growth is proposed. This is particularly so at strategic settlements. Reserved sites must be protected and there should be specific requirements for employment land within major new development sites. Policies should make it clear that applications for conversion of employment land to housing will not be considered within the first ten years of the plan. VALP must ensure that a sound geographic spread of employment sites is maintained across the vale. We are concerned that the provision of employment is under- valued in VALP. It is an important parameter for development. VALP16-09-09-01451 Geoff Culverhouse Policy E2 - 6.2 We consider that this policy, as worded, will make it much too easy for employment land to be converted to housing. (North Bucks Parishes This will be particularly important in strategic settlements such as Winslow where there is already a serious shortfall in local Planning Consortium) employment opportunities. Alternative uses to employment on reserved sites should not be permitted within the first ten years of the plan.

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ID Respondent Name Comment VALP16-09-09-01451 Geoff Culverhouse Policy E3 - 6.3 Replace ‘appropriate’ with ‘encouraged’ at beginning of second line of policy. (North Bucks Parishes Planning Consortium) VALP16-09-09-01451 Geoff Culverhouse Policy E4 - 6.4 This policy is supported (North Bucks Parishes Planning Consortium) VALP16-09-09-01451 Geoff Culverhouse Policy E5 - 6.5 Replace ‘have been considered’ with ‘are met’ in the third line of the second paragraph. Without this change, or (North Bucks Parishes something similar, the policy will be utterly meaningless. Planning Consortium) VALP16-09-09-01451 Geoff Culverhouse Policy E6 - 6.6 We support this policy and can only hope that it is enforced effectively. (North Bucks Parishes Planning Consortium) VALP16-09-09-01451 Geoff Culverhouse Policy E7 - 6.7 The wording of the second sentence in the opening paragraph appears to restrict rather than promote development (North Bucks Parishes of tourism in countryside locations. In particular this could have an adverse impact on much needed expansion of hotel facilities at Planning Consortium) Silverstone which is in a countryside area. AVDC should be encouraging tourism related businesses and working with BCC highways toimprove access to key locations such as Silverstone, Stowe and Waddesdon. VALP16-09-09-01451 Geoff Culverhouse Policy E8 - 6.8 Similarly to the above item ‘b’ is commercially restrictive. Many tourists would prefer to stay at accommodation in (North Bucks Parishes smaller communities. There are already many successful B&B operations in smaller communities. This could also prevent the Planning Consortium) conversion, and thereby preservation, of large country properties to hotels. VALP16-09-09-01451 Geoff Culverhouse Policy E9 - 6.9 After ‘where’ at the end of the introductory sentence delete colon and add. ‘evidence is produced which clearly (North Bucks Parishes illustrates that:’ Planning Consortium) VALP16-09-12-01514 Simon Proctor (Proctor Policy E2 - This policy appears confused. Does it in fact relate to alternative uses (other than employment sites)? Surveyors (Gawcott)) VALP16-09-12-01521 Sean Carolan (Winslow Policy E1 - It is very surprising indeed that there appears not to have been any effort to produce a figure for the net jobs growth for Town Council) the Plan period. One would normally expect that a Local Plan would not only provide a target figure for the delivery of housing to 2033 but also a target for the new jobs to be generated to 2033 in what is designated as a ‘growth area.’ Surely a Local Plan must show that it is sustainable and a key element of that sustainability would be to show that its net employment growth should ideally reduce out-commuting from the Vale by 2033. Without a clear indication of a jobs growth target and therefore a seeming admission that AVDC did not wish to tackle this thorny issue, will this not invite criticism or worse from the Planning Inspector at the Examination? In a document of over 220 pages, does not a mere 5 pages devoted to Employment on employment sites speak volumes?!

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ID Respondent Name Comment VALP16-09-12-01521 Sean Carolan (Winslow Policy E2 - 43) Either in Policy E2 ‘Other employment sites’ or in a separate Policy, there needs to be a robust protection of land Town Council) designated for employment use which, when developed, will significantly address a community’s lack of sustainability because currently there is a very significant under provision of employment on employment sites in that community. This is of particular importance for communities with Neighbourhood Plans which include Employment Policies. In the draft VALP, there does not appear to be clear recognition of this issue. If it is not addressed, one can envisage, with only Policy E2 to refer to, that there will be little to resist an application for example to utilise an employment site for a new supermarket and describing this as an alternative employment use. 44) An explicit policy statement is needed to ensure that designated employment sites will not be converted to residential use in strategic settlements such as Winslow where there is already a shortfall in local employment opportunities. VALP16-09-12-01521 Sean Carolan (Winslow Policy E3 - 45) We endorse the proposal for “provision of ancillary facilities for employees in business, industrial and warehousing Town Council) developments” (6.9). This sounds like good planning and makes life easier for everyone, especially working families. We suggest therefore that the first occurrence of ‘appropriate’ in Policy E3 should be replaced with ‘encouraged’. VALP16-09-12-01521 Sean Carolan (Winslow Policy E5 - 46) E5 needs to refer to the importance of the settlement boundary and the Neighbourhood Plan in any decisions taken Town Council) regarding employment land. 47) Essentially it seems that there is no plan for creating employment opportunities, especially with regards to meeting the needs of local communities. Linking new employment to new housing is too simplistic. There are neighbourhoods which are already underprovided and need redress. VALP16-09-12-01521 Sean Carolan (Winslow Policy E8 - 48) Policy E8 does not support tourist accommodation in smaller settlements. Many tourists would prefer to stay at Town Council) accommodation in smaller communities. There are already many successful B&B operations in smaller communities. This could also prevent the conversion, and thereby preservation, of large country properties to hotels. VALP16-09-12-01521 Sean Carolan (Winslow Policy E9 - 49) Surely appropriate evidence should be required for any proposal under Policy E9. Town Council) VALP16-09-12-01538 Jon Gateley (Savills (on Policy E7 - Policy E7 asserts that proposals should support a growing and sustainable tourism sector. We have no objection to this behalf of Crest Strategic policy, but note that the proposed development at Shenley Park outlined in the accompanying Appendices would promote Projects)) accessibility over the historic parkland area of Whaddon. This would have a small benefit in terms of local tourism.

VALP16-09-12-01541 Sarah Copley (Stoke Policy E1 - Table 10 – Key employment sites Mandeville Parish The Parish Council is pleased that Triangle Business Park is identified as a key employment site that merits protection. It urges the Council) District Council to offer similar protection to other employment sites within Stoke Mandeville Parish. VALP16-09-12-01594 Victoria Chase (Indigo Policy E5 - Policy E5: Development outside town centres Planning Ltd on behalf The Council states that it will require applications for retail development outside of a centre, as defined on the Policies Map, which Sainsbury’s are not in accordance with the local plan, to undertake an impact assessment. The threshold has not yet been determined as the Supermarkets Ltd (SSL)) council are seeking to commission further retail evidence to determine appropriate local thresholds based on past planning applications. They do however note that the impact assessment should comply with the requirements in paragraph 26 of the NPPF. We do not consider it necessary for the Council to commission further work to establish a suitable threshold rather it should be set at the 2,500sqm threshold as per paragraph 26 of NPPF.

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ID Respondent Name Comment VALP16-09-12-01606 Stuart Twigg Policy E1 - Employment – Regarding the Woodlands-Stoke arc, all these will be high cost housing (>£300k to £1m in the case of Hampden fields). There is no point allocating employment land if employees have to add to congestion by driving from the more affordable housing in the northern arc. If you wander out of the Occulus and walk for a few moments, you will see dozens of premises vacant and to let. Cross the railway and turn right and there are empty premises between Fairford Lees and Rabans Lane. There is nothing to attract new employers into Aylesbury, no new business premises are needed especially around the Woodlands roundabout. VALP16-09-12-01606 Stuart Twigg Policy E5 - Funding – An agreement is made with the developer to provide S.106 funds. These funds are then used away from the development for improvements that should have been funded by the council. An example is the traffic lights on the A41 funded by ARLA. Naturally, the developer will load these costs onto the home buyer. Could you tell me how much of the percentage cost of a house in Woodlands or Hampden Fields is actually used to fund S106. S106 is not a cost to the developer; it is an indirect cost to the new home buyer. The s106 costs should be reinvested in the developments, not used to make up a shortfall of council funding.

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ID Respondent Name Comment VALP16-09-12-01610 David Maxwell (GL Policy E1 - Aviva Investors object to the HELAA site ref AYL078 forming part of the key employment site known as the Gatehouse Hearn on behalf of Aviva Industrial Area. Whilst HELAA site ref AYL078 is currently in partial use, the only realistic long term use of the site is for residential Investors ) development. There is very limited demand for the existing types of units on the site, and the site’s location and poor access for modern commercial vehicles, means that the re-use or redevelopment is not viable. Although the site presently has some very short term tenants the only realistic long terms use of the site would be residential development. In addition, it is submitted that policy E1 is overly protective of employment land, particularly of employment land such as that at HELAA site ref AYL078 which is clearly suitable for alternative more appropriate land uses. Paragraph 22 of the NPPF states that: “Planning policies should avoid the long term protection of sites allocated for employment use where there is no reasonable prospect of a site being used for that purpose’…and…’land allocations should be regularly reviewed.’ The Government go on to say in the same paragraph that ‘where there is no reasonable prospect of a site being used for the allocated employment use, applications for alternative uses of land or buildings should be treated on their merits having regard to market signals and the relative need for different land uses to support sustainable local communities.” The NPPF also states that: “To help achieve economic growth, local planning authorities should plan proactively to meet the development needs of business and support an economy fit for the 21st century.” It is submitted that AVDC should continue to release some greenfield land sites for mixed use development that consists of residential and employment space. The strategic greenfield sites would allow for the employment sites to be located in areas that area accessible and sustainable and allow the facilitation of the growth of Aylesbury Vale economy. Research and development, manufacturing and distribution have all traditionally been located on the edge of settlements as they benefit from better connectivity. Given the committed investment projects of East West Rail and HS2 and the larger strategic housing sites, it is likely that Aylesbury will benefit from improved connectivity by 2033. This therefore means that presently allocated land for employment that was once ‘out of town’ (such as land at HELAA site ref. AYL078) will be situated in an urban hinterland due to settlement expansion, rendering the employment sites surplus to modern day requirement. In the case of the HELAA site ref. AYL078, land at Gatehouse Close it is submitted by Aviva Investors that there is very limited demand for the type of units on the site, and the sites location and poor access for modern commercial vehicles, means that re-use or redevelopment is not viable as a continuation of ‘B’ uses. In conclusion, it is submitted that either the Gatehouse Industrial Area should no longer be identified as a key employment site, or alternatively the HELAA site ref. AYL078 should be excluded from identification in the Local Plan as part of the Gatehouse Industrial Area key employment site.

VALP16-09-12-01611 Ross Middleton (CC Policy E3 - Whilst it is accepted that Policy E3 does go some way in enabling this, it is confirmed that in some circumstances a Town Planning on behalf range of alternative uses is vital to ensure the economic viability of proposed development sites. of Mr C Morris & Mr P Whilst it is our client’s intention to deliver a proposal at their site which will assist in achieving the strategic aims of the Local Plan at Cowley) its point of adoption, there will be a need to ensure that the site is both sustainable and remains responsive to the market as the economic dictates.

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ID Respondent Name Comment VALP16-09-12-01630 Hannah Fortune Policy E5 - On behalf of our client, Coal Pensions Properties Limited, we set out below comments on the Vale of Aylesbury Local (Nathaniel Lichfield & Plan (VALP) draft Plan consultation. Partners on behalf of Coal Pensions Properties Limited is an important stakeholder in Aylesbury. Its interest relates to Broadfields Retail Park, which Coal Pensions performs an important role in the retail offer within Aylesbury. Properties Limited) At this stage our comments relate to retail and other main town centre development in out of centre locations (Policy E5). Policy E5 is broadly in line with objectives of the National Planning Policy Framework (NPPF). However we believe the wording of the policy is confusing and repetitive and therefore not effective or justified for the reasons outlined below.

Part a) of Policy E5 seeks to ensure out of centre developments do not have an adverse impact on regardless of their scale. Part c) indicates that a full assessment of impact will be required for proposals over a floorspace threshold (to be determined). Part d) requires all retail developments below the retail impact floorspace threshold to be accompanied by a retail assessment.

The NPPF only requires an impact assessment to be required if development exceeds the proportionate locally set floorspace threshold. Part d) is inconsistent with the NPPF. There is also duplication in the policy with regard to the sequential approach. Policy E5 states that a sequential test will be applied all main town centres uses not located within an existing centre in line with the NPPF. Part b) repeats the sequential test but only for retail developments. Retail development is a main town centre uses and this duplication is unnecessary.

Part e) provides unnecessary additional commentary on the sequential approach which is not justified. Part e) is inconsistent with the NPPF. The NPPF does not require a type of retail goods to be located within sequentially preferable locations, but it asks whether the application proposals can be accommodated. Parts b) and e) should be deleted.

There is no justification for part f). This places an additional burden on developers which is not set out in the NPPF. The sequential and impact tests provide sufficient policy control to ensure out of centre retail developments do not detract from the viability of existing centres. Part f) is not necessary or consistent with the NPPF. On the basis of the above we would suggest the following wording for Policy E5 to ensure the policy is sound:

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ID Respondent Name Comment “A sequential test will be applied to planning applications for main town centre uses that are not in an existing centre. Town centre uses should be located in town centres, then edge of centre locations. Only when suitable sites are not available, will out-of-town centre sites be considered. In terms of edge and out-of-town centre proposals, preference will be given to accessible sites that are well connected to the town centre. Proposals outside defined town centres for non-food retail and food retailing, including extensions, will be granted provided that it can be demonstrated that all the following criteria have been considered: a. the proposal, if over a floorspace threshold (to be determined) is accompanied by a full retail impact assessment to demonstrate that it does not have a significant adverse impact on the vitality and viability of the defined town centres, either as an individual development or cumulatively with similar existing or proposed developments

g b. servicing and customer traffic can be safely and conveniently accommodated by the surrounding road network and does not add to traffic generation in the town centre hc. the proposal is easily accessible by the highway network and public transport and includes provision for access by cycle and on foot, and i.d the design of the buildings will not detract from the character or appearance of the site of the surrounding area.” Coal Pensions Properties Limited seeks clarity on the proposed wording to Policy E5 as set out above.

We trust that the above comments will be of assistance in the preparation of the VALP. Please do not hesitate to contact me or my colleague Peter Wilks if you require further information regarding these comments. We would be grateful if we could be kept informed of progress with the VALP and the next consultation stages. VALP16-09-13-01691 Roy van de Poll Policy E1 - It is very surprising indeed that there appears not to have been any effort to produce a figure for the net jobs growth for the Plan period. One would normally expect that a Local Plan would not only provide a target figure for the delivery of housing to 2033 but also a target for the new jobs to be generated to 2033 in what is designated as a ‘growth area.’ This was the case for the Vale of Aylesbury Plan, AVDLP etc. Surely a Local Plan must show that it is sustainable and a key element of that sustainability would be to show that its net employment growth should ideally reduce out-commuting from the Vale by 2033. Without a clear indication of a jobs growth target and therefore a seeming admission that AVDC did not wish to tackle this thorny issue, will this not invite criticism or worse from the Planning Inspector at the Examination? In a document of over 220 pages, does not a mere 5 pages devoted to Employment on employment sites speak volumes?! I noted with interest that in Paragraph 4.14, the first ‘key employment challenge for Aylesbury’ is to encourage economic growth to meet the forecast in jobs!! Obviously a recognition that such a forecast should be established and be an integral part of the Plan!

VALP16-09-13-01691 Roy van de Poll Policy E2 - Either in Policy E2 ‘Other employment sites’ or in a separate Policy, there needs to be a robust protection of land designated for employment use which, when developed, will significantly address a community’s lack of sustainability because currently there is a very significant under provision of employment on employment sites in that community. This is of particular importance for communities with Neighbourhood Plans which include Employment Policies. In the draft VALP, there does not appear to be clear recognition of this issue. If it is not addressed, one can envisage, with only Policy E2 to refer to, that there will be little to resist an application for example to utilise an employment site for a new supermarket and describing this as an alternative employment use.

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ID Respondent Name Comment VALP16-09-13-01691 Roy van de Poll Policy E5 - E5 needs to refer to the importance of the settlement boundary and Neighbourhood Plans in any decisions taken regarding employment land.

Essentially it seems that there is no plan for creating employment opportunities, especially with regards to meeting the needs of local communities. Linking new employment to new housing is too simplistic. There are neighbourhoods which are already underprovided and need redress. VALP16-09-13-01696 Mark Owen (Barton Policy E1 - We note that the Arla/Woodlands Enterprise Zone is considered a key employment site within the District and therefore, Willmore (on behalf of as indicated within Draft Policy E1 (protection of Key Employment Sites), should be protected. The Hampden Fields proposal Hampden Fields includes 9.45 hectares of employment land which we consider will assist the growth of employment related uses within this part of Consortium)) the District including the Arla/Woodlands Enterprise Zone. In particular the Hampden Fields proposal looks to provide small to medium sized premises for local businesses that are seeking modern space in Aylesbury. VALP16-09-13-01699 Alice Brighton (Planning Policy E5 - As part of the L.ncal Plan process, we understand that the Council is updating their Housing and Economic Land Potential) Availability Assessment that will identify the housing and employment land provision for the plan period. The site has previously been promoted in 2013 as part of a much wider (96. 72ha) site (ref: SHUNLV/014) which was considered poorly screened and peripheral to the services and facilities provided in the village. In 2014 the site in its current form (15ha) was promoted by two separate parties, Freehold Trustees (Reference SHLNLV019a) and Twidgen Homes (Reference SHLNLV019b), for residential development with the potential to accommodate between 150 - 300 residential units based on a minimum of 30 units per hectare. The HELAA does not provide a great deal of narrative with regard to an assessment of the site, however, the following is provided within the HELAA 'Call for Sites Summary Report' (2016), the full report for which is expected to be published at the end of 2016; "Whilst the site is adjacent the railway line to be reopened to passenger services on East West Rail, the site is not adjacent Newton Longville or any other settlement and is highly exposed to views from the northern and western approaches into the village. The site is not well screened or related to the village and the site would be around 1 .1 km to the village core". It is considered that this assessment of the site fails to adequately evaluate the potential for the site to address the substantial housing undersupply within Newton Longville and the villages in Aylesbury as a whole, although it is acknowledged that the full report will be published at the end of 2016 that may provide further detail. Notwithstanding this, the PPG confirms that land availability assessments are an important part of the Local Plan process and that an assessment of land availability should identify a future supply of land which is suitable, availalble and achievalble over the plan period. The following paragraphs demonstrate how 'land between Manor Farm and railway line' meets these three criteria.

VALP16-09-13-01703 Merilyn Munson Policy E2 - We are supportive of this policy and the Brill Society are currently in the process of producing an assessment of architectural features of importance within Brill in order to give greater guidance on local distinctiveness and vernacular character to future developers.

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ID Respondent Name Comment VALP16-09-13-01711 Michael Warren (South Policy E1 - Employment need is usually met by new allocations to satisfy the forecast requirement. However the forecast Northamptonshire requirement for AVDC is 22ha, whilst it has a supply of over 70ha (not including the Arla/Woodlands part of the new Enterprise Council) Zone). AVDC is therefore considering which employment sites it can reallocate to other uses including housing.

With reference to ‘a’, above, unless there is a definition of what might constitute ‘Other similar uses’, it may be difficult to exercise any proper control over types of use that would be permitted.

Silverstone - Silverstone is listed as a key employment site: ‘11. Silverstone Circuit - part of the Aylesbury Vale Enterprise Zone’. Collaborative working between AVDC and SNC (and the other parties) on this very important ‘high-tech’ employment site continues to progress positively. SNC looks forward to this successful collaboration continuing as development of the Circuit and its associated facilities, as well as the adjoining ‘high-tech’ employment land (Silverstone Park), progresses.

SNC is also very supportive of the positive collaboration between AVDC and SNC, and through SEMLEP, on the Cambridge-Oxford Growth Corridor proposals. VALP16-09-13-01721 Robert Ellis Policy E6 - we welcome the requirement that the window and entrance should “relate well to the design of the building and to the street-scene and its setting”, although we would welcome a reference to “historic significance, where appropriate” In this sentence, as part of the positive strategy for the conservation and enjoyment of, and the clear strategy for enhancing, the historic environment required by the NPPF.

Paragraph 6.23 – we welcome the reference to preserving the high quality environmental, historic and cultural assets of the district as part of the positive strategy for the conservation and enjoyment of, and the clear strategy for enhancing,

the historic environment required by the NPPF, although we would prefer “conserving” to “preserving” as terminology more consistent with the NPPF and as recognising that sensitive change can take place that maintains the historic environment or even enhances it.

VALP16-09-13-01770 E. A. Lock Policy E9 - The potential loss of grade 1 and 2 agricultural land is a significant consideration in particular with the recent Brexit vote we have no idea what the food demands for the UK will be in future years. I would also question the assumptions used for population increase as the government is looking at drastically reducing immigration over coming years. VALP16-09-13-01817 Simon Proctor (Proctor Policy E2 - This policy appears confused. Does it in fact relate to alternative uses (other than employment sites)? Surveyors (Newton Longville))

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ID Respondent Name Comment VALP16-09-14-01712 Roger Welchman Policy E2 - The VALP acknowledges that there is an existing oversupply of employment sites with a surplus of 51ha of B use class (Armstrong Rigg development.5 Furthermore it emphasises that in circumstances where it has not been possible to identify sufficient housing sites the Planning (on behalf of Council must reduce its employment land stock or else allocate a significantly larger amount of housing.6 Taylor Wimpey South Given the situation outlined above it is considered unnecessarily onerous to require sites to be marketed for a period of 12 months, Midlands)) which will serve to delay the release of surplus employment sites to alternative uses. It is recommended that part b. of the policy is omitted. Part c. of the policy should be amended as follows: c. there is an over-supply of suitable, available, alternative employment sites in the local area.

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ID Respondent Name Comment VALP16-07-11-00200 Lesley Dance Policy T1 - Vehicle parking, especially near the station is already a massive problem in the village. Commuters are pushing further and further into the village to avoid paying car parking fees making life difficult for locals, though higher levels of noise and pollution. More housing in Haddenham would only increase what is already a big problem. VALP16-07-12-00203 Harriet Sullivan Policy T2 - Cycle path from Haddenham & Thame Parkway to Thame along the A418 is long overdue. VALP16-07-13-00207 Margaret Caffrey Policy T2 - With respect to Buckingham: The plans should plan for cycle routes alongside every access road which form an overall network to ensure that children particularly can ride safely to school and that all can access the town centre and housing estates. At the moment the few cycle routes in Buckingham are piecemeal, petering out forcing cycles onto very busy roads. Cycle routes should particularly be planned for to give access to the town centre and schools from the villages Gawcott, Thornborough and Maids Moreton.

VALP16-07-14-00208 Bill Russell Policy T1 - The provision of parking space for cars has often been inadequate in housing developments, see Fairford Leys for example. The reality is that most families know have two cars and so there should either be on or off road parking for that number of cars. VALP16-08-02-00246 Karen Wedge Policy T1 - I believe that, outside town centres, all new dwellings should have at least two car parking spaces each. Even if there is only 1 bedroom that would often be 2 people of working age, and in Edlesborough, for example, there is insufficient public transport to rely on it to commute to and from work. For some strange reason, around the rush hour there are fewer buses than in the middle of the day. VALP16-08-05-00256 John Wilkinson Policy T1 - This policy states that the number of residential car parking spaces provided should be based on the number of habitable rooms in the dwelling. Habitable rooms are defined as bedrooms, kitchen, living room and dining room. As currently worded this leaves considerable scope for misinterpretation. With open plan layouts where a dining area is combined with the kitchen or living room (or both), how is the number counted? Similarly, where a room designated as a study could equally be used as a bedroom, does that count as a habitable room? Do family rooms, sitting rooms etc count as habitable rooms?

VALP16-08-06-00269 John Scott Policy T2 - An off-road cycle path between Haddenham and Thame would be an excellent by-product of development in this area.

VALP16-08-10-00284 Roz Owens Policy T2 - There is no specific policy to provide a cycle route from Haddenham to Thame. This surely is something that should be focussed on specifically given the growth proposed in Haddenham and the reliance that the village has on services provided by Thame and where developer contributions could help with funding. VALP16-08-11-00299 Andrew Cole Policy T2 - Commitment must be made to ensure any new cycle routes link with existing routes.

VALP16-08-12-00322 Edward Scullard Policy T1 - New developments need to factor in enough parking so that they are not made unsightly by one big car park

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ID Respondent Name Comment VALP16-08-16-00339 Robert John Policy T1 - 7.4 - The practical effect of treating a garage as if it is not a car space is to reduce the likelihood of garages being incorporated into schemes, especially at higher densities. For example, a preliminary scheme has been put forward for a terrace of 3 storey houses at The While Lion., Marsworth, a low lying site where the additional floor is not intrusive and allows more habitable rooms. If the developer is forced to add an additional external car space it will be at the expense of a planted area and may result in the scheme being redesigned on 2 levels to minimise cost, to the considerable detriment of the true usable space in each small house. The emergence of electric vehicles will make the use of garages for cars rather than just storage more likely in the future.

VALP16-08-17-00359 Angela Lucas Policy T1 - I totally agree that rear parking courts should be discouraged. A recent large development in AV shows they are not used and people park on the road near to the front door. 7.4 - agree that most residents use garages for storage c) agree that garages/carports should not be included. Many garages are turned into extra living space with no extra parking provision. VALP16-08-17-00359 Angela Lucas Policy T2 - Agree with the green infrastructure planned

VALP16-08-17-00361 Ella Jones (Wendover Policy T1 - 7.1: Car parking is one of the largest problems Wendover faces at present and there are safety concerns in relation to Parish Council) this after accidents have occurred frequently on Tring Road as a result of the on street parking from Bank Farm to Honeybanks. As much of the on street parking in residential areas surrounds the school there are also concerns for children walking to school and vision of them around parked cars. 7.2: As more young people struggle to afford housing they are choosing to remain living with parents for longer which results in high numbers of cars per household and increased demand for more car parking spaces per household. Wendover is an expensive area and sees many families in this situation. VALP16-08-17-00362 Stephanie Lucas Policy T1 - p.144 7.4 - Berryfields parking is a nightmare Agree that garages and car ports should not be included Off road parking close to front doors is needed VALP16-08-18-00363 Charlotte Newman Policy T1 - Parking is always a key issue. Houses and flat's should definitely have off road parking. 7.4 I agree in not counting garages, hardly anyone uses them for parking cars. In my village they are either used for storage or changed into accomodation. VALP16-08-19-00367 John Lucas Policy T1 - 7.3 Definitely agree - rear parking is not used 7.4 off road parking in the front of properties is used - garages and car ports are not. In Quainton if the driveway only allows tandem parking, the second car sometimes parks on the road. VALP16-08-20-00400 jim woolgar Policy T2 - the village does not have cycle routes

VALP16-08-20-00402 Martin Armitstead Policy T1 - There is insufficient parking in the village

VALP16-08-20-00402 Martin Armitstead Policy T2 - Even now footpaths are inadequately maintained

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ID Respondent Name Comment VALP16-08-20-00402 Martin Armitstead Policy T3 - There is none

VALP16-08-21-00406 Richard Barrie Policy T1 - Haddenham is already plagued by on-street parking by commuters avoiding paying for parking at Haddenham and Thame Parkway station. This has become a major problem. The VALP wants a further 7500 households to be built in the area served by Haddenham and Thame Parkway which is going to mean several thousand more cars being parked on our roads during the day. VALP16-08-21-00412 Tracy Filler Policy T2 - WHA001 is set on a national speed limit road with blind bends and concealed entrances. There are no footpaths into or out of the village on this road and limited public transport in the village. There is no capacity to build footpaths. VALP16-08-22-00416 John Currell Policy T1 - I cannot find anything in the Plan document which relates to PUBLIC OFF-STREET PARKING PROVISION. This seems to be a major omission.

I am particularly concerned with Wendover. It is publicly acknowledged that Wendover is short of off-street parking. This has become particularly acute since the completion of the Princess Mary Hospital Development. It is referred to in the Stage1C: HELAA Site Assessment for RSA-2.

Additional development in Wendover should not be considered or approved until the local shortage of off-street parking is overcome.

VALP16-08-22-00416 John Currell Policy T2 - There is no point is providing additional cycle routes until BCC, as highway authority, is in a sufficiently robust financial position to adequately maintain them. Historically, cycle routes tend to be built to inadequate construction standards and maintained inadequately. Part of the A413 cycle track between Wendover and Aylesbury is unpleasant to use because of lack of maintenance.

VALP16-08-22-00417 Diane Phillips Policy T2 - Additionally the increased traffic makes it unsafe for cyclists and pedestrians alike so these facilities needs to be improved. VALP16-08-22-00437 Aidan Byles Policy T2 - AVDC has already shown what this entails. Wasted money and a bit of paint. No consultation with actual cyclists. No routes where really needed! More housing means more cars. More dangerous for cyclists. A lack of police on the roads also means things can only get worse. VALP16-08-23-00441 Alexander Matthews Policy T2 - Pleased to see reference to creating a "cycle network" across the region. Much more work needs to be done here. Two (Thornton Parish challenges: creating a safe route from Milton Keynes to Buckingham, and addressing the impossibility of cycling on our A roads. Meeting) VALP16-08-23-00446 Arthur Evans Policy T1 - Number of parking spaces, each of which should be wide enough for a modern car, should at least match the number of bedrooms, with no 'piggy back' parking. VALP16-08-23-00446 Arthur Evans Policy T2 - Continue with present policy in town and expand rural routes wherever possible.

VALP16-08-23-00447 Alan Tipple Policy T1 - no reference to additional commuter traffic generated by additional housing. Cheddington has few bus routes and expensive station car park at its unmanned station. Most new members of our community work and travel to London or MK - Station Road is already reduced to a single lane. Many commute to Tring - if the train service was improved and affordable parking provided we would all win.

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ID Respondent Name Comment VALP16-08-24-00454 James Styles Policy T1 - Off road parking for residential and employment areas is very important; must be adequate.

VALP16-08-25-00528 Fiona Lippman Policy T1 - support. Very pleased to see included in this policy that garages will no longer count as off-street parking places. (Buckland Parish Council) VALP16-08-28-00547 Bob LEWIS Policy T1 - Vehicle parking is already a nightmare in Wendover. Where are the extra vehicles to park, when we already have an acute shortage? VALP16-08-28-00548 Nicola Page Policy T1 - The parking review needs to happen as part of this plan. Not later. It is insane in a town which is so congested and difficult to park in to plan new housing over parking space Before new parking is brought in. We must have some idea Prior to plan submission and if possible Written In! VALP16-08-31-00568 Graham Tyack Policy T1 - HVS Comment – paras 7.1 – 7.5: Extant parking issues due to Chiltern Railway area Parkway facilities are not (Haddenham Village addressed. Society) VALP16-08-31-00568 Graham Tyack Policy T2 - HVS Comment – paras 7.6 – 7.7: It is difficult to envisage the implementation of improved footpaths and safe cycle (Haddenham Village routes if the proposed new settlement is created with its undoubted implication for heavy traffic through the centre of the village, with Society) its extensive conservation area. VALP16-08-31-00576 Mary and Allan Policy T1 - We in cheddington with new developments within the high street area and off the high street are already experiencing glendinning difficulties moving along the high street in particular. also our bus service to leighton has just been reduced meaning more people need to have cars and/or use cars VALP16-08-31-00581 Fiona Lippmann (Halton Policy T1 - Very pleased to see this included and that garages will no longer count as off street parking places. Parish Council) VALP16-08-31-00584 Bruce Gardner (Cherwell Policy T1 - Cherwell Gospel Hall Trust welcome the first two paragraphs of the Policy. Gospel Hall Trust) However, the proposed car parking standards for Use Class D1 (g & h) Places of Worship/public assembly buildings appear to be based on Buckinghamshire CC guidance for Zone 1 (more accessible) locations. The 2014 Bucks CC guidance also includes Zone 2 (less accessible) at 1 space per 25 sq m. Zoning is included in the Bucks CC document at Appendix 3. For Aylesbury Vale the entire district is Zone 2 with the exception of the Aylesbury urban area. The VALP standards fail to reflect the Bucks CC document. Nonetheless, the trust considers that neither the Zone 1 or Zone 2 standard for Use Class D1 is appropriate or reasonable. It fails to meet the criteria of NPPF paragraph 39. In particular, irrespective of the location of such site(s), the normal times of use are outside the hours of availability for public transport, such that higher use of private motor cars is inevitable. The Council is requested to review the proposed standard. Attention is drawn to Wiltshire Council Parking Standards http://wiltshire.gov.uk/ltp3-car-parking- strategy.pdf. Where Appendix C – Maximum Parking Standards indicates – D1 Non Residential Institutions : Places of Worship, Church Halls, Public Halls : 1 per 5m². Cherwell Gospel Hall Trust consider that this standard for Class D1 : Places of Worship/public assembly buildings is more appropriate and reflects the advice of NPPF paragraph 39.

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ID Respondent Name Comment VALP16-08-31-00607 Eleanor Dolley Policy T1 - This chapter focuses on parking - but the knock-on effect of so many additional cars on the road, in and around Milton Keynes / Whaddon / Bletchley / Newton Longville is of primary concern to existing residents. As stated in a previous section - it currently takes a minimum of 30 minutes to travel 3 miles by car, between 8am-9am, Monday-Friday, from Oxley Park / Kingsmead area to CMK Train Station - the additional strain on the roads (of a further 4000 households) is just not feasible, particularly as CMK will be the nearest train station for the residents of this new development (on sites adjacent to MK), for the foreseeable future.

VALP16-08-31-00609 Stephen Turner Policy T2 - No safe footpath from Dadbrook in Cuddington to A418, in order to access bus service to Aylesbury, Thame or Oxford, and road to Haddenham VALP16-08-31-00610 Judith Warner Policy T1 - Paras 7.1 - 7.5: There are already serious parking issues in Haddenham due to Chiltern Railways which are not being addressed. VALP16-08-31-00610 Judith Warner Policy T2 - Paras 7.6 - 7.7: The provision of footpaths and cycle routes in Haddenham is already unsatisfactory, and potentially unsafe. It is difficult to see how this is going to improve with the proposed new settlement with the huge implications for heavy traffic through the centre of the village. VALP16-09-01-00618 Jonathan Proctor Policy T1 - It seems questionable that the existing infrastructure (in particular, rail, transport links and parking) can cope with (Stephenson Harwood) development on this scale. VALP16-09-01-00637 Viv Lynch (Wingrave Policy T1 - 7.2 Rural communities face challenges to access employment using public transport therefore require more parking with Rowsham Parish spaces than the numbers indicated in Policy T1 Council) VALP16-09-02-00641 Christopher Matthews Policy T1 - Paragraphs 7.1 to 7.5 - These sections only consider parking issues relating to new houses being built. They take no account of current parking issues, particularly in communities with a railway station. Haddenham, like Stoke Mandeville for example, has a major parking issue arising from the presence of the railway station and the high price of car parking there. This issue is causing a lot of anger with residents close to the station. The large expansion of the whole area, including South Oxfordshire, will draw more and more people to use the station so it is essential that this important parking issue is taken into account. It is also essential that new developments in Haddenham must provide walking and cycle paths to the station which are overlooked by natural surveillance and provide a pleasant environment to encourage reduced car use.

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ID Respondent Name Comment VALP16-09-02-00641 Christopher Matthews Policy T2 - Paragraphs 7.6 & 7.7 - AVDC should be far more pro-active and actually deliver a strategic cycle network and improvements to footpaths. Too much emphasis has been put on Aylesbury Town cycle network and not enough on providing good cycle routes to villages. There are good opportunities to link Haddenham with both Thame and Aylesbury through good quality cycle routes for which feasibility studies have already been drawn up. It is important that AVDC supports both of these proposed cycle routes and ensures that funds are made available through developer money etc. AVDC should work closely with SODC, Haddenham Parish Council, Thame Town Council and other local groups, particularly Sustrans and Haddenham Safe Walking and Cycling Group, to push forward these schemes.

VALP does not take into account the adverse effects on pedestrians of increased traffic on local roads. The scale of housing development proposed for Haddenham and for the surrounding area will lead to a massive increase in traffic when the current level already adversely impacts local families. This leads to families, particularly those with younger children, choosing to travel by car rather than walk locally. Radical solutions need to be adopted to make walking a more pleasant experience for people while discouraging through traffic. 20 mph should be introduced throughout Haddenham and more pedestrian crossings provided on the main roads. All new developments must be designed with the needs of pedestrians and cyclists at the forefront.

VALP16-09-02-00643 Angela Matthews Policy T1 - Paragraphs 7.1 to 7.5 - These sections only consider parking issues relating to new houses being built. They take no account of current parking issues, particularly in communities with a railway station. Haddenham, like Stoke Mandeville for example, has a major parking issue arising from the presence of the railway station and the high price of car parking there. This issue is causing a lot of anger with residents close to the station. The large expansion of the whole area, including South Oxfordshire, will draw more and more people to use the station so it is essential that this important parking issue is taken into account. It is also essential that new developments in Haddenham must provide walking and cycle paths to the station which are overlooked by natural surveillance and provide a pleasant environment to encourage reduced car use.

VALP16-09-02-00643 Angela Matthews Policy T2 - Paragraphs 7.6 & 7.7 - AVDC should be far more pro-active and actually deliver a strategic cycle network and improvements to footpaths. Too much emphasis has been put on Aylesbury Town cycle network and not enough on providing good cycle routes to villages. There are good opportunities to link Haddenham with both Thame and Aylesbury through good quality cycle routes for which feasibility studies have already been drawn up. It is important that AVDC supports both of these proposed cycle routes and ensures that funds are made available through developer money etc. AVDC should work closely with SODC, Haddenham Parish Council, Thame Town Council and other local groups, particularly Sustrans and Haddenham Safe Walking and Cycling Group, to push forward these schemes.

VALP does not take into account the adverse effects on pedestrians of increased traffic on local roads. The scale of housing development proposed for Haddenham and for the surrounding area will lead to a massive increase in traffic when the current level already adversely impacts local families. This leads to families, particularly those with younger children, choosing to travel by car rather than walk locally. Radical solutions need to be adopted to make walking a more pleasant experience for people while discouraging through traffic. 20 mph should be introduced throughout Haddenham and more pedestrian crossings provided on the main roads. All new developments must be designed with the needs of pedestrians and cyclists at the forefront.

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ID Respondent Name Comment VALP16-09-02-00653 Quainton Parish Council Policy T1 - 7.4 - Strategic comments Parking is the number one complaint from residents in both towns and villages. The VALP is a chance to get this right. There should be two off road, close to the front door, parking spaces for smaller properties and at least three for 3 + bedroom properties. There should also be space for visitor car parking. In villages it is not unusual to see a property with four cars with many left on roads, creating road hazards for residents and drivers alike. Berryfields parking is a nightmare, the mistakes made here with regard to parking, should be learnt. Agree that garages and car ports should not be included Off road parking close to front doors is needed. Cars are bigger but garages have stayed the same size. Very few people put their cars in a garage but instead use them for storage. VALP16-09-02-00653 Quainton Parish Council Policy T2 - The PC agree with this policy

VALP16-09-02-00653 Quainton Parish Council Policy T3 - The PC agree with this policy

VALP16-09-01-00615 Peter Smettem T1/T2/T3 - Transport policies should reflect the Bucks CC freight strategy (Ashendon Parish Council) VALP16-09-02-00655 Frances Durkin Policy T1 - As mentioned in my comments on Chapter Four, the on-street parking on the High Street and Mentor Road in Cheddington is frequently so busy as to reduce these roads to a single lane. Can you address the issue of reducing the strain on these main roads through the village? VALP16-09-02-00666 Kate Curry (Aston Policy T2 - a) support this statement. Organisations such as Sustrans should not be allowed to block new cycleways on a Abbotts Parish Council) technicality where a need is proven (eg the cycleway from Wingrave Crossroads to Bierton on the A418)

VALP16-09-02-00671 David Child Policy T1 - Habitable rooms do not correlate with the number of vehicle spaces required as demonstrated on any new housing estate which is littered with parked cars on the roads. All the spaces should be provided on each dwelling and the number increased substantially. Roads are not parking lots! VALP16-09-02-00675 Mr and Mrs Hudson Policy T2 - All footpaths should not be taken over by developments. They should be left open for people to enjoy.

VALP16-09-02-00677 Steven Mitchell Policy T1 - Support.

VALP16-09-02-00677 Steven Mitchell Policy T2 - Support.

VALP16-09-02-00677 Steven Mitchell Policy T3 - Support.

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ID Respondent Name Comment VALP16-09-03-00679 Samita Kirve (Bucks Policy T1 - Parking on the roads near Stoke Mandeville hospital. Recently the council developed a solution of restricting the parking NHS Trust) on one side of the road with yellow lines. But the staff at SM hospital continue to park on the other side and fill up the roads. As an employee of SM hospital, I can confirm that the hospital has indeed provided affordable parking for staff. So we should restrict parking on both sides by having 'resident only' parking bays. However in doing so, please do not penalise the local residents by asking them to pay for resident parking permits! That would be simply unjust! The parking permits for residents should be provided free.

VALP16-09-03-00704 Yasmin Bevan Policy T1 - Para 7.1 The level of additional housing proposed for Edlesborough and the associated growth in vehicular traffic will have a very detrimental impact on the quality of the environment . The existing infrastructure is already overstretched with routes into and out of the village being very hazardous at peak times. VALP16-09-03-00715 Roderick floud Policy T2 - Paras 7.6-7.7 The plan fails to recognise the need for much enhanced cycle and pedestrian routes in rural and semi-rural areas, including routes to and from major urban centres such as Aylesbury. There is an urgent need to provide safe routes, away from fast vehicles, on or alongside narrow country roads; two examples are safe routes required between Aylesbury and Haddenham and Haddenham and Thame. Both are required for commuting and leisure use. Other cycle provision should include routes between rural settlements, where roads are likely to be even narrower and more dangerous; there is a need, for example, for a safe cycle path between Haddenham and Thame Parkway and Chearsley, which could also serve Long Crendon and Cuddington.

VALP16-09-03-00720 Ruth Scott (Scott Travel Policy T2 - There is virtually nothing on how the VALP intends to deal with the major issue of transport infrastructure throughout the Ltd) district, and in particular the northern part? It appears expected to take the major part (40% plus) of the planned 33,000 homes – with no mention of employment in addition. What transport improvements are needed? Where will they go? How will they be financed? What about public transport? How does the plan intend to deal with the ever-increasing and unwelcome HGV traffic that in many ‘rat- run’ instances is ruining the district's rural road system and causing a huge drain on limited resources? These and many other traffic and transport related items should be covered in a plan of this importance, but sadly there is no mention of how these serious issues will be tackled. I understand that Bucks CC appear to have raised ‘no objections’ to the level of growth being proposed, and accordingly AVDC must assume that the existing infrastructure will be sufficient, which is far from the case! There appears to be a disconnected approach to planning infrastructure.

VALP16-09-03-00726 Richard Dorrance Policy T1 - In Edlesborough, there is insufficient parking places at the Surgery, at the School, at the Tithe Barn (a new employer) and outside the shops. It would be very expensive to provide sufficient places as the land is not available. The principles/standards are excellent but they haven't been applied in planning decisions within the last year and so the problems as regards parking will be severe by the time the plan is adopted. VALP16-09-03-00726 Richard Dorrance Policy T2 - I support everything in the Plan about cycle routes. However my experience of trying to establish safe cycle routes in the villages has met with resistance at County Council level, partly because of the lack of funding available, and partly because the planners don't seem to count cycleways as a priority. VALP16-09-04-00740 John Gavan Policy T2 - Increased populations require very much improved cycle and pedestrian routes. Adjoining Milton Keynes where there is a good infrastructure of cycle routes shows what can be done. However as you get to the A421 this facility declines just as the roads get more congested.

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ID Respondent Name Comment VALP16-09-04-00742 Carolyn Cumming Policy T2 - Paragraphs 7.6-7.7 . I urge the VALP to give bridleways the same prominence as footpaths and cycle routes. At present, there is only scant reference to them in paragraph 7.7. Developments have encroached on the existing (poor) network of bridleways and our roads, even the minor routes, have become too dangerous to allow safe riding. This is not only a loss of amenity for residents but a serious omission when trying to attract tourism. Safe bridleways have become rare. Developments should contribute to both re-instatement of bridleways and find ways to interconnect them with routes cross country that will promote tourism across the region. Although there is more detailed guidelines in C4, bridleways should be given equal footing in this section.

VALP16-09-04-00750 Colin Read (Aston Policy T1 - We totally agree that garages should not be included as parking spaces. The new developments within our village are Clinton parish planning) not conforming to your proposed parking space requirements and as a result the density of the housing is very high and results in a very crammed in appearance. VALP16-09-04-00750 Colin Read (Aston Policy T2 - Obviously expansion needed here but new developments are not providing exclusive cycling paths which they should Clinton parish planning) do. VALP16-09-04-00750 Colin Read (Aston Policy T3 - Not sure this is a great idea as hydrogen cars are the future. Beware of spending large sums of money on this. Clinton parish planning) VALP16-09-04-00751 Anthony Winterbottom Policy T2 - parking dominant . Quite wrong. Issue is that traffic flows do not work around and in Aylesbury . Is that solved by building more ? VALP16-09-04-00753 Alan Branch Policy T1 - In my opinion the number of parking space allocated to a dwelling should match the number of bedrooms, with the first bedroom being allocated 2 parking spaces and each other bedroom a single parking space. So for a three bedroom property four parking spaces would be allocated. This would limit the amount of on street parking and "on pavement" parking that is occurring.

VALP16-09-04-00780 Linda Fisher Policy T1 - The cost of parking at haddenham & Thame is outrageous when you take into account the cost of season tickets. Already the roads are blocked with parked cars and now the road pas the station is also being blocked. I walk to the station because I won't pay and I don't think it's fair for local residents to have to put up with commuter parking. Any increase in population will exacerbate this situation. I see no concrete or even proposed plans to resolve this situation. You cannot produce a half baked plan - infrastructure is actually more important than the number of homes per se VALP16-09-04-00780 Linda Fisher Policy T2 - These need to be Improved - well lit paths are needed

VALP16-09-04-00783 Morgan Holt Policy T1 - The roads and railways are already full and expansion could not be sustained by the area. Tailbacks are already an everyday occurrence, and the roads could not support a four-fold increase in traffic. And the railway station has already been expanded, with trains frequently offering ‘standing room only’, and it could not comfortably support such a dramatic increase in commuters. VALP16-09-04-00784 Paul Tattam Policy T1 - Town centre already struggles with parking, that will get worse with these plans. D1f states secondary schools must have one car parking space for each FTE of staff, so all the 6th form staff who drive park on local roads, causing bottlenecks and increasing the chance of personal injury accidents. VALP16-09-04-00788 David Dinsdale Policy T1 - There is currently not enough parking in local villages for shopping, school drop offs and visiting doctors. 7,000 new houses will cause significant extra issues with parking and transport.

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ID Respondent Name Comment VALP16-09-04-00792 John Griffiths Policy T1 - 7.1-7.4 - ensuring new properties have enough parking is paramount as well as enforcement of penalties for illegal parking. VALP16-09-05-00815 Jan Molyneux (Molyneux Policy T2 - The policy should be more positive in seeking improvements to existing and provision of new cycle route. Planning) The Council should promote the provision of cycle routes along strategic routes, for example the A41. Provision of a cycle route is essential, not only to enable journeys between Bicester and Aylesbury, but also to enable safe short journeys along the route, where crossing the A41 requires use of a mile or two of the main road. VALP16-09-05-00818 Sara Jones (Delta Policy T1 - Whilst it is helpful to provide advice on parking standards it is considered that this policy should be applied flexibly and is Planning on behalf of not a rigid requirement on all developments. The text should recognise that this policy is for guidance only and that a flexible The University of approach will be adopted in applying these standards. Buckingham) VALP16-09-05-00827 Jenny Armitstead Policy T1 - We have no vehicle parking provision.There is chaos at school drop off and pick up times as 75% of children at Ickford Combined School live outside the village.This is not an exclusive village school but serves a wide community and is not able to take any more pupils.All figures can be verified. VALP16-09-05-00827 Jenny Armitstead Policy T2 - There are no cycle paths and footpaths very badly maintained

VALP16-09-05-00827 Jenny Armitstead Policy T3 - We have none

VALP16-09-05-00830 Manlet Group Holdings Policy T1 - 7.2 - Manlet Group objects to draft Policy T1 where it states that “garages / integral garages / car ports will not be included within the allocation of parking spaces”. The provision of garages within a residential development is an important part of the scheme’s car parking strategy and whilst it is accepted that not all residents will use the garage / car port spaces for vehicle parking, to omit this from the calculation is unnecessarily restrictive and inappropriate. As such, Criteria c of draft Policy T1 should be deleted. VALP16-09-05-00833 Tim Smee Policy T1 - Inadequate availability of parking in the village. Conflicts with dangerous junction (Windmill Street and Temple Street). Brill is a popular destination for cycles using narrow roads.

VALP16-09-05-00841 Sara Jones (Delta Policy T1 - Whilst it is helpful to provide advice on parking standards it is considered that this policy should be applied flexibly and is Planning on behalf of not a rigid requirement on all developments. The text should recognise that that this policy is for guidance only and that a flexible Crevichon Properties approach will be applied in adopting these standards. Ltd)

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ID Respondent Name Comment VALP16-09-05-00853 Suzanne Lindsey Policy T1, T2 and T3 - Our views on transport are similar to that above expressed in the Economy-Employment section. Far too (Whaddon Parish much text is given over to car and cycle parking (with just two small sections on Footpaths and Cycle routes and Electric vehicle Council) infrastructure) all of which is important, but there is precious little – and indeed virtually nothing on how the VALP intends to deal with the major issue of transport infrastructure throughout the district, and in particular the northern part of the district, which as currently stands is expected to take the major part (45% plus) of the planned for 33000 homes – with little mention of how employment requirements will feature or be built in. What transport improvements are needed to sustain this huge amount of development in the north of the district? Where will the connections/improvements go? How will they be financed? What about public transport? How does the plan intend to deal with the ever increasing and unwelcome HGV traffic that in many ‘rat-run’ locations is contributing to the damage to highway infrastructure (roads, footpaths, verges, drainage grips etc) which is causing a huge drain on already limited County repair funding resources?

These and many other traffic and transport related items should be covered in a plan of this importance, but sadly there is no mention of how these serious issues will be tackled. WPC are very concerned that at the earlier Issues and Options consultation stage Bucks CC appear to have raised ‘no objections’ to the level of growth being proposed, and accordingly AVDC as the planning authority must (and probably wrongly) assume that the existing infrastructure will be sufficient. WPC is very concerned that there appears to be a disconnected approach to planning and infrastructure.

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ID Respondent Name Comment VALP16-09-05-00863 David Peck Policy T1 - 1.The overall plan seems to be a drastic solution and a more thoroughly thought through solution appears to be needed. 2.The proposal seems to be to convert Haddenham from a village into a small town. Which will have very negative impacts on a number of areas, if not properly planned from square one in the proposed development, including: a.Transport, many new roads would be needed and access and parking at the station could become intolerable. The current village roads are not capable of taking any real increase in traffic. b.Doctors’ surgery is currently unable to handle for the 4500ish residents and will be unlikely to handle many additional thousands without significant enhancements. c.The schools are currently almost at capacity and new schools would be needed, including a local secondary school rather than making many more journeys to Waddesdon, Aylesbury and Thame. d.With the other planned developments in South Oxfordshire, especially near to Thame, the services in Thame would be overwhelmed. e.By basing the developments in and around Haddenham that will consume significant quantities of high-grade agricultural land. f.There is a great need in Haddenham for a high quality retirement home area and in any plan to develop Haddenham this is an essential item. 3.The proposal to develop near Haddenham does not appear to take due account of the other available brownfield sites in Buckinghamshire, especially those at Wescott and Winslow’s nearby old airfield. In the not too distant future Winslow will be connected to the new railway line between Oxford and Cambridge making the Winslow area are very attractive transport hub. 4.Further it does not take account of the possibility of generating a completely new town on the railway line between Haddenham and Bicester. 5.The north of the county is wanting development and new homes, whilst this plan seems to further increase the congestion in the southern part of Buckinghamshire. 6.Haddenham is already accepting many hundreds of extra houses within its general boundaries and hence assisting the AVDC to meet its housing objectives. Hence consideration should be given to additional housing in the AVDC area going elsewhere. 7.There is great concern that AVDC is taking on housing requirements from the surrounding district councils, especially Wycombe. Also it is understood that the density of housing proposed for the Wycombe area is far lower than that proposed new developments around Haddenham. This seems totally unreasonable and further detailed assessment of Wycombe’s plans are needed before AVDC except more houses from other authorities. 8.Further, little consideration seems to have been made for the local employment of the new residents, hence exacerbating the transport system by adding to the commuter pool.

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ID Respondent Name Comment VALP16-09-05-00867 Susan Peck Policy T1 - 1.The overall plan seems to be a drastic solution and a more thoroughly thought through solution appears to be needed. 2.The proposal seems to be to convert Haddenham from a village into a small town. Which will have very negative impacts on a number of areas, if not properly planned from square one in the proposed development, including: a.Transport, many new roads would be needed and access and parking at the station could become intolerable. The current village roads are not capable of taking any real increase in traffic. b.Doctors’ surgery is currently unable to handle for the 4500ish residents and will be unlikely to handle many additional thousands without significant enhancements. c.The schools are currently almost at capacity and new schools would be needed, including a local secondary school rather than making many more journeys to Waddesdon, Aylesbury and Thame. d.With the other planned developments in South Oxfordshire, especially near to Thame, the services in Thame would be overwhelmed. e.By basing the developments in and around Haddenham that will consume significant quantities of high-grade agricultural land. f.There is a great need in Haddenham for a high quality retirement home area and in any plan to develop Haddenham this is an essential item. 3.The proposal to develop near Haddenham does not appear to take due account of the other available brownfield sites in Buckinghamshire, especially those at Wescott and Winslow’s nearby old airfield. In the not too distant future Winslow will be connected to the new railway line between Oxford and Cambridge making the Winslow area are very attractive transport hub. 4.Further it does not take account of the possibility of generating a completely new town on the railway line between Haddenham and Bicester. 5.The north of the county is wanting development and new homes, whilst this plan seems to further increase the congestion in the southern part of Buckinghamshire. 6.Haddenham is already accepting many hundreds of extra houses within its general boundaries and hence assisting the AVDC to meet its housing objectives. Hence consideration should be given to additional housing in the AVDC area going elsewhere. 7.There is great concern that AVDC is taking on housing requirements from the surrounding district councils, especially Wycombe. Also it is understood that the density of housing proposed for the Wycombe area is far lower than that proposed new developments around Haddenham. This seems totally unreasonable and further detailed assessment of Wycombe’s plans are needed before AVDC except more houses from other authorities. 8.Further, little consideration seems to have been made for the local employment of the new residents, hence exacerbating the transport system by adding to the commuter pool.

VALP16-09-05-00871 Mary Hunt (Aylesbury Policy T1 - We recognise that parking is one of the most intractable problems for councils. Vale Green Party) We would like to see the council reward people for good behaviour, e.g. more car-share spaces, lower charges for multi-occupancy vehicles. AVDC could find some way of rewarding people for using garages again and those who have gardens and drives that are permeable. We recommend that the Council adopt a scheme for the surfaces of all new parking areas to be permeable, especially in those areas most likely to flood.

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ID Respondent Name Comment VALP16-09-05-00871 Mary Hunt (Aylesbury Policy T2 - Most of our comments are included in the section on Green Infrastructure. Vale Green Party) We wish to see a greater priority given to footpaths and cycle paths. If these are kept in good condition and provided early on in new developments they can help to influence people's transport habits, to the benefit of road users as well. VALP16-09-05-00871 Mary Hunt (Aylesbury Policy T3 - The electric vehicle strategy is to be welcomed. We recommend that a policy should be in place to ensure that electric Vale Green Party) vehicles and bicycles are given priority at any council site.

We note that there is almost no mention of buses in this plan. They are an essential element that has been largely overlooked. We urge the Council to ensure that buses and, in particular, an integrated transport system are included in the next version of the plan. We would like a move to electric/dual-fuel buses to cut down on air pollution. Ideally we would like the County Council to run the bus service. VALP16-09-05-00874 Philip Morley Policy T1 - Paragraph 7.2 - Car parking is clearly an issue everywhere. Many households have two cars, and provision should be made for this. Compare with the existing new development in Wendover (Wood Lane, Babington Road etc.). The parking provision in this area is inadequate, and the roads are often too narrow to facilitate on-street parking. VALP16-09-05-00897 tim dorsett Policy T1 - Should be enough off road parking. One bedroom houses two parking spaces two bedroom three etc

VALP16-09-05-00897 tim dorsett Policy T2 - Should be incorporated with every development to minimise car usage and encourage a more active lifestyle

VALP16-09-05-00897 tim dorsett Policy T3 - Electricity is expensive and still dirty to produce.

VALP16-09-05-00904 Christopher Wayman Policy T1 - Nothing to conflict with BNDP (the parking etc. space standards quoted are optimum, and will only be achievable on (Buckingham Town new developments). But the draft Policy makes no mention of improving existing car park provision, particularly in town centres, Council) anywhere in the Vale - unlike BNDP Policy EE5. Given that Aylesbury is being considerably redeveloped and expanded, it may be safe to assume that adequate car parking will be allocated in the process. The draft Policy might usefully be expanded (para 7.1 to 7.5 and the draft Policy itself) to reflect the growing needs for increased car parking elsewhere in the Vale. It might also incorporate mention of disabled parking, as per BNDP Policy EE5. VALP16-09-05-00904 Christopher Wayman Policy T2 - T2 p150 - Nothing to conflict with BNDP, but could be strengthened to include provision of adequate access for the less (Buckingham Town able (as per BNDP Policy I1). Council) VALP16-09-05-00904 Christopher Wayman Policy T3 - T3 p151 - Applicable to new developments only (i.e. no suggestion of retrospective provision to existing car parks), this (Buckingham Town is broadly in accordance with BNDP Policy EE5. Council)

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ID Respondent Name Comment VALP16-09-05-00928 Tim Northey (Rectory Policy T1 - Object to the inclusion within the policy of the specific exclusion of garaging within the allocation of parking, with the Homes Limited) Council's basis being that often residents use them for domestic storage rather than vehicle storage. Whilst there maybe instances where this occurs, this is often due to developers building them to substandard dimensions meaning that they are not entirely practical for the storage of cars. This blanket approach would render an important design solution as unattractive as garaging is often used to break up what would otherwise result in the creation of car dominated environments. Rather than introduce such a limitation into policy, the development management section of the Council should ensure that the dimension standards of garaging is sufficient to ensure practical use by cars and that their use is limited to car storage through the use of an appropriately worded planning condition. The proposed cycle parking standards provide no indication of acceptable means of providing the parking provision in accordance with the policy. This should be defined to provide certainty on the matter. A matter that also needs addressing is how this policy will be applied in areas where Neighbourhood Plan policies on parking exist, as it needs to state which standards will prevail to avoid confusion on the issue. VALP16-09-05-00959 Penny Pataky Policy T1 - This policy states that the number of residential car parking spaces provided should be based on the number of habitable (Edlesborough Parish rooms in the dwelling. Habitable rooms are defined as bedrooms, kitchen, living room and dining room. Council) As currently worded this leaves considerable scope for misinterpretation. With open plan layouts where a dining area is combined with the kitchen or living room (or both), how is the number counted? Similarly, where a room designated as a study could equally be used as a bedroom, does that count as a habitable room? Do family rooms, sitting rooms etc. count as habitable rooms?

VALP16-09-05-00966 Michelle Kidd (Area Policy T2 - The wording of this policy should refer to green/blue infrastructure and how the footpaths/cycleways can tie in to this Sustainable Places network. Team The Environment Agency) VALP16-09-05-00984 Phillippa Martin-Moran Policy T1 - Parking spaces should be based on numbers of bedrooms, not habitable rooms. Number of bedrooms reflects the (Optimis Estates) number of people living in a house who are likely to have visitors or cars themselves. VALP16-09-05-00986 Simon Maloney Policy T2 - I fully support the preservation of existing and the expansion and development of cycle networks. The provision of facilities which reduce dependence on cars, and increase physical activity can only be beneficial to both our health and our environment. VALP16-09-05-00988 Sue Barber Policy T1 - Adequate parking for all new houses to keep cars off the road and make them safer.

VALP16-09-05-00988 Sue Barber Policy T2 - better footpaths, especially in Halton are vital.

VALP16-09-05-00988 Sue Barber Policy T3 - T3 will electric vehicles really take off! Should the money go into better bus routes and out of town parking with park and ride to keep cars off the road in towns? VALP16-09-05-00992 Helen Hyre Policy T2 - Footpaths, bridleways and cycle routes should be well maintained so that local people and tourists feel safe to use them. Exercise is a good way to stay healthy. VALP16-09-05-00998 Charlotte Beadle Chapter 7 Transport - All paragraphs: I do not support this draft plan for 33000 new homes in Aylesbury Vale.

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ID Respondent Name Comment VALP16-09-05-01005 Andrew Phillips Policy T1 - This email is specifically centred around the expansion plans for Haddenham, either by this village growing or a "new town" on its outskirts. Haddenham is a historic settlement with no natural commercial centre. It is a small residential area with one key selling point = which is the railway station. We have two oversubscribed infant schools and one primary school. We are some distance from any secondary school with the nearest in a neighbouring county and no right to send our children there. We have no shops of note other than a corner shop and minor mini market (McColls). We have four pubs and minimal eateries. To expand this village would be a major failing of AVDC. We have poor village roads which are already overcrowded and often accident blackspot (Staybridge Rd jnt Woodways). The S.E part of the village floods yearly and parking around the railway station is already blocking the residential roads. Princes Risborogh is also adding housing as is Thame (In Oxfordshire). These in conjunction with Haddenhams already approved housing will put a strain on the existing infrastructure and no additional resources. From attending the open days and seeing your reports. Winslow is the only viable option.

VALP16-09-05-01008 John Mortimer Policy T1 - Quite clearly, IF the go-ahead is given for development of dwellings on WDA001, or indeed other such sites, provision has to be made FOR ADEQUATE OFF-ROAD parking. Vehicles parked on the road not only cause congestion but raise the likelihood of accidents (children running out) and even death. Apart from the trauma of loss of life there is the cost to the community. Added to which, congestion on streets makes the passage of emergency vehicles - police, ambulance and fire service appliances - very difficult, if not empossible.

VALP16-09-05-01008 John Mortimer Policy T2 - Again, IF the go-ahead is given for WDA001 and similar sites - but particulalrly WDA001 - provision MUST be made for cycle paths - redways - to link up with Milton Keynes' cycleway system and the national cycle network. There are cycleways in Tattenhoe Park and these should be linked to those implemented by AVDC under the DRAFT plan. The DRAFT plan appears to have closed its eyes to the detail of such an endeavour. In the development of an infrastructure for WDA001, plans MUST also be made to link up WDA001 with Whaddon by means of footpaths and cycleways. Residents of Whaddon are likely to want to use any amenities at WDA001, such as shops and medical facilities - if they are provided. PLEASE NOTE. At present there is neither footpath nor cycleway provision on the Shenley Road. As this will be a key artial road effectively linking WDA001 with Milton Keynes the road will have to be redeveloped. In the redevelopment of the road to carry the increased traffic footprint resulting from WDA001 and other close developments, provision MUST be made for footpath and cycleway. The DRAFT plan appears to take no account of this - again pointing to lack of detailed observation of what will be required to meet future needs of the community.

VALP16-09-05-01008 John Mortimer Policy T3 - As Milton Keynes has wedded itself firmly to the technology of electric vehicles, even to the point of setting itself ahead of other communities through the development of automated guided vehicles in the city centre, the AVDC will have to take cognicence of this. The closest electric charging point to the WDA001 proposed development is at Tattenhoe, adjacent to the V1. it is quite likely that residents in the proposed developments, especially those with close proximity to Milton Keynes where they are most likely to find work, will expect to be able to make use of electric vehicle charging points placed at strategic points.. So these should be provided.

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ID Respondent Name Comment VALP16-09-05-01028 Warren Whyte (AVDC) Policy T1 - New residential roads should be suitable sized to allow ad hoc visitor parking and delivery vehicles etc without causing undue hindrance to footpath users, cyclists and other road road users. Recent residential roads have caused bottle necks and problems for refuse and emergency vehicles. Ensuring car parking is conveniently located for householders (rather than remote parking courts) will also assist in reducing on-street parking. This is especially important for edge-of-town developments where car ownership has to be acknowledged and "modal shift" will not reduce car use significantly during this plan period

VALP16-09-05-01028 Warren Whyte (AVDC) Policy T2 - This policy should also require new developments to have key pedestrian and cycle routes through a development to be added to the definitive map VALP16-09-05-01028 Warren Whyte (AVDC) Policy T3 - Providing some on-street charging points for visitors should be considered in larger developments, and the potential to encourage a car-share zip car type scheme for major development areas. VALP16-09-05-01030 Derek Town Policy T1 - Para 7.1 Parking is a blight in many communities and is the source of much dis-harmony and safe life styles. Current planning rules appear to ignore these issues very often new developments do not accommodate the free and easy access of emergency vehicles or guarantee reasonable residential access. The numbers for off road parking in Panel T1 are les than those identified in the Cheddington NP, why ?. It is generally accepted that most rural households have more that one car to maintain their sustainable existence so any dwelling with 2 bedrooms needs at least 2 off road parking spaces. Para 7.4 - I welcome the sensible approach to garages as not being part of the off road parking allocation per residence. VALP16-09-05-01035 Patricia Owen Policy T1 - This policy states that the number of residential car parking spaces provided should be based on the number of habitable rooms in the dwelling. Habitable rooms are defined as bedrooms, kitchen, living room and dining room. This is very misleading and confusing. My house has 2 sitting rooms and 3 bedrooms plus a kitchen diner.. Do we have 6 habitable rooms then? This should be based on bedrooms not habitable rooms as it is so unclear.... VALP16-09-07-01153 Sylvie Eames Policy T1 - Policy T1 recognising that garages are rarely used for cars but that cars are an essential part of modern life is good. Parking requirements in rural areas evidently greater that in urgan areas VALP16-09-07-01153 Sylvie Eames Policy T2 - T2 footpaths and cycle routes is good.

VALP16-09-07-01153 Sylvie Eames Policy T3 - T3 Electric vehicle infrastructure - is not clear as to who is providing and paying for the privilege!

VALP16-09-07-01159 Mandy Cliffe (Great Policy T1 - 7.1.1 The first part of this policy is largely a restatement of paragraph 39 of the NPPF. Horwood Parish Council) 7.1.2 GHPC considers that the remainder of this policy, specifying parking standards, from the bottom of page 144 to page 149, is at an inappropriate level of detail for inclusion in the Local Plan, and suggests that it would be more appropriate for these standards to be included in a separate Supplementary Planning Guidance document. A reference should be made in the policy to this document, in a similar manner to the reference made in saved AVDLP Policy GP24 to the then current guidance document.

VALP16-09-07-01159 Mandy Cliffe (Great Policy T2 - 7.2 T2 Footpaths and cycle routes Horwood Parish Council) 7.2.1 This policy has the general support of bullet point 2 in paragraph 35 of the NPPF. 7.2.2 Item (b) in the list of criteria in this policy (for cycle routes) is copied verbatim from the lapsed AVDLP Policy GP27, and item (c) in the list (for pedestrian routes) is almost, but not quite, identical to the lapsed AVDLP Policy GP28.

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ID Respondent Name Comment VALP16-09-07-01159 Mandy Cliffe (Great Policy T3 - 7.3.1 - This policy has the general support of bullet point 4 in paragraph 35 of the NPPF. Horwood Parish Council) 7.3.2 - GHPC considers that item (c) in this policy should include a sentence along the following lines: Development proposals required to provide such charging points should outline a financial mechanism for purchasing the electricity required for operation but not available from renewable sources. VALP16-09-07-01160 Dave Norris Policy T1 - Recognising that garages are rarely used for cars but that cars are an essential part of modern life is good. Parking requirements in rural areas evidently greater that in urgan areas VALP16-09-07-01160 Dave Norris Policy T2 - T2 footpaths and cycle routes is good.

VALP16-09-07-01160 Dave Norris Policy T3 - T3 Electric vehicle infrastructure is not clear as to who is providing and paying for the privilege!

VALP16-09-07-01172 Simon Proctor (Proctor Policy T1 - T1 cGarages should continue to be included in the allocation of car parking spaces. Surveyors (Stoke The car parking standards appear excessive. There appears to be no requirement for un-allocated parking provision which is to be Hammond)) supported. Both need to be considered in light of the specifics of any application and rigid adherence may make for unviable development or inappropriate development density particularly with brown field or infill development. See restrictions in policy BE1 below. VALP16-09-08-01204 Mark Furnish (Sport Policy T2 - Sport England are supportive of the footpath and cycle routes protection and provision specified in Policy T2. These England) form part of the principles for Active Design and would assist in creating a healthier and sustainable community to meet the Councils’, the NPPF’s and Sport England’s objectives. VALP16-09-08-01209 Tim Coleby (Peter Brett Policy T2 - 7.1.1 The policies in this chapter are of a generic nature so there is no need for detailed comment, other than to re- Associates LLP on iterate the transport benefits of the Aylesbury Woodlands proposals, including in respect of walking and cycling, as already set out in behalf of chapter 3 above. Buckinghamshire Advantage) VALP16-09-08-01225 Frazer Hickling (Phillips Policy T1 - The transport chapter, sets out parking standards (vehicle and cycling), policy relating to the provision and protection of Planning Services footpaths and cycle networks, and electric vehicle charging points. We have no comments to make in relation to this chapter. Limited) VALP16-09-08-01245 Deborah O’Brien Policy T1 - Lots on parking, nothing definite on transport provision to support development. When will the Infrastructure Delivery (Padbury Parish Council) Plan (including transport) be carried out? Has it even been commissioned yet?

VALP16-09-08-01283 Simon Proctor (Proctor Policy T1 - T1 cGarages should continue to be included in the allocation of car parking spaces. Surveyors (Stoke The car parking standards appear excessive. Both need to be considered in light of the specifics of any application and rigid Hammond 2)) adherence may make for unviable development or inappropriate development density particularly with brown field of infill development. See restrictions in policy BE1 below.

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ID Respondent Name Comment VALP16-09-09-01315 Neil Tiley (Pegasus Policy T1 - Policy T1 seeks to encourage sustainable transport modes. It also requires that infrastructure for electric vehicles should Group (on behalf of be provided in major development schemes. Whilst this is to be welcomed, further clarity on what is being sought is required and the Jeremy Elgin)) viability of such provision will need to be tested. Policy T1 also sets out the optimum parking standards. Paragraph 7.4 identifies that garages will not count towards these parking standards as they tend to be used for storage rather than parking. This may have implications for the density and viability of development and this will need to be tested. VALP16-09-09-01315 Neil Tiley (Pegasus Policy T2 - Policy T2 seeks to safeguard and improve footpaths and this opportunity is provided by the Waldridge Garden Village. Group (on behalf of Jeremy Elgin)) VALP16-09-09-01315 Neil Tiley (Pegasus Policy T3 - Policy T3 requires that developments provide 1 electric vehicle charging point for every 10 dwellings, that trickle charge Group (on behalf of points are provided at employment sites, and that rapid charge points are provided at retail and leisure facilities. This again is to be Jeremy Elgin)) welcomed although the viability of such provision will need to be tested alongside the other proposed policy requirements in order to demonstrate that the cumulative viability effects are consistent with paragraph 173 of the NPPF. Furthermore, the capacity of the current electrical sub-stations will need to be demonstrated to be able to accommodate this Policy requirement. VALP16-09-09-01350 Trish Owen Policy T1 - Policy T1 - Residential car parking standards This policy states that the number of residential car parking spaces provided should be based on the number of habitable rooms in the dwelling. Habitable rooms are defined as bedrooms, kitchen, living room and dining room. This is very misleading and confusing. My house has 2 sitting rooms and 3 bedrooms plus a kitchen diner.. Do we have 6 habitable rooms then? This should be based on bedrooms not habitable rooms as it is so unclear.... VALP16-09-09-01399 Cllr Phil Yerby Policy T3 - We support the policy.

VALP16-09-09-01402 Stephen Beal Policy T1 - Definitely not enough parking per unit. 1.5 where 2 adults will live with no visitor provision (Berry fields)

VALP16-09-09-01402 Stephen Beal Policy T2 - Agree

VALP16-09-09-01407 Simon Handy (Strutt & Policy T2 - Policy T2 – ‘Footpaths and cycle routes’ Parker LLP (Stoke We are supportive of the wording of this policy. The Vision Document shows that the development of our clients’ land would result in Mandeville)) cycle connectivity improvements by relocating the existing cycle path along Wendover Road slightly inside our development boundary to create a more enjoyable cycle experience through a natural setting more separated from the main A road (A413). Pedestrian connectivity throughout the sites would also be a key aspect of our development proposals with pedestrian routes meandering through new public open spaces to create an enhanced Green Infrastructure network in the local area.

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ID Respondent Name Comment VALP16-09-09-01413 Michelle Thompson Policy T1 - Strongly disagree with spaces proposed as acceptable. Minimum 2 spaces with provision for visitors on any development (not infill) over 1. Police parking for caravans etc. to stop road parking. Add a bay for this usage. As you are not using a garage as a space, this leads itself to conversion as storage - why not make the developers build correct size garages? Surgeries need huge car parks for all the new clients (customers nowadays) They will have same dentists etc. Not enough space.

VALP16-09-09-01413 Michelle Thompson Policy T2 - Agree.

VALP16-09-09-01413 Michelle Thompson Policy T3 - Agree.

VALP16-09-09-01416 Kathryn Hedges Policy T1 - Off road paramount for business and domestic.

VALP16-09-09-01427 Phil Yerby (Hampden Policy T3 - We support the policy. Fields Action Group) VALP16-09-09-01440 Nick Butler Policy T1 - All big linear developments should have extra off road parking. No drop off policy for primary schools. Disagree with 1.5 cars/house should be 2 cars/house. With provision of shared guest parking, every big house should have a garage. No allocation of parking for surgery. VALP16-09-09-01440 Nick Butler Policy T2 - No strategic cycle routes between Aylesbury Vale Parkway and villages.

VALP16-09-09-01451 Geoff Culverhouse Policy T1 - 7.1 We support this policy. In particular we note item T1c which recognises that garages are rarely used for parking cars! (North Bucks Parishes However, there needs to be specific recognition that car ownership levels and therefore parking requirements, in rural areas with Planning Consortium) poor public transport provision are greater that in urban areas. We would encourage the introduction of a zoning system for parking standards as promoted in BCC’s parking standards. This would ensure that higher levels of off street parking are delivered in areas where there is limited public transport. VALP16-09-09-01451 Geoff Culverhouse Policy T2 - This is supported (North Bucks Parishes Planning Consortium) VALP16-09-09-01451 Geoff Culverhouse Policy T3 - 7.3 This policy is supported. It would further evidence AVDC’s commitment to supporting sustainable modes of transport (North Bucks Parishes if the policy were extended to call for the provision of charging points at all new dwellings. Where dwellings are delivered as blocks of Planning Consortium) flats one charging point for every five units should be provided at an easily accessible location adjacent to the block.

VALP16-09-12-01514 Simon Proctor (Proctor Policy T1 - T1c - Garages should continue to be included in the allocation of car parking spaces. Surveyors (Gawcott)) The car parking standards appear excessive. Both need to be considered in light of the specifics of any application and rigid adherence may make for unviable development or inappropriate development density particularly with brown field or infill development. See restrictions in policy BE1 below.

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ID Respondent Name Comment VALP16-09-12-01515 Cameron Austin-Fell Policy T1 - Policy T1 includes some very detailed parking and cycle parking standards. These provide some very detailed (RPS Planning & components across all sectors. It is very difficult to accurately assess the evidence base for such standards or the implications of Development (on behalf what is being proposed, and in particular in the context of a plan lasting up-to year 2033, such standards will inevitably change. of Richborough Estates Whilst RPS does not dispute parking standards are helpful, it believes this level of detail should be placed into a separate Site - Churchway, Supplementary Planning Document and a simple policy hook provided from a substantially reduced policy to it. This would enable Haddenham)) more detailed scrutiny and the ability to change the SPD in subsequent years.

VALP16-09-12-01515 Cameron Austin-Fell Policy T3 - RPS does not see where the evidence base for the requirement for charging points from new residential properties has (RPS Planning & been established. It does not therefore consider the policy is robustly prepared. Additionally, there is no evidence that the Council has Development (on behalf considered the viability implications of such policy. In the absence of such evidence the policy should be withdrawn. of Richborough Estates Site - Churchway, Haddenham)) VALP16-09-12-01521 Sean Carolan (Winslow Policy T1 - It is very concerning that only 8 pages are given to transport and the majority of these are focused on vehicle parking. Town Council) There is no clear vision of how transport infrastructure will be developed to meet the extra demand put upon it with the arrival of over 30,000 homes. How this need is going to be met, through improved transport infrastructure, improved public transport or by some other means is not resolved. Vehicle Parking – we were advised this was going to follow the BCC standards but it does not. Justification for different parking standards for Aylesbury compared with rural villages is obvious yet AVDC is again going down the track of ‘one size fits all.’ Also, there is no mention of garage provision and size. If residents don’t use garages for parking but instead use it for storage should not the basic design of these houses be changed? See attached for details of BCC Parking Standards recommendations. VALP16-09-12-01523 Cameron Austin-Fell Policy T1 - Policy T1 includes some very detailed parking and cycle parking standards. These provide some very detailed (RPS Planning & components across all sectors. It is very difficult to accurately assess the evidence base for such standards or the implications of Development (on behalf what is being proposed and in particular in the context of a plan lasting up-to year 2033, such standards will inevitably change. of Richborough Estates Whilst RPS does not dispute parking standards are helpful, it believes this level of detail should be placed into a separate Site - Lower Road, Supplementary Planning Document and a simple policy hook provided from a substantially reduced policy to it. This would enable Aylesbury)) more detailed scrutiny the ability to change the SPD in subsequent years. VALP16-09-12-01523 Cameron Austin-Fell Policy T3 - RPS does not see where the evidence base for the requirement for charging points from new residential properties has (RPS Planning & been established. It does not therefore consider the policy is robustly prepared. Additionally, there is no evidence that the Council has Development (on behalf considered the viability implications of such policy. In the absence of such evidence the policy should be withdrawn. of Richborough Estates Site - Lower Road, Aylesbury))

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ID Respondent Name Comment VALP16-09-12-01538 Jon Gateley (Savills (on Policy T1 - Policy T1 puts forward recommendations for parking standards to apply across the District, and notes that garage space behalf of Crest Strategic will no longer be counted as parking space due to the prevalence of garage use for domestic storage. Buckinghamshire County Projects)) Council has recently updated its car parking standards but it is unclear as to whether AVDC will adopt these, as it has been suggested that this may not be the case. Some clarity would therefore be beneficial in defining the approach that is to be adopted by developments to ensure that a balance is reached between managing demand and maintaining the viability of developments.

VALP16-09-12-01594 Victoria Chase (Indigo Policy T1 - Draft Policy T1 sets out the proposed parking standards for development. It states that in order to accommodate the Planning Ltd on behalf increasing average size of motor vehicles, car parking spaces should have a minimum dimension of 5.0m x 2.8m. The proposed Sainsbury’s parking dimensions are too big, certainly in terms of the proposed length of the bays, which will make it more difficult to achieve Supermarkets Ltd (SSL)) appropriate levels of parking on sites. As such, these dimensions should be reduced to at least 5.0m x 2.5m and the draft policy made clear that the standards for parking numbers and dimensions are “optimum” (underlining our emphasis).

VALP16-09-12-01594 Victoria Chase (Indigo Policy T3 - Draft Policy T3 requires that electric charge points should be provided at long stay locations at a rate of one charging Planning Ltd on behalf point for every 25 parking spaces, except at petrol stations where one space should be provided. It goes on to state that these Sainsbury’s charging points should wherever possible be coupled with renewable energy installations such as solar panels to enhance the Supermarkets Ltd (SSL)) sustainability of the provision. There should be flexibility in this policy that such charging points be provided where possible to allow the appropriate balance between standard parking spaces and electric charging points on a site by site basis. We trust these representations will be taken into consideration when preparing the next stage of the Local Plan.

VALP16-09-12-01606 Stuart Twigg Policy T1 - Traffic – How much actual study has been made into the need for new roads? By actual, I don’t mean modelled to suit the answer that AVDC demands? How many drivers have been questioned about their habits? Where have they gone to and where do they go? There are flawed plans to link affluent Wendover and Amersham to Milton Keynes by a new link road from Stoke to Bierton. Who would use it? Are you trying to induce demand for a road? Induced demand leads to congestion.

VALP16-09-12-01641 MICHAEL KNOTT Policy T1 - Gallagher Estates welcome the inclusion of car parking standards for residential and non-residential (Gallagher Estates) development. However consider it important to allow developers to negotiate on the proposed level of parking specified should local circumstances justify deviation from them. VALP16-09-12-01641 MICHAEL KNOTT Policy T2 - Gallagher Estates welcome the delivery of strategic cycle and footpath improvements. (Gallagher Estates) VALP16-09-12-01641 MICHAEL KNOTT Policy T3 - Gallagher Estates support the introduction of electronic charging points for vehicles at a rate of 1 (Gallagher Estates) charging point for every 10 dwellings, subject to viability.

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ID Respondent Name Comment VALP16-09-13-01672 Derek Bromley Policy T1 - The policy needs changing as it disregards the garages within the allocation of car parking spaces which seems completely contrary to the main function and purpose for such buildings. The planning system is there to make available choices. If some occupiers choose to use a garage other than for a vehicle that is a matter of personal choice and indeed an occupier may not have a requirement to park a car within the garage. The planning authority is not there to legislate how occupiers use either uncovered car parking spaces or garages. The policy provides minimum garage size to ensure that they are capable of parking a vehicle. The proposed car parking standards will impact upon achieving best urban design and making maximum efficiency of land use.

The optimum car parking standards are in excess of what is reasonably required and will only encourage the use of cars rather than alternative means of transport. The previous National Policy provided a target of an average of 1.5 spaces per dwelling.

The use of the wording 'optimum' as a standard would be interpreted by local decision makers as a minimum to be achieved. To place justification for a lower level of parking provision on a site upon the applicant is an unnecessary burden.

The better basis for assessing car parking requirements is bedrooms and not habitable rooms. Bedrooms provide a clearer indication of household numbers.

In our view the policy should be changed so that garages are included in the assessment of onsite car parking provision and the car parking requirements should be as set out in as follows: One bedroom - 1 space Two bedrooms - 2 spaces Three bedrooms - 2.5 spaces Four bedrooms- 3.5 spaces Five bedrooms- 4 spaces Six bedrooms- 5 spaces

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ID Respondent Name Comment VALP16-09-13-01691 Roy van de Poll Policy T1 - It is very concerning that only 8 pages are given to transport and the majority of these are focused on vehicle parking. There is no clear vision of how transport infrastructure will be developed to meet the massive extra demands put upon it with the arrival of over 30,000 homes. How this need is going to be met, through improved transport infrastructure, improved public transport or by some other means is not considered. This head in the sand approach is obviously not rational.

Vehicle Parking – we were advised this was going to follow the BCC standards but it does not. Justification for different parking standards for Aylesbury compared with rural villages is obvious yet AVDC is again going down the track of ‘one size fits all.’ As residents generally don’t use garages for parking but for storage, should not the basic design of these houses be changed? See below details of BCC Parking Standards recommendations.

BCC Consultation on Parking Standards – Relevant Extracts and Comments

The recommendation to have zone parking standards for new housing developments, in recognition of the fact that car use in an urban area will inevitably be less than that in a rural community, has much to commend it. AVDC’s has suggested a simple district- wide approach in the draft VALP, which is obviously out of date, simplistic and not fit for purpose.

1.5.3.1. Residential car parking In urban areas, residents have more opportunity to walk, cycle, and use public transport to move around. Consequently, car ownership tends to be lower in urban areas than in rural areas. Hence, it is not always necessary to provide as many car parking spaces for residential developments in urban areas. This is particularly important given the limited availability of land in urban areas and the importance of ensuring land is developed in the most efficient way. The standards are still calculated to provide enough parking for these areas, based on real-world evidence, but avoid providing too much.

In contrast, residents in rural areas are likely to be more dependent on cars for their day to day trips due to limited access to public transport; fewer designated cycle and footpaths; and more widely dispersed services. This must be reflected within the standards.

Therefore, residential standards have been produced for three zones based on ward population size and accessibility by public transport. We were able to map the bus routes found within the county, and layer them on top of the district zone maps. From this we can see a clear connection between zone allocation and accessibility. The zones are based on wards, as this is how the Office of National Statistics (ONS) provided us with the cross tabulation of data. Each ward has been assigned to one of the three zone types, as set out in Table 1.

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ID Respondent Name Comment VALP16-09-13-01696 Mark Owen (Barton Policy T1 - We would like to comment on the vehicle parking standards provided within Draft Policy T1 (Vehicle Parking) in so far Willmore (on behalf of that: Hampden Fields • The approach to encouraging sustainable modes rather than applying restrictive parking is welcomed. However, some flexibility Consortium)) should apply in some highly accessible locations and/or for some land-uses where low or even carfree development should be something that the Council could support. • There is no clarification provided as to whether BCC, as Highway Authority, has sanctioned the use of these standards in respect of its Development Management function for developments that lie within the Council’s administrative area. This confirmation would be useful as the parking standards in force in most other Buckinghamshire planning authorities reflect those standards laid down by BCC, which are different. • No definition is given as what ‘optimum’ means in terms of applying the parking standards and whether this is intended as maximum or minimum standards, although the allowances made for site-specific adjustments are noted. • The policy to restrict garages from any car parking calculation because of alternative storage use by residents, risk over-stating the amount of parking being provided. Other local authorities that have considered a differential approach to garages have either limited the parking provision to 50% of the total provided or specified the inclusion of larger garages that make specific provision for the storage (of goods and/or cycle, etc). No distinction has also been made regarding how car ports should be treated. • The approach to communal parking recognises that multiple uses of nearby or combined facilities could take place as part of the same vehicular trip. However, the policy does not sufficiently recognise that shared use can also take place where the peak times of visitation for certain co-located facilities may be different from others. In the example of a local centre provided as part of a development, a ‘car parking accumulation’ approach based on the trip generation profile of each land-use would offer a suitable alternative that should be included for consideration within the policy. This would remain subject to review and sanction by the Council. VALP16-09-13-01696 Mark Owen (Barton Policy T2 - We support the principle of ensuring a network of pedestrian and cycle routes as indicated by Draft Policy T2 (Footpaths Willmore (on behalf of and Cycle Routes). The need to provide pedestrian and cycle routes form an important aspect of the overall movement strategy for Hampden Fields the Hampden Fields proposal with an emphasis on providing appropriate connections between the proposed new neighbourhoods Consortium)) and the existing surrounding residential areas. VALP16-09-13-01696 Mark Owen (Barton Policy T3 - We agree with the objective of maximising the use of sustainable modes of transport as detailed within Draft Policy T3 Willmore (on behalf of (Electric Vehicle Infrastructure) although in regards to large scale schemes it is considered that such matters should be considered Hampden Fields at a detailed stage. Consortium))

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ID Respondent Name Comment VALP16-09-13-01702 Derek Bromley Policy T1 - The policy needs changing as it disregards the garages within the allocation of car parking spaces which seems (Bidwells) completely contrary to the main function and purpose of such buildings. The planning system is there to make available choices. If some occupiers choose to use a garage other than for a vehicle that is their choice. The planning authority is not there to legislate how occupiers use either uncovered car parking spaces or garages. The policy provides minimum garage size to ensure that they are capable of parking a vehicle. The proposed car parking standards will impact upon achieving best urban design and making maximum efficiency of land use. The optimum car parking standards are in excess of what is reasonably requ ired and will only encourage the use of cars rather than an alternative means of transport. The previous National Policy provided a target of an average of 1.5 spaces per dwelling. The use of the word 'optimum' as a standard would be interpreted by local decision makers as the minimum to be achieved. To place the justification for a lower level of parking provision on a site upon the applicant is an unnecessary burden. The better basis for assessing car parking requirements is bedrooms not habitable rooms. Bedrooms provide a clear indication of household ;numbers. In our view the policy should be changed so that garages are included in the assessment of onsite car parking provision and the car parking requirements are as set out as follows: One Bedroom- One Car Space Two Bedroom- Two Car Spaces Three Bedroom- Two and a Half Car Spaces Four Bedroom- Three and A Half Car Spaces Five Bedroom- Four Car Spaces Six Bedroom- Five Car Spaces

VALP16-09-13-01708 Rachel Wileman Policy T1 - BCC is pleased to see that cycle parking standards are included, however we would like the policy to include the (Buckinghamshire following ‘cycle parking should be covered, secure, lit and it is essential that the cycle parking is located near to the entrance of a County Council) building to that it is easily accessible (in order to encourage use). Location and quality/security is just as important as providing it.

8.14 Paragraph 7.7 – This narrative should refer to Aylesbury and Buckingham Transport Strategies for proposed cycle network improvements in the two towns.

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ID Respondent Name Comment VALP16-09-13-01708 Rachel Wileman Policy T2 - 8.16 Paragraph 7.6 typo in last sentence. Suggest ‘…should be designed to prioritise pedestrian and cycle movements. (Buckinghamshire 8.17 Policy T2 Page 150 Public rights of way encompass footpaths, bridleways, byways and restricted byways; most in the Vale are County Council) footpath and bridleways (99.1%). This network connects seamlessly with the (road) highway network (roads, quiet lanes, ‘footways’, etc.). Policy T2 doesn’t necessarily need to define all pedestrian and cycle routes, but public footpaths (as distinct from ‘footways’) do provide pedestrian links to development sites and public bridleways provide pedestrian and cycling links to development sites. They are integral both to the sustainable transport network and for countryside access, as outlined in the document’s ‘Protection of Public Rights of Way’ section (page 190). This dual use has been reflected in both Transport and Green Infrastructure chapters of this strategy document and this is supported. 8.18 However, T2 tends to interchange the words ‘footpaths’ and ‘pedestrian routes’. Simply using ‘pedestrian routes’ and avoiding the term ‘footpaths’ might cover all classifications of routes used by walkers (i.e footpaths, bridleways, byways, restricted byways, footways, quiet roads, verges, etc) and avoid doubt. It also avoids confusion when describing public footpaths (rights of way) and footways (alongside roads). 8.19 BCC suggest’s: • Policy T2 For development which will have implications for pedestrian and cycle route networks the following criteria will apply: a. The delivery of a strategic cycle network and improvements to pedestrian routes will be supported. b. The council will protect existing cycling infrastructure from adverse effects of new development. In dealing with planning applications the council will seek new or improved cycle access and facilities, including cycle storage and the provision of new or improved bridleways, and will use planning conditions or legal agreements to secure such arrangement c. The council will safeguard existing pedestrian routes from adverse effects of new development. Development proposals must provide for direct, convenient and safe pedestrian movement and routes, connected where appropriate to the existing pedestrian network. In deciding planning applications the council will use planning conditions or legal agreements to secure the provision of new footpath infrastructure and the improvement of existing routes. d. New and improved routes should be accessible for all and be compliant with the Equlities Act 2010 8.20 We have also added a new section d. Developments should comply with Equality Act 2010 legislation to reflect the overarching principles of access to services for disabled people. The plan highlights Stoke Mandeville Hospital’s sporting heritage and national spinal injuries centre (11.11, p 196) so you may consider other parts of the Plan need strengthening in this area, but I have suggested an inclusion here and in C4 (b) below. 8.21 Note: The document refers to the Equalities Act 2010 (4.152, p 110) and ‘Equalities Act 2014’ 3.66 p 49. However, the legislation title is the Equality Act 2010.

VALP16-09-13-01717 Michael Brown Policy T1 - There is no provision for parking in the village. There is chaos outside the shop and the school, with parents and shoppers competing with through traffic at school starting and finishing times. Many of the children are driven by car or by bus to school from surrounding villages which have no schools VALP16-09-13-01717 Michael Brown Policy T2 - Narrow roads with no cycle paths and dangerously potholed road surfaces.

VALP16-09-13-01717 Michael Brown Policy T3 - There is none.

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ID Respondent Name Comment VALP16-09-13-01718 Craige Burden Policy T1 - The policy sets out parking standards based on habitable rooms; and emphasizes the use of sustainable modes of (Persimmon Homes) transport. However, the policy seems to fail to recognize the need for all home owners to park a car, even if they are using sustainable modes of transport. The parking requirements need to be reconsidered based on car ownership, rather than car usage.

VALP16-09-13-01718 Craige Burden Policy T3 - The policy requires the provision of charging points across larger sites. This appears to have no reference to the viability (Persimmon Homes) implications upon proposed development. VALP16-09-13-01722 Sarah James Policy T2 - Footpaths aren't kept well as it is and neither and.the roads of surrounding villages,increasing traffic threw this areas and.the amount of roads/estates the vale has.to.care for is only going to decrease the service.to villages. Hedges and footpaths threw newton longville used to be well kept,now they are lucky to have it done twice during the much needed season

VALP16-09-13-01731 Stephanie Schneider Policy T1 - Vehicle Parking (T1) – I agree that an appropriate level of parking is required for new developments. There should be adequate parking provided for residents and visitors. The latter includes tradespeople and health care workers, as many people are living in their homes and receiving care packages. VALP16-09-13-01731 Stephanie Schneider Policy T2 - Cycle and Footpath Network (T2) - I agree with AVDC’s policy to deliver a strategic cycle network and improvements to, and creation of, footpaths. VALP16-09-13-01817 Simon Proctor (Proctor Policy T1 - T1 cGarages should continue to be included in the allocation of car parking spaces. Surveyors (Newton The car parking standards appear excessive. There appears to be no requirement for un-allocated parking provision. Both need to Longville)) be considered in light of the specifics of any application and rigid adherence may make for unviable development or inappropriate development density particularly with brown field or infill development. See restrictions in policy BE1 below VALP16-09-19-01834 Martha Simpson Policy T1 - I do not think there is enough off road parking 1.5 for a one to four room house. There is a major problem with parking. There should be more off road spaces ie two spaces for a one bed flat etc. There are one bedroom flat's in Quainton lived in by two people who both have cars as public transport is not available at regular intervals. VALP16-09-19-01838 Phyllis Simms Policy T1 - I agree that garages should not be classed as parking spaces as people use garages for storage. Adequate parking needs to be off the road. A one bedroom flat might have two people living in it and two cars.

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ID Respondent Name Comment VALP16-07-29-00236 John Oldfield Policy BE2 - There is a history of flooding in the Great Ouse catchment. All new development should be founded around reducing (Buckingham and River the flood risk to the new development as well as the existing communities. Ouzel IDB) Flood Risk should be managed with strategic, integrated and maintainable Sustainable Drainage Systems and infrastructure. To ensure the SuDS continue to operate in the future, the Council should require a robust maintenance regime, which typically requires adoption by a statutory flood risk authority with a CIL/S106 commuted sum. This will ensure that they are maintained and that they continue to operate as designed in 10, 20, 30 years...

Particular attention should be given in the plan to define the high standard of requirements for drainage of major development sites. Buckingham has suffered significant flooding in the past, so major development here should also be reducing the existing risk. Developments in AVDC that abuts Milton Keynes Council or Central Bedfordshire Council should be planned in a coordinated manner with the neighbouring authority, such that flood risk is reduces, such as the receiving downstream watercourses of Loughton Brook, the Ouzel and Water Eaton Brook. VALP16-08-06-00269 John Scott Policy BE2 - In your proposals for new housing around Haddenham please do not assume there is capacity in Thame to provide supporting infrastructure for those homes. Thame is very stretched in regards to infrastructure provision and suffers from being on the boundary between local authorities, with the risk that a holistic view is not taken. I would ask that you please ensure that fully joined-up thinking is undertaken where issues span the border to Thame.

On a separate matter, I would encourage you to ensure that new housing developments are demonstrably treated as more than 'just numbers' and that they will genuinely add quality to the local environment. For example, whether the properties are large or small, it is really important for the future that they should be energy efficient buildings, they should support local energy generation and storage, and encourage the uptake of electric vehicles. If this is combined with green spaces that encourage walking and cycling, and new developments include actions that help build community, then the new housing becomes not a burden but an opportunity for the area.

An off-road cycle path between Haddenham and Thame would be an excellent by-product of development in this area. VALP16-08-16-00341 Elaine Standen Policy BE1 - Marsworth is a farming Parish and the land proposed by AVDC is prime farming land. We have alternative brownfield sites available that should be considered as an alternative. VALP16-08-17-00361 Ella Jones (Wendover Policy BE2 - Wendover Parish Council supports sustainable design and design in keeping with the environment. Parish Council) VALP16-08-18-00363 Charlotte Newman Policy BE2 - Design should be in keeping with neighbouring properties VALP16-08-19-00374 Simon Milliken (National Policy BE1 - Comment: WE/NT/HH support in principle for policy relating to the protection of heritage assets (including historic parks Trust, Waddesdon and gardens). This Policy should carry significant material weight when considering any proposal for development which could have Estate and Hartwell an adverse impact on the heritage asset – such as HS2 and proposed new housing development south of the A418 Oxford Road in House) the case of Hartwell House. VALP16-08-20-00400 jim woolgar Policy BE3 - School and village hall/playing field will not accomodate such an increase VALP16-08-20-00402 Martin Armitstead Policy BE2 - Ther is no way to maintain the village character. VALP16-08-20-00402 Martin Armitstead Policy BE3 - The water table and lack of infrastructure mitigates against development here.

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ID Respondent Name Comment VALP16-08-21-00406 Richard Barrie Policy BE1 - Haddenham has many listed buildings and a large conservation area. The imposition of 7000 new houses is going to totally swamp this environment. VALP16-08-21-00406 Richard Barrie Policy BE3 - 8.63 How can the tripling in size of Haddenham be in any way considered "Protection of the Amenity" for the residents of Haddenham. Our whole quality of life is going to be taken away from us by the imposition of 7000 new houses. VALP16-08-23-00441 Alexander Matthews Policy BE1 - Lets be more robust about identifying and promoting our heritage. We could do with a much more assertive approach (Thornton Parish here. ( Happy to get involved) Meeting) VALP16-08-23-00446 Arthur Evans Policy BE1 - protect. VALP16-08-23-00446 Arthur Evans Policy BE2 - Allow ample width for emergency vehicles. Stop parking on pavements and grassed areas. VALP16-08-24-00448 Michael Henderson Policy BE1 - We support the need for continued protection of the special nature of conservation areas and listed buildings, including (Dinton with Ford and the Dinton, Westlington, Upton and Gibraltar Conservation Area. We would wish to seek the setting and nature of these areas Upton Parish Council) protected. We would however wish to see a review and extension of the boundary of these areas to ensure that they are adequately covered. VALP16-08-25-00529 Lucy Murfett (Chilterns Policy BE1 - The Chilterns Conservation Board supports this policy and welcomes the reference to Landscape Character Conservation Board) Assessments. VALP16-08-25-00529 Lucy Murfett (Chilterns Policy BE2 - The policy text starts with ‘All new development proposals shall follow the guidance set out within the council’s adopted Conservation Board) design guides” but these are not listed or linked to anywhere. Suggest that a new paragraph of lower case text is added referring to the adopted design guides. This should include: “For the AONB area, the Chilterns Buildings Design Guide and supplementary technical notes on brick, flint and roofing materials, available here http://www.chilternsaonb.org/conservation-board/planning- development/buildings-design-guidance.html”.

Typo in para 8.32, correct to: “from the nationally designated natural beauty of the Chiltern Hills Area of Outstanding Natural Beauty”

Para 8.34 should also refer to the AONB: “This will be especially important in areas recognised for the landscape or townscape quality, i.e. the Chilterns AONB, the designated Special Landscape Ares and conservation areas.”

VALP16-08-25-00530 Eric Sergeant Policy BE1 - 8.8. Non designated heritage assets, agree with this statement "A non-designated heritage asset can be a building, monument, site, place, area or landscape identified as having a degree of significance meriting consideration in planning decisions".

VALP16-08-28-00548 Nicola Page Policy BE3 - Why just protect amenities? If the community is going to increase by 50% we need to extend amenities. Shopping may be done online but we all need a doctor, dentists, Schools! these have to be in the plan. VALP16-08-31-00576 Mary and Allan Policy BE3 - If new developments are too big for the amenities and the structure of the village the life experences in and character of glendinning the village will be lost

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ID Respondent Name Comment VALP16-09-01-00633 Frazer Hickling (Phillips Policy BE2 - CHAPTER 8-BUILT ENVIRONMENT Planning Services (on The built environment chapter sets out policies in relation to the historic, environment, design and amenity. behalf of Mrs Davis, Mrs We have no comments to make in relation to these policies, however it is noted that the ‘External Space Standards’ section of policy Church and Mr Davis of BE2 relates purely to the residential development. It is therefore considered that this would more usefully be located within the Corner Farm, Gib Lane housing chapter of the plan. Bierton))

VALP16-09-02-00641 Christopher Matthews Policy BE1 - Paragraphs 8.1 to 8.7 - These sections completely encapsulate why the scale of development proposed for Haddenham is unacceptable. In 8.1 it states ‘The historic environment is an asset of great cultural, social, economic and environmental value. It contributes significantly to our quality of life and to the character of the district, representing a non-renewable resource that once lost is gone forever’. The historic environment of Haddenham and its outstanding conservation area has not been given due weight. ‘The council has a statutory duty to have a special regard to the desirability of preserving any listed building or its setting’ (8.3). In the case of Haddenham the church is a Grade I listed building set in part of the conservation area, Church End, where there is a green and 3 Grade II listed buildings. The whole setting has to be considered and the impact of nearby housing developments and traffic on this. It is debatable whether the proposal for 280 houses on the site closest to this area will directly affect it, but what is certain is that the resulting increase in traffic, coupled with the additional traffic for the expanded school (Haddenham St Mary’s School), will have a major detrimental effect. Church End is already being spoilt by heavy traffic, particularly at school times, but with the extra developments planned the character will be ruined forever. Similarly, the whole conservation is an essential part of our heritage and requires protection equal to that given for Green Belt and Areas of Outstanding Natural Beauty. I believe that the council is failing in its statutory duty as set out in section 8.3.

VALP16-09-02-00641 Christopher Matthews Policy BE2 - Paragraphs 8.30 to 8.35 - New developments in Haddenham should conform to the design principles set out in Haddenham Neighbourhood Plan Policy HD9 (page 44). VALP16-09-02-00641 Christopher Matthews Policy BE3 - Paragraph 8.37 – the scale of proposed developments in Haddenham will definitely lead to excessive traffic within the village. The council is not following its declared aim of protecting the amenity of Haddenham residents.

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ID Respondent Name Comment VALP16-09-02-00643 Angela Matthews Policy BE1 - Paragraphs 8.1 to 8.7 - These sections completely encapsulate why the scale of development proposed for Haddenham is unacceptable. In 8.1 it states ‘The historic environment is an asset of great cultural, social, economic and environmental value. It contributes significantly to our quality of life and to the character of the district, representing a non-renewable resource that once lost is gone forever’. The historic environment of Haddenham and its outstanding conservation area has not been given due weight. ‘The council has a statutory duty to have a special regard to the desirability of preserving any listed building or its setting’ (8.3). In the case of Haddenham the church is a Grade I listed building set in part of the conservation area, Church End, where there is a green and 3 Grade II listed buildings. The whole setting has to be considered and the impact of nearby housing developments and traffic on this. It is debatable whether the proposal for 280 houses on the site closest to this area will directly affect it, but what is certain is that the resulting increase in traffic, coupled with the additional traffic for the expanded school (Haddenham St Mary’s School), will have a major detrimental effect. Church End is already being spoilt by heavy traffic, particularly at school times, but with the extra developments planned the character will be ruined forever. Similarly, the whole conservation area is an essential part of our heritage and requires protection equal to that given for Green Belt and Areas of Outstanding Natural Beauty. I believe that the council is failing in its statutory duty as set out in section 8.3.

VALP16-09-02-00643 Angela Matthews Policy BE2 - Paragraphs 8.30 to 8.35 - New developments in Haddenham should conform to the design principles set out in Haddenham Neighbourhood Plan Policy HD9 (page 44). VALP16-09-02-00643 Angela Matthews Policy BE3 - Paragraph 8.37 – the scale of proposed developments in Haddenham will definitely lead to excessive traffic within the village. The council is not following its declared aim of protecting the amenity of Haddenham residents. VALP16-09-02-00653 Quainton Parish Council Policy BE1 - The PC agree with this policy

VALP16-09-02-00655 Frances Durkin Policy BE3 - To build on the Croft Meadows site of Cheddington would "unreasonably harm any aspect of the amenity of nearby residents when considered against the benefits arising from the proposal." The views across to Ivinghoe Beacon and the Chilterns are a benefit to the local residents and the present use of the site as agricultural pasture for livestock connects the villagers with the character of the area. VALP16-09-02-00666 Kate Curry (Aston Policy BE1 - construction materials etc – there must be a way to ensure developers comply with planning permission – it is too late Abbotts Parish Council) once the build is completed and an area has been ruined because cheaper materials have been used.

VALP16-09-02-00671 David Child Policy BE2 - 8.35 much of the public outdoor amenity space is of no use. Narrow green areas count as green space but are no use at all except of "exercising" the dog. Even large green areas outside housing can cause more any annoyance than benefit.

VALP16-09-02-00673 rod phillips Policy BE2 - there should be more consistency in the design decisions for new development. VALP16-09-02-00675 Mr and Mrs Hudson Policy BE3 - 8.36 This should be one of the main considerations on any new planning applications. Planning should not be at the expense of unreasonable harm to peoples existing peaceful enjoyment of their property. VALP16-09-02-00677 Steven Mitchell Policy BE1 - Support. VALP16-09-02-00677 Steven Mitchell Policy BE2 - Support. VALP16-09-02-00677 Steven Mitchell Policy BE3 - Support.

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ID Respondent Name Comment VALP16-09-03-00715 Roderick floud Policy BE1 - Whole section It is difficult to see how this series of policies can be squared with the proposal for a new settlement in the vicinity of Haddenham, which would severely affect one of the most historic villages in Buckinghamshire, with a large conservation area, which would be adversely affected by the traffic movements to Thame and Aylesbury which are envisaged in the proposal. Pious words about the protection of heritage assets are not enough; they must be put into practice. VALP16-09-03-00715 Roderick floud Policy BE2 - Para 8.32 The policy should give explicit recognition to the need for adequate provision of gardens, since many of the additional housing developments are likely to be planned for families with children, who require safe space for exercise and access to the open air. Suburban and village gardens are now also a major source of biodiversity. The provision of a few square metres of backyard, seen in some modern developments, is not adequate; there must be space of children to run around, play with balls etc.

VALP16-09-03-00726 Richard Dorrance Policy BE3 - I like the proposals. VALP16-09-04-00739 Pierre & Wendy Hibble Policy BE1 - Paragraphs 8.3, 8.22, 8.23 and 8.24 The Vale Plan makes reference to the obligations to protect heritage sites and the benefit to the community. The Lowndes Arms public house in Whaddon is just such an important historic building. It is an equally important centre, providing a focal point for organising young and old social activities. The pub is currently closed and needs to be re-openned as soon as possible. We understand the request to have the Lowndes Arms declared a community asset has not been supported by AVDC. Again therefore, do we have a situation where the fine words of the Vale Plan have little bearing in reality? The conversion of the village asset to residential property with additional developments would be detrimental to the village. VALP16-09-04-00742 Carolyn Cumming Policy BE1 - Paragraph 8.16 Integrity. This is a very important concept. Can windows be cited as an example? Change in fenestration is often what harms the integrity.

General: Active enforcement must be undertaken when breaches occur (all too frequently). VALP16-09-04-00742 Carolyn Cumming Policy BE2 - BE2 Design of new development Boundaries, e.g. fences, hedges, walls, etc. also add or detract from the overall design of developments. BE2 should include specific mention of their importance so that they can be evaluated within any planning application.

Whether an existing building or a “new” development, there should be a policy to cover extensions. All too often, extensions fail to complement the integrity of the ‘host’ building. I note there is specific mention of extensions in paragraphs 10.23-10.26. Why not in this chapter?

External Space Standards SuDS should be included as part of any proposal to alter private external space. E.g. garden, or other soft landscape areas that are converted to hard landscape for parking, etc.

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ID Respondent Name Comment VALP16-09-04-00744 Cllr David Finch Policy BE1 - Paras 8.8-8.12 - It should be clarified in both the proposed Policy and supporting text that the existence of heritage asset designation (whether designated or not) will be a factor given due consideration when assessing the suitability (See Additional |Notes) of a site for allocation to be developed. The overriding aim of the policy should be to ensure the protection of designated and non-designated heritage assets, including listed buildings, conservation areas and archaeological sites from unwarranted development. VALP16-09-04-00745 Marianne Faux Policy BE1 - Paras 8.8-8.12 - It should be clarified in both the proposed Policy and supporting text that the existence of heritage asset designation (whether designated or not) will be a factor given due consideration when assessing the (See Additional Notes)

VALP16-09-04-00750 Colin Read (Aston Policy BE1 - Preservation of these are most appropriate. Clinton parish planning) VALP16-09-04-00750 Colin Read (Aston Policy BE3 - This is most important as it is being disregarded at the moment in the rush to acquire building land before this plan is Clinton parish planning) implemented. VALP16-09-04-00755 Joyce Docherty Policy BE1 - Paras 8.8 - 8.12: It should be made clear in the proposed Policy and supporting text that the existence of heritage asset designation - whether designated or non-designated - will be a factor counting against the suitability of a site for allocation to be developed. The overall aim of the policy should be to ensure the protection of designated and non-designated heritage assets including listed buildings conservation areas and archaeological sites from harmful development. VALP16-09-04-00756 Andrew Docherty Policy BE1 - Paras 8.8 - 8.12: It should be made clear in the proposed Policy and supporting text that the existence of heritage asset designation - whether designated or non-designated - will be a factor counting against the suitability of a site for allocation to be developed. The overall aim of the policy should be to ensure the protection of designated and non-designated heritage assets including listed buildings conservation areas and archaeological sites from harmful development. VALP16-09-04-00780 Linda Fisher Policy BE3 - Apart from consultation this appears to be superfluous.mthe plans do not take. into consideration residents, Many of whom have lived in haddenham for years VALP16-09-04-00783 Morgan Holt Policy BE3 - par 8.36 The larger of the expansion options (6000+ houses) requires a mirroring of the village on the West side of the railtracks. This creates two centres for the village. Haddenham is already suffering a lack of centre, and sprawling out in this way will cause the village to completely lose its identity. VALP16-09-04-00792 John Griffiths Policy BE2 - 8.30 - A new settlement at Haddenham would not respect the existing character of the existing settlement. VALP16-09-05-00806 Jeff_ Deacon Policy BE1 - It is good to see that you continue to use Conservation Areas to provide "eye candy" benefit for others, but no tangible benefit for the residents despite the hoops you make them jump through. VALP16-09-05-00827 Jenny Armitstead Policy BE1 - There are a number of sites in the village which are conservation areas and homes VALP16-09-05-00833 Tim Smee Policy BE3 - Brill should, in my view be a classified as a 'conservation area' with its historic roots and rich heritage buildings and streetscape.

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ID Respondent Name Comment VALP16-09-05-00853 Suzanne Lindsey Policy BE1 - POLICY BE1 HERITAGE ASSETS. (Whaddon Parish Council) WPC are concerned that policies safeguarding listed buildings, conservation areas and sites adjoining or impacting CA’s have been allowed to slip in their importance in recent years, possibly due to the pressure on development team staff and time – even department cuts - so whilst supporting the policies and paragraphs it is essential that the guidance principles are not allowed to be ‘glossed over’ as unimportant. Officers must listen to local opinion and not simply go by their own, often ‘blinkered’ views. Issues of this importance are often ‘subjective’, so even more necessity, for those making important decisions to listen to the majority and not the few, especially where conservation area officers sometimes have little understanding of the local situation.

VALP16-09-05-00871 Mary Hunt (Aylesbury Policy BE2 - External Space Standards Vale Green Party) We believe that new developments should be designed with generous space standards. We are concerned to see developments where it is difficult/impossible for large lorries, e.g. removal vans, and emergency vehicles to get by when cars are parked. VALP16-09-05-00951 Charles Robinson (DLP Policy BE2 - There is insufficient flexibility in that the provision of amenity space requires private areas only whereas other solutions Planning Limited) may be more appropriate in terms of providing usable and effective open space/amenity areas. VALP16-09-05-00955 Jonathan Clover Policy BE1 - I believe that effective resources and expertise must be provided to ensure the protection of buildings of interest of all kinds. This should be a priority. VALP16-09-05-00955 Jonathan Clover Policy BE2 - I have no technical comments on the proposals but would ask that research is undertaken or if available considered to canvas the views of residents on existing new developments in Aylesbury for example to find out about their experience of living on new estates as far as privacy and use of amenities is concerned. VALP16-09-05-00966 Michelle Kidd (Area Policy BE2 - Point (d) of this policy should be strengthened so that the natural qualities and features of the area are protected and Sustainable Places enhanced through development and that these should be at the heart of master planning. These features should be regarded as Team The Environment being assets rather than constraints in the design of any development. Agency) VALP16-09-05-00986 Simon Maloney Policy BE1 - I again support this policy.

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ID Respondent Name Comment VALP16-09-05-00987 Jonathan Glasspool Policy BE1 - 8.6, 8.7, 8.14, 8.17: the proposed development HAD07 goes completely against the points made in these clauses about the importance of preserving and enhancing heritage assets. This development - a similar one of which was rejected by the village within the past 15 years - is on land directly adjoining a conservation area. Development to the south of the village has been rejected on this basis; why does the rejection not apply here?

In section 8.29 you state: "Proposals for development will not be permitted if they cause harm to the character or appearance of conservation areas, their settings or any associated views of or from the conservation area."

How can this proposed new development HAD07 be permitted on this basis?

A new development here will ruin the very pleasing perspective of the village from the principal entrance into the village from the north on Stanbridge Road, with the view of the village set against the Chiltern Hill escarpment. It will also completely obscure from view the sight of Haddenham's longest contiguous piece of Wychert walling, a historic boundary to the village that has been in place since the village has been in existence. VALP16-09-05-00988 Sue Barber Policy BE1 - Must maintain and support heritage. VALP16-09-05-00988 Sue Barber Policy BE2 - Design must be in keeping with local areas VALP16-09-05-00988 Sue Barber Policy BE3 - local amenities are vital to people to help support families, older people and reduce road usage. VALP16-09-05-00992 Helen Hyre Policy BE1 - Para 8.24 Repair and refurbishment of historic buildings should be encouraged. VALP16-09-05-00992 Helen Hyre Policy BE2 - Para 8.31 It is important that new development is designed sensitively to reflect local building materials and styles.

Para 8.33 I agree that development should be appropriate to the local area. VALP16-09-05-00998 Charlotte Beadle Chpater 8 Built Environment - All paragraphs: I do not support this draft plan for 33000 new homes in Aylesbury Vale.

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ID Respondent Name Comment VALP16-09-05-01005 Andrew Phillips Chapter 8 Built Environment - This email is specifically centred around the expansion plans for Haddenham, either by this village growing or a "new town" on its outskirts. Haddenham is a historic settlement with no natural commercial centre. It is a small residential area with one key selling point = which is the railway station. We have two oversubscribed infant schools and one primary school. We are some distance from any secondary school with the nearest in a neighbouring county and no right to send our children there. We have no shops of note other than a corner shop and minor mini market (McColls). We have four pubs and minimal eateries. To expand this village would be a major failing of AVDC. We have poor village roads which are already overcrowded and often accident blackspot (Staybridge Rd jnt Woodways). The S.E part of the village floods yearly and parking around the railway station is already blocking the residential roads. Princes Risborogh is also adding housing as is Thame (In Oxfordshire). These in conjunction with Haddenhams already approved housing will put a strain on the existing infrastructure and no additional resources. From attending the open days and seeing your reports. Winslow is the only viable option.

VALP16-09-05-01008 John Mortimer Policy BE1 - These must be protected. VALP16-09-05-01008 John Mortimer Policy BE3 - The Lowndes Arms public house in Whaddon is both historically important as a building and hugely needed as a meeting place. It is currently closed. But it should be retained, re-opened and if possible supported by AVDC as a community asset.

VALP16-09-05-01012 Alysoun Glasspool Policy BE1 - 8.6, 8.7, 8.14, 8.17: The proposed development HAD07 goes completely against the points made in these clauses about the importance of preserving and enhancing heritage assets. This development - a similar one of which was rejected by the village within the past 15 years - is on land directly adjoining a conservation area. Development to the south of the village has been rejected on this basis; why does the rejection not apply here?

In section 8.29 you state: "Proposals for development will not be permitted if they cause harm to the character or appearance of conservation areas, their settings or any associated views of or from the conservation area."

How can this proposed new development HAD07 be permitted on this basis?

A new development here will ruin the very pleasing perspective of the village from the principal entrance into the village from the north on Stanbridge Road, with the view of the village set against the Chiltern Hill escarpment. It will also completely obscure from view the sight of Haddenham's longest contiguous piece of Wychert walling, a historic boundary to the village that has been in place since the village has been in existence. VALP16-09-05-01016 Gordon Pell Policy BE3 - Acceptance of the requirement for 20000+ houses in the Vale is not justified and does nothing to protect the character, environment or heritage of the area. Imposing developments of the scale proposed in the Local Plan will substantially alter the feel and nature of mid-Bucks.

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ID Respondent Name Comment VALP16-09-05-01028 Warren Whyte (AVDC) Policy BE2 - The opportunity for good quality modern design that considers local characteristics carefully should be encouraged, and that the policy should be worded in a way that does not allow lazy copying of local features and applied as a veneer and create a poor pastiche. Use of independent Design Reviews should be mandated for complex or large sites using CABE and RIBA guidance.

VALP16-09-05-01028 Warren Whyte (AVDC) Policy BE3 - Some examples of amenity could be included in the policy; including overlooking, significant loss of day light, noise (post construction) VALP16-09-05-01031 Alison Timman Policy BE3 - 8.37 Ref. "Amenity can be harmed in a number of ways, for example by noise, fumes or odours, excessive or speeding traffic, loss of light, the overbearing nature of a new structure, disruptions to services, increased risk of injury, illness or damage to property. Aylesbury Vale is a valued place in which to live, and the council aims to protect this aspect of its residential environment."

The proposed development in Stone (STO008) would require new access routes to be built, and likely double the traffic travelling along Creslow Way. The estate on this site has already grown in size dramatically over the last 10 years through the building work to the South of Beacon Close - adding to the traffic entering and leaving the estate on this side of Oxford Road. Further development on this land goes against the council's wish to protect the amenity of residents.

VALP16-09-07-01131 Ruth Millard Policy BE1 - Chapter 8 Built Environment Policy BE1 and 8.1 to 8.29 Heritage Assets • We welcome the strong protection regime proposed for heritage assets, both designated and non designated. This is essential to preserve the historic richness of the Vale villages and towns in view of the extreme building growth agenda being extended to ALL settlements. VALP16-09-07-01150 Mr and Mrs Bradford Policy BE1 - We believe that the fundamental nature of villages and hamlets must be respected and preserved so that important heritage, historic and conservation areas are safe and the rural environment, small, close community spirit and quality of life they afford for residents, are protected. Our local villages provide amongst other things important creative communities that enhance, develop and strongly support the artistic traditions of the area and country as a whole - as showcased each year during Bucks Open Studios. Doubling and trebling the size of small communities fundamentally and irretrievably changes their core nature and destroys much of their valuable and unique characteristics. It also makes them less attractive as tourist destinations, and in some cases television and film locations, which in turn affects the revenue such activities bring to villages, the surrounding area, and the small businesses within them. VALP16-09-07-01153 Sylvie Eames Policy BE1 - Policies BE1 and BE2 covering Heritage Assets and Design of new development read well. I particularly liked the section on space between dwellings!

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ID Respondent Name Comment VALP16-09-07-01159 Mandy Cliffe (Great Policy BE1 - BE1 Heritage assets Horwood Parish Council) GHPC suggest an additional sentence at the beginning of this policy along the lines of Development proposals affecting heritage assets will be considered in accordance with the NPPF, relevant legislation and published national and local guidelines. with an appropriate adjustment to the wording of the existing first sentence. The suggested insertion is essentially the same as paragraph A in Policy 24 Management of the Historic Environment of SWDP.

GHPC also suggest that Policy BE1 should include a reference to the positive contribution which heritage assets can offer in the way of, for example, the development of employment or tourism, in addition to describing the way in which such assets should be protected. Such a sentence would be in conformity with paragraph 126 of the NPPF: Local planning authorities should set out in their Local Plan a positive strategy for the conservation and enjoyment of the historic environment, [...]

The sentence The level of detail required will depend upon the nature of the works proposed. at the end of the first paragraph of Policy BE1 should be in parentheses, as the phrase “the following information” in the preceding sentence is intended to refer to the list on the next page.

Paragraph (g) in the list does not describe information that should be included in a heritage assessment. The text of this paragraph should not be part of the policy, and would be more appropriate in the supporting text.

The remaining text in the first part of this policy is essentially taken verbatim from saved AVDLP Policy GP53. The section of the policy headed Archaeology and ancient monuments is taken verbatim from saved AVDLP Policy GP59. The section of the policy headed Historic parks and gardens is taken verbatim from saved AVDLP Policy GP60. GHPC do not suggest any modifications to these parts of the policy.

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ID Respondent Name Comment VALP16-09-07-01159 Mandy Cliffe (Great Policy BE2 - BE2 Design of new developments Horwood Parish Council) The first part of this Policy, at the bottom of page 157, is copied from saved AVDLP Policy GP35 with some minor modifications, and with the interchange of clauses (b) and (c).

GHPC suggest that consideration be given to including in addition some more specific guidance, such as that included in paragraphs B (ii) Relationship to Surroundings and Other Development, B (viii) Scale, Height and Massing, and B (x) Detailed Design and Materials in Policy 21 Design of SWDP.

The second part of Policy BE2 could be improved in several ways. The first sentence of the first paragraph The distance between dwellings and the treatment of spaces around them have an important effect on the appearance of an area, the quality of life for residents and the distinctiveness of development. Is descriptive rather than normative, and so should form part of the accompanying text rather than part of the Policy.

The first sentence of the second paragraph Outlook from a dwelling is allied to privacy and both are necessary for quality of life in dwellings. is again descriptive and should be moved. The second sentence Whilst an adequate standard of privacy may be achieved by the use of walls, fences and planting, consideration will need to be given to the outlook that would then be achieved, as an enclosed or cramped outlook from habitable rooms is likely to be oppressive. Is too negative, and should be rephrased along the lines of Walls, fences and planting should be used to achieve an adequate standard of privacy without imposing an enclosed or cramped outlook from habitable rooms. The detailed information about space between dwellings on page 159 is presumably not part of Policy BE2 as it is not on a coloured background, but its status is unclear. GHPC suggest that this page be removed from the VALP and included in “the council’s adopted design guides” and that a suitable reference be included in the first paragraph of the second part External space standards of Policy BE2.art of the Policy.

GHPC’s comments below on draft VALP Policy C3 Renewable energy suggest that those aspects of the policy concerning carbon emission reduction methods for residential development should be included in this Chapter, either as part of Policy BE2 or as a separate policy. VALP16-09-07-01159 Mandy Cliffe (Great Policy BE3 - This Policy is copied verbatim from saved AVDLP Policy GP8. Horwood Parish Council) GHPC suggest the insertion of the following sentence between the two existing sentences in the Policy, in order to provide more specific guidance to decision takers: In particular, development should provide an adequate level of privacy, outlook, sunlight and daylight, and should not be unduly overbearing. The suggested insertion is essentially the same as paragraph B (iv) Neighbouring Amenity in Policy 21 Design of SWDP.

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ID Respondent Name Comment VALP16-09-07-01172 Simon Proctor (Proctor Policy BE1 - 8.27 The definition of an archaeological field evaluation is unclear. Proportionate archaeological investigations only Surveyors (Stoke should be required, this may take the form of a desk based assessment. Hammond)) Development adjacent to any conservation area should draw influence from the conservation area not seek to mimic or provide a pastiche. Development adjacent should be encouraged where it enhances or mitigates against previous inappropriate development.

VALP16-09-07-01172 Simon Proctor (Proctor Policy BE2 - This policy should not be used to prevent or hinder innovate design. In paragraph c the presumption is that the existing Surveyors (Stoke development is of high quality and this may not be the case. Hammond)) Appropriate flexibility must be allowed in application of the standards to reflect individual circumstance as such guidance is often based on new green field development and on infill or sites within a conversation area are too restrictive. VALP16-09-07-01172 Simon Proctor (Proctor Policy BE3 - Amenity is subjective. Laws of nuisance and rights to light should prevail. Surveyors (Stoke Hammond)) VALP16-09-08-01205 Mark Rose (Define (on Policy BE1 - BHL recognise the overarching principle of safeguarding heritage assets. However, the requirement to preserve the behalf of Bovis Homes)) historic interest of archaeological remains without substantial change is too negative and prescriptive with the result that it could prevent otherwise sustainable development. The policy should be reworded to reflect the distinction between designated and non- designated heritage assets, and the wider economic, social and environmental considerations that should be applied in determining applications for development in order to accord with the NPPF (paras. 128 and 129).

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ID Respondent Name Comment VALP16-09-08-01209 Tim Coleby (Peter Brett Policy BE1 - BA supports this chapter of the VALP and we show below how the Aylesbury Woodlands proposals comply with Associates LLP on relevant policies within it. behalf of Policy BE1 Heritage Assets 8.2 Buckinghamshire The Aylesbury Woodlands planning application is supported by an assessment of heritage assets and archaeology, which follows Advantage) guidance set out in the NPPF and would comply with the guidance set out in this emerging policy. The assessment demonstrates that Aylesbury Woodlands does not contain any designated heritage assets, such as World Heritage Sites, scheduled monuments, registered parks and gardens, registered battlefields or listed buildings. Aylesbury Woodlands does not lie within a Conservation Area. The potential for effects of proposals on the significance of heritage assets in the vicinity of the site - through changes to their setting- is assessed as only minor, which would not be significant. The setting (or experience) of these heritage assets makes only a limited contribution to their heritage value, as inter-visibility is restricted by a combination of the filtering and screening effects of overgrown boundary vegetation within and around the site and the general flatness of the southern vale. In compliance with policy, recent archaeological investigation has been undertaken, the approach to which has been agreed with the Buckinghamshire County Council Archaeological Curator. A number of potential archaeological sites are evidenced by crop-marks identified from aerial photographs and geophysical survey, undertaken to inform the application, has identified these and further areas of potential across the site. Trial trenching is being undertaken at the time of this submission, exploring these features in more detail and testing ‘blank’ areas of the site to verify the potential for the presence of significant buried archaeology. Work done to date (desk based research, magnetometry survey) suggests that potential below ground archaeological remains might possibly be small Iron Age/Romano-British settlements, with associated field systems, but these would be expected to be fairly unremarkable in local and regional contexts and the effect of their loss would not be expected to give rise to a significant effect. Two possible features of greater archaeological interest have been identified - a possible Roman building and a possible kiln. If proven, through the trial trenching being undertaken, these would likely be of interest at a regional or county level and there is some potential for these assets to be preserved in situ, should it be considered that their loss is not acceptable.

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ID Respondent Name Comment VALP16-09-08-01209 Tim Coleby (Peter Brett Policy BE2 - A comprehensive Design and Access Statement (DAS) accompanies the outline planning application for Aylesbury Associates LLP on Woodlands. The DAS describes the proposals as a series of fixed parameter plans, but also includes a masterplan and sections behalf of illustrating one possibility of how the detailed scheme might be delivered. The outline design has been informed by published design Buckinghamshire guidance, but also by empirical analysis of the surrounding landscape and built environment, including typology reviews of Advantage) surrounding villages and the Grand Union Canal basin and corridor.

The physical characteristics of Aylesbury Woodlands, as described in the Parameter Plans and illustrative sections, have responded to the site and its surroundings: the lower, less dense residential areas have been located towards the GUC canal corridor and open countryside to the north. There is then an increasing gradation of height, density and massing towards the larger commercial and industrial areas in the south-east, which are in closer proximity to similar existing uses around Arla and the elevated Arla junction off the A41. Thedesign has aimed to respect public views from footpaths north of the site towards the Chiltern Hills, by not creating skyline development. The design of the streetscape has also created and frame new public viewpoints out of Aylesbury Woodlands to the surrounding countryside.

Details such as architectural detailing and material palettes are not appropriate for this outline application, but would be described in detail as part of a subsequent Reserved Matters application.

External space standards The Residential Density Parameter Plan describes the density of dwellings and therefore describes the likely average distance between dwellings, which would be able to satisfy the guidance set out in this policy.

The Land Use and Amount Parameter Plan shows the considerable amount of formal and informal space around dwellings, including play areas which will have an important positive effect on the appearance of Aylesbury Woodlands and the quality of life for its future residents. Open space within Aylesbury Woodlands will have distinct characters depending upon its functional hierarchy and to help legibility and navigation with the development. Aylesbury Woodlands offers a significant contribution towards Aylesbury’s needs for easily accessible amenity open space comprising:

VALP16-09-08-01209 Tim Coleby (Peter Brett a. Open Parkland either side of the ELR(S) and linked beneath it via the proposed Burcott Brook bridge; Associates LLP on b. Amenity space forming a key link within the County’s proposed Aylesbury Linear Park; behalf of c. A ‘Blue Grid’ network of incidental amenity space throughout the heart of the built development, incorporating linear SuDS Buckinghamshire attenuation and conveyance features and forming a grid pattern which includes the Canalside development; Advantage) d. A Primary flood conveyance corridor and woodland which forms the main ‘setting’ for arrival at the Aylesbury Woodlands; and e. A Wildlife Area along the Bear Brook, some of which would be accessible by the public in a controlled manner so as not to overly disturb wildlife. The specific alignment of buildings and private outdoor space and proposed boundary treatments (e.g. walls, fences and planting) would be considered as part of a Reserved Matters application, but BA agrees with the general guidance as set out in this policy relating to outlook, orientation, enclosure, usability, accessibility and security

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ID Respondent Name Comment VALP16-09-08-01209 Tim Coleby (Peter Brett Policy BE3 - There are few existing adjacent residents to Aylesbury Woodlands. The nearby residential dwellings are located and Associates LLP on assessed in the Landscape and Visual Impact Assessment (LVIA) chapter of the EIA accompanying the outline planning application. behalf of In all cases, there is a very substantial development offset between proposed development and existing dwellings, for example Buckinghamshire College Farm and dwellings along Aston Clinton Road. In instances where proposed development would be visible from nearby Advantage) existing dwellings and appropriate level of structural planting is proposed that would filter or screen the development without being overbearing in itself. For these reasons, there is no expectation that Aylesbury Woodlands (as described by the Parameter Plans) would unreasonably harm any aspect of the amenity of nearby residents, when considered against the benefits arising from the proposals.

On this basis, BA supports policy BE3. VALP16-09-08-01225 Frazer Hickling (Phillips Policy BE3 - The built environment chapter sets out policies in relation to the historic, environment, design and amenity. Planning Services Limited) We have no comments to make in relation to these policies, however it is noted that the ‘External Space Standards’ section of policy BE2 relates purely to the residential development. It is therefore considered that this would more usefully be located within the housing chapter of the plan. VALP16-09-08-01233 Mark Hyde MRTPI Policy BE3 - Environmental Benefits AIEMA (South West • Provide substantial areas of Green Infrastructure which include new habitats of native broadleaved woodland, species-rich Milton Keynes grassland and wetland to enhance wildlife; Consortium) • Provide additional strategic landscaping, woodland planting, green infrastructure and open space to enhance the surrounding landscape; • Promote sustainable forms of transport by including walking, cycling and public transport infrastructure and facilities, which connect to the existing networks in the surrounding area; • Deliver a Framework Travel Plan to manage and promote walking and cycling within the site and surrounding area, including initial targets and measures to achieve a modal shift towards non-car modes of transport; • Deliver a Public Transport Strategy comprising a new bus service through the Application Site, and a commitment by the developer to fund new vehicles to service the proposed new bus route; • Reduce in-commuting by car which would have positive benefits for air quality; • Contribute towards traffic calming in Newton Longville to discourage rat-running and speeding traffic; • Reserve land for a possible extension of the grid road so in the long term a connection can be made from the A421 to the A4146, which would remove through traffic (including HGVs) from local villages. VALP16-09-08-01283 Simon Proctor (Proctor Policy BE1 - BE1Development adjacent to any conservation area should draw influence from the conservation area not seek to Surveyors (Stoke mimic or provide a pastiche. Development adjacent should be encouraged where it enhances or mitigates against previous Hammond 2)) inappropriate development. VALP16-09-08-01283 Simon Proctor (Proctor Policy BE2 - BE2This policy should not be used to prevent or hinder innovate design. In paragraph c the presumption is that the Surveyors (Stoke existing development is of high quality and this may not be the case. Hammond 2)) Appropriate flexibility must be allowed in application of the standards to reflect individual circumstance as such guidance is often based on new green field development and on infill or sites within a conversation area are too restrictive.

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ID Respondent Name Comment VALP16-09-08-01283 Simon Proctor (Proctor Policy BE3 - BE3Amenity is subjective. Laws of nuisance and rights to light should prevail. Surveyors (Stoke Hammond 2)) VALP16-09-08-01291 Martin Small (Historic Policy BE1 - Policy BE1 – we welcome this in principle as a detailed development management policy setting out the requirements England) of development proposals and providing an indication of how a decision maker should react to a development proposal, but to provide a “clear indication” as required by paragraph 154 of the NPPF it should be more explicit as to when permission would be granted. We consider that a development management policy (or policies) is necessary as part of the positive strategy for the conservation and enjoyment of, and the clear strategy for enhancing, the historic environment required by the NPPF. However, it is not a “strategic” policy as required by paragraph 156 of the NPPF, with which neighbourhood plans should be in general accordance. This can be overcome by introducing a more generic introduction in this policy or a new policy on the Council’s approach to heritage assets. We are not clear why it does not include listed buildings. We consider that development management policies for the historic environment should include criteria for assessing the potential impact of development proposals on the significance of all relevant heritage assets: designated assets such as listed buildings, Scheduled Monuments, conservation areas and Registered Historic Parks and Gardens, and non-designated assets, such as those of local significance (as identified on local lists), archaeological deposits (as identified on the Buckinghamshire Historic Environment Record and historic landscapes (as may be identified in the Aylesbury Vale Historic Landscape Character Assessment/ Buckinghamshire Historic Landscape Characterisation. The development management policy or policies should reflect the requirement in paragraph 132 of the NPPF that any harm or loss of a heritage asset should require clear and convincing justification, most often in the form of public benefits. In accordance with paragraphs 132 -135 of the NPPF, the more important the asset, the greater the weight that should be given to its conservation – the greatest weight should be given to designated heritage assets of the highest significance, then other designated assets, then non- designated assets (including archaeological remains, except those that are demonstrably of equivalent significance to designated heritage assets – also known as “nationally important”, which should be considered subject to the policies for designated heritage assets). As explained above, we feel that Policy BE1 is somewhat confused in that a. – f. appear to be a list of information requirements from applicants where their proposed development would affect a heritage asset or assets (which we welcome), whereas g. is a statement of intent by the Council (which we also welcome) and in its use of the term “site of archaeological importance”.

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ID Respondent Name Comment VALP16-09-08-01291 Martin Small (Historic In addition we feel that the Policy does not clearly distinguish between the Council’s approach to designated assets and non- England) designated assets, as exemplified by the generic terms “site of archaeological importance” and “park or garden of special historic interest”, whereas the NPPF does distinguish in its policies.

It would be helpful if there was a sub-heading for “Conservation Areas”. Strictly-speaking, “historic interest” in the first sentence under the “Archaeology and ancient monuments” sub-heading should be “archaeological and historic interest”.

Paragraph 8.34 – we welcome the recognition of the historic environment as an important component of local distinctiveness and the encouragement of development that respects the historic characteristics of its surroundings, as part of the positive strategy for the conservation and enjoyment of, and the clear strategy for enhancing, the historic environment required by the NPPF.

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ID Respondent Name Comment VALP16-09-08-01291 Martin Small (Historic Policy BE 1 - Section 8 – we would prefer this section of the Plan titled “Historic and Built Environment” to reflect more fully the England) matters it covers. . Paragraphs 8.1 - 8.7 – we welcome these paragraphs as part of the positive strategy for the conservation and enjoyment of, and the clear strategy for enhancing, the historic environment required by the NPPF.

Paragraph 8.8 – this should be titled “Non-designated heritage assets”. We consider that it would be helpful for the Plan to explain the difference between designated and non-designated heritage assets, recognising that some non-scheduled archaeological remains may demonstrably be of equivalent significance to scheduled monuments, as part of the positive strategy for the conservation and enjoyment of, and the clear strategy for enhancing, the historic environment required by the NPPF.

Paragraph 8.9 - we consider that this paragraph would be better as the second paragraph in Section 8 as “significance” relates to both designated and non-designated assets.

Paragraph 8.10 – we consider that it would be clearer and accord more with the NPPF if this paragraph read “The following criteria will be used by the council as local planning authority to establish whether any building, monument, site, place, area or

Landscape meets the definition of a non-designated heritage asset in the National Planning Policy Framework”.

Paragraph 8.11 – we consider that the Plan would read better if this paragraph followed the paragraphs on the criteria.

Paragraph 8.13 – this does not accord with the definition of “archaeological interest” in the NPPF “There will be archaeological interest in a heritage asset if it holds, or potentially may hold, evidence of past human activity worthy of expert investigation at some point. Heritage assets with archaeological interest are the primary source of evidence about the substance and evolution of places, and of the people and cultures that made them.” This paragraph should therefore be amended.

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ID Respondent Name Comment VALP16-09-08-01291 Martin Small (Historic Paragraph 8.24 – Paragraph 126 of the NPPF requires the positive strategy for the conservation and enjoyment of the historic England) environment to include heritage assets most at risk through neglect, decay or other threats. There are 11 assets at risk on the current Register, including the grade I listed Church of St Mary in Long Crendon, although the Register does not include grade II listed buildings or parks/gardens.

We therefore welcome, in principle, paragraph 8.24, but we feel that it fails to really grasp the issue of heritage at risk. However, we welcome the Council’s commitments to heritage at risk in Policy BE1, although they are rather lost in what otherwise appears to be a list of information requirements from applicants where their proposed development would affect a heritage asset or assets.

Paragraphs 8.25 – 8.28 – we welcome these paragraphs in principle. However, the consent of the Secretary of State is needed only for proposals that directly affect a scheduled monument, not for proposals within the setting of a monument, even though the NPPF recognises that significance can be harmed or lost by development within the setting of a heritage asset.

We are unclear exactly what the Council has in mind by “sites of archaeological importance” in paragraph 8.26. Given that paragraph 8.25 covers scheduled monuments, we presume that paragraph 8.26 is intended to cover non-scheduled archaeological remains.

However, Policy BE1 only refers to sites of “archaeological importance”, which suggests that the Council is using this as a generic term to cover all archaeological sites, whether scheduled or not. As “sites of archaeological importance” is not a recognised term, this needs clarifying – “sites of archaeological interest” (which is defined in the NPPF) would be a better term (see our comment on paragraph 8.13 above).

This clarification should include a reference to non-scheduled heritage assets of archaeological interest that are demonstrably of equivalent significance to scheduled monuments (also known as “nationally important” assets), which paragraph 139 of the NPPF explains should be subject to the policies for scheduled monuments. We welcome the expectation that important archaeological remain will be preserved in situ in paragraph 8.28, but the first sentence needs rewording as it currently implies that the expectation is that the proposals are to be preserved in situ !

VALP16-09-08-01291 Martin Small (Historic Paragraph 8.29 – this paragraph could explain that inclusion on the Register of Historic Parks and Gardens means that consideration England) has to be given to the impact of a proposed development on the park or garden as a material consideration. “English Heritage” should now be “Historic England”. Is there a county list of parks and gardens ? VALP16-09-08-01291 Martin Small (Historic Policy BE2 - Policy BE2 – we welcome Policy BE2. England)

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ID Respondent Name Comment VALP16-09-09-01315 Neil Tiley (Pegasus Policy BE1 - Policy BE1 proposes that development will not be permitted if it results in harm to conservation areas. However, this is Group (on behalf of contrary to paragraph 133 of the NPPF which identifies that applications should only be refused where the harm to designated assets Jeremy Elgin)) is substantial and only where this harm is not outweighed by substantial public benefits. The Policy also recognises that harm can be associated with the settings of conservation areas. The Western Expansion to Haddenham option for a new settlement lies immediately adjacent to and within the setting of the Haddenham Conservation Area and so will inevitably cause harm. However, the Waldridge Garden Village is large enough to provide the flexibility to avoid and/or minimise any harm to the setting of conservation areas and so should be preferred. VALP16-09-09-01315 Neil Tiley (Pegasus Policy BE2 - Policy BE2 is followed by a section on the space between dwellings. It is not clear whether this is intended to be applied Group (on behalf of as policy or as guidance. There is also no supporting evidence for this section. Jeremy Elgin)) The effects of this section on the capacity of allocations has also not been considered, and so it is possible that this would significantly reduce the developable supply in which case additional allocations would be required. It may also affect the viability of schemes which will need to be tested. VALP16-09-09-01399 Cllr Phil Yerby Policy BE1 - We support the policy. VALP16-09-09-01399 Cllr Phil Yerby Policy BE2 - It should be made clear that the overall design of new developments will be considered at Outline Planning Stage VALP16-09-09-01399 Cllr Phil Yerby Policy BE3 - We support the aim of the policy but it is weakly worded: “would unreasonably harm any aspect of the amenity ...when considered against the overall benefits...” will lead to debate and is very difficult to substantiate. The thinking and wording here need to be smart. VALP16-09-09-01402 Stephen Beal Policy BE1 - Agree VALP16-09-09-01413 Michelle Thompson Policy BE1 - Agree. VALP16-09-09-01427 Phil Yerby (Hampden Policy BE1 - We support the policy. Fields Action Group) VALP16-09-09-01427 Phil Yerby (Hampden Policy BE2 - It should be made clear that the overall design of new developments will be considered at Outline Planning Stage Fields Action Group) VALP16-09-09-01427 Phil Yerby (Hampden Policy BE3 - We support the aim of the policy but it is weakly worded: “would unreasonably harm any aspect of the amenity ...when Fields Action Group) considered against the overall benefits...” will lead to debate and is very difficult to substantiate. The thinking and wording here need to be smart. VALP16-09-09-01440 Nick Butler Policy BE1 - 4 village assets: Heritage properties are confused and too easy to overturn for development. VALP16-09-09-01451 Geoff Culverhouse Policy BE1 - 8.1 In the list which follows the opening two sentences item ‘g’ should be separated and become an independent (North Bucks Parishes sentence as the content does not relate to the list above. We feel that support for heritage assets in AVDC’s area has been in decline Planning Consortium) in recent times. How successful this policy will be in protecting heritage assets will depend entirely on the interpretation of it in planning decisions.

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ID Respondent Name Comment VALP16-09-09-01451 Geoff Culverhouse Policy BE2 - Policy BE2 Design of new development (North Bucks Parishes 8.2 We have some concern that this policy restricts opportunities for modern design where appropriate and will merely encourage Planning Consortium) developments which are a pastiche of historic local development, often with mixed period styles of dwellings. Policy BE2a External space standards 8.3 We have shown this item as policy BE2a as it would appear that it is a separate policy but has not been given a reference number. This should be clarified which may need renumbering in this section. VALP16-09-09-01451 Geoff Culverhouse Policy BE3 - No further comment. (North Bucks Parishes Planning Consortium) VALP16-09-09-01468 Sarah Hamilton-Foyn Policy BE1 - Policy BE1 proposes that development will not be permitted if it results in harm to conservation areas. However, this is (Pegasus Group (Revera contrary to paragraph 133 of the NPPF which identifies that where a proposed development will lead to substantial harm to or total Limited on behalf of loss of significance of a designated heritage asset, local planning authorities should refuse consent, and only where this harm is not M&G Property Limited outweighed by substantial public benefits. Partnership)) VALP16-09-09-01468 Sarah Hamilton-Foyn Policy BE2 - Policy BE2 is followed by a section on the space between dwellings. It is not clear whether this is intended to be applied (Pegasus Group (Revera as policy or as guidance. There is also no supporting evidence for this section of the Plan. Limited on behalf of The effects of this section on the capacity of allocations has also not been considered, and so it is possible that this would M&G Property Limited significantly reduce the developable supply in which case additional allocations would be required. It may also affect the viability of Partnership)) schemes which will need to be tested. VALP16-09-12-01514 Simon Proctor (Proctor Policy BE1 - 8.27 The definition of an archaeological field evaluation is unclear. Proportionate archaeological investigations only Surveyors (Gawcott)) should be required, this may take the form of a desk based assessment.

BE1Development adjacent to any conservation area should draw influence from the conservation area not seek to mimic or provide a pastiche. Development adjacent should be encouraged where it enhances or mitigates against previous inappropriate development. VALP16-09-12-01514 Simon Proctor (Proctor Policy BE2 - This policy should not be used to prevent or hinder innovate design. In paragraph c the presumption is that the existing Surveyors (Gawcott)) development is of high quality and this may not be the case. Appropriate flexibility must be allowed in application of the standards to reflect individual circumstance as such guidance is often based on new green field development and on infill or sites within a conversation area are too restrictive. VALP16-09-12-01514 Simon Proctor (Proctor Policy BE3 - BE3Amenity is subjective. Laws of nuisance and rights to light should prevail. Surveyors (Gawcott)) VALP16-09-12-01515 Cameron Austin-Fell Policy BE1 - The policy needs to be re-considered in light of the requirements of the NPPF and NPPG. For example the policy states (RPS Planning & that development will not be permitted if it causes harm to the character or appearance of conservation areas or their settings. This is Development (on behalf inconsistent with chapter 12 of the NPPF. An example of where the Local Plan allows for the balancing approach to take place is of Richborough Estates Policy NE1 (first sentence). The Council should re-consider all policies in the plan in this context. Site - Churchway, Haddenham))

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ID Respondent Name Comment VALP16-09-12-01515 Cameron Austin-Fell Policy BE2 - Requiring all new developments to follow the guidance in adopted design guides effectively elevates the SPD or similar (RPS Planning & to policy. The policy must be amended to indicate developments must demonstrate how they have considered such design guides. Development (on behalf Similarly, the space standards between dwellings are better placed in SPD, as opposed to the Local Plan. of Richborough Estates Site - Churchway, Haddenham)) VALP16-09-12-01521 Sean Carolan (Winslow Policy BE2 - In light of more and more land being used for development it is an absolute must that new developments are well Town Council) landscaped and that planting schemes put forward by developers are adhered to and actually carried out. More emphasis needs to be placed on good landscape design with large numbers of trees to break up the flat monotony of new developments.

The current wording of Policy BE2 may restrict opportunities for modern design and simply encourage developments which are a pastiche of historic local development, often with mixed period styles of dwelling.

VALP16-09-12-01523 Cameron Austin-Fell Policy BE1 - The policy needs to be re-considered in light of the requirements of the NPPF and NPPG. For example the policy states (RPS Planning & that development will not be permitted if it causes harm to the character or appearance of conservations areas or their settings. This Development (on behalf is inconsistent with chapter 12 of the NPPF. An example of where the Local Plan allows for the balancing approach to take place is of Richborough Estates Policy NE1 (first sentence). The Council should re-consider all policies in the plan in this context. Site - Lower Road, Aylesbury)) VALP16-09-12-01523 Cameron Austin-Fell Policy BE2 - Requiring all new development to follow the guidance in adopted design guides, effectively elevates SPD or similar to (RPS Planning & policy. The policy must be amended to indicate developments must demonstrate how they have considered such design guides. Development (on behalf Similarly, the space standards between dwellings are better placed in SPD, as opposed to the Local Plan. of Richborough Estates Site - Lower Road, Aylesbury)) VALP16-09-12-01538 Jon Gateley (Savills (on Policy BE2 - This policy sets out an approach to design which is generally appropriate. However CSP do not agree with the wording behalf of Crest Strategic that: ‘All new development proposals shall’ follow the guidance set out within the council’s adopted design guides and shall respect Projects)) and complement: ….. c. The local distinctiveness and vernacular character of the locality, in terms of ordering, form, proportions, architectural detailing and materials. Modifications to Policy BE2 sought by CSP The Policy should be redrafted to reflect an approach to contemporary design on strategic sites and how this may involve contrast of design and form, particularly when seeking to create a distinctive sense of place, while still respecting vernacular design.

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ID Respondent Name Comment VALP16-09-12-01567 Laura Tilston (Gladman Policy BE1 - Gladman do not believe Policy BE1 is in accordance with the requirements set out in the Framework and therefor will Developments) not be capable of being found sound in its current form. Policy BE1 needs to differentiate between designated and non-designated heritage assets and the policy tests the framework sets out for each. The Framework states that if the harm to a designated heritage asset is deemed to be substantial, then the proposal needs to achieve substantial public benefits to outweigh the harm. If the harm is less than substantial, then the harm should be weighed against the public benefits of the proposal including securing its optimal viable use.

With reference to non-designated heritage assets Policy BE1 should reflect the guidance given in paragraph 135 of the Framework. This states that the policy test to be applied in these cases is that a balanced judgement should be reached having regard to the scale of any harm and the significance of the heritage asset.

Policy BE1 should therefore make a distinction between the two tests included in the Framework for designated heritage assets to ensure that it is capable of being found sound.

Policy BE1 states “Proposals for development will not be permitted if they cause harm to the character or appearance of conservation areas, their setting or any associated views of or from the conservation area.” Gladman submit that this element of Policy BE1 is too onerous. The use of the phrase ‘cause harm’ is too vague and all encompassing. The policy should refer to the scale of harm caused and the need to consider this in a balanced manner.

VALP16-09-12-01612 Jane Rogers Policy BE1 - 1 This unspoiled area of open countryside is more precious to our sense of place than the AONB, it should be preserved for its own sake. Your proposals would mean that one of the few areas of unspoiled countryside remaining in this area would be destroyed forever. VALP16-09-12-01617 Christopher Walker Policy BE2 - We acknowledge the housing pressures that influence the strategic objectives of the plan and would urge the Council to (Drayton Beauchamp ensure that new housing is properly designed and integrated successfully to safeguard the character of existing settlements across Parish Council) the Vale. With so much change proposed, we feel it important that adequate resources are made available to realise the spatial vision through the more detailed policies of the plan, rather than see a continuation of the more ad hoc developer driven proposals that have been put forward in recent years. VALP16-09-12-01637 Michael John Coker Policy BE1 - HERITAGE I am perturbed by AVDC's cavalier attitude to the preservation of the heritage features of the Croft Meadow /Town Farm site by its scant dismissal of 'ridge and furrow' farming contours seemingly on the grounds that there many other examples of this in the vicinity.

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ID Respondent Name Comment VALP16-09-12-01641 MICHAEL KNOTT Policy BE1 - Gallagher Estates support the need for all applications that relate to a heritage asset to have regard to the specific (Gallagher Estates) guidance set out in the council's adopted Conservation Areas Supplementary Planning Document, design guides, and advice notes. Sites such as Land at Eaton Leys can come forward without any significant adverse cumulative effects on heritage assets. In fact, as is the case in respect of the current proposal for Land at Eaton Leys, a number of positive heritage benefits have been identified.

As is set out clearly in the documentation contained within the current outline planning application (ref: 15/02201/AOP) following early consultation with English Heritage and relevant local authority archaeological officers, measures have been incorporated into the Parameter Plans to protect in-situ, preserve, manage and enhance that part of the designated area of Magiovinium that falls within the application site. In addition, a non-designated area of sub-surface features, identified by geophysical survey, and evidently associated with the Roman settlement will be preserved in-situ within open space. Baseline conditions have been established by a Desk Based Assessment which has considered built, buried and other historic landscape assets and this has been supplemented by a walkover inspection and a site-wide geophysical survey.

Defining the setting of the designated and non-designated Roman settlement is difficult because there are no appreciable earthwork remains or other visible traces (other than plough-damaged artefacts on the field surface) to indicate the presence of this archaeological site. However, the settlement owes its origins to the crossing point of Watling Street over the River Ouzel and the axis of the settlement lies along Watling Street. Development will alter the current rural context of the designated asset. However, it is considered that benefits accruing from removing this site from damaging ploughing outweighs any harm to the setting of the assets caused by development to the south of the designated area.

Baseline desk and geophysical studies, undertaken in accordance with industry standards, have identified a number of archaeological assets on and in close proximity to the Site and designated built heritage assets (listed buildings and conservation areas) in the hinterland of the Development. Site inspections have identified that there is no intervisibility between the Site and most of the built heritage assets such that development would have any significant impact on the asset or its setting. Where potential impacts to built or archaeological assets are considered possible, these have been assessed.

VALP16-09-12-01641 MICHAEL KNOTT In addition to the measures to protect and enhance the designated Roman settlement of Magiovinium, a number of development- (Gallagher Estates) related impacts are identified on archaeological assets and where appropriate mitigation by archaeological excavation, recording and dissemination of results is proposed. Following submission of the outline planning application for Land at Eaton Leys, further intrusive archaeological investigations in the form of trial trenching were requested by Aylesbury Vale District Council and are currently on- going. The submission of additional archaeology is expected to be submitted by the applicant during October which we expect will confirm the suitability of the site for development and the benefits the proposal will bring in terms of heritage value.

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ID Respondent Name Comment VALP16-09-12-01641 MICHAEL KNOTT Policy BE2 - Gallagher Estates agree that all new development proposals shall follow the guidance set out within the council's (Gallagher Estates) adopted design guides and shall respect and complement: a. The physical characteristics of a. the site and its surroundings. b. The scale and context of the site and its setting. c. The local distinctiveness and vernacular character of the locality, in terms of ordering, form, proportions, architectural detailing and materials. d. The natural qualities and features of the area. e. The effect on important public views and skylines. VALP16-09-12-01641 MICHAEL KNOTT Policy BE3 - Gallagher Estates agree that planning permission will not be granted where the proposed development would (Gallagher Estates) unreasonably harm any aspect of the amenity of nearby residents when considered against the benefits arising from the proposal.

VALP16-09-13-01672 Derek Bromley Policy BE2 - The external space standards are excessive and more onerous that the policy guidance of other nearby authorities. The use of the space distances will reduce the efficiency of land use. We do not consider that the additional three storey height of building materially impacts upon the privacy between households. Other than for amenity space and privacy standards, the spacing of buildings within the development is a matter of urban design. We consider that space requirements should be amended as follows: Front to front- 20 metres • Back to back - 22 metres • Side to back- 11 metres.

VALP16-09-13-01674 Nicola Thomas (Milton Policy BE2 - Specific guidance on incorporating biodiversity in and around developments for multiple benefits should inform Policy Keynes Natural BE2, Design of new development (Section 8 of draft Local Plan, pg 157). Environment Partnership) VALP16-09-13-01691 Roy van de Poll Policy BE3 - In the light of more and more land being used for development it is an absolute must that new developments are well landscaped and that planting schemes put forward by developers are adhered to and actually carried out. More emphasis needs to be placed on good landscape design with large numbers of trees to break up the flat monotony of new developments.

VALP16-09-13-01696 Mark Owen (Barton Policy BE1 - We agree with the principle of Draft Policy BE1 (Heritage Assets) that proposals for development should protect, and Willmore (on behalf of where possible, enhance heritage assets. In addition we also consider that it is appropriate that development proposals affecting a Hampden Fields site of archaeological importance should preserve the historic interest without substantial change to the site itself. This does not and Consortium)) should not imply that change cannot be accommodated in immediately adjoining areas and the policy should be applied positively to enable change to be accommodated whilst preserving the most important heritage assets. The impact of development on archaeological features has been considered appropriately as part of the Hampden Fields development which has included correspondence with the County Council’s archaeology officer to ensure that such features are preserved appropriately.

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ID Respondent Name Comment VALP16-09-13-01696 Mark Owen (Barton Policy BE2 - We agree that all new development proposals should follow the guidance set out within the Council’s adopted design Willmore (on behalf of guides as indicated by Draft Policy BE2 (Design of New Development) although it is considered that this policy should also refer to Hampden Fields national policy in particular section 7 (Requiring Good Design) of the NPPF. That said, the Hampden Fields proposal has been Consortium)) designed with the Council’s adopted design guides in mind to ensure that the development respects the character, form, scale and context of the surrounding residential areas as well as providing appropriate areas of open space to ensure separation from neighbouring villages such as Weston Turville.

We also agree with the importance of external space standards as referred to within Draft Policy BE2 (Design of New Development) and in regards to the Hampden Fields proposal it is expected that such standards would be considered thoroughly at a detailed matters stage. VALP16-09-13-01697 Jodi Stokes (Persimmon Policy BE2 - Space between Dwellings Homes Midlands) The minimum front to front distance of 22 metres between two 2 storey dwellings is unnecessarily high. This should be balanced with what parking solutions are used and also from an urban design viewpoint to create different vistas and different character areas within a site.

The minimum front to front distance of 28 meters between a 2 storey and 3 storey dwelling is also unnecessarily high. It should be considered that this will have an impact on urban design, parking solutions and also the density of any scheme. There is no justification on why this would need to be higher than the front to front of two 2 storey dwellings. VALP16-09-13-01702 Derek Bromley Policy BE2 - The external space standards are excessive and more onerous than the policy guidance of other nearby authorities. (Bidwells) The use of the space distances will reduce the efficiency of land use. We do not consider that the additional three storey height of buildings materially impacts upon the privacy between households. Other than for amenity space and privacy standards the space in the buildings within a development is a matter of urban design. We consider the space requirements should be amended as follows: Front to Front- 20 metres Back to Back- 22 metres Side to Flank- 11 metres

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ID Respondent Name Comment VALP16-09-13-01708 Rachel Wileman Policy BE1 - Archaeology (Buckinghamshire County Council) BCC welcome the inclusion that the historic environment throughout the document(s) such as:

•Objective 6 of the Strategic Objectives. •Policy S1 part g. •Policy C3 part c. •4.26 •and that it recognises the interpretation possibilities of the major archaeological sites on the Aylesbury Linear Park Green Infrastructure Proposal Map. We especially welcome Chapter 8 on the Built Environment and associated Policy BE1 Heritage Assets.

We do however query the wording of 8.13 Archaeological Interest in Chapter 8.

The NPPF Annex 2: Glossary defines Archaeological Interest as:

•There will be archaeological interest in a heritage asset if it holds, or potentially may hold, evidence of past human activity worthy of expert investigation at some point. Heritage assets with archaeological interest are a primary source of evidence about the substance and evolution of places, and of the people and cultures that made them.

The NPPF Annex 2: Glossary defines a Heritage Assets as:

•A building, monument, site, place, area or landscape identified as having a degree of significance meriting consideration in planning decisions, because of its heritage interest. Heritage asset includes designated heritage assets and assets identified by the local planning authority (including local listing).

The NPPF Annex 2: Glossary defines a Historic Environment Record as:

•Information services that seek to provide access to comprehensive and dynamic resources relating to the historic environment of a defined geographic area for public benefit and use.

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ID Respondent Name Comment VALP16-09-13-01708 Rachel Wileman The NPPF Annex 2: Glossary defines Historic Environment as: (Buckinghamshire County Council) • All aspects of the environment resulting from the interaction between people and places through time, including all surviving physical remains of past human activity, whether visible, buried or submerged, and landscaped and planted or managed flora.

The Buckinghamshire County Archaeological Service therefore provides information and advice on above and below ground heritage assets; we would however expect AVDC to maintain its expertise and the provision of information and advice on the historic built environment such as Listed Buildings and Conservation Areas.

VALP16-09-13-01708 Rachel Wileman Policy BE2 - Public health (Buckinghamshire County Council) There are specific health challenges in Buckinghamshire where building places which make healthy choices easier choices and which support healthy and resilient communities can help to make improvements. Both nationally and locally people are living longer, but they are also spending more time in poorer health which is a cost to the individual and to local services.

There are increasing levels of long term conditions, such as diabetes, high blood pressure, cardiovascular disease and lung disease. However these are largely preventable. The prevalence of long term conditions is driven by the ageing population and low levels of healthy lifestyles which protect against these conditions. In March 2015 there were 24,925 patients in Buckinghamshire which is expected to rise by around 17% between 2015 and 2020.

Adopting healthier lifestyles can make a major contribution to increasing healthy life expectancy with behavioural risk factors accounting for 25.8% of disability adjusted life years and 4.5% being attributable to environmental factors such as air pollution. The leading contributor to the burden of disease are smoking (12%), being overweight or obese (9%), being physically inactive (5%), drinking alcohol above recommended limits (5%) and poor diet (5%).

Although Bucks is generally affluent and this is reflected in health outcomes that are better than the national average, there are still concerning levels of unhealthy lifestyles: •14.5% (around 58,400 adults) smoke •91% of 2 – 4 year olds (18,690 children in Buckinghamshire), do not meet recommended levels of activity and that only 26% of boys aged 5 – 15 (9703 boys) and 16% of girls (5678 girls) meet the recommended levels. •20.9% of adults are inactive (87,000 people) and do less than 30 minutes physical activity per week •62% of adults in Buckinghamshire are overweight or obese, with 26% being obese •7.2% of 4 – 5 year olds are obese and this doubles to 14.2% in 10 – 11 year olds •1 in 5 adults in Buckinghamshire are consuming alcohol at levels that are a risk to their health, which is estimated to be 106,700 adults aged 16 and over

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ID Respondent Name Comment VALP16-09-13-01708 Rachel Wileman The burden of disease is greater in poorer communities in Buckinghamshire with a difference in 15 years life expectancy for men (Buckinghamshire and 18 years for women between the areas with the highest and lowest life expectancy. Planning policies which contribute to the County Council) creation of quality and health promoting environments are key. VALP16-09-13-01715 Susan Fenn Policy BE3 - In Grendon Underwood the residents enjoy the benefits of a linear village. They do not have a lot of houses built behind them and can therefore enjoy the countryside, which is why they have chosen to live in such a village. Any building behind existing houses would mar this enjoyment. It would also cause major disruption to such residents.

Also if building is allowed behind existing properties it would mean a lot more traffic accessing the main street at one single point. At certain times of the day there are a lot of parked cars on main street and it can be rather busy, especially at school times. Increased traffic in this already busy road would increase the risk of injury for those children who walk to school. It would be better to extend the village out towards Kingswood along the one road, as most additional traffic would then exit the village via Kingswood onto the A41

VALP16-09-13-01717 Michael Brown Policy BE1 - The village is an ancient settlement, with a 12th century church and many ancient thatched cottages -even a thatched pub. As a result, a number of parts of the village are designated as conservation areas, such as those off Worminghall Road.

VALP16-09-13-01717 Michael Brown Policy BE3 - The village is low lying on the edge of a river flood plain, and the topography causes drains to overflow and sewage to flow down the streets and into homes. VALP16-09-13-01718 Craige Burden Policy BE2 - The policy is not specific and needs to be reconsidered. Particular attention needs to be had in relation to the external (Persimmon Homes) space standards, with terms being defined more clearly (such as 'steeply sloping'). VALP16-09-13-01722 Sarah James Policy BE3 - Residents want to live in.Villages,people pay good money to live in rural areas,to enjoy the countryside,the increase in traffic and noise is going to be huge..especially for.newton longville. VALP16-09-13-01817 Simon Proctor (Proctor Policy BE1 - 8.27 The definition of an archaeological field evaluation is unclear. Proportionate archaeological investigations only Surveyors (Newton should be required, this may take the form of a desk based assessment. Longville)) BE1Development adjacent to any conservation area should draw influence from the conservation area not seek to mimic or provide a pastiche. Development adjacent should be encouraged where it enhances or mitigates against previous inappropriate development. VALP16-09-13-01817 Simon Proctor (Proctor Policy BE2 - BE2This policy should not be used to prevent or hinder innovate design. In paragraph c the presumption is that the Surveyors (Newton existing development is of high quality and this may not be the case. Longville)) Appropriate flexibility must be allowed in application of the standards to reflect individual circumstance as such guidance is often based on new green field development and on infill or sites within a conversation area are too restrictive. VALP16-09-13-01817 Simon Proctor (Proctor Policy BE3 - Amenity is subjective. Laws of nuisance and rights to light should prevail. Surveyors (Newton Longville))

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ID Respondent Name Comment VALP16-07-11-00200 Lesley Dance Policy NE2 - It is difficult to see how there can be any biodiversity when AVDC are planning to pave over Haddenham. Without our natural enivronment there is no wildlife and without our wildlife there are no pollinators, no resistance to flooding (ie hedges, trees etc) poor water and air quality. All this will impact on our economy VALP16-07-11-00200 Lesley Dance Policy NE8 - We need to retain what little trees and hedgerows we have left to protect our natural world. Trees and hedgerows also protect against the elements including flooding and wind damage. If we work with the environment instead of against it we can all gain.

VALP16-07-27-00230 Alan Bilham Policy NE3 - The most important landscape in the district is the Chilterns Area of Outstanding Natural Beauty in the vicinity of Wendover and Pitstone/Edlesborough. This forms part of a continuous landscape from Central Bedfordshire to South Oxfordshire. The Chiltern Hills.

Please be very aware that the land off Slicketts lane very much forms a part of the Important landscape of the Chilterns both from within the AONB and looking into the AONB. To develop this land would be quite wrong as it would totally destroy the rural nature of the area. There is also no adequate road access and so the destruction of Slicketts lane with it's ancient hedgrow would be inevitable. Edlesborough is not a 'Large' village and doesn't warrant such a high number of houses in this plan. Please re-consider your allocation for Edlesborough as you have got it wrong ! VALP16-07-29-00236 John Oldfield Policy NE6 - There is a history of flooding in the Great Ouse catchment. All new development should be founded around reducing (Buckingham and River the flood risk to the new development as well as the existing communities. Ouzel IDB) Flood Risk should be managed with strategic, integrated and maintainable Sustainable Drainage Systems and infrastructure. To ensure the SuDS continue to operate in the future, the Council should require a robust maintenance regime, which typically requires adoption by a statutory flood risk authority with a CIL/S106 commuted sum. This will ensure that they are maintained and that they continue to operate as designed in 10, 20, 30 years...

All SuDS assets should be designed, built and maintained to function to manage flood risk as well as provide the wider environmental and biodiversity benefits. The Plan should ensure development provides adequate space to deliver this mulit function space.

VALP16-08-10-00284 Roz Owens Policy NE3 - I applaud the inclusion of provision for reduction of the impact of lighting. This is particularly important in a village such as Haddenham where the village is relatively dark at night, and should remain so! VALP16-08-10-00284 Roz Owens Policy NE8 - In a rural area such as Haddenham it is most important that roads maintain the old hedgerows and verges which are important for wildlife and biodiversity and the maintenance of landscape quality. Developers should not just be allowed to plough these up and replace with a few suburban shrubs as token landscaping. VALP16-08-11-00299 Andrew Cole Policy NE5 - Please see previous comments.

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ID Respondent Name Comment VALP16-08-15-00325 Martin Hodson Policy NE7 - Sections 9.42 and 9.43 I am a Visiting Researcher and former Principal Lecturer in Environmental Biology at Oxford Brookes University, but am writing in a personal capacity. I have worked on environmental impact assessment for many years, particularly looking at soils and land impacts of developments. I have become increasingly concerned at the steady decrease in protection of our best and most versatile agricultural land (Grades 1, 2 and 3a). During the Second World War we really needed to maximise agricultural production as imports were severely restricted. After the War successive governments recognised this by protecting our best land, but the regulations were gradually relaxed. Now we import much of our food. With our increased population we have even more demand for food. But what happens if we suddenly find imports are more difficult again? Brexit may complicate things a bit, but suppose unfriendly regimes come to power in Europe. Then what? I really worry that much of the proposed building around Haddenham is on good quality agricultural land. Once it is built on it is effectively lost forever, and we will severely decrease our food security for the future. I would strongly advise locating the building on brownfield sites or at least on less good quality (3b, 4 and 5) land. I can see that Sections 9.42 and 9.43 have given some coverage to this topic, but there is not one mention of food security in the entire report. Surely this is a major oversight! VALP16-08-16-00341 Elaine Standen Policy NE3 - The land proposed for development MAR003 is not near to the centre of the village although MAR001 an MAR002 are very close to the centre and are brownfield sites. VALP16-08-16-00341 Elaine Standen Policy NE7 - The land proposed MAR003 is agricultural land and should be protected from development. There are brownfield sites available which should be considered as an alternative, MAR001 an MAR002. VALP16-08-17-00359 Angela Lucas Policy NE6 - I agree with this policy. VALP16-08-17-00359 Angela Lucas Policy NE7 - Agree with this policy VALP16-08-17-00359 Angela Lucas Policy NE8 - Policy NE8 Support this policy Paragraph 2 -protecting hedgerows and trees- these are such an important part of the AV landscape. VALP16-08-17-00361 Ella Jones (Wendover Comments removed at the request of Wendover Parish Council1 - 9.1: Wendover currently has an outline application partly within its Parish that borders the SSSI in Weston Turville. Parish Council) Wendover Parish Council strongly oppose this development and is pleased to see it is not in the draft VALP as it is so close to the SSSI. VALP16-08-17-00361 Ella Jones (Wendover Policy NE5 - 9.34: It is agreed that potentially contaminated sites need bringing back to beneficial use. It is suggested that the old Parish Council) sewage works off of Aylesbury Road are considered as a site for development instead of land off of Tring Road for this reason. VALP16-08-17-00361 Ella Jones (Wendover Policy NE6 - 9.40: Walnut Tree Meadow is part of the suggested land to be removed from the Green Belt (S4) for development but Parish Council) this land has been protected from development and is in a very central location in the community as well as being a small tact of land separated from the rest of the land in S4 by the canal. This land also floods regularly. 9.43: The land off of Tring Road suggested for removal from the Green Belt to provide for development is a large area of agricultural land. The land suggested off Aylesbury road does not have strong agricultural potential. VALP16-08-17-00362 Stephanie Lucas Policy NE1 - Agree with this policy VALP16-08-18-00363 Charlotte Newman Policy NE6 - I agree with this policy. Local Green spaces identified in neighbourhood plans should be respected. VALP16-08-19-00367 John Lucas Policy NE6 - Local Green Spaces identified in neighbourhood plans should be respected. I agree with this policy. VALP16-08-19-00367 John Lucas Policy NE8 - I agree with this policy. It is so important to protect the hedgerows and trees which make leafy Buckinghamshire .

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ID Respondent Name Comment VALP16-08-19-00374 Simon Milliken (National Policy NE3 - Comment: WE/NT/HHH support the re-designation of land in its control as Areas of Attractive Landscape. This policy Trust, Waddesdon should carry significant material weight when considering any proposal for development which could have an adverse impact on a Estate and Hartwell heritage asset. House) VALP16-08-20-00402 Martin Armitstead Policy NE1 - Ickford has special bio diversity that needs recognition and protection VALP16-08-20-00402 Martin Armitstead Policy NE3 - You cannot permit development without destroying the character. VALP16-08-20-00402 Martin Armitstead Policy NE8 - The hedgerows are not maintained to allow easy vehicle movement VALP16-08-21-00406 Richard Barrie Policy NE3 - Haddenham currently sits in a network of small communities. The proposed large scale development of Haddenham will absolutely destroy this ancient inter-relationship amongst these communities. VALP16-08-21-00406 Richard Barrie Policy NE7 - The agricultural land around Haddenham is some of the most productive available. This is land is far too important to just throw away for pointless development. VALP16-08-22-00437 Aidan Byles Policy NE1 - This means any proposed development (Worlds End) at or near Weston Turville reservoir will be turned down then??.

VALP16-08-23-00441 Alexander Matthews Policy NE1 - Already mentioned but can we nake sure the Great Ouse corridor is properly protected please? (Thornton Parish Meeting) VALP16-08-23-00446 Arthur Evans Policy NE3 - Pay due regard to all national policies. VALP16-08-23-00446 Arthur Evans Policy NE8 - Protect VALP16-08-24-00448 Michael Henderson Policy NE3 - We welcome the continued protection of areas of attractive landscape value. (Dinton with Ford and Upton Parish Council) VALP16-08-24-00489 Glynn White Policy NE5 - Policy NE5 seeks to prevent development if it materially affects “existing and continuous poor air quality” yet the strategy to put mass development to the South of Aylesbury shows significant increases in traffic at key Air Quality Management Areas, especially at the gyratory system in Aylesbury. VALP16-08-25-00529 Lucy Murfett (Chilterns Policy NE1 - The title should explain that these are natural environment protected sites to distinguish them from other forms of Conservation Board) protected sites eg historic environment or protected employment sites. NE1 and NE2 could potentially be streamlined and brought together. It is unclear why the supporting text about Special Areas of Conservation (para 9.9) is not part of the NE1 supporting text. NE1 should not just be about SSSIs, ancient woodland and ancient trees, it should establish a hierarchy including European sites (SACs) and assign them appropriate weight, in order to follow the advice in NPPF Para 113: “Local planning authorities should set criteria based policies against which proposals for any development on or affecting protected wildlife or geodiversity sites or landscape areas will be judged. Distinctions should be made between the hierarchy of international, national and locally designated sites, so that protection is commensurate with their status and gives appropriate weight to their importance and the contribution that they make to wider ecological networks.” VALP16-08-25-00529 Lucy Murfett (Chilterns Policy NE3 - To establish the appropriate hierarchy, this policy would sit better after NE4 on the AONB. Typos in para 9.15, correct Conservation Board) to: “Areas of Outstanding Natural Beauty” and para 9.17 “has not been given”

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ID Respondent Name Comment VALP16-08-25-00529 Lucy Murfett (Chilterns Policy NE4 - The Chilterns Conservation Board supports and welcomes the inclusion of this policy, which is based on joint work to Conservation Board) create a consistent Chilterns-wide AONB policy carried out with our Planning Forum of local policy officers and stakeholders. Some changes have been introduced e.g. the introduction of a distinction between major and non-major development with only criteria a, d and e applying to non-major development. If continuing this approach, it would be better if f-m applied to all development, whilst removing the requirement for every non-major development to carry out landscape and visual impact assessment. This could be achieved by changing the second half of the policy to read: “Actions to conserve and enhance the AONB shall focus upon: (list as before) then new criterion “(n) and in the case of major development proposals, shall be informed by landscape and visual impact assessment, having considered all relevant landscape character assessments” Various minor corrections are needed to the supporting text, which looks dated (e.g. refers to the Shadow Chilterns Conservation Board which was replaced by the Chilterns Conservation Board in 2004). This newly developed model supporting text might help improve the plan’s supporting text: “Areas of Outstanding Natural Beauty (AONBs) are designated by the Government for the purpose of ensuring that the special qualities of the finest landscapes in England and Wales are conserved and enhanced. In policy terms they have the same planning status as National Parks . The Chilterns AONB was designated in 1965 and extended in 1990. The Countryside and Rights of Way Act 2000 places a statutory duty on local authorities to have regard to the purpose of conserving and enhancing the natural beauty of AONBs when coming to decisions or carrying out their activities relating to, or affecting, land within these areas . The Chilterns AONB covers 13 local authorities and the Councils work together to safeguard the future of this shared nationally protected area through the Chilterns Conservation Board. The Board prepares a statutory AONB Management Plan which may be / has been endorsed as a material consideration in planning decisions . (delete as appropriate)

The AONB is a nationally designated landscape and as such permission for major developments will be refused unless exceptional circumstances prevail as defined by national planning policy . National guidance explains that whether a proposal constitutes major development is a matter for the relevant decision taker, taking into account the proposal in question and the local context . For the purposes of this plan, ‘major development’ will not be restricted to the definition of major development in the Town and County Planning (Development Management Procedure)(England) Order 2015 or to proposals that raise issues of national significance, and will include consideration of whether a proposal has the potential to have a serious adverse impact on the AONB. Add locally specific paragraph on AONB extent and special qualities and characteristics within each district. Development proposals which lie outside the AONB but within its setting can also have impacts on it. The Council’s duty of regard applies to development outside but which would affect land in an AONB . For example, views out of the AONB from key visitor viewpoints into surrounding areas can be very significant. Although it does not have a defined geographical boundary, the setting of the Chilterns AONB is the area within which development and land management proposals, by virtue of their nature, size, scale, siting, materials or design could be considered to have an impact, either positive or negative, on the natural beauty and special qualities of the Chilterns AONB. Advice on development in the setting of the AONB is contained within guidance produced by the Chilterns Conservation Board .”

VALP16-08-25-00530 Eric Sergeant Policy NE3 - Agree with all policies VALP16-08-25-00530 Eric Sergeant Policy NE5 - Agree with Noise pollution and Light pollution VALP16-08-25-00530 Eric Sergeant Policy NE7 - Strongly agree with part a. Date: 25/11/2016 Project Number: 1664569/A0 Page 4 of 66 VALP Summer 2016 Consultation Responses – Chapter 9 Natural Environment

ID Respondent Name Comment VALP16-08-28-00544 Kevin Hewson Policy NE3 - Fully supported and vital to rural communities VALP16-08-28-00544 Kevin Hewson Policy NE6 - Where land is identified as local green space in a Neighbourhood Development Plan, national policy must be applied. No new development should be permitted. Measures to improve public access should be encouraged. VALP16-08-28-00547 Bob LEWIS Policy NE4 - See previous comments. Do not Develop within the AONB and Green Belt areas. VALP16-08-28-00548 Nicola Page Policy NE6 - Must be available to all even in new settlements. There must be access to the countryside and existing paths outside the development and even new cycle paths put in to encourage people to cycle in country paths. VALP16-08-31-00569 Paul Moss Policy NE6 - Development at WHA01 will impact local green space which currently separates Whaddon from Milton Keynes Development. WHA01 encroaches on this space conglomerating with Milton Keynes into what is an amenity for Milton Keynes residents and an important wildlife corridor for bats etc. (AV Landscape Character Assessment 2008/2015, Buckingham and MK Bio Diversity Plan). I would like to see this area designated a Local Landscape Amenity to provide Whaddon with a defensible development boundary what will ensure its rural village nature. VALP16-08-31-00576 Mary and Allan Policy NE3 - We understand that a site that has been rejected on previous occasions is being considered for new development. this glendinning site is of historical interest and keeps the village in touch with the surrounding countryside. we are already losing a beautiful vista from the village by the agreed neighbourhood plan we object to further loss of visitas VALP16-08-31-00580 Fiona Lippmann Policy NE4 - 9.24 is in contradiction to removing the Green Belt in 3.37 VALP16-08-31-00581 Fiona Lippmann (Halton Policy NE4 - 9.24 is in contradiction to removing the Green Belt in 3.37 VALP16-08-31-00607 Eleanor Dolley Policy NE2 - The area of proposed development between Whaddon and MK is very beautiful and home to many species of animal including bats. This stretch of beautiful rural farmland was until recently, much larger, but has now been greatly reduced due to development around Calverton / Stony Stratford (e.g. the Stony Manor and Fairfields developments). To further eliminate the surrounding countryside is not acceptable to existing residents and should not be allowed in light of the additional animal habitat which will be lost. VALP16-08-31-00607 Eleanor Dolley Policy NE5 - Further reducing the green space in this area, and significantly increasing the number of households and cars must impact local air quality. VALP16-08-31-00607 Eleanor Dolley Policy NE6 - A significant proportion of the area of proposed development between Whaddon and MK should be marked as 'Local Green Space' - not only is it very beautiful rural space, but it is frequently used by residents of Milton Keynes and surrounding villages particularly by joggers, dog walkers, cyclists and horse riders. This is crucial recreational land for many in the local community, and is the reason why they moved to the area in the first place. VALP16-09-01-00618 Jonathan Proctor Policy NE7 - The Plan would result in the loss of agricultural land which is in the top "best and most versatile" (Stephenson Harwood) VALP16-09-01-00637 Viv Lynch (Wingrave Policy NE3 - 9.17 & 9.19 It is essential the AALs are preserved and in particular the views from the hills to the north of Aylesbury. with Rowsham Parish Council) VALP16-09-01-00637 Viv Lynch (Wingrave Policy NE5 - 9.27 Whilst lighting is important it needs to be in sympathy with its surroundings and not increase the levels of night time with Rowsham Parish night light pollution. Council) 9.34 Contaminated land should be cleaned thereby enabling these sites to be used as brown field development sites.

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ID Respondent Name Comment VALP16-09-01-00637 Viv Lynch (Wingrave Policy NE6 - 9.39 Where made Neighbour Plans identify local green spaces these should be recognised as such and will not be with Rowsham Parish developed VALP16-09-02-00641 Christopher Matthews Policy NE1 - Paragraph 9.4 - The local Haddenham Nature Reserve would be seriously adversely affected if the proposal for a new settlement to the west of Haddenham were adopted. However, as explained in comments under Chapters 3 and 4 I do not agree that there is a need for such a new settlement. VALP16-09-02-00641 Christopher Matthews Policy NE3 - Paragraphs 9.15 to 9.20 - ‘Development should consider the role of the landscape character area and: b) be located to avoid the loss of important on-site views and off-site views towards important landscape features’. Haddenham is situated so that there is a good view of the Chilterns across open countryside from many points in the village, due to the slope down from north to south. It is important that this is recognised and preserved. The new development at Aston Road will have a major impact in this respect. VALP16-09-02-00641 Christopher Matthews Policy NE7 - Paragraphs 9.42 & 9.43 ‘the council will seek to protect the best and most versatile farmland for the longer term.’ This principle must be adhered to when considering development in and around Haddenham. VALP16-09-02-00643 Angela Matthews Policy NE1 - Paragraph 9.4 - The local Haddenham Nature Reserve would be seriously adversely affected if the proposal for a new settlement to the west of Haddenham were adopted. However, as explained in comments under Chapters 3 and 4 I do not agree that there is a need for such a new settlement. VALP16-09-02-00643 Angela Matthews Policy NE3 - Paragraphs 9.15 to 9.20 - ‘Development should consider the role of the landscape character area and: b) be located to avoid the loss of important on-site views and off-site views towards important landscape features’. Haddenham is situated so that there is a good view of the Chilterns across open countryside from many points in the village, due to the slope down from north to south. It is important that this is recognised and preserved. The new development at Aston Road will have a major impact in this respect. VALP16-09-02-00643 Angela Matthews Policy NE7 - Paragraphs 9.42 & 9.43 ‘the council will seek to protect the best and most versatile farmland for the longer term.’ This principle must be adhered to when considering development in and around Haddenham. VALP16-09-02-00653 Quainton Parish Council Policy NE1 - The PC agree with this policy

VALP16-09-02-00653 Quainton Parish Council Policy NE6 - These areas are so important. 'Made' NDPs have selected green spaces important to locals and such areas should be protected. VALP16-09-02-00655 Frances Durkin Policy NE3 - Section NE3 addresses the need to preserve Particular Landscape Character Areas and I wish to argue that the Croft Meadows site in Cheddington is one of these areas. Not only does it provide stunning views from which the entire village benefits but it is also an important example of medieval 'ridge and furrow' farming techniques. This site must be protected. VALP16-09-02-00655 Frances Durkin Policy NE4 - As the section 9.2 emphasises, the "Chiltern Hills were designated as an Area of Outstanding Natural Beauty (AONB) in 1965 by the government in recognition that the Chilterns countryside is amongst the finest in England and Wales. The main purpose of designation is to conserve beauty which includes protecting flora, fauna and geological features as well as the overall landscape". The view from Cheddington across the Croft Meadows site benefits from this AONB and must be protected from development. The Cheddington Neighbourhood Plan has already provided practical alternative sites for the building of new housing in the village. Any development on the Croft Meadows site would "[affect] the setting or appreciation of the AONB" from Cheddington as set out in section NE4.

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ID Respondent Name Comment VALP16-09-02-00655 Frances Durkin Policy NE6 - Croft Meadows in Cheddington should be designated a Local Green Space according to the NPPF as it is located right beside the High Street and very close to the local Primary School thus benefitting local residents. It also connects the current agricultural role of the site to the significant heritage asset of the archaeological evidence of medieval 'ridge and furrow' farming techniques located on that site. This site is used for agriculture and gives exceptional views from the High Street across the local countryside to the Chiltern Hills. This view not only gives the village its character but it benefits the residents and should be protected for all residents present and future. VALP16-09-02-00664 Ken Trew (Cuddington Policy NE3 - Landscape Parish Council) "9.11 Therefore all the landscape in the district is considered to have innate value as referred to in the National Policy Planning Framework (NPPF)28 That said, of the locally significant landscape, the Areas of Attractive Landscapes (AALs) are of the greatest significance followed by the Local Landscape Areas (LLAs)"

Policy NE3 Landscape character and locally important landscape addresses effects on landscape character and quality. NPPF distinguishes between guidance on landscape character and the hierarchy of designated landscapes including locally designated areas such AALs. For this reason, it is customary for policies that define landscape designations (such as Areas of Attractive Landscapes) to have separate policies to those that deal with landscape features and qualities so that these elements are adequately protected. This approach is recommended for VALP. VALP16-09-02-00666 Kate Curry (Aston Policy NE8 - Stricter penalties need to be introduced for ignoring these guidelines Abbotts Parish Council)

VALP16-09-02-00667 Robert Barnes Policy NE7 - Should be preserved and food production encouraged VALP16-09-02-00667 Robert Barnes Policy NE8 - Essential to environment VALP16-09-02-00675 Mr and Mrs Hudson Policy NE1 - 9.14 Flight corridors for bat populations should be protected within rural areas. VALP16-09-02-00675 Mr and Mrs Hudson Policy NE3 - This should be of utmost importance in rural areas identifying the special qualities of the local landscape. VALP16-09-02-00675 Mr and Mrs Hudson Policy NE8 - Many hedgerows are ancient and should be protected equally along with trees. VALP16-09-02-00677 Steven Mitchell Policy NE5 - Support. VALP16-09-02-00677 Steven Mitchell Policy NE6 - Support. VALP16-09-02-00677 Steven Mitchell Policy NE8 - Support. VALP16-09-03-00680 John Sylvester Policy NE3 - In 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature and in particular the views in and out of the Bierton conservation areas and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape'. VALP16-09-03-00681 Jenny Sylvester Policy NE3 - In 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature and in particular the views in and out of the Bierton conservation areas and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape'. VALP16-09-03-00682 Philip Moriarty Policy NE3 - In 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature and in particular the views in and out of the Bierton conservation areas and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape'.

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ID Respondent Name Comment VALP16-09-03-00683 Annette Moriarty Policy NE3 - In 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature and in particular the views in and out of the Bierton conservation areas and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape'. VALP16-09-03-00684 Sarah Feeney Policy NE3 - In point 9.15 to 9.29, the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature and in particular the views in and out of the Bierton conservation areas and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape'. VALP16-09-03-00686 Emma Cable Policy NE3 - In 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature and in particular the views in and out of the Bierton conservation areas and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape'. VALP16-09-03-00687 Paul Cable Policy NE3 - In 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature and in particular the views in and out of the Bierton conservation areas and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape'. VALP16-09-03-00689 Robert Fowler Policy NE3 - n 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature and in particular the views in and out of the Bierton conservation areas and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape'. VALP16-09-03-00691 Barbara Hewson Policy NE3 - Fully supported and vital to rural communities VALP16-09-03-00691 Barbara Hewson Policy NE6 - Where land is identified as local green space in a Neighbourhood Development Plan, national policy must be applied. No new development should be permitted. Measures to improve public access should be encouraged. VALP16-09-03-00692 Denis Elliott Policy NE3 - In 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature and in particular the views in and out of the Bierton conservation areas and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape'. VALP16-09-03-00693 Christine Elliott Policy NE3 - In 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature and in particular the views in and out of the Bierton conservation areas and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape'. VALP16-09-03-00694 Mark Seymour Policy NE3 - In 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature, its historic ridge & furrow field patterns and in particular the views in and out of the Bierton conservation areas both from Bierton and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape'. VALP16-09-03-00695 Amanda Seymour Policy NE3 - In 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature, its historic ridge & furrow field patterns and in particular the views in and out of the Bierton conservation areas both from Bierton and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape'. VALP16-09-03-00696 John Sylvester (Bierton Policy NE3 - In 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to Action Group) its distinctive nature, its historic ridge & furrow field patterns and in particular the views in and out of the Bierton conservation areas both from Bierton and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape'.

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ID Respondent Name Comment VALP16-09-03-00697 Toby Sylvester Policy NE3 - In 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature, its historic ridge & furrow field patterns and in particular the views in and out of the Bierton conservation areas both from Bierton and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape'. VALP16-09-03-00698 Colin Thomson Policy NE3 - In 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature and in particular the views in and out of the Bierton conservation areas and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape'. VALP16-09-03-00699 Jack Sylvester Policy NE3 - In 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature, its historic ridge & furrow field patterns and in particular the views in and out of the Bierton conservation areas both from Bierton and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape'. VALP16-09-03-00700 Mavis Thomson Policy NE3 - In 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature and in particular the views in and out of the Bierton conservation areas and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape'. VALP16-09-03-00702 Sheila Sylvester Policy NE3 - In 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature and in particular the views in and out of the Bierton conservation areas and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape'. VALP16-09-03-00706 Nigel Lamburn Policy NE3 - In 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature and in particular the views in and out of the Bierton conservation areas and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape'. VALP16-09-03-00707 Joanna Lamburn Policy NE3 - In 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature and in particular the views in and out of the Bierton conservation areas and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape' VALP16-09-03-00710 Elizabeth Mary Policy NE3 - In 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to Hawksford its distinctive nature, its historic ridge & furrow field patterns and in particular the views in and out of the Bierton conservation areas both from Bierton and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape'. VALP16-09-03-00714 Robert Venning Policy NE3 - In 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature, its historic ridge & furrow field patterns and in particular the views in and out of the Bierton conservation areas both from Bierton and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape'. VALP16-09-03-00721 Edward Piotrowski Policy NE3 - In 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to Piotrowski its distinctive nature, its historic ridge & furrow field patterns and in particular the views in and out of the Bierton conservation areas both from Bierton and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape'.

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ID Respondent Name Comment VALP16-09-03-00723 natalie roberts Policy NE3 - In 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature, its historic ridge & furrow field patterns and in particular the views in and out of the Bierton conservation areas both from Bierton and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape'. VALP16-09-03-00724 Lynn Thomson Policy NE3 - the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature and in particular the views in and out of the Bierton conservation areas and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape'. VALP16-09-03-00727 Lisa Welling Policy NE3 - In 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature, its historic ridge & furrow field patterns and in particular the views in and out of the Bierton conservation areas both from Bierton and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape' VALP16-09-03-00727 Lisa Welling Policy NE6 - 9.39 Green spaces that are used for recreational activities, such as dog walking & jogging provide essential green space boundaries between the bigger developments such as Kingsbrook and help the villages keep some identity and are not engulfed by the new developments. So we would be strongly against applications such as William Hill Drive and Barnett Way.

VALP16-09-03-00728 Gemma Fraser Policy NE3 - In 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature and in particular the views in and out of the Bierton conservation areas and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape'. VALP16-09-03-00728 Gemma Fraser Policy NE6 - 9.39 Green spaces that are used for recreational activities, such as dog walking & jogging provide essential green space boundaries between the bigger developments such as Kingsbrook and help the villages keep some identity and are not engulfed by the new developments. So we would be strongly against applications such as William Hill Drive and Barnett Way in Bierton

VALP16-09-03-00729 Sian Williams Policy NE3 - In 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature and in particular the views in and out of the Bierton conservation areas and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape'. VALP16-09-03-00729 Sian Williams Policy NE6 - 9.39 Green spaces that are used for recreational activities, such as dog walking & jogging provide essential green space boundaries between the bigger developments such as Kingsbrook and help the villages keep some identity and are not engulfed by the new developments. So we would be strongly against applications such as William Hill Drive and Barnett Way.

VALP16-09-03-00730 Paula Lambert Policy NE3 - In 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature, its historic ridge & furrow field patterns and in particular the views in and out of the Bierton conservation areas both from Bierton and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape'. VALP16-09-03-00730 Paula Lambert Policy NE6 - 9.39 Green spaces that are used for recreational activities, such as dog walking & jogging provide essential green space boundaries between the bigger developments such as Kingsbrook and help the villages keep some identity and are not engulfed by the new developments. So we would be strongly against applications such as William Hill Drive and Barnett Way.

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ID Respondent Name Comment VALP16-09-04-00735 John Brine Policy NE3 - In 9-15-9-20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to itsdistinctive nature and in particular the views in and out of the Bierton conservation areas and surrounding villages such as Weedon This area area should be considered for a designation of an 'Area of Attractive Landscape' VALP16-09-04-00740 John Gavan Policy NE2 - Building in areas which are presently farm land will have a large impact on biodiversity. the removal of hedgerows and removal of vegitation will have a huge impact on this area and its biodiversity. VALP16-09-04-00740 John Gavan Policy NE8 - Removal of these will prove important not only on air quality but also on aesthetics of the landscape. Just replacing with immature specimens will not maintain biodiversity. VALP16-09-04-00743 Fiona Simmonds Policy NE3 - In 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature, it's historic ridge and furrow field patterns and in particular the views in and out of the Bierton conservation areas both from Bierton and from surrounding villages such as Weedon. This area should be considered for a designation of an Area of Attractive Landscape. VALP16-09-04-00744 Cllr David Finch Policy NE4 - Para 9.24 - This refers to views of the Areas of Natural Beauty from the “south of Cheddington”. It should be noted that there are notably important views of the AONB from public access points east of Cheddington. The wording should be amended to acknowledge this.

VALP16-09-04-00744 Cllr David Finch Policy NE6 - Land at Croft Meadow - which is currently shown in the VALP as a potential housing allocation - is of particular importance to the local community and meets the criteria for Local Green Space designation and should therefore be so designated (See Additional Notes)- either in the VALP or in a review of the Cheddington Neighbourhood Plan. VALP16-09-04-00745 Marianne Faux Policy NE4 - Para 9.24 - this refers to views of the Areas of Natural Beauty from the "south of Cheddington". It should be noted that there are notably important views of the AONB from public access (See Additional Notes) VALP16-09-04-00745 Marianne Faux Policy NE6 - Land at Croft Meadow - which is currently shown in the VALP as a potential housing allocation - is of particular importance to the local community and meets the criteria for Local Green Space designation and should therefore (See Additional Notes) VALP16-09-04-00746 Ian Denison Denison Policy NE3 - In 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature, its historic ridge and furrow field patterns and in particular the views in and out of the Bierton conservation areas both from Bierton and from the surrounding villages such as Weedon. This area should be considered for a designation of an, 'Area of Attractive Landscape'. VALP16-09-04-00748 Jeanette Denison Policy NE3 - In 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature, its historic ridge and furrow field patterns and in particular the views in and out of the Bierton conservation areas both from Bierton and from surrounding villages such as Weedon. This area should be considered for a designation of an, 'Area of Attractive Landscape'. VALP16-09-04-00750 Colin Read (Aston Policy NE2 - All the requirements that imposed at reserved matters stage must be adhered to. They are not being done so at the Clinton parish planning) moment. Enforcement is lax and it makes a mockery of the planning system. VALP16-09-04-00750 Colin Read (Aston Policy NE4 - Have already mentioned this and the views towards the Chilterns from Aston Clinton are paramount. They should not be Clinton parish planning) degraded in any way. VALP16-09-04-00750 Colin Read (Aston Policy NE6 - We would like to see Green Park and Aston Park designated as local green spaces. This is the intention through the Clinton parish planning) NHP as well.

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ID Respondent Name Comment VALP16-09-04-00752 Wendy Fellowes Policy NE3 - In 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature, its historic ridge & furrow field patterns and in particular the views in and out of the Bierton conservation areas both from Bierton and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape' VALP16-09-04-00754 Scott Messenger Policy NE3 - In 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature, its historic ridge & furrow field patterns and in particular the views in and out of the Bierton conservation areas both from Bierton and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape'. VALP16-09-04-00755 Joyce Docherty Policy NE4 - Para 9.24 refers to views of the AONB from the 'south of Cheddington.' There are important views of the AONB from public vantage points east of Cheddington and the text should be amended to acknowledge this. VALP16-09-04-00755 Joyce Docherty Policy NE6 - Land at Croft Meadows - which is presently shown in the VALP as a potential housing allocation - is of particular importance to the local community; meets the criteria for Local Green Space designation; and should be so designated - either in the VALP or in a review of the Cheddington Neighbourhood Plan. VALP16-09-04-00755 Joyce Docherty Policy NE8 - It is important that trees which are protected by the proposed policy are viable and healthy. It is suggested that 'viable and healthy' is inserted in the policy befit '...heritage trees.' VALP16-09-04-00756 Andrew Docherty Policy NE4 - Para 9.24 refers to views of the AONB from the 'south of Cheddington.' There are important views of the AONB from public vantage points east of Cheddington and the text should be amended to acknowledge this. VALP16-09-04-00756 Andrew Docherty Policy NE6 - Land at Croft Meadows - which is presently shown in the VALP as a potential housing allocation - is of particular importance to the local community; meets the criteria for Local Green Space designation; and should be so designated - either in the VALP or in a review of the Cheddington Neighbourhood Plan. VALP16-09-04-00756 Andrew Docherty Policy NE8 - It is important that trees which are protected by the proposed policy are viable and healthy. It is suggested that 'viable and healthy' is inserted in the policy before '...heritage trees.' VALP16-09-04-00759 geoffrey day Policy NE3 - The area to the north of Bierton should be recognised in the Plan as of high landscape value, with views in Bierton, and out of Bierton such as those from Weedon. Several footpaths provide varied access to these views. This area should be treated as an area of attractive landscape VALP16-09-04-00766 Barbara Venables Policy NE3 - In 9.15 and 9.20 the area to the north of Bierton shoudl be recognised in the plan as an area of high landscaped value due to its distrinctive nature and in particular the views in and out of the Bierton Conseervation Areas and from surrounding villages such as Weedon. This area should be considered as an Area of Attractive Landscape. VALP16-09-04-00767 christine Parry Policy NE3 - In 9.15-9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature and in particular the views in and out of the Bierton conservation areas and from surrounding villages such as Weedon and Wingrave.This area should be considered for a designation of an Area of Attractive Landscape. VALP16-09-04-00779 Aaron Gibbs Policy NE3 - In 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature, its historic ridge & furrow field patterns and in particular the views in and out of the Bierton conservation areas both from Bierton and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape'. VALP16-09-04-00780 Linda Fisher Policy NE3 - Plans for so many houses do not take into account the character of haddenham. . The logical place to build would be between thame and haddenham such that people could easily access the station and the village amenities if they wanted

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ID Respondent Name Comment VALP16-09-04-00782 Amie Gibbs Policy NE3 - In 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature, its historic ridge & furrow field patterns and in particular the views in and out of the Bierton conservation areas both from Bierton and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape'. VALP16-09-04-00784 Paul Tattam Policy NE5 - The air in Bedgrove is already polluted, there are 3 air quality management areas and more traffic proposed, compute that. VALP16-09-04-00797 Emily Godfrey (River Policy NE1 - 9.1: Proposed development that has an adverse effect on SSSI. whether individually or in combination with other Thame Conservation developments, will not normally be permitted. SSSIs (as the name suggests) are special and designated for good reason as the prime Trust) sites in the country, damage to them should not be permitted in any circumstance. VALP16-09-04-00797 Emily Godfrey (River Policy NE2 - 9.6: In order to do this, there must be more of a focus on the water environment when talking to developers given the Thame Conservation significant impact new developments have on our water infrastucture and freshwater habitats . There is no mention of using the Trust) 'Water Advice Note' guidance that is currently in development? This has been attached for ease of reference. It was produced and submitted as a draft document to AVDC at the end of 2015 by my predecessor at the River Thame Conservation Trust, Andrew Callender.

9.8: BOAs (Biodiversity Opportunity Areas) must be considered when discussing the fate of section 106 money and other developer mitigation work . Several local BOAs have been identified in Buckinghamshire. BOAs are the most important areas for biodiversity in the county. Buckinghamshire and Milton Keynes Biodiversity Partnership is developing a vision for delivering Buckinghamshire’s Biodiversity Action Plan (BAP) through a focus on BOAs. BOAs represent a targeted landscape-scale approach to conserving biodiversity and the basis for an ecological network. VALP16-09-04-00797 Emily Godfrey (River Policy NE5 - 9.26: Pollution caused by development should also include the extra sewage and waste water that will be produced by Thame Conservation the new residents within these developments. Historically the Aylesbury sewage treatment works has had severe issues and caused Trust) detrimental loss to biodiversity within the River Thame Catchment. ( eg see http://www.bucksherald.co.uk/news/probe-launched-after- sewage-leaks-into-aylesbury-river-1-5503753). Consultation with Thames Water should be included in this plan, ensuring that they are fully consulted before the approval of new developments so that time to make upgrades in sewage and waste water capacity can be incorporated. VALP16-09-05-00805 Natalie Harris Policy NE3 - In 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature, its historic ridge & furrow field patterns and in particular the views in and out of the Bierton conservation areas both from Bierton and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape'. VALP16-09-05-00807 Angela Truesdale Policy NE3 - 9.24 Haddenham is not mentioned but has clear, uninterrupted views across the fields to the south and east of the Chilterns ridge from the public footpaths. A new settlement would block this view, contrary to your policy C4 on protection of public rights of way 'no negative visual impacts on the setting and amenity of existing rights of way'. VALP16-09-05-00807 Angela Truesdale Policy NE7 - 9.42/43 With Brexit there will be tariffs added to our imports of grain and other foodstuffs. It therefore seems unwise to build on the high grade agricultural land bordering Haddenham at a time when Britain will need to be more self-sufficient. Other sites on lower grade land should be considered for development before even considering Haddenham’s agricultural land, in line with your policy. The new settlement should not be considered on the south and east of Haddenham for these reasons, neither should the land parcel HAD007, which is also on high grade agricultural land.

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ID Respondent Name Comment VALP16-09-05-00807 Angela Truesdale Policy NE8 - 9.44 to 9.46 The 'Haddenham Vale' and 'Thame Meadowland' to the south of Haddenham are in sensitive zones (Haddenham Neighbourhood Plan paras 3.5.1 and 3.5.3) with ancient hedgerows containing pollarded black poplars. A proper survey needs to take place before any decision is made on these sensitive zones being considered for a new settlement. VALP16-09-05-00813 Marion Kiff Policy NE3 - In 9.15-9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature. Its historic ridges furrow field patterns and in particular the views in and out of Bierton conservation areas both from Bierton and from surrounding villages such as Weedon. This area should be considered for designation of attractive landscape

VALP16-09-05-00815 Jan Molyneux (Molyneux Policy NE6 - There are instances where local green space has been identified on private land with no public access Planning) The policy should allow for some development of the local green space in order to secure public access to the green space. VALP16-09-05-00827 Jenny Armitstead Policy NE2 - The landscape will be altered.We are an important historical village going back to the Civil War with many historical landmarks VALP16-09-05-00827 Jenny Armitstead Policy NE3 - Areas of historical interest throughout the village including the site of battle during the Civil War VALP16-09-05-00830 Manlet Group Holdings Policy NE2 - Policy NE2 Biodiversity Draft Policy NE2 seeks the protection and enhancement of biodiversity and natural habitats, the principle of which is supported. However, Manlet Group objects to the requirement to provide a “net gain in biodiversity”. This is considered unnecessarily onerous and is inconsistent with draft Policy I1. The NPPF states in para, 109 that “the planning system should contribute to and enhance the natural environment by….minimising impacts on biodiversity and providing net gains in biodiversity where possible”.

The requirement should be to provide “no net loss of biodiversity”. Manlet Group also objects to the wording of Criteria b and suggest that this should be amended to read: “if significant harm resulting from a development cannot be adequately mitigated, or compensated for either on site or off-site, the development will not be permitted”.

VALP16-09-05-00830 Manlet Group Holdings Policy NE8 - Policy NE8 Trees, Hedgerows and Woodlands 8.4Draft Policy NE8 seeks to resist development that results in the loss of trees. This is considered unduly restrictive and it is suggested that the draft Policy is amended to read: “development that would result in the unacceptable loss of, or damage to, or threaten the continued well-being of protected trees, hedgerows, designated community orchards, high quality veteran trees or woodland (including those that are not protected but are considered to be worth of protection) will be resisted. Where the loss of trees is considered acceptable, replacement provision may be required that utilise species that are in sympathy with the character of the existing tree species in the locality and the site”. VALP16-09-05-00833 Tim Smee Policy NE3 - The area is unique and attractive and must be preserved. VALP16-09-05-00838 Kay Vause Policy NE3 - In 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature, its historic ridge & furrow field patterns and in particular the views in and out of the Bierton conservation areas both from Bierton and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape'. VALP16-09-05-00842 Mrs Caroline Aston Policy NE1 - Much of this area is an Area of Attractive Landscape therefore not suitable for mass development VALP16-09-05-00842 Mrs Caroline Aston Policy NE4 - Any proposal for development would have a visual impact on the AONB VALP16-09-05-00842 Mrs Caroline Aston Policy NE7 - This proposed area is productive agricultural land both for arable and dairy

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ID Respondent Name Comment VALP16-09-05-00844 Cara Marshall Policy NE2 - The tone and theme of biodiversity and net gain running throughout the draft Local Plan is welcome, particularly Policy (Environment Bank) NE2 – Biodiversity “In considering proposals for development, a net gain in biodiversity a. will be sought by protecting, managing, enhancing and extending existing resources, and by creating new resources.” We endorse the use of planning conditions/obligations to secure net gains in biodiversity – as at NE2 Biodiversity ‘h. Planning conditions/obligations will be used to secure net gains in biodiversity where possible by helping deliver Bucks and MK BAP targets in the Biodiversity Opportunity Areas.’ Planning conditions/obligations have also been used to secure off-site compensation sites that have been calculated using the Government biodiversity metric. See the amendments below that contains example wording for planning conditions or obligations. Suggested amendments We recommend the following inclusion/amendment to NE2 – Biodiversity; - at b. add ‘As per the mitigation hierarchy, if significant harm resulting from a development cannot be adequately avoided, mitigated, or as a last resort compensated for on, or off-site, then development will not be permitted. - between g. and h. add; ‘Development must complete biodiversity impact assessments, using the locally approved Defra biodiversity metric, to confirm adherence to the mitigation hierarchy and that no net biodiversity loss will be achieved’ Response attached. VALP16-09-05-00851 Michelle Bye Policy NE3 - In 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature, its historic ridge & furrow field patterns and in particular the views in and out of the Bierton conservation areas both from Bierton and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape'.

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ID Respondent Name Comment VALP16-09-05-00853 Suzanne Lindsey Policy NE3 - POLICY NE3 LANDSCAPE CHARACTER AND LOCALLY IMPORTANT LANDSCAPES (Whaddon Parish Council) Landscape Para’s 9.15 – 9.20

Whilst WPC respects the work undertaken by LUC on the review of the 2008 Landscape Character Assessment, it does not mean that local residents agree with their findings. In fact WPC have long campaigned to have the boundaries of the Whaddon Nash Valley LLA expanded, without success. The area currently comprising the Whaddon/Nash LLA seems oddly designated, and when considering the landscape qualities it seems both logical and sensible to extend the current LLA area both further Northwards to include that area of the historic hunting forest that lies to the West of the Shenley Ridge (so eloquently and properly saved from intrusive development by the 2004 MK Local Plan Inspector), and further East up to the historic North Bucks Way bridleway, which serves as an excellent physical landscaped barrier to the western edge of MK, beyond which no such permanent barrier to future development exists. This area to the East (basically including area WHA001) includes a variety of interesting buildings (Coddimoor Farm), historic sites (Snelshall Priory) and woodland remnants (Thickbare Wood, Coddimoorhill Wood, Briary Plantation, Hogpound Wood, Thrift and Broadway Woods). By extending this LLA as described, would provide a logical protective landscape which would guarantee the separate identity and character of Whaddon village, the south west side of which is currently exposed to the threat of development (as from WHA001). The Whaddon Chase hunting ground has been massively reduced in size over the last 100 years, and now needs protection to preserve some of the tranquil atmosphere that is critical to the survival of rural life in the South East of England. In 1862, Whaddon featured in James Sheahan’s History & Topography of Buckinghamshire, which states :- ‘The parish of Whaddon, independent of Nash which formally belonged to it…...rises into considerable elevations in some parts…..The prospects from it’s vicinity are fine and interesting’. WPC wishes to emphasise that just because a greenfield site does not benefit from a landscape designation, does not make it any less attractive to people living in that local area. Indeed WPC would venture to suggest that the more interesting and valued landscapes around MK should be protected, not just for the benefit of local villages, but for the future enjoyment of all residents of the area including Milton Keynes itself, and in so doing make public access into and through it more pleasurable so that the benefits of the many local footpaths and bridleways can be enjoyed by many more people.

END OF WHADDON PARISH COMMENTS ON VALP. 05/09/2016

VALP16-09-05-00860 John Careford Policy NE7 - Very careful consideration should be given on the use of land for houses that was previously used for farming or open countryside. It will never be reclaimed as land with a growing potential again for several lifetimes, if ever. VALP16-09-05-00871 Mary Hunt (Aylesbury Policy NE2 - We welcome all consideration of the natural environment. Vale Green Party) We urge the Council to ensure that good standards are maintained, e.g. wildlife corridors, critical in a period of huge development, should be large enough to fulfil their purpose, not be a gesture. They should also not include significant proporitions of vegetation that is at risk e.g. ash trees. Considerable research is needed to ensure that they are fit for purpose. We urge the Council to scrutinise developers carefully on such features. VALP16-09-05-00897 tim dorsett Policy NE4 - HS2 says it all

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ID Respondent Name Comment VALP16-09-05-00900 Jennifer Kruppa Policy NE3 - Areas of Attractive Landscape

Particularly sensitive or highly valued landscapes between Aylesbury and the villages should be specifically protected particularly Hampden Fields and the area of West End ditch that runs between Weston Turville and Bedgrove. The amount of development proposed in the plan (HELAA) for Hampden Fields is wholly inappropriate in this context and strongly resisted. VALP16-09-05-00927 James Yeoman (Savills Policy NE3 - Policy NE3 relates to Areas of Attractive Landscape (AAL) and Local Landscape Areas (LLA). The Airfield Site lies on behalf of Lands wholly outside of the Brill-Winchendon Hills AAL which extends across the landscape to the north of the A418. It is accepted that there Improvement Holdings is no proposal to change the extent of this AAL, however, it is noted that Paragraph 9.17 of the Draft Plan states that: “Neither of (LIH)) these designations are seeking to resist development in principle, unless regard has not been given to distinctive features and key characters of the AALs and LLA’s.” VALP16-09-05-00928 Tim Northey (Rectory Policy NE7 - This policy seeks to protect the best and most versatile farmland from development for the longer term. This policy is Homes Limited) though considered much more onerous than the guidance set out in the NPPF (paragraph 112) through the omission of the term where "significant development" is demonstrated to be necessary. The policy should therefore be revised to ensure consistency with the NPPF. VALP16-09-05-00955 Jonathan Clover Policy NE4 - I believe that the proposed removal of land at Wendover from the Green Belt (see earlier) has an impact on the enjoyment of the AONB from the vantage for example of Coombe/Bacombe Hill. The Wendover site is I believe part of the AONB. It can also be viewed form points within the Vale and its loss would affect enjoyment of the escarpment line. Its development would therefore offend against this policy. VALP16-09-05-00955 Jonathan Clover Policy NE5 - One of my reasons for urging a restriction of development at Aylesbury is the impact of further expansion (whether in advance of environmental mitigation or not) on air quality. You only have to walk along the Tring Road for example at busy times to be affected by the poor air quality and the impact of noise (which can prevent a conversation at someone's front door as well as on the footpath). This policy is not likely to have any impact unless the situation is monitored and restrictions on traffic and other impacts on air quality and noise brought into force. VALP16-09-05-00966 Michelle Kidd (Area Policy NE1 - It is not clear who in the council will make judgement with regard to the ecological impacts and the benefits of the Sustainable Places development. Expert ecological opinion should be sought, including input from the Council’s ecologist. Team The Environment In point (c), omit “where possible” so that the sentence reads “appropriate mitigation, compensation and enhancement measures have Agency) been put in place”.

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ID Respondent Name Comment VALP16-09-05-00966 Michelle Kidd (Area Policy NE2 - With regard to paragraph 9.7, reference should be made to the emerging Vision and Principles for the Improvement of Sustainable Places Green Infrastructure in Buckinghamshire and Milton Keynes currently being produced by the Buckinghamshire and Milton Keynes Team The Environment Natural Environment Partnership. Agency) Again, reference must be made to watercourses and their associated corridors as these are important in connecting designated and non-designated biodiversity sites with each other and the wider countryside. In paragraph 9.12, omit “where possible” in the last line to make it stronger. Policy NE2 Biodiversity Point (a) of this policy should be amended to read “In considering proposals for development, there shall be no net loss and a net gain in biodiversity…” We are pleased to see that watercourses are referred to in point (g) of policy NE2, but we consider that this is not strong enough protection for watercourses and their associated corridors. We consider that a specific stand-alone policy is required for the protection and enhancement of watercourses and their associated corridors. In the Aylesbury Vale Local Development Plan Written Statement Part 1 (January 2004), Policy GP.66 did deal specifically with conservation/protection and enhancement of rivers and canals; not to have such a policy is a retrograde step and one which we cannot accept. In previous consultations in the lead up to the production of this draft document, we have on more than one occasion suggested wording for such a policy. Please see our response entitled Vale of Aylesbury Plan: Scope of Development Management Policies dated 10 October 2013, our ref: WA/2006/000227/PO-01/IS1-L01, your ref: 03/04/VAP DM Policies/Reg18. The wording of this suggested policy is along the lines of Wycombe District Council’s policy DM15 Protection and Enhancement of River and Stream Corridors contained within their Adopted Delivery and Site Allocations Plan for Town Centres and Managing Development (July 2013). In addition to the above, reference should be made to the emerging Aylesbury Vale Waterways Advice Note.

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ID Respondent Name Comment VALP16-09-05-00966 Michelle Kidd (Area Policy NE5 - We are pleased to see a section in this policy about contaminated land. Sustainable Places However in parts g and h you need to be specific and include groundwater and surface water quality to be protected. Under part H we Team The Environment would expect to see a desk top study followed by a site investigation and remediation strategy followed by a verification report for Agency) development proposed on sites with a former contaminative use. This is in accordance with paragraphs 109, 120 and 121 of the NPPF. Source Protection Zones (SPZs) SPZs are used to identify those areas close to drinking water sources where the risk associated with groundwater contamination is greatest. SPZs are an important tool for identifying highly sensitive groundwater areas and for focusing control or advice beyond the general groundwater protection measures applied to aquifers as a whole. SPZs are categorised from SPZ3 (Total Catchment) to SPZ1 (Inner Source Protection Zone requiring highest degree of protection). You should reference SPZs in your local plan. Within Aylesbury Vale there are only relatively small areas in the south east corner of the district covered by bespoke modelled SPZs. This is associated with the chalk principal aquifer. We believe there however around 50 smaller private drinking water supplies in Aylesbury Vale. Private supplies are managed by Aylesbury Vale District Council, so we cannot be definitive on numbers. We do model bespoke SPZ for private supplies, however all private drinking water supplies have default 50m SPZ1. The proximity of SPZs should be accounted for in any development proposal. This should be at least listed as a constraint when assessing the suitability of a site for development. Certain activities and developments, with higher pollution risk would not be acceptable in source protection zones. We will have objections to certain developments at the planning application stage if, as a result of piling for example, they were to form pathways for contamination through the ground into the drinking water supply. Please refer to our Groundwater protection: Principles and practice (GP3) document. This document explains SPZs and which type of development we would object to in SPZs. Please use the following link to this documents on the GOV. UK website https://www.gov.uk/government/publications/groundwater- protection-principles-and-practice-gp3 VALP16-09-05-00966 Michelle Kidd (Area Policy NE6 - Measures to improve the ecological value of Local Green Spaces should be encouraged also and this should be Sustainable Places included within the wording of this policy. Team The Environment Trees, hedgerows and woodlands Agency) Reference should be made within paragraphs 9.44 to 9.47 of The Hedgerow Regulations 1997. VALP16-09-05-00973 Julie Ward Policy NE3 - 9.15-9.20 the area to the North of Bierton should be recognised in the plan as an area of high landscape value due to it's distinctive nature, it's historic ridge and furrow field patterns and in particulare the views in and out od the Bierton conservation areas both from Bierton and surrounding villages such as Weedon. This area should be considered for a designation of an Area of Attractive Landscape.. VALP16-09-05-00974 Nigel Ward Policy NE3 - In 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature, its historic ridge & furrow field patterns and in particular the views in and out of the Bierton conservation areas both from Bierton and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape'.

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ID Respondent Name Comment VALP16-09-05-00980 Jennifer Mitchell Policy NE3 - In 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature, its historic ridge & furrow field patterns and in particular the views in and out of the Bierton conservation areas both from Bierton and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape'. VALP16-09-05-00981 Michael Crockett Policy NE6 - Highly valued landscapes between villages need explicit protection, especially the area threatened by ‘Hampden Fields’, the West End Ditch, and the green buffers between Stoke Mandeville, Aston Clinton and Aylesbury. VALP16-09-05-00986 Simon Maloney Policy NE1 - I support this policy and all others under chapter 9 of the Plan. VALP16-09-05-00987 Jonathan Glasspool Policy NE7 - The land north of Haddenham is considered to be good quality agricultural land, as well as being a natural belt around unsustainably large development around the village. VALP16-09-05-00988 Sue Barber Policy NE1 - No brainer! they must be preserved and news ones created where appropriate. Halton and Wendover have some special elements, Halton has Kingfishers on the canal, water voles, toads, grebes, deer, badgers, owls, the list goes on. These must be protected buy preserving the environment they need to survive VALP16-09-05-00988 Sue Barber Policy NE4 - This is already under threat from HS2 please, please don't allow more to be lost and spoilt! Green belt is vital in Wendover and Halton. VALP16-09-05-00988 Sue Barber Policy NE6 - The RAF land provides open green space which is part of the key character of the area. Maintaining this is vital to keep the character of the area. Industrialisation or housing on this land should the RAF move , pwould change the area and remove a rural village with very special Rothschild connections. VALP16-09-05-00992 Helen Hyre Policy NE2 - Para 9.2 It is important that ancient woodland should be preserved. Para 9.8 - I support the concept of Biodiversity Opportunity Areas for the restoration and creation of priority habitat. VALP16-09-05-00992 Helen Hyre Policy NE5 - Para 9.27 I agree that lighting should only illuminate the intended area and should not negatively impact surrounding areas.

Para 9.31 - Many main roads have a problem with air pollution, especially given the high percentage of diesel cars. This impacts especially on children and there are many places where air quality needs to be improved. VALP16-09-05-00992 Helen Hyre Policy NE8 - Para 9.45 It is vital to protect mature trees and hedgerows due to the diversity of species which they provide. VALP16-09-05-00995 Joanna Mayers Policy NE3 - Housing development on farmland VALP16-09-05-00998 Charlotte Beadle Chapter 9 Natural Environment - All paragraphs: I do not support this draft plan for 33000 new homes in Aylesbury Vale.

VALP16-09-05-01000 Gillian Rowswell Policy NE3 - 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature and in particular the views in and out of the Bierton conservation areas and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape'. VALP16-09-05-01002 Raymond Rowswell Policy NE3 - n 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature and in particular the views in and out of the Bierton conservation areas and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape'.

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ID Respondent Name Comment VALP16-09-05-01005 Andrew Phillips Policy NE7 - This email is specifically centred around the expansion plans for Haddenham, either by this village growing or a "new town" on its outskirts. Haddenham is a historic settlement with no natural commercial centre. It is a small residential area with one key selling point = which is the railway station. We have two oversubscribed infant schools and one primary school. We are some distance from any secondary school with the nearest in a neighbouring county and no right to send our children there. We have no shops of note other than a corner shop and minor mini market (McColls). We have four pubs and minimal eateries. To expand this village would be a major failing of AVDC. We have poor village roads which are already overcrowded and often accident blackspot (Staybridge Rd jnt Woodways). The S.E part of the village floods yearly and parking around the railway station is already blocking the residential roads. Princes Risborogh is also adding housing as is Thame (In Oxfordshire). These in conjunction with Haddenhams already approved housing will put a strain on the existing infrastructure and no additional resources. From attending the open days and seeing your reports. Winslow is the only viable option.

VALP16-09-05-01008 John Mortimer Policy NE1 - Everey effort should be made to preserve all items mentioned in this section. It goes without saying. We cannot give up our heritage. VALP16-09-05-01011 Karen Barker (Great Policy NE3 - The initial sentence states all the landscape in the vale is of distinctive character, there for the same criteria for Brickhill Parish Council) development should be applied to greenfield development sites as AAL’s and LAA’s, otherwise there will be a general degradation of the overall character of the vale, particularly as many AAL’s include high ground, (as does the Chilterns AONB) from which any adjacent greenfield development could be seen, and thereby debasing their character. VALP16-09-05-01012 Alysoun Glasspool Policy NE7 - The land north of Haddenham is considered to be good quality agricultural land, as well as being a natural belt around unsustainably large development around the village. VALP16-09-05-01013 Malika Goodwin Policy NE3 - In 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature, its historic ridge & furrow field patterns and in particular the views in and out of the Bierton conservation areas both from Bierton and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape'. VALP16-09-05-01016 Gordon Pell Policy NE3 - Proposed developments in many of the proposed locations of the scale suggested will destroy significant areas of unspoilt green field land. VALP16-09-05-01016 Gordon Pell Policy NE7 - Many of the proposed developments will require use of good quality, productive farm land. This should be resisted as far as is possible. VALP16-09-05-01019 richard goodwin Policy NE3 - In 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature, its historic ridge & furrow field patterns and in particular the views in and out of the Bierton conservation areas both from Bierton and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape'. VALP16-09-05-01022 Craig Harrison Policy NE8 - Support protection of existing tree, hedge and woodland features, especially designated sites and ancient or native woodland. Black poplar especially important and must be protected and conserved. More woodland planting needed across the Vale where cover is lower than the national average (which is lowest in Europe). Trees play crucial role where development is planned to soften landscape and maintain social connection with nature, reduce air pollution and provide shade.

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ID Respondent Name Comment VALP16-09-05-01024 Philip Kerr Policy NE3 - In 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature, its historic ridge & furrow field patterns and in particular the views in and out of the Bierton conservation areas both from Bierton and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape'. VALP16-09-05-01025 Joanne Kerr Policy NE3 - In 9.15 - 9.20 the area to the north of Bierton should be recognised in the plan as an area of high landscape value due to its distinctive nature, its historic ridge & furrow field patterns and in particular the views in and out of the Bierton conservation areas both from Bierton and from surrounding villages such as Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape'. VALP16-09-05-01028 Warren Whyte (AVDC) Policy NE3 - The River Great Ouse - from Northants to Milton Keynes - provides an important landscape feature, and flood plain.

VALP16-09-05-01029 John Chantler Policy NE3 - the area to the north of Bierton should be recognised in the plan (In 9.15 - 9.20) as an area of high landscape value due to its distinctive nature, its historic ridge & furrow field patterns and in particular the views in and out of the Bierton conservation areas both from Bierton and from surrounding villages such as Hardwick and Weedon. This area should be considered for a designation of an 'Area of Attractive Landscape'. VALP16-09-05-01031 Alison Timman Policy NE8 - 9.45 Ref. "Mature trees, woodlands and hedges are sensitive to the impacts of development, both directly through their removal or indirectly through the impacts of construction."

The area of land proposed for develoment in Stone (STO008) contains mature, protected trees that would be detrimentally impacted by any construction on this site. VALP16-09-05-01037 Janette Eustace Policy NE3 - For some rural villages in North Bucks, the open spaces may not have AAL or LLA designation however for the people (Stewkley Parish living in that area, the fields and open views are important to them. Some consideration should be given to the importance of their Council) countryside views to the residents of a rural village. VALP16-09-07-01119 Roger Williams Policy NE3 - Landscape Policies in NE 3 all seem to accept the inevitability of development. Surely there should be an additional clause in the policy that allows for development to be rejected if it would cause unacceptable harm ? VALP16-09-07-01131 Ruth Millard Policy NE1 - Chapter 9 Natural Environment Policy NE1 and 9.15 to 9.20 Landscape Character and Locally Important Landscape • We support the continuation of the Aylesbury Vale Landscape Assessment 2008 as amended 2015. We consider that landscape is also a heritage asset and that the most attractive landscapes should be protected with equal force to buildings. VALP16-09-07-01150 Mr and Mrs Bradford Policy NE7 - We believe it is important to protect and preserve high grade, versatile agricultural land so that optimum food production is not lost, particularly in an atmosphere of uncertainty following the UK decision to leave the EU. VALP16-09-07-01153 Sylvie Eames Policy NE1 - NE1 and NE2 are good. VALP16-09-07-01153 Sylvie Eames Policy NE3 - NE3 Landscape character and locally important landscape is ambiguous as greenfield locations are attractive to the inhabitants even if they do not have a landscape designation! VALP16-09-07-01159 Mandy Cliffe (Great Policy NE1 - NE1 Protected sites Horwood Parish Council) This policy is consistent with paragraph 118 of the NPPF. However GHPC suggest that it should make specific reference to legislative requirements, such as Section 28E of the Wildlife and Countryside Act 1981.

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ID Respondent Name Comment VALP16-09-07-01159 Mandy Cliffe (Great Policy NE2 - NE2 Biodiversity Horwood Parish Council) 9.2.1 This policy is an implementation of paragraph 113 and 114 of the NPPF. The policies in AVDLP covering these areas (such as GP61, GP62, GP64) were not saved, and so have lapsed. VALP16-09-07-01159 Mandy Cliffe (Great Policy NE3 - 9.3 NE3 Landscape character and locally important landscape Horwood Parish Council) 9.3.1 This policy is a significant extension of the saved AVDLP Policy RA8 (most of the wording of which is incorporated in the final paragraph of the new draft policy), and is consistent with paragraph 113 of the NPPF. VALP16-09-07-01159 Mandy Cliffe (Great Policy NE4 - 9.4.1 This policy is an implementation of paragraphs 115 and 116 of the NPPF. Horwood Parish Council)

VALP16-09-07-01159 Mandy Cliffe (Great Policy NE5 - 9.5.1 This policy is an implementation of paragraphs 109 and 110 of the NPPF. In particular the section of the policy Horwood Parish Council) labelled Light pollution is an implementation of paragraph 125 of the NPPF, and the section labelled Air quality is an implementation of paragraph 124 of the NPPF. The policies in AVDLP covering these areas (such as GP41, GP97, GP102) were not saved, and so have lapsed. VALP16-09-07-01159 Mandy Cliffe (Great Policy NE6 - 9.6.1 This policy is an implementation of paragraph 76 of the NPPF. Horwood Parish Council) 9.6.2 GHPC wish to propose the Great Horwood Recreation Ground (“Horwode Pece”) as Local Green Space. Details of this proposal are given in Appendix A to this document. VALP16-09-07-01159 Mandy Cliffe (Great Policy NE7 - 9.7.1 This policy is consistent with paragraph 112 of the NPPF. Horwood Parish Council)

VALP16-09-07-01159 Mandy Cliffe (Great Policy NE8 - 9.8.1 This policy is a replacement for saved AVDLP Policies GP39 and GP40. The species Black Poplar, several of Horwood Parish Council) which grow in Great Horwood, is mentioned in GP40 as particularly worthy of preservation as it is regarded by the Forestry Commission as the most endangered native timber tree in Britain1. 9.8.2 Policy NE8 states in its first paragraph Development should seek to enhance and expand the district’s tree and woodland resource,including native Black Poplars. There is, however, no specific reference to Black Poplars in the paragraph following, regarding loss of or damage to trees. GHPC suggests that the following sentence be added to the end of thesecond paragraph: Development that would result in the unacceptable loss of, or damage to, or threaten the continued well-being of Black Poplars will be permitted only in exceptional circumstances.

VALP16-09-07-01159 Mandy Cliffe (Great General Comment - 9.9.1 There does not appear to be a general policy in the draft VALP referring to riverside or canalside Horwood Parish Council) development proposals. GHPC suggest that saved AVDLP Policy GP66 be included as a policy in this Chapter, for the purpose of maintaining public amenity. VALP16-09-07-01160 Dave Norris Policy NE3 - NE3 Landscape character and locally important landscape is ambiguous as greenfield locations are attractive to the inhabitants even if they do not have a landscape designation! COUNTRYSIDE - Agree with all and congratulate the appearance of policy for renewable energy. VALP16-09-07-01171 Nick Osgerby (Steeple Policy NE6 - The Steeple Claydon Neighbourhood Plan team are identifying the village’s green spaces which will be included in the Claydon Parish Council) draft plan.

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ID Respondent Name Comment Policy NE7 - I have a number of more specific concerns:

1.The area proposed for development is prime agricultural land which we believe should be protected under Policy NE7. 2.Although the draft plan talks about providing protection for settlements such as Mursley, Whaddon and Newton Longville, to preserve their unique characteristics, there is no mention of protection for Kingsmead and Tattenhoe Park, the latter is currently in development. Kingsmead is a village style development of just 420 houses on the edge of MK, adjacent to rich agricultural land with views of the open countryside in some parts and bordered by ancient hedges and woodland in others. These features have significant amenity value for the residents and need to be recognised, protected and preserved. 3.The Kingsmead and Tattenhoe Park area currently marks the edge of MK and there are no grid roads beyond this point. Grid roads are an essential part of MK’s infrastructure, ensuring fast movement of traffic into and out of the city, whereas the proposed development talks about S106 Agreements and a Community Infrastructure Levy to fund essential services, this is just a fleeting reference. We believe that the infrastructure requirements, especially relating to transport and traffic for a development of this size, have been substantially played down. In estimating transport infrastructure requirements the development NLV001 and NLV023 and WHA001 must be considered together. That is a total of 4,000 houses and therefore around 6,000 additional cars on the road. Developers’ contributions will not fund the level of transport infrastructure investment required, which is to extend the grid roads and provide major junction upgrades with existing grid roads. 4.Links to the existing by-pass at Stoke Hammond and a means to bypass Bletchley are essential to prevent severe congestion and potential grid lock at peak times on already congested roads. The effect on residential communities close to the proposed sites, without significant investment in road infrastructure, would be hugely detrimental and intolerable at peak times. 5.I note the references to the A421 upgrades and reserved land for a potential new station on the East-West rail line but these are mere wish lists rather than concrete enabling plans. 6.Primary health care and hospital provision is already under significant pressure in MK. Whilst arguably primary care such as GP services would be covered by S106/CIL, our experience in MK is that provision lags behind need. This is certainly the case in MK’s Western Expansion area where some GP surgeries are under severe pressure from new housing developments. Hospital provision is also of major concern. 7.I note that school provision would be provided under developers’ agreements. However in the early stages of development it is likely that children will come into MK schools. The Tattenhoe ward schools are already full and struggling to cater for expansion due to developments in Tattenhoe Park, Kingsmead South and Oxley Park.

VALP16-09-08-01204 Mark Furnish (Sport Policy NE5 - Natural Environment England) Outdoor sport facilities, such as Artificial Grass Pitches, Multi Use Games Areas and grass pitches have floodlights to maximise community use of such facilities during the peak periods (evenings). Sport England would object to any policy that hinders community use of sports facilities and therefore trusts that Policy NE5 would not be applied to prevent use of facilities in the evenings by preventing them from being floodlight or limiting the hours during the peak period. The Local Authority are advised to consider Sport England’s lighting guidance which can be found via the following link:

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ID Respondent Name Comment VALP16-09-08-01204 Mark Furnish (Sport Policy NE6 - It is welcomed that Policy NE6 specifically includes ancillary sport facilities as well as the playing pitches and courts England) themselves as ancillary facilities, such as changing rooms, are vital facilities for mass participation in sport. VALP16-09-08-01205 Mark Rose (Define (on Policy NE1 - BHL support the overarching objective to protect and enhance biodiversity and the natural environment, but the opening behalf of Bovis Homes)) premise of Policy NE2 should be to seek to minimise impacts and then, where possible, enhance biodiversity. That would more properly reflect the provisions of the NPPF (para 109). The draft policies are also overly prescriptive and prohibitive to the potential wider benefits of sustainable development. As such it does not reflect the positive approach to ecological enhancement and sustainable development set out in the NPPF (para. 114). VALP16-09-08-01205 Mark Rose (Define (on Policy NE3 - BHL recognise the aspiration to support the conservation and enhancement of valued landscapes as provided for by behalf of Bovis Homes)) paragraph 109 of the NPPF. However, whilst it maybe the case that all landscape in the District has some innate value that does not mean that it is necessarily a valued landscape in the terms of the NPPF as suggested by paragraph 9.15 of the Draft VALP. The identification of valued landscapes needs to be robustly justified in order to avoid an undue constraint being placed on sustainable development akin to the inappropriate blanket protection of countryside referred to above in relation to Policy S3. The Draft VALP proposes to redesign ate Areas of Attractive Landscape (AAL) and Local Landscape Areas (LLA) on the basis of the LUC Landscape Assessment (dated October 2015). However, the redesignation of the AALs and LLAs has taken place without regard to the need to identify development sites to be allocated in the VALP in particular parts of the District. For example the proposed redesignation of the Brickhills AAL could be seen as a means of restricting development adjacent to Milton Keynes, despite the clear need for development in this location in both the short and long term, and the wider benefits that would directly result from the development (as set out above). Notwithstanding that, as set out above, in the case of the proposed Brickhills AAL there is a clear distinction to be made in landscape character/quality terms between the areas close to the urban edge of Milton Keynes and the countryside to the south east around Great Brickhills. The land around the A4146 does not warrant particular protection as a result of its landscape quality and value and should be excluded from the AAL.Furthermore, whilst the Draft VALP states (para 9.17) that neither of the local designations are seeking to resist development in principle, it is clear from the conclusions of the HELLA in relation to GRB003 and GRB004 that they have historically been applied that way and that is likely to continue in the future unless that specific point is made in Policy NE3 itself. Moreover, the NPPF states (para 113) that criteria based policies should be set against which development proposals can be judged, and the level of protection should be commensurate with their status. In that regard Policy NE3 would be prohibitive to otherwise sustainable development without the inclusion of a balancing reference to the potential wider benefits of the development which may outweigh any specific harm.

VALP16-09-08-01205 Mark Rose (Define (on Policy NE7 - The draft policy is unduly restrictive and goes beyond the terms of paragraph 112 of the NPPF. behalf of Bovis Homes))

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ID Respondent Name Comment VALP16-09-08-01209 Tim Coleby (Peter Brett Policy NE2 - 9 Natural Environment Associates LLP on Summary 9.1 behalf of BA supports the policies in this chapter of the VALP, subject to two concerns about the wording of policies NE2 and NE4 as below. Buckinghamshire Advantage) Policy NE2 Biodiversity 9.2 BA supports the principle of protecting and enhancing biodiversity but is concerned that the policy is inflexible in that it does not seem to allow for off site mitigation proposals where mitigation on site is not practical or reasonable, as is the case with Aylesbury Woodlands. BA therefore considers appropriate re-wording of relevant parts of the policy is required to enable it to be implemented more flexibly whilst retaining its overall aims.

VALP16-09-08-01209 Tim Coleby (Peter Brett Policy NE3 - Associates LLP on BA supports policy NE3 and we show below how the Aylesbury Woodlands proposals comply with it. behalf of The proposals have considered the Aylesbury Vale Landscape Character Assessment 2008 (as amended 2015) and aimed to be Buckinghamshire sensitive to the individual character and distinctiveness of the local Landscape Character Areas. Advantage) The scale, massing and height of the development has been designed to: a. Minimise impact on visual amenity, e.g. by not obscuring views of the Chiltern AONB when viewed from public rights of way to the north of the site; b. Reflect the existing built form, e.g. by locating larger commercial and industrial units proximal to corresponding units around Arla and so locating the smaller, residential units and public open space proximal to the open countryside north of the GUC; and c. Reflect the pattern of the existing fields and hedgerows, albeit that hedgerow will be lost - and replanted - due to required ground engineering works. The proposals have also been conceived to minimise the impact of lighting and the level and frequency of noise generation. In general, a development of this scale on a green field site cannot avoid a degree of harm to landscape character. The design has aimed to minimise harm, but where potentially unacceptable harm is acknowledged – through consultation with AVDC - specific on- site mitigation is being proposed.

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ID Respondent Name Comment VALP16-09-08-01209 Tim Coleby (Peter Brett Policy NE4 - Associates LLP on Aylesbury Woodlands lies outside the Chilterns AONB, however BA acknowledges that it lies within the setting of the AONB. For this behalf of reason, the planning application refers to the Chilterns Conservation Board’s (CCB) Position Statement - ‘Development Affecting the Buckinghamshire Setting of the Chilterns AONB’ (October 2011 – Rev B). The submitted LVIA demonstrates the limited effect of the proposals on the Advantage) setting of the AONB. The proposed policy NE4 is more onerous than the policy it replaces, because it makes no distinction between development within the AONB and development within the setting. For example, “Planning permission for any major development within the AONB, or affecting the 27 J:32113 - Aylesbury EastPlanningVale of Aylesbury Local Plan consultation final.docx setting or appreciation of the AONB, will not be granted unless it can be demonstrated it…”: For this reason BA has concerns about the proposed wording and suggests that development outside the AONB, but within its setting, should simply be required to meet the requirements set out in the CCB’s Position Statement. Aylesbury Woodlands has been designed to be sensitive to the requirements of the CCB’s Position Statement and consultation with the CCB. The application material assesses that the AONB ‘setting’ has a very high sensitivity to change and would experience a low magnitude of change during operation year 1, reducing to very low by year 15 as the proposed planting matures and the development assumes a ‘settled vale’ character. Specifically, changes to panoramic views out of the AONB would be apparent from only a limited area within the AONB. No views from the AONB would be blocked nor interfered with. No new skyline would be created in these views through the introduction of vertical elements and no significant or abrupt change to landscape character would be introduced - the vale is already well-settled with noticeable residential, commercial and industrial elements and the proposed larger units would be located adjacent to existing (or consented) units around Arla. In short, by year 15, there would be no notable change or harm to the ‘special quality’ of the AONB as it relates to panoramic views across the Southern Vale.

VALP16-09-08-01225 Frazer Hickling (Phillips Policy NE3 - In respect of the ‘Natural Environment’ chapter, it is noted that there is a wide range of policies, including the Planning Services assessment criteria for considering applications related to specific designations (e.g. statutory ecological, landscape etc) as well as Limited) matters including noise, air quality and light. We have no comments to make in relation to this chapter. VALP16-09-08-01233 Mark Hyde MRTPI Policy NE2 - Ecology: The impact of the Proposed Development on protected species and habitats is explained in the Ecology AIEMA (South West Chapter in the Environmental Statement. The site contains woodland, hedgerows and mature trees, which will largely be retained Milton Keynes within the proposed development. A wide range of new habitats and green infrastructure will be delivered as part of the Proposed Consortium) Development, including native broadleaved woodland, species-rich grassland and wetland. A Biodiversity Management Plan will also be prepared for the proposed development. VALP16-09-08-01233 Mark Hyde MRTPI Policy NE7 - Agricultural Land: The Application Site mostly comprises Grade 3b agricultural land, AIEMA (South West but there is a small area of Grade 3a land. Milton Keynes Consortium)

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ID Respondent Name Comment VALP16-09-08-01242 Louise, Thomas & Eleri Policy NE4 - Policy NE4 The Chilterns AONB and setting states ‘planning permission for any major development affecting the setting Hosking or application of the AONB will not be granted unless it can be demonstrated it conserves and enhances the Chiltern AONB’s special qualities, distinctive character, tranquillity and remoteness; is appropriate to the economic, social and environmental wellbeing of the area or is desirable for its understanding and enjoying.’ The Aston Sandford option for a new settlement would be within sight and close proximity of the Chilterns Area of Outstanding Natural Beauty (AONB). It is also very near Conservation Areas in the villages of Aston Sandford, Ilmer and Owlswick. There is also a Scheduled Ancient Momument being the Medieval Settlement East of Waldridge Manor near Owlswick. It is also a very rural area which is intrinsically dark at night. For these reasons, it would not be a suitable location for a new settlement and would go against what is stated in policies BE1, NE3 and NE4. VALP16-09-08-01291 Martin Small (Historic Policy NE3 - Policy NE3 – we find having two levels of landscape significance categorisation below the nationally important AONBs; England) Areas of Attractive Landscapes and Local Landscape Areas, confusing. The policy does not appear to distinguish in its approach between AALs and LLAs which begs the question why have the two designations ? VALP16-09-08-01291 Martin Small (Historic Policy NE4 - Policy NE4 – we welcome this policy on the Chilterns AONB and its setting, but as a nationally important landscape, we England) would have expected it to come before Policy NE3 on locally important landscapes. We welcome criteria d., f. and k. although the NPPF recognises that the conservation of cultural heritage generally (including, but not limited to, landscapes) is an important consideration in AONBs, which should ideally be reflected in k. VALP16-09-08-01291 Martin Small (Historic Policy NE5 - Policy NE5 – we welcome criterion b. of Policy NE5 as part of the positive strategy for the conservation and enjoyment England) of, and the clear strategy for enhancing, the historic environment required by the NPPF. VALP16-09-09-01315 Neil Tiley (Pegasus Policy NE1 - Policy NE1 bullet point (b) applies a sequential test to development that affects a SSSI or an ancient woodland. This is Group (on behalf of contrary to the second bullet of paragraph 118 of the NPPF. Each planning application needs to be determined on its own merits Jeremy Elgin)) rather than being required to demonstrate that there are no preferable sites in terms of these impacts. VALP16-09-09-01315 Neil Tiley (Pegasus Policy NE3 - Policy NE3 relates to landscape. It sets a series of criteria that should be respected by developments. However, some of Group (on behalf of these criteria are less applicable to a new settlement as such a development will necessarily be more remote. The policy will need to Jeremy Elgin)) be refined to recognise that an alternative set of criteria may be more appropriate for specific developments, including the new settlement.

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ID Respondent Name Comment VALP16-09-09-01389 Amy Stone Policy NE1 - Policy NE1 – Protected Sites We do not object to the principle of Policy NE1 in so far as it relates to the prevention of harm to protected sites, including Sites of Special Scientific Interest (‘’SSSI’’). In particular, we support the acknowledgement that even an individual or cumulative substantial adverse impact on a protected site will not be determinative but will instead be a consideration in the overall planning balance. However, we object to the statement is criterion a) that planning permission will only be granted where the benefits of, and need for, the development clearly ‘significantly‟ outweigh the direct and indirect impact on the protected site. The policy as worded implies a more onerous test than is provided for in paragraph 118 of the NPPF, the second bullet point of which (in specific reference to development affecting SSSIs) states that development may be acceptable where the benefits ‘clearly ‟ outweigh the likely impact on features at the site or the broader network of sites. There is no reference to such benefits needing to clearly and ‘significantly‟ outweigh harm. We also note that the wording of criterion a) is inconsistent with Policy NE2 criteria d) of the VALP which does not use the word significantly in reference to harm to a SSSI being outweighed.

Changes Sought Delete reference to the benefits of a proposal needing to clearly and significantly outweigh the direct and indirect impacts under criteria a) to ensure consistency with other policies in the VALP and with national policy in the NPPF.

VALP16-09-09-01389 Amy Stone Policy NE2 - Policy NE2 – Biodiversity Whilst we support the principle of protecting and enhancing, where possible, biodiversity and the natural environment, we consider that Policy NE2 as drafted is overly lengthy and, as a consequence, confusing. We consider that it should be rationalised, which will assist clarity, and in so doing, the Council should ensure that the wording used in wholly consistent with guidance in the NPPF and PPG.

Changes Sought Rationalise Policy NE2 and ensure that the wording is consistent with national policy in the NPPF / PPG.

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ID Respondent Name Comment VALP16-09-09-01389 Amy Stone Policy NE4 - Policy NE4 – The Chilterns AONB and setting Policy NE4 as worded outlines a range of criteria that major development within, or affecting the setting or appreciation of the AONB, must adhere to. Whilst we support the thrust of the policy, we object in so far as it refers to the ‘’appreciation’’ of the AONB – a statement which is vague and unclear and should, therefore, be omitted. Furthermore, the NPPF deals specifically with AONB’s at paragraphs 115 and 116 but refers only to development within the AONB. It includes no references to the setting or appreciation of an AONB. As such, Policy NE4 should be revised so that it deals only with the requirements for development within the AONB, in a way which is consistent with the NPPF. In revising the policy, we would also suggest that it is rationalised as it extends to approximately a page in length, with thirteen separate criteria, some of which apply to certain forms of development and others that do not. This is overly complicated and will make utilising the policy at the development management stage extremely difficult. Change Sought Rationalise Policy NE4 to make it simpler and easier to interpret. As part of this process, omit references to the ‘’appreciation’’ of the NPPF and remove references to the setting of the AONB. VALP16-09-09-01389 Amy Stone Policy NE7 – Best and most versatile agricultural land We object to Policy NE7 as it is inconsistent with paragraph 112 of the NPPF. As drafted, policy NE7 seeks to apply a blanket protection to all best and most versatile agricultural land. However, paragraph 112 of the NPPF states only that local planning authorities should ‘take into account the economic and other benefits of best and most versatile agricultural land’ and ‘where significant development of agricultural land is demonstrated to be necessary, to use poorer areas in preference to that of a higher quality. As such it is evident that the NPPF does not support blanket protection of agricultural land and focusses specifically on the loss of ‘significant development’ of agricultural land i.e. the loss of major areas and ensuring that LPA’s take into account the benefits of such land as part of the planning balance.

Suggested Change Revise Policy NE7 to accord with the guidance at paragraph 112 of the NPPF. VALP16-09-09-01399 Cllr Phil Yerby Policy NE1 - The aim of the policy is supported. Bullet point b. should rule out development in or near any SSSI as the VALP itself will have identified “alternative, less harmful locations”. VALP16-09-09-01399 Cllr Phil Yerby Policy NE2 - We support the policy.

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ID Respondent Name Comment VALP16-09-09-01399 Cllr Phil Yerby Policy NE3 - Policy NE3 Landscape character and locally important landscape We strongly urge the Council to ensure designation of Hampden Fields, West End ditch and Manor Farm Field in Weston Turville as Locally Valued Landscape Areas. We refer to the supporting evidence provided to the Council as part of our VALP Issues and Options submission. There is no evidence that these areas have even been considered by LUC in their Final Report into Areas of Attractive Landscape (AAL’s) and Local Areas of Attractive Landscapes (LAA”s) in the VALP supporting evidence. Radmall submission under HFAG VALP Issues and Options Consultation (December 2014) recommendation at 5.4.4: “Reliance on the NPPF is not an acceptable alternative to proactive landscape planning at a local level. As the Introduction to the NPPF makes clear, it provides the framework within which local policy should be formulated. There is a clear need for local policies that reflect the NPPF’s focus on local character/distinctiveness and valued landscapes.” AVDC have not shown that any of this evidence has been considered. The Aylesbury Vale Landscape Character Assessment only considers the landscape in general and does not look at specifically valued landscapes within it. Clearly, Hampden Fields, including West End Ditch, is a locally valued landscape and the Council should reflect this in its plan.

VALP16-09-09-01399 Cllr Phil Yerby Policy NE4 - Policy NE4 The Chilterns AONB and setting We do not support a policy, which potentially allows development in the AONB. The policy only appears to cover “major” development within the AONB and not any development within the AONB. VALP16-09-09-01399 Cllr Phil Yerby Policy NE5 - Policy NE5 Pollution, air quality and contaminated land The policy is not robust enough as regards to Air Quality and in particular the existing Air Quality Management Areas within the district. The should clearly state “No development will be allowed which has any detrimental impact on Air Quality within the current Air Quality Management Areas”. This could be easily added after bullet point f. VALP16-09-09-01399 Cllr Phil Yerby Policy NE7 - Policy NE7Best and most versatile agricultural land The policy is weak. Some of the sites advanced by the Council are on sites that consist, at least in part, of best and most versatile agricultural land, which makes a the policy irrelevant and out of date from the outset. The policy only states the Council will “seek” to protect BMVAL. Bullet point b. seems to suggest a sequential test, which we would support, but which the Council clearly has not done as regards to the site allocations in the VALP. VALP16-09-09-01399 Cllr Phil Yerby Policy NE8 - Policy NE8 Trees, hedgerows and woodlands Once again the policy is weakly worded and unspecific. It merely says developers should “seek to enhance”. There is no definition of “unacceptable loss of” or where “loss of trees is considered acceptable” or “adequate” replacement. VALP16-09-09-01402 Stephen Beal Policy NE1 - Agree VALP16-09-09-01402 Stephen Beal Policy NE6 - Major important, these spaces are precious to rural life and must be protected - NOT revisited if this plan is not delivering quick enough - Go to brownfield. VALP16-09-09-01413 Michelle Thompson Policy NE1 - Agree. VALP16-09-09-01413 Michelle Thompson Policy NE6 - Very important. Made NDP LGS's should be untouchable along with Green Infrastructure. Look to brownfield sites.

VALP16-09-09-01416 Kathryn Hedges Policy NE1 - SSSI's must be protected. Once lost you cannot get them back. VALP16-09-09-01416 Kathryn Hedges Policy NE6 - NDP's must have maximum whilst VALP is being made.

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ID Respondent Name Comment VALP16-09-09-01417 David Wilson Policy NE3 - 6)Areas of Attractive Landscape

Particularly sensitive or highly valued landscapes between Aylesbury and the villages should be specifically protected particularly Hampden Fields and the area of West End ditch that runs between Weston Turville and Bedgrove. The amount of development proposed in the plan (HELAA) for Hampden Fields is wholly inappropriate in this context and strongly resisted. VALP16-09-09-01417 David Wilson Policy NE5 - •The strategy to put mass development to the South of Aylesbury shows significant increases in traffic at key Air Quality Management Areas, especially at the gyratory system in the town. This will further worsen the air quality and associated health risks. Conflicting Policy NE5. VALP16-09-09-01427 Phil Yerby (Hampden Policy NE1 - The aim of the policy is supported. Bullet point b. should rule out development in or Fields Action Group) near any SSSI as the VALP itself will have identified “alternative, less harmful locations”. VALP16-09-09-01427 Phil Yerby (Hampden Policy NE2 - 116. We support the policy. Fi ld A i G ) VALP16-09-09-01427 Phil Yerby (Hampden Policy NE3 - We strongly urge the Council to ensure designation of Hampden Fields, West End ditch and Manor Farm Field in Fields Action Group) Weston Turville as Locally Valued Landscape Areas. We refer to the supporting evidence provided to the Council as part of our VALP Issues and Options submission. There is no evidence that these areas have even been considered by LUC in their Final Report into Areas of Attractive Landscape (AAL’s) and Local Areas of Attractive Landscapes (LAA”s) in the VALP supporting evidence. Radmall submission under HFAG VALP Issues and Options Consultation (December 2014) recommendation at 5.4.4: “Reliance on the NPPF is not an acceptable alternative to proactive landscape planning at a local level. As the Introduction to the NPPF HFAG RESPONSE To VALP v.7.docx Page 27 of 37 Hampden Fields Action Group Quince House, School Lane, Weston Turville. Bucks. HP22 5SE makes clear, it provides the framework within which local policy should be formulated. There is a clear need for local policies that reflect the NPPF’s focus on local character/distinctiveness and valued landscapes.” AVDC have not shown that any of this evidence has been considered. The Aylesbury Vale Landscape Character Assessment only considers the landscape in general and does not look at specifically valued landscapes within it. Clearly, Hampden Fields, including West End Ditch, is a locally valued landscape and the Council should reflect this in its plan.

VALP16-09-09-01427 Phil Yerby (Hampden Policy NE4 The Chilterns AONB and setting We do not support a policy, which potentially allows development in the AONB. The Fields Action Group) policy only appears to cover “major” development within the AONB and not any development within the AONB. VALP16-09-09-01427 Phil Yerby (Hampden Policy NE5 Pollution, air quality and contaminated land The policy is not robust enough as regards to Air Quality and in particular the Fields Action Group) existing Air Quality Management Areas within the district. The should clearly state “No development will be allowed which has any detrimental impact on Air Quality within the current Air Quality Management Areas”. This could be easily added after bullet point f. VALP16-09-09-01427 Phil Yerby (Hampden Policy NE7 Best and most versatile agricultural land The policy is weak. Some of the sites advanced by the Council are on sites that Fields Action Group) consist, at least in part, of best and most versatile agricultural land, which makes a the policy irrelevant and out of date from the outset. The policy only states the Council will “seek” to protect BMVAL. Bullet point b. seems to suggest a sequential test, which we would support, but which the Council clearly has not done as regards to the site HFAG RESPONSE To VALP v.7.docx Page 28 of 37 Hampden Fields Action Group Quince House, School Lane, Weston Turville. Bucks. HP22 5SE allocations in the VALP. VALP16-09-09-01427 Phil Yerby (Hampden Policy NE8 Trees, hedgerows and woodlandsOnce again the policy is weakly worded and unspecific. It merely says developers Fields Action Group) should “seek to enhance”. There is no definition of “unacceptable loss of” or where “loss of trees is considered acceptable” or “adequate” replacement.

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ID Respondent Name Comment VALP16-09-09-01440 Nick Butler Policy NE1 - With HS2 and Crossrail removing SSSI and CWS and BNS, how do we replace that? VALP16-09-09-01440 Nick Butler Policy NE6 - Any existing green space should be protected and not compromised. VALP16-09-09-01440 Nick Butler Policy NE7 - Should encourage best agricultural land particularly organic land not sprayed with pesticides. VALP16-09-09-01451 Geoff Culverhouse Policy NE1 - This policy is supported. (North Bucks Parishes Planning Consortium) VALP16-09-09-01451 Geoff Culverhouse Policy NE2 - This policy is supported. (N th B k P i h VALP16-09-09-01451 Geoff Culverhouse Policy NE3 - Policy NE3 Landscape character and locally important landscape (North Bucks Parishes Proposals for development in all greenfield locations need to address the issues referred to for AAL’s and LLA’s. Just because a Planning Consortium) greenfield site does not benefit from a landscape designation does not make it any less attractive to people living in that area or indeed any receptor. VALP16-09-09-01451 Geoff Culverhouse Policy NE4 - Policy NE4 The Chilterns and AONB setting (North Bucks Parishes No comment Pl i C i ) VALP16-09-09-01451 Geoff Culverhouse Policy NE5 - NE5 Pollution, air quality and contaminated land (North Bucks Parishes This policy is supported. Pl i C ti ) VALP16-09-09-01451 Geoff Culverhouse Policy NE6 - Policy NE6 Local green space (North Bucks Parishes At item ‘a’, in line one, after ‘outdoor sport and’ replace ‘recreational’ with ‘community recreation and/or leisure facilities’. As written the Planning Consortium) policy could prevent the use of Local Green Spaces as locations for buildings to support or contain sport and leisure facilities. VALP16-09-09-01451 Geoff Culverhouse Policy NE7 - Policy NE7 Best and most versatile agricultural land (North Bucks Parishes This policy is supported. VALP16-09-09-01451 Geoff Culverhouse Policy NE8 - Policy NE8 Trees hedgerows and woodlands (North Bucks Parishes This policy is supported. VALP16-09-09-01467 KG Oldknow Policy NE3 - Highly valued landscapes between villages need explicit protection, especially the area threatened by ‘Hampden Fields’, the West End Ditch, and the green buffers between Stoke Mandeville, Aston Clinton and Aylesbury. VALP16-09-09-01468 Sarah Hamilton-Foyn Policy NE1 - Policy NE1 bullet point (b) applies a sequential test to development that affects a SSSI or an ancient woodland. This is (Pegasus Group (Revera contrary to the second bullet of paragraph 118 of the NPPF. Each planning application needs to be determined on its own merits Limited on behalf of rather than being required to demonstrate that there are no preferable sites in terms of these impacts. M&G P t Li it d VALP16-09-09-01472 Nigel Rosier Policy NE3 - Highly valued landscapes between villages need explicit protection, especially the area threatened by ‘Hampden Fields’, the West End Ditch, and the green buffers between Stoke Mandeville, Aston Clinton and Aylesbury. VALP16-09-09-01477 Jane Eden (Aylesbury Policy NE2 - Environment Town Council.) The expansion of Aylesbury will undoubtedly place a burden on the natural environment, this must be managed not just for what is expected to be built in the duration of this plan, but into the future, the effects of climate change, increased potential flooding and the development and potential creation of new flood areas must be addressed. In addition development that affects our wildlife must take that damage into account and reduce the damage.

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ID Respondent Name Comment VALP16-09-12-01515 Cameron Austin-Fell Policy NE2 - The policy (criterion b) should also allow for off-site mitigation as a way of mitigating the harmful effects of a (RPS Planning & development. Several authorities (Warwickshire County) are now using landbanks as a way of ensuring a development has a net gain Development (on behalf in biodiversity, by enabling financial contributions towards off-site mitigation. of Richborough Estates Site - Churchway, Criterion D appears to replicate policy NE1 and should be deleted. Haddenham)) VALP16-09-12-01515 Cameron Austin-Fell Policy NE3 - The policy does not allow for a balancing approach to development (as per Policy NE1) and should be re-drafted. (RPS Planning & Stating development should be grouped is not specific and needs to be removed or defined. Development (on behalf The policy also needs amending to place less rigid reliance upon the 2008 Aylesbury Vale Landscape Character Assessment. This is of Richborough Estates only an evidence base document and relying on it several times as the policy does is effectively elevating an evidence base document Site - Churchway, to policy status. This document is now quite dated and will not, in many instances, reflect more recent developments which may have Haddenham)) an impact upon its conclusions. This document in most instances includes very large appraisal sites and indicates in some instances such large areas to have a high negative landscape impact, whereas the planning applications quite often will only relate to a smaller or discrete area of such wider parcels. The policy must therefore acknowledge that individual LVIAs and a more refined assessment may well be able to demonstrate that harms to the landscape character of that area does not represent negative impact and thereby inconsistency with the 2008 report should not be definitive in making a recommendation or decision on a planning application.

VALP16-09-12-01515 Cameron Austin-Fell Policy NE6 - The policy should specifically include reference to LGS not being on large tracts of land and should also establish that (RPS Planning & such designations must complement and not prevent sufficient homes being provided in an area – consistent with NPPF paragraph Development (on behalf 76. VALP16-09-12-01515 Cameron Austin-Fell Policy NE7 - 2.72 The policy is inconsistent with the NPPF which does not protect BMV land; it merely requires LPAs to take into (RPS Planning & account the economic and other benefits of BMV land. The policy should be re-written. Development (on behalf VALP16-09-12-01515 Cameron Austin-Fell Policy NE8 - 2.73 The policy needs to allow a balance (as per NE1). Stating a development will be resisted because of the loss of (RPS Planning & trees, hedges and orchards requires re-drafting as there could be many instances where additional planting, either on-site on off-site, Development (on behalf could mitigate and significantly reduce the area lost. VALP16-09-12-01518 Silas Willoughby Policy NE4 - However, we respectfully request the removal of the site (Pitstone Quarry no.2) from the green belt and Area of (Dominic Lawson Outstanding Natural Beauty (“AONB”) designations in this location. We consider that the site does not contribute to these Bespoke Planning (on designations and should be removed. behalf of ICP Asset Management Limited and JGE Truck & Plant Ltd)) VALP16-09-12-01521 Sean Carolan (Winslow Policy NE6 - 55) Policy NE6(a) is too restrictive. It needs to be reworded to allow wider community or leisure uses. Town Council)

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ID Respondent Name Comment VALP16-09-12-01521 Sean Carolan (Winslow Policy NE8 - 54) It interesting to note in 9.44 that “Trees and woodlands take many years to mature“but no mention of replanting them Town Council) or replacing them elsewhere before they actually are mature. In regards to NE8 and where trees around sites are lost AVDC must ensure that replacement provision is carried out. VALP16-09-12-01523 Cameron Austin-Fell Policy NE2 - The policy (criterion b) should also allow for off-site mitigation as a way of mitigating the harmful effects of a (RPS Planning & development. Several authorities (Warwickshire County) are now using landbanks as a way of ensuring a development has a net gain Development (on behalf in biodiversity, by enabling financial contributions towards off-site mitigation. of Richborough Estates Site - Lower Road, Criterion d appears to replicate policy NE1 and should be deleted. Aylesbury)) VALP16-09-12-01523 Cameron Austin-Fell Policy NE3 - The policy does not allow for a balancing approach to development (as per Policy NE1) and should be re-drafted. Stating (RPS Planning & development should be grouped is not specific and needs to be removed or defined. Development (on behalf The policy also needs amending to place less rigid reliance upon the 2008 Aylesbury ValeLandscape Character Assessment. This is of Richborough Estates only an evidence base document and relying on it several times as the policy does is effectively elevating an evidence base Site - Lower Road, document to policy status. This document is now quite dated and will not in many instances reflect more recent developments which Aylesbury)) may have an impact upon its conclusions. This document in most instances includes very large appraisal sites and indicates in some instances such large areas to have a high negative landscape impact, whereas the planning applications quite often will only relate to a smaller or discrete area of such wider parcels. The policy must therefore acknowledge that individual LVIAs and a more refined assessment may well be able to demonstrate that harms to the landscape character of that area does not represent negative impact and thereby inconsistency with the 2008 report should not be definitive in making a recommendation or decision on a planning application.

VALP16-09-12-01523 Cameron Austin-Fell Policy NE6 - The policy should specifically include reference to LGS not being on large tracts of land and should also establish that (RPS Planning & such designations must complement and not prevent sufficient homes being provided in an area – consistent with NPPF paragraph Development (on behalf 76. VALP16-09-12-01523 Cameron Austin-Fell Policy NE7 - 2.72 The policy is inconsistent with the NPPF which does not protect best and most versatile (BMV) land it merely (RPS Planning & requires LPAs to take into account the economic and other benefits of BMV land. The policy should be re-written. Development (on behalf VALP16-09-12-01523 Cameron Austin-Fell Policy NE8 - 2.73 The policy needs to allow a balance (as per NE1). Stating a development will be resisted because of the loss of (RPS Planning & trees, hedges and orchards requires re-drafting as there could be many instances where additional planting either on site on off-site Development (on behalf could mitigate and significantly reduce the area lost.

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ID Respondent Name Comment VALP16-09-12-01538 Jon Gateley (Savills (on Policy NE3 - Paragraph 9.15 behalf of Crest Strategic This states: ‘Therefore all the landscape in the district is considered to have innate value as referred to in the National Policy Planning Projects)) Framework (NPPF) para 109’ We note that while all landscape may have an innate value this does not equate to the cross reference of ‘valued landscapes’ as set out in paragraph 109 of the NPPF. The Landscape Institute’s Guidelines for Landscape and Visual Impact Assessment 3rd Edition (5.45) distinguishes between landscape valued by designation from International, National and local level. It also includes non- designated landscapes valued at a local level based on clearly stated criteria and /or those of specific community value. However, this does not include all landscapes. Modifications to Paragraph 9.15 sought by CSP Delete cross reference to NPPF paragraph 109

Policy NE3: Landscape character and locally important landscape CSP supports the general thrust of Policy NE3 to ensure that the district’s landscape character is maintained, that development must have regard to the Aylesbury Vale Landscape Character Assessment 2008 (as amended 2015), and recognise the individual character and distinctiveness of particular Landscape Character Areas set out in the Assessment. However CSP has specific comments as follows: Criterion (a) – grouping development with existing buildings to minimise impact on visual amenity This may be appropriate in the countryside but is not always relevant for a strategic development. Criterion (c) - reflecting local character and distinctiveness in terms of settlement form and field pattern, spacing, height, scale, plot shape and size, elevations, roofline and pitch, overall colour, texture and boundary treatment (walls, hedges, fences and gates) This will depend on the location of the development. For larger site allocations, such as WHA001, and where detached from a settlement, making references to existing settlement patterns (such as Whaddon) will be of less relevance as a cue for design, than in built up areas. We suggest amending this wording to reflect “appropriate” neighbouring settlement patterns. The policy continues: ‘The policies map defines Areas of Attractive Landscape (AALs) and Local Landscape Areas (LLAs) which have particular landscape features and qualities considered appropriate for particular conservation and enhancement opportunities. Of the two categories, the Areas of Attractive Landscape have the greater significance. Development in AALs and LLAs should have particular regard to the character identified in the report ‘Defining the special qualities of local landscape designations in Aylesbury Vale District’ (Final Report, 2016) and Aylesbury Vale Landscape Character Assessment (2008)’. We support this Policy wording.

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ID Respondent Name Comment VALP16-09-12-01538 Jon Gateley (Savills (on However the Policy continues, “Development that adversely affects this character will not be permitted unless appropriate mitigation behalf of Crest Strategic can be secured”. Where permission is granted, the council will require conditions or Section 106 agreements to best ensure the Projects)) mitigation of any harm caused to the landscape interest.’ This part of the Policy is supported in respect of development within AALs and LLAs. However, the wording is unclear in relation to development outside the designations. If interpreted too strictly it could mean that any adverse effect, including those outside a designated landscape and regardless of the relative weight could form a potential reason for refusal of an application. Furthermore, the effectiveness of ‘appropriate mitigation’ is often a matter of judgement and in some cases may take a number of years to be fully effective. Where effects occur outside an AAL or LLA a reasoned planning balance judgement needs to be made on the relative effects involved and the scope to provide effective mitigation in the medium- to long-term.

Modifications to Policy NE3 sought by CSP - Amend criterion (a) to state: ‘be grouped, where possible and relevant, with existing buildings to minimise impact on visual amenity - Amend criterion (c) to state: ‘reflect, as relevant, local character and distinctiveness in terms of any appropriate settlement form and field pattern, spacing, height, scale, plot shape and size, elevations, roofline and pitch, overall colour, texture and boundary treatment (walls, hedges, fences and gates)

VALP16-09-12-01567 Laura Tilston (Gladman Policy NE3 - Policy NE3: Landscape Character and Locally Important Landscape Gladman commissioned FPCR to undertake a Developments) review of the Councils landscape evidence and the emerging policy which has been prepared on the basis of this evidence. The full technical note is included as Appendix 3 to this submission. This technical note highlights that the LUC 2015 report clearly set out the requirements in order to make the existing evidence base NPPF complaint. This work has not yet been carried out and therefore the evidence base cannot yet be considered valid. As outlined in detail within the appended technical note, Policy NE3 does not appear to reflect the recommendations. The two documents referenced within NE3 have not incorporated the suggested revisions to its evidence base necessary to make the LVSLCA compliant with the NPPF and current guidance, or to make the LVASL robust and utilising and evidence based character approach. Should LLAs and AALs be carried forward into the VALP, these should be reviewed based on detailed assessments; such as that undertaken within the LUC 2016 study; following completion of the updates to the LVDLCA in accordance with recommendations as set out in the 2015 LUC report. Consequently, as drafted Gladman object to Policy NE3 as further work is required to provide the justification for these designations and ensure the designations and policy are NPPF compliant.

VALP16-09-12-01567 Laura Tilston (Gladman Policy NE7 - 7.2 Policy NE7: Best and Most Versatile Agricultural Land 7.2.1 Policy NE7 relates to development within areas of Best Developments) and Most Versatile (BMV) agricultural land. Part (a) sets out that planning consent will not be granted unless the benefits of the development outweighs the harm resulting from the loss of the agricultural land. Gladman support this element of the policy, however object strongly to Policy NE7(b) which states that planning consent will not be granted unless “there are no otherwise suitable sites of poorer agricultural quality that can accommodate the development.” This effectively would require the sequential test to be undertaken in relation to BMV. This is not appropriate and may act to restrict sustainable development from coming forward. There is no requirement in national policy for a sequential test to be applied to BMV, this element of Policy NE7 is unsound and should be removed in its entirety.

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ID Respondent Name Comment VALP16-09-12-01617 Christopher Walker Policy NE4 - In response to the specific policies, we strongly support the approach taken to safeguard the setting of the Chiltern Hills (Drayton Beauchamp AONB (NE4) and views across the Vale towards the AONB. We believe however that views from the escarpment over the Vale are Parish Council) equally important and on a fine day can be stunning. We would therefore suggest a policy reference to address the impact that some new development may have on those outward views. An example would be industrial shed roofs.

VALP16-09-12-01627 Joanna Shepherd Policy NE5 - Pollution is a serious concern. VALP16-09-12-01629 Kenneth David Shaw Policy NE3 - 8. Highly valued landscapes between villages need explicit protection, especially the area threatened by ‘Hampden Fields’, the West End Ditch, and the green buffers between Stoke Mandeville, Aston Clinton and Aylesbury. VALP16-09-12-01632 Roger Williams Policy NE3 - The landscape, within which Brill sits, is designated as an AAL, an Area of Attractive Landscape. Policy NE 3 sets out policies to maintain the landscape character. The Brill Fact Pack identified Brill as having a landscape sensitivity of 90-100%. At villages, where environmental protection is paramount, as in the case of Brill, there is a case for adopting policies to guide development similar to RA 13 and 14 of the 2004 Local Plan. · Landscape Policies in NE 3 all seem to accept the inevitability of 1 ) l3 development. Surely there should be an additional clause in the policy that allows for development to be rejected if it would cause unacceptable harm?

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ID Respondent Name Comment VALP16-09-12-01633 Neil Rowntree (Berks, Policy NE2 - Achieving a net gain in biodiversity Bucks & Oxon Wildlife The delivery of the Aylesbury Vale Local Plan must result in a net gain in biodiversity. To achieve this all developments must deliver a Trust) net gain in biodiversity where possible. Justification for this is provided in paragraphs 7, 9, 109, 118, 152 of the NPPF and the references to the NERC Act 2006 in the NPPF Planning Guidance.

We welcome the following policy statements in the draft Plan:

“NE2 Biodiversity - Protection and enhancement of biodiversity and the natural environment will be achieved by the following: In considering proposals for development, a net gain in biodiversity a. will be sought by protecting, managing, enhancing and extending existing resources, and by creating new resources. h. Planning conditions/obligations will be used to secure net gains in biodiversity where possible by helping deliver Bucks and MK BAP targets in the Biodiversity Opportunity Areas.”

“I1 Green infrastructure - ….biodiversity mitigation where warranted, should result in no a. net loss, and where possible a net gain, in biodiversity (linked with Policy NE2)…..”

however it does not fully reflect the wording of the NPPF paragraphs mentioned above. The following wording, or words to the effect of it, should be added into Policy NE2: “The Council will deliver a high quality natural environment within the District by…… ensuring there is a net gain in biodiversity across the District as a whole over the plan period.” In the interests of clarity the following statement in Policy I1: “….biodiversity mitigation where warranted, should result in no a. net loss, and where possible a net gain, in biodiversity …..” should either also be included in NE2, or be transferred to NE2.

To enable the plan to comply with the NPPF (see above paragraph numbers) it must be able to demonstrate that a net gain is being delivered, so there needs to be a way of measuring net gain/net loss. What is lacking from the Plan at present is reference to any mechanism for ensuring that net gains in biodiversity are actually achieved. Without such a mechanism then with each application it becomes a subjective process to assess this, likely to involve significant and lengthy negotiations between developers, local authorities and wildlife interests, which could affect deliverability of the Plan.

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ID Respondent Name Comment VALP16-09-12-01633 Neil Rowntree (Berks, The established method for measuring if net gain has been achieved is through the use of the metric (or Biodiversity Impact Bucks & Oxon Wildlife Assessment calculator) produced as part of the DEFRA Biodiversity Offsetting guidance. Some local authorities (such as in the Trust) Warwickshire, Coventry and Solihull sub-region) have produced bespoke metrics to assess this. The most appropriate metric to use is either the above mentioned one within the DEFRA Biodiversity Offsetting guidance or the amended version, produced by the Environment Bank, which is used in Warwickshire. Local authorities in Warwickshire, Coventry and Solihull sub-region have agreed to use the metric in relation to all Major and Minor developments and we consider this to be an appropriate threshold. The use of the Biodiversity Impact Assessment calculator is already being requested in some cases for applications within several local authorities in Buckinghamshire. The requirement for its use has been included in at least five Neighbourhood Plans within Aylesbury Vale and has been supported on several occasions by Inspectors. For example the adopted Haddenham Neighbourhood Plan states: “10.5.1 Development will be expected to result in a net gain to biodiversity, as set out in the National Planning and Policy Framework. This will be calculated by applying the DEFRA and Natural England endorsed Biodiversity Impact Assessment Calculator……... Policy SRL3: Enhancing, Protecting and Providing new Natural Environment Habitats, Trees and Hedgerows……….. Landscaping proposals should include native species and habitats that respect the distinctive local landscape character and should seek to demonstrate a net gain in biodiversity in accordance with the Defra Biodiversity Impact Calculator……. “ and the adopted Wing Neighbourhood Plan states: “5.20 The contribution of any development to these issues of biodiversity, either on-site or in surrounding sites or corridors, will be assessed in accordance with the DEFRA Biodiversity Offsetting habitat valuation metric to demonstrate an equal or improved ecological unit score than previously……. Policy CGS1: Respecting the Environment New development in the Parish will be required to: Protect and where possible, enhance wildlife value, on the site, surrounding sites and wildlife corridors. The use of the DEFRA and Natural England endorsed Biodiversity Impact Assessment Calculator (as updated) will be required to quantify ecological impact and outcome. Only neutral or positive scores will be approved…….” The benefits of the use of a metric are many, and include: Creates a clear objective method of assessing net gain and thus reduces lengthy negotiations between developers, local authorities and wildlife interests in order to determine what level of compensation is needed by a development;

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ID Respondent Name Comment VALP16-09-12-01633 Neil Rowntree (Berks, Creates a “level playing field” between developers so that those who do provide appropriate biodiversity measures to achieve a net Bucks & Oxon Wildlife gain are not disadvantaged compared to those who do not; Trust) Encourages development to not be located on the best habitats for wildlife; Encourages development to create high quality wildlife habitat within their green spaces, of benefit to people and wildlife alike.

The move towards using a metric has received widespread support across Buckinghamshire. The Buckinghamshire and Milton Keynes Natural Environment Partnership (the NEP), which Aylesbury Vale District has a Duty to Co-operate with as it is a Local Nature Partnership (see Town and Country Planning (Local Planning (England) Regulations as amended by the Town and Country Planning (Local Planning) (England) (Amendment) Regulations 2012 to include Local Nature Partnerships), has requested its use e.g. Extract from NEP standard Local Plan response: “Does the Local Plan include a means of assessing whether a net gain in biodiversity is proposed? (e.g. for Major and Minor applications, through the use of a Biodiversity Impact Assessment calculator - e.g. based on that described in the DEFRA Biodiversity Offsetting guidance, or a suitably amended version?” NEP response to draft Aylesbury Vale Local Plan: “State clearly that net gain in biodiversity is an expectation on ALL developments, wherever possible. This is so the Local Plan as a whole achieves a net gain, and the impact on biodiversity of development is not restricted to “major” development only – an approach that would wrongly assume minor developments cannot cause significant harm in biodiversity terms.“ “Identify a means of assessing whether net gain is proposed, and then is achieved (i.e. how the net gain will be monitored, for example through using a biodiversity impact calculator / metric to monitor ecological works – which should be included in the monitoring framework of the Local Plan). NB - at this stage, commitment should be made to at least using a suitable metric to ensure proposed and actual net gains in biodiversity.”

We support the responses of the NEP and also that of the Environment Bank. The NEP is also leading in moving towards an agreed strategy across Buckinghamshire for the accounting of net gain in developments. To quote from a recent NEP briefing paper: “The NEP has discussed a county-wide Biodiversity Accounting Strategy (Making Space for Buckinghamshire v1.2) with the BPOG in February and received support in principal for the Strategy Papers produced.”

The above mentioned NEP paper, Making Space for Nature in Buckinghamshire and Milton Keynes v1.2 identified the benefits of adopting such a Strategy as follows:

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ID Respondent Name Comment VALP16-09-12-01633 Neil Rowntree (Berks, “For developers biodiversity accounting provides a more consistent and objective approach which is transparent and more predictable Bucks & Oxon Wildlife saving time and reducing risk. Trust) For wildlife it means more effective mitigation on site and where compensatory habitat is required, this can be strategically placed so that ecologically coherent networks result. For people it means our environment will be more resilient to change so that present and future generations can continue to enjoy our special environment. For local authorities biodiversity accounting facilitates the Biodiversity Duty (NERC, 2006) and adherence with the National Planning Policy Framework” In the long-term this Strategy points towards the creation of an SPD for Biodiversity Accounting. In the short-term the key policies needed in Local Plans to achieve the delivery of net gain, as required by the NPPF, are: 1. Clear references in Policy to the requirement for a net gain in biodiversity (which in our opinion has been only partly achieved in the wording in the draft Aylesbury Vale Local Plan). 2. Clear references in Policy to the use of a metric to assess in a quantifiable way if a net gain is being achieved (critically, this is currently absent from the draft Aylesbury Vale Local Plan). The Aylesbury Vale Local Plan should therefore include a requirement for all Major and Minor applications to demonstrate a net gain in biodiversity through the use of a Biodiversity Impact Assessment calculator based on that described in the DEFRA Biodiversity Offsetting guidance or a suitably amended version. Recommended policy wording is as follows: “All Major and Minor applications must demonstrate a net gain in biodiversity in a quantifiable way through the use of a Biodiversity Impact Assessment calculator based on that described in the DEFRA Biodiversity Offsetting guidance or a suitably amended version.” Policy relating to legally protected species, priority species and priority habitats Whilst we welcome the policies in NE2 as follows: “c. Internationally important sites and species will be protected……….. d. Development on or likely to have an adverse effect on sites of nationally important sites, such as Sites of Special Scientific Interest will not be permitted unless the benefits of the development clearly outweigh the substantial harm it would cause to the site and the wider national network of SSSIs, and the loss can be mitigated and where possible achieve a net gain on biodiversity/geodiversity. e. Development in Local Wildlife Sites and Biological Notification Sites will only be permitted where the benefits of development clearly outweigh harm to nature conservation interests. Additionally, where every effort has been made to minimise harm, and where appropriate mitigation and where possible enhancement measures can be put in place.”

there are some significant omissions as we can find no reference to nationally protected species or to priority species (otherwise known as species of principal importance as defined by the NERC Act 2006) or to the protection of priority habitats, contrary to the

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ID Respondent Name Comment VALP16-09-12-01633 Neil Rowntree (Berks, Buffers for ancient woodland and other irreplaceable habitats Bucks & Oxon Wildlife To protect irreplaceable habitats such as ancient woodland we would recommend a policy is included within NE2 to specify a minimum Trust) buffer between development and these habitats. Lying in or adjacent to the Chilterns AONB, which contains the most extensive area of native beechwoodland in England, and incorporating significant parts of the Chilterns Beechwoods Special Area of Conservation, and also containing the Bernwood Forest with a wealth of ancient woodlands, Aylesbury Vale is at the heart of one of the most important networks of ancient woodland in the UK. As such the ancient woodland resource is of major importance here. The Standing Advice for Ancient Woodland and Veteran Trees, produced jointly by the Forestry Commission and Natural England (http://www.forestry.gov.uk/pdf/AncientWoodsSA_v7FINALPUBLISHED14Apr3.pdf/$FILE/AncientWoodsSA_v7FINALPUBLISHED14 Apr3.pdf ), states, in relation to the effects on ancient woodland of the development of adjacent land: “Effects from development of adjacent land: -fragmentation and loss of ecological connections with surrounding woodland / veteran trees and the wider natural landscape -effects on the root protection area of individual trees -reduction in the area of other semi--natural habitats adjoining ancient woodland; -increased exposure to pollutants from the surrounding area -increased deposition of dust, particularly from quarries, resulting in physical and/or chemical effects; -impacts on local hydrology through drainage or water table levels changing - increased public use near veteran trees such that safety works leading to possible damage to the tree may be needed; - change to the landscape context for ancient woods and veteran trees - change to light pollution at night (if development includes street lighting) -fly tipping, garden encroachment and increased predation from cats

The following two Woodland Trust research reports also identify a range of impacts: https://www.woodlandtrust.org.uk/mediafile/100168353/Impacts-of-nearby-development-on-the-ecology-of-ancient-woodland- addendum.pdf https://www.woodlandtrust.org.uk/mediafile/100168350/Impacts-of-nearby-development-on-the-ecology-of-ancient-woodland.pdf

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ID Respondent Name Comment VALP16-09-12-01633 Neil Rowntree (Berks, The Addendum report described above includes a Table (Table 3 on page 19) which identified a range of research reports which gave Bucks & Oxon Wildlife figures anywhere between 50m and 400m for the width of buffer zone needed to ensure no negative impacts on ancient woodland Trust) from adjacent development. The 15m buffer zone width given in the FC/NE Standing Advice document mentioned above is clearly described as a minimum e.g. “Development must be kept as far as possible from ancient woodland, with a buffer area maintained between the ancient woodland and any development boundary. An appropriate buffer area will depend on the local circumstances and the type of development. In a planning case in West Sussex the Secretary of State supported the arguments for a 15m buffer around the affected ancient woodland, but larger buffers may be required.” (our emphasis) As the ancient woodland of Aylesbury Vale is a resource of such critical importance in the UK context (see above) we consider that a considerably larger buffer than 15m is needed, with particularly large buffers for ancient woodlands that are of high quality, typically identified by them being designated as an SSSI, LWS or BNS. The Woodland Trust often asks for a minimum buffer of at least 30m. And recent research by Natural England (“Is the management of Local Wildlife Sites affected by the urban fringe? (NERR063)” http://publications.naturalengland.org.uk/publication/6134796821463040 identified negative impacts on LWSs from urban development as far as 100m away from the development.

The FC/NE Standing Advice also states: “The permanent retention of buffer zones must be secured as part of the planning permission. These should be allowed to develop into semi-natural habitat. Developments such as gardens must not be included within buffer zones as there is limited control over how they may be used, or developed in the future; for example, they might be paved or decked without the need for planning permission or they may include inappropriate species which could escape into the woodland.” This issue should be included within the Aylesbury Vale Planning Policy.

As such we would suggest the following policy is included within Policy NE2: “Secure a minimum 30 metre buffer to Ancient Woodland and other irreplaceable habitats, rising to a minimum of 50m where the ancient woodland/irreplaceable habitat is designated as a SSSI, LWS or BNS. The buffer should be made up of appropriate semi- natural habitat, and gardens must not be included within the buffer.”

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ID Respondent Name Comment VALP16-09-12-01633 Neil Rowntree (Berks, Locally important species - We welcome the inclusion of the sentence in paragraph 9.12 which recognises certain species of particular Bucks & Oxon Wildlife importance locally. There are many other species that could be added here and appreciate that there is a limit to how many can be Trust) included however we consider that the following should be added to the list: Black and brown hairstreak butterflies - Aylesbury Vale is a key area for these species which are both largely limited in distribution to a belt from Oxfordshire to Cambridgeshire with Aylesbury Vale central to this belt. They rely on blackthorn hedgerows and the retention and good management is critical to them. Breeding farmland birds and wintering waders – the arable farming with mature hedgerows that is typical of Aylesbury Vale means that these species are of particular importance in the local context. Management in perpetuity of wildlife habitat created as mitigation, compensation and enhancement. All developments have some impact on wildlife, some markedly so. Wherever possible wildlife impacts should be avoided. Where development is proposed which will involve unavoidable loss of biodiversity, and it is deemed necessary, habitat will need to be created or enhanced by the developer to ensure that wildlife impacts are mitigated or compensated for. All developments that involve land-take should also provide for enhancement wherever possible, on or off site, to ensure a net gain in biodiversity (see above section). The impacts on the wildlife will exist for the lifetime of the development, which is how long built development remains on the site. In practice, developments involve land-take in perpetuity, so the impacts on wildlife will be there forever and therefore wildlife habitat created to ensure a net gain in biodiversity must be managed forever. Also the residents will forever be in need of wildlife rich green space for recreation so the funding for that should be there forever. An established method for achieving that is the payment, by the developer, into an endowment fund dedicated to the management of the green space for biodiversity in the development (and/or off-site when off-site compensation provided). An example is the model used in Milton Keynes for the management of green spaces in new developments by The Parks Trust. The annual dividends from the investment of the fund cover the cost of the work whilst the capital remains intact. This would allow management of wildlife habitat created, enhanced or retained to ensure a net gain in biodiversity continues for the lifetime of the development. Ultimately it is the natural environment of Aylesbury Vale that makes it distinctive, attracts people to live in, work in and visit the area, provides numerous benefits to people, and makes a vast contribution to quality of life. The economy of the area is therefore underpinned by the natural environment and wildlife of the area. And yet the natural environment of Aylesbury Vale continues to be eroded by development. Unless Aylesbury Vale moves to such a system as described above then a steady erosion of the natural environment brought about by immense development pressure seems inevitable. This will harm wildlife and impair the very thing that makes Aylesbury Vale an attractive and healthy place to live and work, its natural environment, ultimately harming the economy of the District and the well-being of its residents and workers.

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ID Respondent Name Comment VALP16-09-12-01633 Neil Rowntree (Berks, With proper funding provided in perpetuity of wildlife habitat created, enhanced or retained to ensure a net gain in biodiversity, then Bucks & Oxon Wildlife Aylesbury Vale can continue to attract people to live in, work in and visit, with a high quality of life, all underpinned by a high quality Trust) natural environment. Without any such arrangement the plan will fail to meet the requirement in the NPPF of a “net gain” for biodiversity, and the plan would therefore be unsound. The above could be incorporated into Policy by the inclusion of the following in Policy NE2: “Development is required to enhance the natural and built environment to achieve a net gain in biodiversity through mitigating any essential or residual impacts by requiring development to enhance environmental assets either on or off-site, and ensuring that these are managed to maintain the necessary quality of biodiversity in perpetuity.” The text below the Policy could then explain that in perpetuity means in this case for the lifetime of the development and outline the expected endowment fund method of maintaining the funds for the lifetime of the development. Recommended additional policy: Biodiversity Opportunity Areas (recommended to be placed directly after the Policy NE2 Biodiversity) Whilst we welcome the reference to Biodiversity Opportunity Areas (BOAs) in Policy NE2: “h. Planning conditions/obligations will be used to secure net gains in biodiversity where possible by helping deliver Bucks and MK BAP targets in the Biodiversity Opportunity Areas.” we do not consider that this alone is sufficient to reflect the NPPF paragraphs indicated below. We consider that an increase in content is required, preferable by a separate policy on BOAs, or at the very least by the inclusion of the below policy text within Policy NE2. Such a separate policy has been adopted in the Local Plan of a neighbouring local authority for their own landscape scale ecological networks. Biodiversity Opportunity Areas are key landscape-scale areas in Aylesbury Vale District for the restoration and creation of priority habitat (habitats of principal importance under the NERC Act 2006) and are the ecological networks referred to in the NPPF extracts that follow (with our underlining): NPPF paragraph 109 states: “The planning system should contribute to and enhance the natural and local environment by: minimising impacts on biodiversity and providing net gains in biodiversity where possible, contributing to the Government’s commitment to halt the overall decline in biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures;” Paragraph 113 of the NPPF also states: “Local planning authorities should set criteria based policies against which proposals for any development on or affecting protected wildlife or geodiversity sites or landscape areas will be judged. Distinctions should be made between the hierarchy of international, national and locally designated sites, so that protection is commensurate with their status and gives appropriate weight to their importance and the contribution that they make to wider ecological networks.”

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ID Respondent Name Comment VALP16-09-12-01633 Neil Rowntree (Berks, Paragraph 117 of the NPPF states: “To minimise impacts on biodiversity and geodiversity, planning policies should; plan for Bucks & Oxon Wildlife biodiversity at a landscape-scale across local authority boundaries; identify and map components of the local ecological networks, Trust) including the hierarchy of international, national and locally designated sites of importance for biodiversity, wildlife corridors and stepping stones that connect them and areas identified by local partnerships for habitat restoration or creation; promote the preservation, restoration and re-creation of priority habitats, ecological networks and the protection and recovery of priority species populations, linked to national and local targets, and identify suitable indicators for monitoring biodiversity in the plan.” 165. Planning policies and decisions should be based on up-to-date information about the natural environment and other characteristics of the area including drawing, for example, from River Basin Management Plans. Working with Local Nature Partnerships where appropriate, this should include an assessment of existing and potential components of ecological networks. BOAs are also key areas for the environmental enhancement described in paragraph 21 of the NPPF: “21. …..In drawing up Local Plans, local planning authorities should: identify priority areas for economic regeneration, infrastructure provision and environmental enhancement;” The ecological networks, or Biodiversity Opportunity Areas, are already recognised in planning policy in local authorities across Buckinghamshire and Milton Keynes. Biodiversity Opportunity Areas are critical to the functioning of biodiversity in Aylesbury Vale District, and also to the many “ecosystem services” that are essential for human survival and well-being and which are derived from nature. They are also clearly given a high profile in the NPPF. As such we consider that a specific policy on Biodiversity Opportunity Areas is essential. Suggested wording in the text is: “Biodiversity Opportunity Areas in Buckinghamshire have been mapped by the Buckinghamshire and Milton Keynes Environmental Records Centre (BMERC) in consultation with local authorities and nature conservation organisations. The Opportunity Areas have been identified to focus work to restore biodiversity at a landscape scale through the maintenance, restoration and creation of UK BAP priority habitats, and this is their principle aim. Biodiversity Opportunity Areas represent the areas of greatest opportunity for strategic biodiversity improvement in the District and as such development will be expected to contribute to the achievement of the aims of the target areas through avoiding habitat fragmentation and enhancing biodiversity. General targets for maintenance, restoration and creation of habitats have been set for each area, to be achieved through a combination of biodiversity project work undertaken by a range of organisations, agri-environment schemes and biodiversity enhancements secured in association with development. Habitat improvement within each area will contribute towards achieving County targets, which in turn will contribute towards national biodiversity targets identified in Biodiversity 2020: A strategy for England’s wildlife and ecosystem services (DEFRA).

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ID Respondent Name Comment VALP16-09-12-01633 Neil Rowntree (Berks, A lead partner has been appointed for several of the Biodiversity Opportunity Areas to co-ordinate action. Bucks & Oxon Wildlife Biodiversity enhancements sought in association with development could include the restoration or maintenance of habitats through Trust) appropriate management, new habitat creation to link fragmented habitats, or a financial contribution towards biodiversity initiatives in the Biodiversity Opportunity Area. There are a number of Biodiversity Opportunity Areas within Aylesbury Vale District, and their boundaries are indicated on the Policies Map.” Recommended policy wording is as follows: “Biodiversity Opportunity Areas In order to conserve and enhance the environmental capacity of the District, all new development should maximise opportunities to achieve net gains in biodiversity in accordance with the “Buckinghamshire and Milton Keynes Biodiversity Action Plan – Forward to 2020”. Opportunities will be taken to create links between natural habitats and, in particular, strategic opportunities for biodiversity improvement will be actively pursued within the Biodiversity Opportunity Areas. Where development is proposed within or adjacent to a Biodiversity Opportunity Area biodiversity surveys and a report will be required to identify constraints and opportunities for biodiversity enhancement. Development which would prevent the aims of a Biodiversity Opportunity Area being achieved will not be permitted. Where there is potential for development, the design and layout of the development, planning conditions or obligations will be used to secure biodiversity enhancement to help achieve the aims of the Biodiversity Opportunity Area.” The local plan should also in this section include a map of Biodiversity Opportunity Areas in Aylesbury Vale District. Additional policy: Protection and Enhancement of River and Stream Corridors: An additional policy on Protection and Enhancement of River and Stream Corridors should be included. The river network of Aylesbury Vale has considerable ecological and amenity value and the Local Plan should include policy to ensure the protection and enhancement of its watercourses. Recommended policy wording is as follows: “Planning permission will only be granted for development proposals which would not have an adverse impact on the functions and setting of any watercourse and its associated corridor. Development should seek to conserve and enhance the biodiversity, landscape and recreational value of the watercourse and its corridor through good design. Opportunities for de-culverting of watercourses should be actively pursued. Planning permission will only be granted for proposals which do not involve the culverting of watercourses and which do not prejudice future opportunities for de-culverting (including on sites specifically identified in Aylesbury town centre). Development proposals adjacent to or containing a watercourse should provide or retain a 10m buffer between the top of the river VALP16-09-12-01633 Neil Rowntree (Berks, Policy NE5 - We welcome the inclusion of Policy NE5 and the accompanying text. Bucks & Oxon Wildlife

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ID Respondent Name Comment VALP16-09-12-01633 Neil Rowntree (Berks, Policy NE8 - Policy NE8 Trees, hedgerows and woodland - We welcome the inclusion of this policy but we consider it needs more Bucks & Oxon Wildlife content on hedgerows in order to give adequate protection to these priority habitats (or habitats of principal importance under the Trust) NERC Act 2006) in keeping with the following NPPF paragraphs: “117. To minimise impacts on biodiversity and geodiversity, planning policies should: promote the preservation, restoration and re-creation of priority habitats, ecological networks and the protection and recovery of priority species populations, linked to national and local targets, and identify suitable indicators for monitoring biodiversity in the plan;” “118. When determining planning applications, local planning authorities should aim to conserve and enhance biodiversity by applying the following principles: if significant harm resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused;” Hedgerows within development sites should be retained and also protected by a 10m buffer of semi-natural habitat. We would suggest that wildflower meadow would be the appropriate habitat for the buffers. The hedgerows and buffers should also be specified as dark corridors with no lighting and measures to ensure lighting in other areas does not enter them. 10m wildflower meadow buffers and dark corridors are what is being offered by numerous developments today and we consider that these should be adopted as standard for these sites. Trimming hedgerows annually or even every two years considerably reduces the value of the hedgerows for invertebrates (such as the black and brown hairstreaks which are key species locally (see above comment). Management of the hedgerows should be by a three-year rotation for trimming and allowing some stretches of hedgerow to remain untrimmed for longer.” In addition to that, in order to ensure the hedgerows can make a meaningful contribution to the development achieving a net gain in biodiversity, then the trimming should not be back to the same point as the previous trim so that the hedgerow is allowed to gradually grow in size with rejuvenation when necessary through hedgelaying, conservation hedging or wildlife hedging. Further details on this are available at: http://www.ceh.ac.uk/sites/default/files/HedgerowManagementResearchProject_SummaryLeaflet_June15.pdf , http://www.ceh.ac.uk/sites/default/files/HedgerowRejuvenationResearchProject_SummaryLeaflet_June15.pdf and http://www.ceh.ac.uk/sites/default/files/ScienceForEnvironmentPolicyHedgerowArticle2015.pdf The above content should be included within the text and a statement should be included within the policy as follows: “Hedgerows should be retained, buffered with 10m of semi-natural habitat and should be managed so as to maximise their value for wildlife. The hedgerows and buffers should be maintained within a “dark corridor” with no lighting. Where hedgerow loss is unavoidable then the loss should be compensated by the creation of native species-rich hedgerow at least three times the length that is to be lost.” Additional policy: Biodiversity in built development. NPPF paragraph 118 states: “When determining planning applications, local planning authorities should aim to conserve and enhance biodiversity by applying the following principles: …..opportunities to incorporate biodiversity in and around developments should be encouraged;”

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ID Respondent Name Comment VALP16-09-12-01633 Neil Rowntree (Berks, Policy NE2 “g) Development proposals will be expected to incorporate features to encourage biodiversity, and retain and where Bucks & Oxon Wildlife possible enhance existing features of nature conservation value on site.” and paragraph 9.13 address this issue to some extent. Trust) However we consider more detail than this will be needed in order to comply with the NPPF policy and to ensure that clear expectations are set out to developers as to what is needed for the benefit of both people and wildlife. The text should emphasise that biodiversity in built development is not only about helping wildlife. It is also about creating a much better environment for people, and also about wider “ecosystem service” benefits to people. There is clear evidence that wildlife habitat in urban areas can also have a highly significant beneficial effect for humans by: - reducing the urban heat-island effect in a warming world where summer heatwaves will make any urban areas dominated by tarmac, concrete and bricks (as opposed to street trees, wetlands and other green space) increasingly unbearable and dangerous to health; - reducing air pollution, particularly by removing gaseous pollutants from vehicle exhausts, such as nitrogen oxides and particulates from vehicle exhausts that are increasingly shown to be harmful to human health; - reducing flood risk, by increasing infiltration and therefore slowing run-off into watercourses. Table 1 below provides a recommended “Contents” (further detail would need to be added in each section) for a Biodiversity in Built Development section. All the features in Table 1 offer benefits for wildlife and for people through enjoyment of wildlife and open space, and consequent physical and mental health benefits and in many other ways. The table identifies additional specific benefits: table attached We consider that a specific Policy on Biodiversity in Built Development is needed or much more detail needs to be provided in paragraph 9.13 and Policy NE2. The wording should emphasise the multi-functional nature of biodiversity in built development as highlighted above, and should indicate minimum requirements for what should be included within development. Whilst the bird and bat boxes referred to in 9.13 are welcome this should only be a small part of what is required. It also appears to refer to residential development (e.g. “9.13……modern housing standards….” whereas commercial development often has as much or even more scope to include biodiversity.

VALP16-09-12-01633 Neil Rowntree (Berks, The Local Plan should set out minimum requirements from both commercial and residential developers for the following elements: Bucks & Oxon Wildlife green roofs / green walls Trust) species-rich wildflower road verges street trees provision for wildlife within garden areas – both domestic and business bat and bird boxes within structure of buildings wildlife habitat within SuDS schemes. By setting high standards in this area the Council will be ensuring developments in Aylesbury Vale will be better for the health and wellbeing of residents, workers and visitors, and better for wildlife. Policy wording should be as below, or words to the effect of: “All development proposals should be designed to maximise biodiversity by conserving, enhancing or extending existing resources or creating new areas or features. Examples of what would be required are set out below……..(see above paragraph)”

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ID Respondent Name Comment VALP16-09-12-01641 MICHAEL KNOTT Policy NE3 - Gallagher Estates consider that landscape designations such as Areas of Attractive Landscapes (AALs) or Local (Gallagher Estates) Landscape Areas (LLAs) do not seek to resist development in principle, unless regard has not been given to their distinctive features and key characteristics. It is noted that the southern part of the site, which is located within Aylesbury Vale District, lies within an area designated as an AAL. Policy RA.8 identifies that the designation of AALs in the Aylesbury Vale Local Plan is taken directly from the former Buckinghamshire Structure Plan. The evidence base is therefore significantly out of date and will need to be reviewed through the preparation of the VALP. In responding to the existing saved planning local plan policy (Policy RA.8), the Fleet Marston appeal Inspector in his decision (para 9.140) concluded that "the policy merits very little weight". A copy of the relevant extract of this appeal decision (reference APP/J0405/A/12/2181033) is contained at Appendix 7. The basis for this conclusion was that: 1) it does not set express criteria to be used in measuring whether or not harm would occur and the credentials for assessing mitigation; and "additionally"; 2) there has been no comprehensive analysis of the area and its boundaries and whether the designation continues to be justified. The Local Plan Inspector had also recommended that policy RA.8 not be adopted. In responding to both the existing saved local plan policy (RA.8) and the proposed replacement policy, contained in the current consultation local plan (NE.3) the first stage in mitigating impact is to avoid the identified harmful impact. Where it is accepted there will be harm to the landscape character, specific on-site mitigation will be required and, as a last resort, compensation will be required as part of a planning application. It is acknowledged that applicants must consider the enhancement opportunities identified in the Aylesbury Vale Landscape Character Assessment and how they apply to a specific site. The policies map defines AALs and LLAs which have particular landscape features and qualities considered appropriate for particular conservation and enhancement opportunities. Development in AALs and LLAs should have particular regard to the character identified in the report 'Defining the special qualities of local landscape designations in Aylesbury Vale District' (Final Report, 2016) and Aylesbury Vale Landscape Character Assessment (2008). Development that adversely affects this character will not be permitted unless appropriate mitigation can be secured. Where permission is granted, the council will require conditions or Section 106 agreements to best ensure the mitigation of any harm caused to the landscape interest. Whaddon (HELAA reference: WHA001) The Council's assessment of sites concludes that sites such as Whaddon (HELAA reference: WHA001) is identified as highly sensitive in landscape terms whilst still being proposed as an allocation within the draft local plan. It is therefore clear that this demonstrates how a highly sensitive landscape is not on the councils' approach a bar to a site coming forward.

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ID Respondent Name Comment VALP16-09-12-01641 MICHAEL KNOTT Paragraph 113 of the NPPF advises that local planning authorities should include criteria-based policies to protect landscape areas, (Gallagher Estates) giving appropriate weight to their importance and status in the hierarchy. As explained below, the adverse impact on the AAL arising from the proposed development is not significant and is outweighed by a wide range of benefits, in terms of the social, economic and environmental gains to be delivered. A number of primary and secondary landscape and visual mitigation measures have been employed to minimise adverse effects arising from the development. These include set back of development from the Site boundaries, extending the riparian character of the river corridor to the west and providing additional landscape structure flanking the A4146 to the east; controlling building and planting heights to provide view corridors over the Development to the ridgeline of the Greensand Ridge; using and extending the existing green infrastructure of the Site as the basis for the development layout, incorporating two principal green infrastructure corridors across the Site, including framed views to the Greensand Ridge. VALP16-09-12-01641 MICHAEL KNOTT In terms of landscape features, the Development would result in the loss of agricultural fields but would result in the introduction of (Gallagher Estates) extensive green infrastructure, including woodland, treebelts, wetland, allotments, sports pitches, publicly accessible rough grassland and additional informal open space. This will provide a greatly enhanced array of landscape features within the Site, which largely offsets the adverse change to the agricultural fields such that the residual effects on this feature would not be significant. In addition, there would be significant beneficial effects arising from the expanded wetland area on the western edge of the Site. Furthermore, there would be limited loss of existing vegetation, which is incorporated wherever possible into the Development as part of the proposed green infrastructure; and there would be a large extent of new tree, treebelt and woodland planting, resulting in significant beneficial residual effects on trees as landscape features. As a result of the primary and secondary mitigation measures and establishment under ongoing positive management of the proposed green infrastructure over 20 years, there would be very limited significant adverse residual visual effects. These would be limited to locations in the River Ouzel corridor which did not coincide with the view corridors retained over the Development and PROW within the area of built development. Whilst specific mitigation measures would reduce the adverse effects on both of these sets of visual receptors and, from the Ouzel corridor, the extended and enhanced riparian character of the view would create a beneficial change in view, the proximity of built development would nevertheless result in adverse residual visual effects of moderate significance. In views from the limited locations on the Greensand Ridge from where the Site is seen, the Development would be seen against the backdrop of the wider urban area and the overall composition pattern of the view would remain largely intact, including a foreground of relatively open agricultural land; large scale roadway infrastructure; built development set within vegetation and a distant wooded skyline. With regard to landscape character, the primary and secondary landscape and visual mitigation measures will minimise adverse change in landscape character and increase beneficial changes. The latter include the reinforcement of vegetation structure, notably on the eastern edge of the Site, in part enhancing the assimilation of the A4146 within the landscape structure; the extension and enhancement of the riparian character of the River Ouzel corridor; and the enhancement of the character of the SM in the northern area of the Site. These measures would in part offset the remaining adverse change, such that adverse residual effects on landscape character would be of minormoderate significance at a Site level and, at most, a minor-moderate significance at the wider local level.

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ID Respondent Name Comment VALP16-09-12-01641 MICHAEL KNOTT Policy NE3 - Introduction (Gallagher Estates) Chilmark Consulting Ltd. (CCL) are instructed by and write for and on behalf of Barwood Land and Estates Ltd. (BLEL) with respect to the Vale of Aylesbury Local Plan: Draft Plan, Summer 2016 (VALP) published for consultation by Aylesbury Vale District Council (AVDC). This representation is concerned with Policy NE3 (Landscape Character and Locally Important Landscape) and the supporting evidence base. This representation must be read in conjunction with the other representations submitted by BLEL dealing with related matters. Nature of Representation Draft Policy NE3 states that: “To ensure that the district’s landscape character is maintained, development must have regard to the Aylesbury Landscape Character Assessment 2008 (as amended 2015) and recognise the individual character and distinctiveness of particular Landscape Character Areas”. It continues, stating: “Applicants must consider the enhancement opportunities identified in the Aylesbury Vale Landscape Character Assessment and how they apply to a specific site”. Landscape character analysis for new development is therefore to have regard to the Aylesbury Landscape Character Assessment 2008 (AVLCA) as amended in 2015. BLEL has reviewed in detail the 2008 AVLCA prepared by Jacobs and the recent Landscape Advice to Aylesbury Vale (March 2015) (LAAV) and the Defining the Special Qualities of Local Landscape Designations in Aylesbury Vale (March 2016) (DSQLLD) prepared by Land Use Consultants (LUC). This review is appended at Table 1 to the representation. Whilst the LAAV provides an update of the changes to various Landscape Character Areas to reflect development since the 2008 AVLCA was prepared, the AVLCA has not been updated as a cohesive assessment to reflect recommendations made by LUC to re- assess the landscape using up-to-date methodologies to establish the sensitivity and perceptual qualities of the landscape and incorporate the changes associated with recent development as part of this. At the time of writing, an updated Landscape Character Assessment including the recommendations set out in the LAAV report has yet to be published and Policy NE3 is erroneous in describing the Landscape Character Assessment 2008 as “amended in 2015”. Landscape Character Assessment Review and Update It is instructive to consider the range and extent of the LAAV report’s critique and recommendations as these serve to highlight the limited extent to which AVDC’s landscape character assessment evidence has actually been updated.

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ID Respondent Name Comment VALP16-09-12-01641 MICHAEL KNOTT The LAAV makes a series of recommendations to AVDC for the reconsideration of landscape sensitivities at paragraph 7.2 and the (Gallagher Estates) associated bullet points. These include: the inclusion of greater detail in relation to key landscape characteristics and the need to update the assessment to reflect changes in the baseline conditions since 2008. It also includes recommendations to consider settlement and built form in greater detail and to include sensitivity to specific forms of development. BLEL has reviewed these recommendations in detail and evaluated the extent to which the recommendations have been acted upon in the evidence now presented in the Draft VALP. The findings of BLEL’s analysis is set out in the appended Table 1. The LAAV summarised at paragraph 2.35 that, whilst the assessment was in broad accordance with the NPPF and provided a useful guide to assist in the development of policies: • the AVLCA does not contain as much detail on aesthetic and perceptual factors as current guidance suggests; • the key characteristics identified are brief; and • the concept of inherent sensitivity of landscapes is outdated, with the emphasis currently on understanding the sensitivities to specific types of change. The LAAV identifies that the AVLCA is not in line with current thinking in relation to the sensitivity of landscapes, with an emphasis on the inherent sensitivity of the landscape as opposed to the current approach which is to assess the sensitivity in relation to a specific type of development. The LAAV therefore recommends (at paragraph 5.43 and 7.2 bullet points) that an updated addendum to the assessment be undertaken to clarify how sensitivity is to be interpreted. Whilst the LAAV recognises that the NPPF is not prescriptive in relation to the need for local landscape designations, the need to protect and enhance ‘valued’ landscapes is acknowledged. However, the LAAV recommended that an alternative approach to the use of local landscape designations would be to use a criteria based approach, highlighting the key features and valued characteristics of each of the LCAs and using policy to protect and enhance these valued landscape features. This is in line with the NPPF which requires policies to be based on a criteria based approach (paragraph 113). The Conjoined Inquiry Inspector1 made criticism of the approach and evidence of saved policy RA.8 of the Aylesbury Vale District Local Plan (concerned with Areas of Attractive Landscape). At paragraph 9.140 he concluded that the policy did not set express criteria to be used in measuring harm that would occur; that there has been no comprehensive up-to-date analysis of the area and its boundaries; and even queried whether the designation continued to be justified. He concluded that the policy, based on its construction and the currency of its evidence base merited very little weight. The LAAV specifically advises at paragraph 7.2 that AVDC: • update site descriptions of, among others LCA8.5 Northern Vale and LCA8.10 Southern Vale; • clarify how sensitivity should be interpreted;

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ID Respondent Name Comment VALP16-09-12-01641 MICHAEL KNOTT • consider replacing local landscape designation with an evidence based character approach highlighting key valued features and (Gallagher Estates) characteristics of each LCA; and • if landscape designations are to be maintained, produce evidence on the special qualities / values of locally designated landscape. This would enable the evidence base to consider the situation of land in relation to the up-to-date baseline conditions, including new and proposed development, as well as taking account of localised variations in the character and features. The LAAV report also identified a number of changes ‘on the ground’ resulting from development since the preparation of the Jacobs AVLCA. For example, within the Northern Vale LCA (within which BLEL has a land interest at Fleet Marston) the following baseline context changes and intrusive landscape elements were identified by the LAAV: • Berryfields MDA; • Quarrendon Field Wind Turbine; and • Aylesbury Vale Parkway Train Station. In addition to the above, BLEL consider that the proposed HS2 railway line should also be included as this major infrastructure project will have a significant impact on the character of this area. Additionally, the ongoing development of East West Rail should also be considered as amongst other changes, the train track is proposed to be dualled in the vicinity of Berryfields and BLEL’s Fleet Marston land interests. This will also have significant landscape impacts. At the time of writing however an updated Landscape Character Assessment, taking account of the recommendations set out in the LAAV report and the conclusions of the Conjoined Inquiry Inspector as noted above, has yet to be published. The evidence base is therefore fundamentally flawed in its consideration of landscape sensitivity and the approach taken when identifying land that may be suitable for development based on its condition and inherent sensitivity, without giving due weight to the value of the landscape. This is reflected in the Council’s approach to identifying areas for strategic growth around Aylesbury. Development at Stoke Mandeville, Weston Turville and Aston Clinton are justified through the use of the flawed and out of date assessment that does not take into account the value placed on the landscape that separates these settlements, protects their individual identities and restricts coalescence with Aylesbury.

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ID Respondent Name Comment The critical importance of protecting settlement identity and the avoidance of coalescence through new development is also highlighted in the recent Secretary of State decision concerning proposed development of land between Watermead and Bierton2. At paragraphs 15 – 17 of the Secretary of State’s decision, he concludes that the proposed development would cause Bierton to lose its separate identity (paragraph 15 and IR 7.51). He concludes that the proposed green infrastructure would effectively tie Watermead to Bierton and as such be a further agent of coalescence (IR 7.55). At paragraph 17, the Secretary of State also concluded that the ability to read or appreciate the history of the landscape as a whole would be seriously diminished by built development through the loss of a generally well preserved field pattern (IR 7.66). The importance of the separation of these settlements from Aylesbury to maintain their identity, history and the landscape setting to the villages and Aylesbury town is reflected by the current saved AVDLP Policy RA2 (Loss of Open Gaps and Consolidation of Settlements) and also within the Draft VALP’s Policy S3 (Settlement Hierarchy and Cohesive Development). Taken together with the Secretary of State’s decision with respect to Land East of the A413 Buckingham Road and Watermead set out above, there is a clear, current and unambiguous emphasis on the importance of protecting the identity of individual settlements, avoiding coalescence and the loss of countryside areas separating existing places. VALP16-09-12-01641 MICHAEL KNOTT The Draft VALP’s approach to housing site allocations to the south and east of Aylesbury should be reconsidered in light of this to (Gallagher Estates) avoid loss of identity and coalescence. Special Qualities of Local Landscape Designations Despite receiving advice from Land Use Consultants recommending that local landscape designations may be replaced with an evidence based character approach that highlighted the key valued features and characteristics of LCAs, AVDC have opted to retain the Areas of Attractive Landscape (AAL) and Areas of Landscape Value (ALV) designations in the Draft VALP. BLEL do not accept that the use of the AAL is appropriate. It is out of date and has not been reassessed or updated since its designation in 1979, 37 years ago. As Inspector Rose identified in his report (paragraphs 9.138 – 9.140, page 255) to the Secretary of State on the Conjoined Inquiry (APP/J0405/A/12/2181033) in January 2015, the AAL designation does not comply with the requirements of the NPPF, which encourages the use of criteria based policies against which proposals affecting protected landscape areas can be judged. Therefore, defining the special qualities of the AAL is using an out dated approach that is no longer of relevance, as the independent advice from LUC concluded in the LAAV report. The DSQLLD report seeks to identify the special qualities that are of relevance to each of the local landscape designations but does not reassess the extent of boundaries of the areas or identify other possible AAL areas. By identifying the special qualities that are of particular relevance to the AAL, it is possible to understand the valued features and characteristics and features that may be affected by development. Of particular interest to BLEL are those qualities identified for the Brill- Winchendon Hills AAL within which a very small proportion of their land interest at Fleet Marston (0.06% of the total AAL or 5.5 hectares) is situated and which is separated from the rest of the site by the A41. HS2 will provide further physical and visual separation of the Fleet Marston site from the wider landscape within the AAL, with the mitigation woodland planting shown in the HS2 proposals situated within the AAL area itself. Indeed, the very small area of Fleet Marston within the AAL (in the north-western edge) will be entirely severed visually and physically from the remainder of the wider AAL area by the development of HS2. The Fleet Marston site proposals show clearly where the HS2 line will pass along the western side of the site.

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ID Respondent Name Comment VALP16-09-12-01641 MICHAEL KNOTT Conclusions (Gallagher Estates) Given the magnitude of changes within the landscape since 2008 and the flawed and limited extent of the 2008 AVLCA, there needs to be a complete and comprehensive re-assessment of the character areas as per the recommendations made by LUC, in order: • that the Landscape Character Assessment may properly reflect the character, features and influence of development. For the Northern Vale LCA, this should include existing and planned development at Berryfields MDA, the Aylesbury Vale Parkway Station, HS2 and East West Rail which will pass through the district, and have a significant influence as a feature within the landscape; and • to reflect current thinking in relation to sensitivity and the importance of considering the sensitivity of the landscape to a particular type of development / change. LUC have not produced a separate report for AVDC that deals with this matter. Furthermore, there needs to be a complete and thorough reassessment and update of the scope, extent, boundaries and qualities of the AAL and ALV areas if these areas are to form part of the VALP evidence. These currently rely on outdated and partial assessments which do not reflect subsequent changes in the landscape baseline and the policy fails to accord with national policy by lacking a criteria based approach.

VALP16-09-12-01641 MICHAEL KNOTT Policy NE3 is therefore unsound as it is not: (Gallagher Estates) • Justified – the evidence base is fundamentally flawed in its consideration of landscape sensitivity and the approach taken when identifying land that may be suitable for development based on its condition and inherent sensitivity, without giving due weight to the value of the landscape. • Consistent with national policy – for the reasons identified, the policy and its evidence base are inconsistent with the NPPF at paragraph 113.

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ID Respondent Name Comment VALP16-09-13-01674 Nicola Thomas (Milton Policy NE2 - Policy NE2 and text (pg 164) a) Welcome net gain to be “sought”. Could be strengthened – net gain required – and Keynes Natural make clear this is for all development proposals. Environment b) There is another way – compensation off-site as a last resort. Partnership) g) Welcome ref to features to encourage biodiversity in the built environment and retaining habitat connectivity. Should be a requirement. See Principle 8 and Appendix 2 of the NEP’s Principles document. h) Need to make use of a metric to measure biodiversity loss, and ensure the gain. 7. In respect of biodiversity references in the draft Local Plan: In line with the NEP’s standard Local Plan response in respect of biodiversity, we would also expect the Local Plan to: - Identify the biodiversity that will be lost as a result of the Local Plan and what will be gained; and a check that the gain would outweigh the loss; - Include policies on protecting, enhancing and expanding sites of international, national and local ecological importance – including Local Wildlife Sites and Biological Notification Sites; and protection of protected species and priority species. Also – of BOAs and meeting the 2020 goals of the NEP’s Biodiversity Action Plan in Buckinghamshire for the expansion of priority habitats. - Include requirements for development to respect, protect and help achieve the aims of a BOA; and also to respect, protect and, where possible, improve other valued landscapes and habitats. This could mean avoidance of development, incorporation of ecologically-sufficient buffers, etc. -State clearly that net gain in biodiversity is an expectation on ALL developments, wherever possible. This is so the Local Plan as a whole achieves a net gain, and the impact on biodiversity of development is not restricted to “major” development only – an approach that would wrongly assume minor developments cannot cause significant harm in biodiversity terms. - Identify a means of assessing whether net gain is proposed, and then is achieved (i.e. how the net gain will be monitored, for example through using a biodiversity impact calculator / metric to monitor ecological works – which should be included in the monitoring framework of the Local Plan). NB - at this stage, commitment should be made to at least using a suitable metric to ensure proposed and actual net gains in biodiversity. - Make reference to the mitigation hierarchy (avoidance, mitigation, compensation) – which would strengthen Point 9 of the policy, emphasising that developments should seek to avoid impacts (e.g. by re-design, location at different sites); mitigate for them adequately, or otherwise compensate for them on-site or, as a last resort, off-site. (Policy NE2, Biodiversity, bullet a [pg 164 of the draft Local Plan], should make reference to such “biodiversity offsetting” as a last resort in the mitigation hierarchy). - Encourage the incorporation of biodiversity in and around developments for the benefit of people and the economy as well as for wildlife – including details on how this can be achieved (in the Plan or in a separate design guide) - for example, green roofs, green walls, street trees, SUDs schemes including biodiversity, wildflower meadows and grass verges, woodland, etc. (See the NEP’s draft “Vision and Principles for the Improvement of GI in Buckinghamshire and Milton Keynes – Principle 8 and Appendix 2). We would also encourage the draft Local Plan to take on board the NEP’s standard response to Local Plans (previously submitted) in respect of biodiversity, green infrastructure, energy and the economy. Further comments attached.

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ID Respondent Name Comment VALP16-09-13-01696 Mark Owen (Barton Policy NE1 - We agree with the importance of protected sites such as SSSIs and ancient woodland as indicated within Draft Policy Willmore (on behalf of NE1 (Protected Site). Hampden Fields Consortium)) VALP16-09-13-01696 Policy NE2 - We also agree with the principle of Draft Policy NE2 (Biodiversity) which emphasises the need to protect and enhance biodiversity and the natural environment which has been considered appropriately as part of the Hampden Fields proposal.

VALP16-09-13-01696 Policy NE3 - We agree with Draft Policy NE3 (Landscape Character and Locally Important Landscape) which states that development should consider the role of the landscape character area. VALP16-09-13-01696 Policy NE4 - Furthermore we support the need to protect the setting and appreciation of the Chilterns Area of Outstanding Natural Beauty (AONB) and therefore agree with the objective of Draft Policy NE4 (The Chilterns AONB and Setting). VALP16-09-13-01696 Policy NE5 - We agree that a policy (Draft Policy NE5 (Pollution, Air Quality and Contamination Land)) to consider noise pollution, light pollution, air quality and contaminated land should be included within the Draft VALP. With this in mind, the Hampden Fields proposal has sufficiently considered each of these aspects as part of the Environmental Statement that supported the planning application, and if granted planning permission, will also be considered further at a detailed matters stage.

VALP16-09-13-01696 Policy NE8 - We agree that development should seek to enhance and expand the District’s tree and woodland resource as indicated by Draft Policy NE8 (Trees, Hedgerows and Woodlands). An Arboricultural Impact Assessment and Tree Survey was submitted to support the application for the Hampden Fields proposal and every effort was made to ensure that existing trees on site where retained. In addition the planting of additional trees and vegetation play an important part of the sites proposed green infrastructure corridors. VALP16-09-13-01703 Merilyn Munson Policy NE3 - We support this policy and reiterate the conflict between the AVLCA 2008 and the proposal of Policy S2 to require a blanket level of growth across all of the villages in the District regardless of these environmental constraints.

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ID Respondent Name Comment VALP16-09-13-01708 Rachel Wileman Policy NE2 - Ecology (Buckinghamshire There are three general comments on the draft local plan that require further consideration: County Council) 1)It is important that the document references to the Vision and Principles for the Improvement in Green Infrastructure in Buckinghamshire and Milton Keynes which is being produced by the NEP in partnership with the County Council and District Councils within policy I1 "Vision and principles for the Improvement of Green Infrastructure in Buckinghamshire and Milton Keynes". BCC are in support of the NEP’s response to the draft VALP.

2)The document refers to both a ‘no net loss’ and a ‘net gain’ in biodiversity as the default objective within different sections. It should be made clear (as is the case with the Wycombe LP) that a biodiversity net gain is sought both within the district (strategic) operations and in individual requests for planning permission. ‘No net loss’ should be the exception where it is not possible or viable to achieve (e.g. small conversions) but the policy will be stronger if the emphasis is put on developers or departments to justify a ‘no net loss’ situation.

3)In order to calculate the ‘net loss’ and therefore mitigate or offset it is very important to refer to a Biometrics calculator such as The Metric (or Biodiversity Impact Assessment calculator) produced as part of the DEFRA Biodiversity Offsetting guidance. BCC understands that a countywide approach to this is planned. It is vital that in the minimum a reference is made within this plan to such a metric so that an addendum can be applied once agreement is reached on the bespoke calculator agreed.

Other ecology comments Paragraph 2.6 Objective 7. This bears little reference to any objectives for biodiversity and appears to be an omission. In addition the adaption of wildlife the climatic change should be included in the objections. E.g.; ‘Retention and enhancement of wildlife corridors to ensure adaption to climatic change by wildlife.

Paragraph 3.43 should include reference to NEP Visions and Principal document as mentioned above,

Paragraph 3.81. BCC welcome the constraint on the objective that building on previously developed land can be automatic provided it is not of high environmental value. However it is important to ensure that the determination of environmental value is carried out by a qualified ecologist and not the developer as it is not an easy habitat to assess. An addition to the clause as determined by a professional ecologist may be appropriate.

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ID Respondent Name Comment VALP16-09-13-01708 Rachel Wileman Chapter 9, Natural Environment needs clarifying. The section is divided into ‘Protected sites’ and ‘Biodiversity policies’ which do not (Buckinghamshire lend themselves to easy organisation of the policies. County Council) In paragraphs 9.1-9.5 both European sites (SAC’s and Local Wildlife Sites) have not been included and need to be. Mention of the ‘Hierarchy of protected sites (C/F the NPPF) should be made. NE1 needs to include mention of legislation. ‘Sufficient information…importance of protected sites taking into account any legislative requirements. Even though this is mentioned in policies later, it needs to be included within this policy too.

Paragraphs 9.10 -9.12 Local Wildlife Sites (LWS) have been included (presumably to line up with BMERC providing records for protected species and LWS’s) However it is important that LWS’s are included within NE1 as they are of equal or greater status to ancient woodlands. They should therefore be omitted from this section to avoid duplication.

Policy NE2 refers to a ‘Net Gain in Biodiversity’. I welcome this but as stipulated above reference to an agreed biometric needs to be made. BCC welcome reference to the requirement of a ‘Monitoring and Management Plan’ for developments.

Paragraph 10.1 Conversion of rural buildings. There is no mention of protected species within this section yet a substantial number of rural buildings are likely to harbour bat roosts. A paragraph should be inserted e.g. Old rural buildings have a high likelihood of harbouring bat roosts or bird nests which are legally protected. It is likely that at a minimum a bat risk assessment is required and advice should be sought from the planning authority or district ecologist prior to an application being made.

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ID Respondent Name Comment VALP16-09-13-01709 James Yeoman (Savills Policy NE3 - Policy NE3 relates to Areas of Attractive Landscape (AAL) and Local Landscape Areas (LLA). The Airfield Site lies on behalf of Lands wholly outside of the Brill-Winchendon Hills AAL which extends across the landscape to the north of the A418. It is accepted that there Improvement Holdings is no proposal to change the extent of this AAL, however, it is noted that Paragraph 9.17 of the Draft Plan states that: “Neither of (LIH)) these designations are seeking to resist development in principle, unless regard has not been given to distinctive features and key characters of the AALs and LLA’s.”

Deliverability of Proposed Allocations Subject to the intentions of the local community in respect of updating the Haddenham Neighbourhood Plan, the Draft Plan reports the allocation of part of HELAA Site HAD007, along with HAD001, HAD015 and HAD016. A total capacity of circa 266 dwellings is reported. Based on the Council’s current approach, future housing delivery in Haddenham (excluding commitments) is almost entirely reliant on one site, HAD007. LIH understands this site is being promoted by Cala Homes and Persimmon Homes but it is unclear if these promoters control the land, particularly the eastern portion which borders Church Way and may be required for vehicular access. LIH questions the deliverability of this site and suggests that the housebuilder promoters be required to demonstrate that the landowners are on board and supportive of development before this site is allocated to ensure this is a deliverable housing site.

LIH formally responded to the Draft HELAA (October 2015) at the VALP I&OCD consultation period. Subsequent detailed representations were submitted to AVDC’s Planning Department, outside of the formal consultation period, in March 2016. The purpose of this submission was to assist the Council in respect of the HELAA Version 3 document preparation. These representations provided a Masterplan Concept Document and Landscape Representations concerning the Airfield

The HELAA Version 3 (May 2016) assesses the Airfield under Site Reference HAD005 – Land North of Pegasus Way, Haddenham Airfield. As per the HELAA Version 2 (October 2015), the document reports a site area of 68 hectares. Only the southern parcel of the site (26 hectares) is assessed by AVDC (October 2015) as being suitable for residential, retail and employment development. The Council’s assessment reports:

Site is part suitable – 26 ha of the site is allocated in the neighbourhood plan for mixed use development including 300 dwelling and 4.85ha of employment land. The site has planning permission for 233 dwellings, 6,456 sqm B1 uses, 4,366sqm B2 uses, 9,661sqm B8 uses, 418sqm D uses and 501sqm A1 uses;

b) the northern part of the site is unsuitable due to landscape impacts; c) development should protect the openness and views into the village from the north and reflect ecological interests.

The Council’s assessment of the northern part of the Airfield is unchanged between Version 2 and 3 of the HELAA, albeit a reduced capacity from 300 to 233 residential units is reported to reflect the consented scheme.

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ID Respondent Name Comment VALP16-09-13-01711 Michael Warren (South Policy NE3 - To ensure that AVDC’s landscape character is maintained, development must have regard to the Aylesbury Vale Northamptonshire Landscape Character Assessment 2008 (as amended 2015) and recognise the individual character and distinctiveness of particular Council) Landscape Character Areas set out in the Assessment. Development should consider the role of the landscape character area. The policies map defines Areas of Attractive Landscape (AALs) and Local Landscape Areas (LLAs) which have particular landscape features and qualities considered appropriate for particular conservation and enhancement opportunities. Of the two categories, the Areas of Attractive Landscape have the greater significance. Development in AALs and LLAs should have particular regard to the character identified in the report ‘Defining the special qualities of local landscape designations in Aylesbury Vale District’ (Final Report, 2016) and Aylesbury Vale Landscape Character Assessment (2008). Development that adversely affects this character will not be permitted unless appropriate mitigation can be secured.

SNC response: SNC is particularly supportive of the allocation of Stowe (1) as an Area of Attractive Landscape and Great Ouse Valley – West (7) and Great Ouse Valley – East (8) as Local Landscape Areas.

VALP16-09-13-01717 Michael Brown Policy NE2 - More housing development would detract from the rich historical features of the village eg ridge and furrow landscape, Civil War landmarks VALP16-09-13-01717 Michael Brown Policy NE3 - The village contains a wealth of architectural and historical features, including the site of a Civil War battle VALP16-09-13-01718 Craige Burden Policy NE4 - The policy is not specific and tries to cover too many points. The Chilterns AONB should be afforded a specific level of (Persimmon Homes) protection. The setting to the AONB does not need to be afforded the same level of protection. The policy needs to define the requirements between the two types of areas. VALP16-09-13-01731 Stephanie Schneider Policy NE3 - AREAS OF ATTRACTIVE LANDSCAPE Sensitive or highly valued landscapes between Aylesbury and the villages should be specifically protected, particularly Hampden Fields and the area of West End ditch that runs between Weston Turville and Bedgrove. The amount of develpment proposed in the Plan for Hampden Fields is wholly inappropriate. VALP16-09-13-01731 Stephanie Schneider Policy NE5 - 1) Traffic - The information on the transport strategy does not give enough detail on which to of AVDC’s proposals. Traffic is a major issue currently in and around Aylesbury town and the planned development would significantly worsen congestion on the A41 Tring Road, the A413 Wendover Road and the gyratory system in Aylesbury.There are already areas of poor air quality in the town and the increased traffic would exacerbate this problem (NE5). VALP16-09-13-01734 Charles Routh (Natural Policy NE1 - NE1 Protected sites England) We suggest it is confusing having a policy for “protected sites” and a policy for “biodiversity” which also includes policy relating to protected sites. It may be clearer to have either one policy for both or two policies, the biodiversity one making no reference to matters specific to protected sites. We advise the word “substantive” is removed from line one of the policy. The NPPF does qualify impacts on SSSIs in this way. The policy does not include the NPPF requirement that development affecting a SSSI should not normally be permitted. To address these, we advise that the policy is amended as follows: Where development proposals would lead to an individual or cumulative substantial adverse impact on SSSIs, ancient woodland or ancient trees, the council will balance the overall benefits of the proposal against the impact. Such proposals impacting a SSSI will not normally be permitted.

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ID Respondent Name Comment VALP16-09-13-01734 Charles Routh (Natural Policy NE2 - NE2 biodiversity England) We note that paragraph (b) is likely to be both overly restrictive and potentially too permissive. It requires all compensation to occur onsite, which may be inappropriately restrictive. However, to meet the aspiration of the NPPF of minimising impacts on biodiversity and providing net gains in biodiversity where possible (para 109), we advise that where avoidance and mitigation measures cannot fully alleviate the potential harm, all residual harm to biodiversity should be compensated for appropriately. The following would address these points: b. If significant harm resulting from a development cannot be adequately mitigated, or as a last resort compensated for on site, then development will not be permitted. In cases where it is not possible to fully avoid or mitigate for the loss of biodiversity interests resulting from a development, appropriate compensation should be secured for any residual losses via on or off site compensation measures.

“Substantial” is not a qualification used in the NPPF with respect to SSSIs, and so we suggest the policy is changes as follows: d. Development on or likely to have an adverse effect on sites of nationally important sites, such as Sites of Special Scientific Interest will not be permitted unless the benefits of the development clearly outweigh the substantial harm it would cause to the site and the wider national network of SSSIs, and the loss can be mitigated and where possible achieve a net gain on biodiversity/geodiversity. It might be helpful if the policy was more explicit in how between priority habitats and species (see para 9.10), and locally important species (para 9.12) would be considered in determining planning applications. The plan does not “identify suitable indicators for monitoring biodiversity” as per NPPF 117.

VALP16-09-13-01734 Charles Routh (Natural Policy NE3 - NE3 Landscape character and locally important landscape England) You may wish to modify point e. as follows, as signage is often intentionally prominent in the landscape: e. ensure that the buildings, signage and any outdoor storage and parking areas are not visually prominent in the landscape. VALP16-09-19-01835 Barbara Richardson Policy NE4 - It is really important to protect Areas of Outstanding Natural Beauty, SSSI, and other important countryside areas for the future - once built on the area is lost. VALP16-09-19-01838 Phyllis Simms Policy NE6 - I agree with this policy. VALP16-09-19-01839 Robert Skinner Policy NE6 - I agree with this policy so long as 'made' neighbourhood plan's green spaces are given maximum weight. They need the protection as they are valued community areas, even if VALP has not been made

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ID Respondent Name Comment VALP16-09-01-01854 Keith Brook Policy NE7 - I have a number of more specific concerns:

1.The area proposed for development is prime agricultural land which we believe should be protected under Policy NE7. 2.Although the draft plan talks about providing protection for settlements such as Mursley, Whaddon and Newton Longville, to preserve their unique characteristics, there is no mention of protection for Kingsmead and Tattenhoe Park, the latter is currently in development. Kingsmead is a village style development of just 420 houses on the edge of MK, adjacent to rich agricultural land with views of the open countryside in some parts and bordered by ancient hedges and woodland in others. These features have significant amenity value for the residents and need to be recognised, protected and preserved. 3.The Kingsmead and Tattenhoe Park area currently marks the edge of MK and there are no grid roads beyond this point. Grid roads are an essential part of MK’s infrastructure, ensuring fast movement of traffic into and out of the city, whereas the proposed development talks about S106 Agreements and a Community Infrastructure Levy to fund essential services, this is just a fleeting reference. We believe that the infrastructure requirements, especially relating to transport and traffic for a development of this size, have been substantially played down. In estimating transport infrastructure requirements the development NLV001 and NLV023 and WHA001 must be considered together. That is a total of 4,000 houses and therefore around 6,000 additional cars on the road. Developers’ contributions will not fund the level of transport infrastructure investment required, which is to extend the grid roads and provide major junction upgrades with existing grid roads. 4.Links to the existing by-pass at Stoke Hammond and a means to bypass Bletchley are essential to prevent severe congestion and potential grid lock at peak times on already congested roads. The effect on residential communities close to the proposed sites, without significant investment in road infrastructure, would be hugely detrimental and intolerable at peak times. 5.I note the references to the A421 upgrades and reserved land for a potential new station on the East-West rail line but these are mere wish lists rather than concrete enabling plans. 6.Primary health care and hospital provision is already under significant pressure in MK. Whilst arguably primary care such as GP services would be covered by S106/CIL, our experience in MK is that provision lags behind need. This is certainly the case in MK’s Western Expansion area where some GP surgeries are under severe pressure from new housing developments. Hospital provision is also of major concern. 7.I note that school provision would be provided under developers’ agreements. However in the early stages of development it is likely that children will come into MK schools. The Tattenhoe ward schools are already full and struggling to cater for expansion due to developments in Tattenhoe Park, Kingsmead South and Oxley Park.

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ID Respondent Name Comment VALP16-09-05-01855 Daisy Somerville Policy NE7 - I have a number of more specific concerns:

1.The area proposed for development is prime agricultural land which we believe should be protected under Policy NE7. 2.Although the draft plan talks about providing protection for settlements such as Mursley, Whaddon and Newton Longville, to preserve their unique characteristics, there is no mention of protection for Kingsmead and Tattenhoe Park, the latter is currently in development. Kingsmead is a village style development of just 420 houses on the edge of MK, adjacent to rich agricultural land with views of the open countryside in some parts and bordered by ancient hedges and woodland in others. These features have significant amenity value for the residents and need to be recognised, protected and preserved. 3.The Kingsmead and Tattenhoe Park area currently marks the edge of MK and there are no grid roads beyond this point. Grid roads are an essential part of MK’s infrastructure, ensuring fast movement of traffic into and out of the city, whereas the proposed development talks about S106 Agreements and a Community Infrastructure Levy to fund essential services, this is just a fleeting reference. We believe that the infrastructure requirements, especially relating to transport and traffic for a development of this size, have been substantially played down. In estimating transport infrastructure requirements the development NLV001 and NLV023 and WHA001 must be considered together. That is a total of 4,000 houses and therefore around 6,000 additional cars on the road. Developers’ contributions will not fund the level of transport infrastructure investment required, which is to extend the grid roads and provide major junction upgrades with existing grid roads. 4.Links to the existing by-pass at Stoke Hammond and a means to bypass Bletchley are essential to prevent severe congestion and potential grid lock at peak times on already congested roads. The effect on residential communities close to the proposed sites, without significant investment in road infrastructure, would be hugely detrimental and intolerable at peak times. 5.I note the references to the A421 upgrades and reserved land for a potential new station on the East-West rail line but these are mere wish lists rather than concrete enabling plans. 6.Primary health care and hospital provision is already under significant pressure in MK. Whilst arguably primary care such as GP services would be covered by S106/CIL, our experience in MK is that provision lags behind need. This is certainly the case in MK’s Western Expansion area where some GP surgeries are under severe pressure from new housing developments. Hospital provision is also of major concern. 7.I note that school provision would be provided under developers’ agreements. However in the early stages of development it is likely that children will come into MK schools. The Tattenhoe ward schools are already full and struggling to cater for expansion due to developments in Tattenhoe Park, Kingsmead South and Oxley Park.

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ID Respondent Name Comment VALP16-07-11-00200 Lesley Dance Policy C3 - Whatever building is planned renewable energy must be at the heart of it. We can no longer rely on fossil fuels and must make every possible effort to include solar panels and every type of renewal resource we have. VALP16-08-02-00246 Karen Wedge Policy C3 - Is it worth considering that all new dwellings/developments should have solar panels installed?

VALP16-08-10-00284 Roz Owens Policy C3 - Any significant housing development should be required to provide homes with renewable energy supplies, not just asked nicely as part of AVDC promoting their policy. VALP16-08-15-00330 emma wheatley Policy C4 - Plan to build on glebe land -what about the public footpath there?

VALP16-08-20-00402 Martin Armitstead Policy C1 - There is no policy in the village for this.

VALP16-08-20-00402 Martin Armitstead Policy C3 - Where?

VALP16-08-20-00402 Martin Armitstead Policy C4 - These are already overloaded.

VALP16-08-23-00446 Arthur Evans Policy C4 - Very important.

VALP16-08-25-00529 Lucy Murfett (Chilterns Policy C1 - The Board supports the policy’s approach of retaining agricultural buildings for rural enterprise, with stricter controls on Conservation Board) residential use. In paragraph 10.6 a third reference could be added as follows: "AVDC Design Guide for Conversion of Traditional Farm Buildings and Conversion of Listed Historic Farm Buildings, and in the AONB, to the Chilterns Buildings Design Guide."

VALP16-08-25-00529 Lucy Murfett (Chilterns Policy C2 - The Board supports the policy and suggests adding controls on other aspects of equestrian use which alter the character Conservation Board) of the countryside, such as security lighting, floodlit manege, and suburban style fencing. VALP16-08-25-00529 Lucy Murfett (Chilterns Policy C3 - The policy could usefully refer to noise, motion, glint and glare as types of impact as well as visual impact. The Chilterns Conservation Board) Conservation Board has produced a Position Statement on Renewable Energy which could be referred to in relation to renewable energy proposal in or affecting the Chilterns AONB, available here http://www.chilternsaonb.org/conservation-board/planning- development/position-statements.html. VALP16-08-28-00544 Kevin Hewson Policy C4 - Fully supported.

VALP16-08-28-00548 Nicola Page Policy C4 - footpaths must link from new areas of development onto established paths and new paths between old and new areas be created and if possible new cycle routes which are an improvement on the old ones. All areas should have access to the countryside! VALP16-08-31-00569 Paul Moss Policy C4 - New Developments (WHA01) should not encroach on the North Bucks and SwansWay long distance footpaths.

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ID Respondent Name Comment VALP16-08-31-00607 Eleanor Dolley Policy C4 - There are many public rights of way in the form of pathways and bridlepaths within the proposed development space adjacent to MK / Whaddon, it's hard to see how Aylesbury Vale could possibly manage to protect and retain all these as required by law, if their development plans go ahead? Particularly with regards to point 10.62, f. 'Development proposals should ensure no negative visual impacts on the setting and amenity of existing rights of way' - if plans go ahead, it is impossible to uphold this, as the development will cut through miles of rural land with public rights of way; rows of housing as opposed to countryside, will clearly be a 'negative visual impact'. VALP16-09-01-00633 Frazer Hickling (Phillips Policy C3 - CHAPTER 10-COUNTRYSIDE Planning Services (on This chapter provides, policies on the re-use of rural buildings, equestrian development, renewable energy developments and public behalf of Mrs Davis, Mrs rights of way. Although, we have no comments to make on this chapter, it is considered that the matter of renewable energy Church and Mr Davis of development provision, would be better suited to be located within the ‘infrastructure’ chapter, as such development is not exclusively Corner Farm, Gib Lane suited for the countryside (and the policy contains sets out ‘validation requirements’ for various sizes and forms of development e.g. Bierton)) developments of 10 or more dwellings etc.

VALP16-09-01-00637 Viv Lynch (Wingrave Policy C4 - Paras. 10.60 & 10.61 Many areas are devoid of bridleways but there is a surfeit of footpaths. A review needs to be with Rowsham Parish undertaken of foot paths with a view to upgrading some of these to bridleways or multi user paths. Cyclists are permitted on Council) bridleways but horse riders are not permitted to use cycle ways. This is wrong and needs to be addressed. VALP16-09-02-00641 Christopher Matthews Policy C4 - Paragraphs 10.60 to 10.62 – the principles set out are good but no details are provided. In Haddenham local groups have worked hard with Sustrans and local councils, to obtain Feasibility Studies for safe cycle routes to both Aylesbury and Thame. It is very important that these cycle routes are provided at the earliest opportunity to prevent traffic overwhelming local roads. VALP should make the provision of such cycleways a top priority to be provided at the earliest stage of housing development.

VALP16-09-02-00643 Angela Matthews Policy C4 - Paragraphs 10.60 to 10.62 – the principles set out are good but no details are provided. In Haddenham local groups have worked hard with Sustrans and local councils, to obtain Feasibility Studies for safe cycle routes to both Aylesbury and Thame. It is very important that these cycle routes are provided at the earliest opportunity to prevent traffic overwhelming local roads. VALP should make the provision of such cycleways a top priority to be provided at the earliest stage of housing development.

VALP16-09-02-00653 Quainton Parish Council Policy C1 - The PC agree with this policy.

VALP16-09-02-00653 Quainton Parish Council Policy C2 - The PC agree with this policy.

VALP16-09-02-00671 David Child Policy C4 - C4 funding stream need to be identified for this

VALP16-09-02-00673 rod phillips Policy C1 - If there has to be a policy like this it needs to include all rural buildings and not just barns, it should include all permanent structures including barns and stables providing these buildings are of a permanent build. A condition could be attached to limit these unwanted barn conversions to be adjacent and close to the villages. This should make the existing proposed policy much fairer and would benefit the smaller villages. VALP16-09-02-00677 Steven Mitchell Policy C1 - Support.

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ID Respondent Name Comment VALP16-09-02-00677 Steven Mitchell Policy C3 - Support.

VALP16-09-02-00677 Steven Mitchell Policy C4 - Support.

VALP16-09-04-00750 Colin Read (Aston Policy C4 - We agree with the preservation of footpaths and we do not wish to see them incorporated into developments as Clinton parish planning) pavement alongside roads. This is totally against the principal of the footpath within villages. VALP16-09-05-00802 Ruth Hewitt (Admiral Policy C4 - Public rights of way should be retained in new developments. Costumes) VALP16-09-05-00806 Jeff_ Deacon Policy C1 - Noted that only cute buildings may be converted to other uses, nothing clad in asbestos cement sheeting or profiled steel. More eye candy for the occasional visitor, not the needs of residents. Noted that no isolated building is suitable for re-use. Noted that areas external to buildings are not to be used for the activity within the converted building. VALP16-09-05-00806 Jeff_ Deacon Policy C4 - Noted that you support the continued barging of pedestrians off footpaths by self righteous cyclists.

VALP16-09-05-00807 Angela Truesdale Policy C4 - 10.60 - 62 There are many public footpaths around Haddenham with outstanding views of the Chiltern Hills over rolling countryside. These public footpaths to the south of the village cannot be protected if they are surrounded by a new settlement. These footpaths are well maintained and well used. VALP16-09-05-00820 Christine Yates (EDaN Policy C2 - Very much in keeping with the local environment and nature of our village. (Edlesborough, Dagnall & Northall) community projects) VALP16-09-05-00842 Mrs Caroline Aston Policy C4 - A large number of well used Rights of Way.

VALP16-09-05-00871 Mary Hunt (Aylesbury Policy C3 - Para. 10.56 If we are building this many houses and they are difficult to afford for many people then every possible step Vale Green Party) must be made to ensure that their running costs are low. We recommend that the Council require that all new houses are energy neutral.

C3 the wording is weak. Why should the Council only 'encourage' and not insist?

We recommend that AVDC should take all possible opportunities to generate solar electricity at its sites. This should include car parks e.g roofed cycle stores, park buildings, public conveniences.

All industrial development should be encouraged to maximise renewable energy production, through whatever means available – solar, wind, geothermal, etc. Para.4.96 states that there is already over capacity in terms of industrial and commercial land provision. We recommend that the Council insist that any land not required for industry itself should be used for renewable energy production, be that solar or wind or a combination of both, rather than being re-directed to housing. Such schemes could significantly reduce the energy costs of neighbouring businesses. VALP16-09-05-00897 tim dorsett Policy C1 - Need to maintain some buildings for wildlife

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ID Respondent Name Comment VALP16-09-05-00897 tim dorsett Policy C4 - Very important as these were hard won and provide every one with access to the countryside.

VALP16-09-05-00955 Jonathan Clover Policy C2 - d and f Equestrian development in the right place does provide a leisure resource, as well as employment and opportunities for the young. However, I would ask for stronger provisions on screening and good design standards to be considered for buildings on new developments. VALP16-09-05-00986 Simon Maloney Policy C1 - I support this and all policies under this chapter

VALP16-09-05-00987 Jonathan Glasspool Policy C4 - The proposed development HA07 does not allow for the protection of the main footpath leading north out of the village. This ancient path to Cuddington - marked on the oldest of maps that Haddenham possesses - would be ruined by the addition of so many new houses. VALP16-09-05-00988 Sue Barber Policy C1 - In-keeping the with the local area makes sense but not to demolish and build an increased number of homes.

VALP16-09-05-00988 Sue Barber Policy C3 - Without damaging the look of an area or making noise which ruins the lives of people.

VALP16-09-05-00988 Sue Barber Policy C4 - Required to allow people to enjoy the countryside.

VALP16-09-05-00992 Helen Hyre Policy C3 - Para 10.56 I support the proposal that all development schemes achieve greater efficiency in the use of natural resources (better energy use, better water efficiency and more recycling). VALP16-09-05-00992 Helen Hyre Policy C4 - Para 10.60 I agree that we should protect existing rights of way. However, it isn't ideal for horses and walkers to share the same path because horses can make a path very muddy and impassable for walkers. VALP16-09-05-00998 Charlotte Beadle Chapter 10 Countryside - All paragraphs: I do not support this draft plan for 33000 new homes in Aylesbury Vale. VALP16-09-05-01005 Andrew Phillips Policy C1 - This email is specifically centred around the expansion plans for Haddenham, either by this village growing or a "new town" on its outskirts. Haddenham is a historic settlement with no natural commercial centre. It is a small residential area with one key selling point = which is the railway station. We have two oversubscribed infant schools and one primary school. We are some distance from any secondary school with the nearest in a neighbouring county and no right to send our children there. We have no shops of note other than a corner shop and minor mini market (McColls). We have four pubs and minimal eateries. To expand this village would be a major failing of AVDC. We have poor village roads which are already overcrowded and often accident blackspot (Staybridge Rd jnt Woodways). The S.E part of the village floods yearly and parking around the railway station is already blocking the residential roads. Princes Risborough is also adding housing as is Thame (In Oxfordshire). These in conjunction with Haddenhams already approved housing will put a strain on the existing infrastructure and no additional resources. From attending the open days and seeing your reports. Winslow is the only viable option.

VALP16-09-05-01008 John Mortimer Policy C2 - This should be retained where possible.

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ID Respondent Name Comment VALP16-09-05-01008 John Mortimer Policy C3 - No windfarms or solar farms.

VALP16-09-05-01008 John Mortimer Policy C4 - These must be safeguarded in every way possible. Sometimes they form a defensible boundary and therefore cannot be eliminated. VALP16-09-05-01011 Karen Barker (Great Policy C3 - The draft focusses solely on wind turbines. All forms of renewable energy should be included, additionally conventional Brickhill Parish Council) (non-renewable) energy generation in the vale should be included in the plan. The Plan abdicates responsibility on providing local (and there for not subject to transmission line losses) electrical power generation facilities. VALP16-09-05-01012 Alysoun Glasspool Policy C4 - The proposed development HA07 does not allow for the protection of the main footpath leading north out of the village. This ancient path to Cuddington - marked on the oldest of maps that Haddenham possesses - would be ruined by the addition of so many new houses. VALP16-09-05-01028 Warren Whyte (AVDC) Policy C4 - Developments that alter existing row, or connect onto row should make good and improve signage, gates/styles and ensure that any new row are added to the definitive map - especially those provided as per C4d and e. VALP16-09-07-01153 Sylvie Eames Policy C3 - Agree with all and congratulate the appearance of policy for renewable energy.

VALP16-09-07-01159 Mandy Cliffe (Great Policy C1 - 10.1 C1 Conversion of rural buildings 10.1.1 This policy is an expansion and modification of saved AVDLP Policy RA11. Horwood Parish Council) 10.1.2 GHPC considers that much of the section of this policy headed Proposed uses is repetitious and could usefully be simplified. While the first paragraph in this section could remain unchanged, the remainder of the section would be clearer if it were rewritten along the lines of The re-use of existing buildings for occupational or non-occupational residential purposes will be permitted only if • the redundant or disused status of the building(s) has been confirmed, • no new dwellings are created in the open countryside in the absence of special circumstances, and • it can be demonstrated that the re-use of the building would enhance the immediate setting. If the building proposed for such re-use is a heritage asset, whether designated or not, then the proposal will also be considered under Policy BE1.

VALP16-09-07-01159 Mandy Cliffe (Great Policy C2 - 10.2 C2 Equestrian developments Horwood Parish Council) 10.2.1 This policy is a significant expansion of saved AVDLP Policies GP77 and GP78. 10.2.2 Whereas the section of the policy headed Failure of a commercial enterprise requires an assessment that an existing equestrian enterprise is not viable before a subsequent change of use is permitted, and whereas paragraph 10.47 of the accompanying text refers to the need for a business plan to show that a commercial equestrian development would be viable, there is no explicit requirement in Policy C2 for a positive viability assessment of a proposed equestrian development. GHPC believe that this is an unintended loophole which should be closed by an explicit statement within the policy.

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ID Respondent Name Comment VALP16-09-07-01159 Mandy Cliffe (Great Policy C3 - 10.3.1 GHPC considers this policy to involve the conflation of two separate issues which should be separated. The first Horwood Parish Council) issue concerns the reduction of carbon emissions relating to proposals for residential or non-residential development (which might include, amongst other methods, the provision of renewable energy schemes) in accordance with paragraph 95 of the NPPF; the second concerns the impact of stand-alone proposals for the generation of renewable energy in accordance with paragraph 97 of the NPPF. 10.3.2 The first paragraph of the policy, starting “Planning applications ...” and including the itemised list (a) – (g), together with the final paragraph “Planning permission will be granted ...” and including the itemised list (m) – (o), would appear to concern stand- alone proposals; it is appropriate for them to appear in Chapter 10 Countryside. 10.3.3 The remaining part of the policy “In seeking to … as part of the development.” would appear to concern the reduction of carbon emissions for residential or non-residential development. In the view of GHPC this part of Policy C3 would sit better in Chapter 8 Built environment, either as a part of Policy BE2 or as a separate policy. 10.3.4 Wherever it is located, the itemised list describing the “energy hierarchy” should not include item (l), specifying a requirement for an Energy Statement. This requirement is not part of any hierarchy, and should appear as a stand-alone paragraph immediately after the itemised list. VALP16-09-07-01159 Mandy Cliffe (Great Policy C4 - 10.4.1 This policy is an implementation of paragraph 75 of the NPPF. Horwood Parish Council) 10.4.2 GHPC suggest an additional item in the list of requirements in the policy, along the lines of the following: g. if rights of way are modified or enhanced, special attention should be given to the amenity and convenience of people with disabilities 10.4.3 GHPC also suggest an additional paragraph along the lines of the following: If, exceptionally, it is proposed to stop up or divert a public right of way to enable development to take place, permission will only be granted where there is an existing suitable alternative route, or provision is so made. This wording is taken from saved AVDLP Policy GP84. VALP16-09-07-01172 Simon Proctor (Proctor Policy C1 - Para. 10.11 If re-use is to be resisted then the result is dereliction. Para. 10.16 This policy should not prevent Surveyors (Stoke innovative design. Hammond)) VALP16-09-07-01172 Simon Proctor (Proctor Policy C4 - Rights of way are protected in law. Whilst policies should aim to improve and enhance them when and where ever Surveyors (Stoke possible they should not be used to usurp the sovereignty of the law. It may be appropriate for rights of way to be moved or Hammond)) extinguished and development should not be unnecessarily restricted as a result VALP16-09-08-01205 Mark Rose (Define (on Policy C3 - In relation to the requirement for all developments of 100 dwellings or more to deliver decentralised energy systems behalf of Bovis Homes)) where it is demonstrated that they are deliverable and viable in a feasibility assessment, it is important to note that AVDC must in the first instance establish whether the cumulative policy requirements imposed by the VALP are deliverable and would not render the proposed development unviable (NPPF paras 173-174). VALP16-09-08-01205 Mark Rose (Define (on Policy C4 - The draft policy is unduly restrictive and unreasonable in requiring that development ensure that there is absolutely no behalf of Bovis Homes)) negative visual impact on existing public rights of way.

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ID Respondent Name Comment VALP16-09-08-01225 Frazer Hickling (Phillips Policy C3 - This chapter provides, policies on the re-use of rural buildings, equestrian development, renewable energy developments Planning Services and public rights of way. Although, we have no comments to make on this chapter, it is considered that the matter of renewable Limited) energy development provision, would be better suited to be located within the ‘infrastructure’ chapter, as such development is not exclusively suited for the countryside (and the policy contains sets out ‘validation requirements’ for various sizes and forms of development e.g. developments of 10 or more dwellings etc). VALP16-09-08-01262 Geoff Gardner Policy C3 - Renewable Energy (Gardener Planning Ltd This Report supports the section which recognises the importance of renewable energy developments in the countryside e.g. Policy on behalf of Arnold C3 which includes: White Estates Ltd) Planning applications involving renewable energy development will be encouraged provide that there is no unacceptable adverse impact, including cumulative impact, on the following issues: a.landscape and biodiversity including designations, protected a. habitats and species, and Conservation Target Areas b. visual impacts on local landscapes c. the historic environment including designated and non designated assets and their settings d. the Green Belt, particularly visual impacts on openness e. aviation activities f. highways and access issues, and g. residential amenity. VALP16-09-08-01283 Simon Proctor (Proctor Policy C1 - 10.11 If reuse is to be resisted then dereliction is the result.Para. 10.16 This policy should not prevent innovative Surveyors (Stoke design. Hammond 2)) VALP16-09-08-01283 Simon Proctor (Proctor Policy C4 - Rights of way are protected in law. Whilst policies should aim to improve and enhance them when and where ever Surveyors (Stoke possible they should not be used to usurp the sovereignty of the law. It may be appropriate for rights of way to be moved or Hammond 2)) extinguished and development should not be unnecessarily restricted as a result VALP16-09-08-01291 Martin Small (Historic Policy C1 - Policy C1 – we welcome criteria a. and j. as part of the positive strategy for the conservation and enjoyment of, and the England) clear strategy for enhancing, the historic environment required by the NPPF, although we would welcome a requirement to retain features of architectural or historic importance. Paragraph 10.13 – we welcome the recognition of the many buildings of historic or architectural importance in the countryside and the seeking of their retention as part of the positive strategy for the conservation and enjoyment of, and the clear strategy for enhancing, the historic environment required by the NPPF, but care has to be taken to retain features of architectural or historic importance, the character of the building and its setting when re-using such buildings. VALP16-09-08-01291 Martin Small (Historic Policy C3 - we welcome criteria c. and m. as part of the positive strategy for the conservation and enjoyment of, and the clear England) strategy for enhancing, the historic environment required by the NPPF.

Strategic Principles for Aylesbury Vale – we welcome the principles that Green Infrastructure should contribute to the protection, conservation and management of historic landscapes, archaeological and built heritage assets and be managed to provide cost effective and multi-functional delivery and funded in urban areas to accommodate nature, wildlife, historic and cultural assets, as part of the positive strategy for the conservation and enjoyment of, and the clear strategy for enhancing, the historic environment required by the NPPF.

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ID Respondent Name Comment VALP16-09-09-01389 Amy Stone Policy C4 - Policy C4 – Protection of Public Rights of Way 10.1 Whilst we have no objection to the protection of public rights of way, we question the need for this policy given that public rights of way are protected via separate legislation. 10.2 Nonetheless, we object to criterion f) of the policy which requires that there should be no “…negative visual impacts on the setting and amenity of existing rights of way”. This requirement is wholly inappropriate, has no basis in policy and could be used to prevent any development in close proximity to an existing right of way. This would be perverse as it is generally good planning to ensure that new developments are permeable and connect, wherever possible, to the existing public right of way network. Change Sought 10.3 Delete criterion f) from Policy C4.

VALP16-09-09-01399 Cllr Phil Yerby Policy C4 - The aim of the policy is supported but it is not easily translatable into specific and measurable objectives, which significantly weaken its potential to be applied. 116.124. At the end of bullet point a. the words “in situ, without alteration to alignment ofr existing route of the footpath” should be added. At bullet point c. the word “adverse” needs to be defined by adding “proposed realignment of any footpath from its historical position will be considered as adverse. As will any restriction of view from any position on the footpath across open land or towards an area of open countryside. The loss of views to any areas of AONB or Areas of Attractive Landscapes will be resisted in all circumstances”. VALP16-09-09-01417 David Wilson Policy C4 - Many of the council’s own polices conflict with the strategy: There is no Infrastructure Delivery Plan. The Council has no idea if the required infrastructure to deliver an Aylesbury Garden Town can be delivered, as it is not yet within the VALP documents. Conflicting Policy C4. VALP16-09-09-01427 Phil Yerby (Hampden Policy C4 - The aim of the policy is supported but it is not easily translatable into specific and measurable objectives, which Fields Action Group) significantly weaken its potential to be applied. At the end of bullet point a. the words “in situ, without alteration to alignment of existing route of the footpath” should be added. At bullet point c. the word “adverse” needs to be defined by adding “proposed realignment of any footpath from its historical position will be considered as adverse. As will any restriction of view from any position on the footpath across open land or towards an area of open countryside. The loss of views to any areas of AONB or Areas of Attractive Landscapes will be resisted in all circumstances”.

VALP16-09-09-01451 Geoff Culverhouse Policy C1 - This policy is supported. In the first line of the section headed ‘Proposed uses’ we assume it should read ‘economic (North Bucks Parishes development or community uses’ not 'of'. Planning Consortium) VALP16-09-09-01451 Geoff Culverhouse Policy C2 - In respect of Riding Areas this policy needs a reference to the use of arena lighting being restricted in order to avoid light (North Bucks Parishes pollution in rural areas. Planning Consortium) VALP16-09-09-01451 Geoff Culverhouse Policy C3 - This policy is supported but there should be a specific section, or separate policy, relating to guidance for the (North Bucks Parishes development of Wind Turbines and Solar Farms. Planning Consortium) VALP16-09-09-01451 Geoff Culverhouse Policy C4 - 10.4 This policy is supported. (North Bucks Parishes Planning Consortium)

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ID Respondent Name Comment VALP16-09-12-01514 Simon Proctor (Proctor Policy C1 - 10.11 If re-use is to be resisted then dereliction is the result. Para. 10.1 This policy should not prevent innovative Surveyors (Gawcott)) design. VALP16-09-12-01514 Simon Proctor (Proctor Policy C4 - Rights of way are protected in law. Whilst policies should aim to improve and enhance them when and where ever Surveyors (Gawcott)) possible they should not be used to usurp the sovereignty of the law. It may be appropriate for rights of way to be moved or extinguished and development should not be unnecessarily restricted as a result. VALP16-09-12-01515 Cameron Austin-Fell Policy C3 - Requiring a feasibility assessment for Combined Heat and Power (CHP) for all developments over 100 units should be (RPS Planning & omitted. There is no support for such a stringent policy and no viability testing as to the implications of it. Development (on behalf of Richborough Estates Site - Churchway, Haddenham)) VALP16-09-12-01521 Sean Carolan (Winslow Policy C2 - Policy C2 needs a provision to prevent or minimise light pollution from outdoor equestrian facilities. Town Council) VALP16-09-12-01521 Sean Carolan (Winslow Policy C3 - A clear policy on the siting of wind turbines is required. Town Council) VALP16-09-12-01523 Cameron Austin-Fell Policy C3 - Requiring a feasibility assessment for CHP for all developments over 100 units should be omitted. There is no support (RPS Planning & for such a stringent policy and no viability testing as to the implications of it. Development (on behalf of Richborough Estates Site - Lower Road, Aylesbury))

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ID Respondent Name Comment VALP16-09-12-01538 Jon Gateley (Savills (on Policy C3 - Policy C3 highlights a feasibility assessment of District Heating/Combined Heat and Power, including consideration of behalf of Crest Strategic biomass fuelled CHP, will be required for residential development for 100 dwellings or more. Where these assessments show Projects)) decentralised energy systems are deliverable and viable, such systems will be required as part of the development. CSP objects to this policy as regulating energy use would place the area as out of step with many other districts. The requirement for all developments to connect or make provision for Combined Heat and Power (CHP) is unjustified, and not supported by specific evidence. There are some locations where CHP can be made both viable and feasible, however, these are typically higher density developments, in urban locations. There are limited, if any, examples nationally of major and large scale developments of lower densities (below 50 dph) enabling CHP. NPPF paragraph 173 states that pursuing sustainable development requires careful attention to viability and costs in plan-making and decision-taking. The Government’s Ministerial Statement of 25 March 2015 set out that that from the date the Deregulation Bill is given royal assent (26 March 2015), Local Plans should not include any additional (to the new “optional building regulations” and the new national space standards) local technical standards or requirements relating to the construction, layout or performance of new dwellings. The purpose of the Standards Review was to impose consistency across the country, to assist with the delivery of development and thus matters such as energy efficiency are addressed by the Building Regulations. Paragraph 95 of the NPPF states that when setting local requirements for a building's sustainability, local planning authorities must do so in a way consistent with the Government’s energy policy and adopt nationally described standards. Modifications to Policy C3 sought by CSP The wording of Policy C3 should be amended to make clear the policy is ‘encouraging’ rather than requiring measures to be met. The policy should require a fair and reasonable approach to carbon reduction, which takes full account of economic viability and technical feasibility factors.

VALP16-09-12-01538 Jon Gateley (Savills (on Policy C4 - We broadly support this policy. However, we note that it states: ‘Development proposals should ensure: f) there are no behalf of Crest Strategic negative visual impacts on the setting and amenity of existing rights of way’. This will not be achievable in all circumstances and it is Projects)) recommended to amend the wording as suggested below: Modifications to Policy C4 sought by CSP Replacement criterion for criterion f: “any negative visual impacts on the setting and amenity of existing rights of way are minimised’

VALP16-09-12-01567 Laura Tilston (Gladman Policy C3 - 8.1.1 Gladman object to Policy C3(l) which requires a feasibility assessment for District Heating / Combined Heat and Developments) Power (DH/CHP) for all residential developments of 100 dwellings or more. DH/CHP schemes are massively expensive and would need to be delivered through very large scale schemes in order for them to be viable. Gladman believe the threshold of 100 dwellings to prepare a feasibility assessment is far too low, it will be pointless for schemes of this size to prepare a feasibility assessment as they clearly would not viably be able to deliver DH/CHP. Gladman believe the threshold for preparing the feasibility assessment should be increased significantly.

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ID Respondent Name Comment VALP16-09-12-01567 Laura Tilston (Gladman Policy C4 - Gladman support the inclusion of a policy seeking to protect public rights of way. However, Gladman object to some of Developments) the proposed policy wording within this, specifically parts (c) and (f) and the references to “no adverse impacts…” and “no negative visual impacts…” This terminology is too strong and realistically not achievable if the plan is seeking to boost housing delivery. Instead Gladman suggest that reference should be made in this policy to mitigating any impacts on the public rights of way.

VALP16-09-12-01621 Stewart Patience Policy C3 - Paragraph 10.56 (Anglian Water Services The Council has an objective of achieving greater efficiency in relation to natural resources including water as outlined in para 10.56. Limited) Local Planning Authorities are able to adopt the optional higher water efficiency standard taking account of evidence provided in Water Resource Management Plans and the Environment Agency’s Water Stressed Area Classification Maps. It is therefore considered that the District Council should consider whether the inclusion of the optional higher water efficiency standard would be appropriate. We would support the principle of the optional water efficiency standard being applied within our area of responsibility assuming that Aylesbury Vale District is located in a water stressed area as identified in the Environment Agency’s maps. However the Council will also need to seek the views of the Environment Agency and Thames Water and consider further the impact that such a requirement would have on the overall financial viability of the Local Plan.

VALP16-09-12-01633 Neil Rowntree (Berks, Policy C3 - We welcome the inclusion of Policy C3 Renewable energy and the accompanying text relating to Renewable Energy, Bucks & Oxon Wildlife Carbon reduction and resource use, and off-site renewable energy. Trust) VALP16-09-12-01641 MICHAEL KNOTT Policy C4 - Gallagher Estates support the retention and enhancement of public rights of way. There are numerous Public Rights of (Gallagher Estates) Way crossing our clients' land interests at Eaton Leys which will be retained and enhanced as a result of the development.

VALP16-09-13-01674 Nicola Thomas (Milton Policy C3 - We see that much of our standard response to Local Plans, submitted at the Issues and Options stage, has been taken Keynes Natural into account in the Renewables section in particular. Environment Partnership) Welcome policy C3, Renewable Energy, much of which aligns with the NEP’s standard response regarding renewable energy.

Could the Policy also promote renewable energy, where appropriate, in existing, as well as new developments?

We would also encourage the draft Local Plan to take on board the NEP’s standard response to Local Plans (previously submitted) in respect of biodiversity, green infrastructure, energy and the economy.

VALP16-09-13-01696 Mark Owen (Barton Policy C3 - We support the use of renewable energy within new developments as indicated by Draft Policy C3 (Renewable Energy). Willmore (on behalf of It should be noted that the Hampden Fields proposal is supported by an Energy Statement and it is expected that at a detailed Hampden Fields matters stage that the use of renewable energy will be considered effectively. Consortium))

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ID Respondent Name Comment VALP16-09-13-01696 Mark Owen (Barton Policy C4 -Draft Policy C4 (Protection of Public Rights of Way) states that development proposals should ensure that existing rights Willmore (on behalf of of way and byways are retained and enhanced. We agree with the principle of this draft policy and as part of the Hampden Fields Hampden Fields proposal has ensured that the existing Public Rights of Way have been retained plus additional pedestrian and cycle connections are Consortium)) also proposed. VALP16-09-13-01708 Rachel Wileman Policy C4 - 8.22 Policy C4 Protection of public rights of way (p 190) (Buckinghamshire The introductory preamble on p 190 is excellent. One additional point worth acnkowledging is the role played by public righs of way in County Council) supporting tourism by providing access to countryside sites: SSSI’s, open access land, historic sites, pubs, cafes, canal network, etc. Therefore, suggest: • 10.60 Walking, cycling and horse riding have a valuable role in recreational and leisure trips, supporting tourism and meeting local access needs. • 10.62 typo: ‘Public rights of way’ shouldn’t need a capital p. 8.23 Therefore C4 is excellent and encompasses everything BCC would wish to be included. A few points of clarity, are included below: 8.24 Development proposals should ensure: a. existing public rights of way are retained and enhanced b. the delivery of improvements to the public rights of way network, including provision for disabled people c. no adverse impact on the existing public rights of way network d. new pedestrian routes are provided that link to the wider public rights of way network e. new cycle routes, bridleways and where appropriate greenways or dual /multiple-user routes are connected to the strategic network f. there are no negative visual impacts on the setting and amenity of existing rights of way VALP16-09-13-01734 Charles Routh (Natural Policy C4 -C4 Protection of public rights of way. In many cases development will have unavoidable impacts on public rights of way, England) by reducing their quality (e.g. by urbanising a hitherto rural footpath). Where residual loss of quality occurs, development should provide for compensation such that there is no net detriment to the public right of way network. The policy and or supporting text should make this clear. Reference is made in the policy to visual impacts, but not to acoustic impacts, which can also be significant in terms of amenity. VALP16-09-13-01817 Simon Proctor (Proctor Policy C1 - 10.11 If re-use is to be resisted then dereliction is the result. Para. 10.16 This policy should not prevent innovative Surveyors (Newton design. Longville)) VALP16-09-13-01817 Simon Proctor (Proctor Policy C4 - Rights of way are protected in law. Whilst policies should aim to improve and enhance them when and where ever Surveyors (Newton possible they should not be used to usurp the sovereignty of the law. It may be appropriate for rights of way to be moved or Longville)) extinguished and development should not be unnecessarily restricted as a result.

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ID Respondent Name Comment VALP16-07-13-00205 Terry Cavender Policy I1 - Reference to the canal should explicitly include the arms and not just the Grand Union eg "....Grand Union Canal (including (Buckingham Canal its arms)..." Society) VALP16-07-13-00205 Terry Cavender Policy I4 - As part of SUDS, an ability to allow community groups and other bodies such as Local Area Forum to suggest remediation (Buckingham Canal schemes to existing local/surface water flooding. These can then be reviewed and if approved enacted through partnership using Society) community grants etc match funded by AVDC engineering staff etc. VALP16-07-14-00208 Bill Russell Policy I2 - There needs to be better provision for local exercise opportunities. Link with the NHS for better health & wellbeing through more exercise. VALP16-07-14-00208 Bill Russell Policy I3 - See my comments on the need for links with health care services about Community Hubs. Much social & health care will be provided in the future through the activities of the voluntary sector and the community itself. These activities need a nexus of some sort and community facilities may provide that function. VALP16-07-20-00211 John Bell (Edlesborough Policy I3 - As a GP providing services to the communities of Edlesborough, Eaton Bray, Northall and Dagnall we rely on Surgery) patients driving to the surgery. Any additional community growth will cause huge difficulties with access and parking and we feel that any development near Cow Lane Surgery MUST include additional parking space to allow access to vulnerable patients.

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ID Respondent Name Comment VALP16-07-25-00224 Colin Boddy Policy I2 - Following viewing of the AVDC Local Plan proposals on show in the Buckingham Community Centre on 13th July 2016, I (Buckingham West End would like to thank your representative Roger for taking the time to answer queries I had, relating to future developments in and Bowls Club) around the town. As a committee member of Buckingham West End Bowls Club, I brought to his attention our plight at our longstanding home along the Brackley Road, whereby our present facilities are in a poor state of repair and do not fulfil our needs going forward. We currently have a planning application being considered by the planners for a single dwelling, who are of a mind to grant planning permission, providing we can demonstrate that we can relocate to a suitable site in order to prevent the loss of a public amenity and to overcome a couple of objections from the Environment Agency, whom we are in discussions with to come to a solution, which we are confident can be achieved. With planning this would enable us to raise sufficient funds together with other funding to move to a more suitable location. To this end when presenting our case to the local council, they assisted in forwarding contacts of the agents for the proposed housing site along the Tingewick Road, whom we have been in contact with for initial discussion. It seems apparent that traditionally, when larger development sites have been submitted for both planning, and in some cases to completion, they contain areas for either football pitches with suitable changing facilities, as Emberton Way and Lace Hill, and more recently rugby pitches as the application along the Moreton Road. As everyone locally knows, the Emberton Way facilities were never used for football, rather becoming, after eleven years, a home for the scouts. Although Lace Hill will be used by a new local football club and presumably the rugby pitches, close to the local rugby club, will be used as intended. Is it possible for future larger developments to have facilities allocated for other types of sporting facilities, which in our case would prolong the club’s existence, provide active enjoyment to our 70 members, and potential new members, in the summer and modern facilities which would be used all year round, as we are very active socially. In addition such facilities would, if designed properly, be available for use by the community. Assuming we gain the planning mentioned above, we can also make a substantial financial contribution to any scheme. In addition we would not require so much land as football and rugby pitches. We would welcome the opportunity to discuss the foregoing in more detail with the council, hopefully to enable us to achieve our ambitions of prolonging our legacy, beyond the 106 years the bowls club has been established.

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ID Respondent Name Comment VALP16-07-29-00236 John Oldfield Policy I4 - There is a history of flooding in the Great Ouse catchment. All new development should be founded around reducing the (Buckingham and River flood risk to the new development as well as the existing communities. Ouzel IDB) Flood Risk should be managed with strategic, integrated and maintainable Sustainable Drainage Systems and infrastructure. To ensure the SuDS continue to operate in the future, the Council should require a robust maintenance regime, which typically requires adoption by a statutory flood risk authority with a CIL/S106 commuted sum. This will ensure that they are maintained and that they continue to operate as designed in 10, 20, 30 years...

Particular attention should be given in the plan to define the high standard of requirements for drainage of major development sites. Buckingham has suffered significant flooding in the past, so major development here should also be reducing the existing risk. Developments in AVDC that abuts Milton Keynes Council or Central Bedfordshire Council should be planned in a coordinated manner with the neighbouring authority, such that flood risk is reduces, such as the receiving downstream watercourses of Loughton Brook, the Ouzel and Water Eaton Brook.

All SuDS assets should be designed, built and maintained to function to manage flood risk as well as provide the wider environmental and biodiversity benefits. The Plan should ensure development provides adequate space to deliver this multi function space.

VALP16-07-29-00239 Mr Jan Blackhall Policy I5 - I have written to you under the subject of 16/02/02183/APP on this item already but for completeness: Newton Longville telecoms and Broadband are served by 3 BT cabinets, two of which provide high-speed fibre Broadband service. The third, Cabinet 24, located at the southern end of Westbrook End does not. Properties from no. 56 Westbrook End southwards, all of Drovers Way and some of Drayton Road are fed by copper cable with low-speed (<0.95Mbs) Broadband. Despite a persistent campaign by residents, involving our MP, BT has steadfastly refused to programme works to install fibre to this cabinet. AVDC should undertake urgent discussions with BT to turn this around and The Plan should emphasise the need by any housing or employment developer to incorporate High- speed fibre in its proposals as a matter of prequalification.

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ID Respondent Name Comment VALP16-08-05-00254 Abigail Alderson Policy I4 - Flooding Section - as a context needs to refer to the Strategic Flood Risk Assessment (SFRA) being carried out at Level 1 (Buckinghamshire and that Level 2 SFRA may be required as part of the VALP dependent on the outcome of Level 1 report. County Council) This section needs to refer to Local Flood Risk Management Strategy (LFRMS) which has recently been refreshed and is on Buckinghamshire County Council website flooding pages. Also needs to refer to the Catchment Flood Management Plans – published by the Environment Agency for the Thames and Ouse catchments.

Section 11.19 – check that climate change predictions are correct and up to date Section 11.21 & 11.22 – should link to the sequential test approach for determining where development should go – reference 11.27 Section 11.23 refers to the 2012 SFRA – this is not correct and should refer to the current SFRA level 1 being prepared. Reference should be made to level 2 SFRA when it is available Section 11.26 – poorly worded as does not highlight the risk of surface water flooding. Need to be clear about responsibilities here too – it is not all local authorities who have responsibilities for local flood management but the Lead Local Flood Authority which in this case in Buckinghamshire County Council. Section 11.27 – this should be raised in 11.21 and 11.22 and referenced through to here. The sequential test is not the way of managing and reducing flood risk in the District. It is the way of managing where development should be placed so as to avoid flood risk being raised by development and to ensure that development is placed in a location away from the highest flood risk areas – needs re-wording Section 11.28 – what about areas a risk from surface water as identified in the Updated Maps for Surface Water and groundwater May not need sections 11.27 to 11.30 as it is covered adequately in the policy statement I4

Management and maintenance plans: BCC are not the SUDS approval body we are a statutory consultee for planning.

For any sites where a watercourse is altered or diverted for the development Land Drainage Consent will be required under Section 23 of the Land Drainage Act 1991, we ask that this is promoted to ensure that developers are aware.

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ID Respondent Name Comment VALP16-08-06-00269 John Scott Policy I3 - In your proposals for new housing around Haddenham please do not assume there is capacity in Thame to provide supporting infrastructure for those homes. Thame is very stretched in regards to infrastructure provision and suffers from being on the boundary between local authorities, with the risk that a holistic view is not taken. I would ask that you please ensure that fully joined- up thinking is undertaken where issues span the border to Thame.

On a separate matter, I would encourage you to ensure that new housing developments are demonstrably treated as more than 'just numbers' and that they will genuinely add quality to the local environment. For example, whether the properties are large or small, it is really important for the future that they should be energy efficient buildings, they should support local energy generation and storage, and encourage the uptake of electric vehicles. If this is combined with green spaces that encourage walking and cycling, and new developments include actions that help build community, then the new housing becomes not a burden but an opportunity for the area.

An off-road cycle path between Haddenham and Thame would be an excellent by-product of development in this area.

VALP16-08-08-00272 Martin Wilkinson Policy I2 - I would like to see greater new sports infrastructure in Wendover, which is a growing town. for example, the proposal to remove green belt status to land north of Wendover (RSA2), should be complemented by a proposal to make a new leisure centre. If it was located next to John Colet school, a expanded single sports facility could be made. It is crazy that existing organisations like the pool, youth club, cricket club are all doing their own individual efforts, when there is an opportunity for one site, which would be more sustainable. VALP16-08-08-00272 Martin Wilkinson Policy I3 - Previous increases in housing in Wendover have not been adequately matched with improvements in parking, roads, health care, school facilities. These need to invested in before even more housing is added. VALP16-08-11-00305 Ross Anthony (Theatres Policy I3 - We welcome the proposed Policy I3 Community Facilities, but we are unable to find it sound, as it does not clearly include Trust) cultural facilities. This is required by Para 70 of the NPPF. We do appreciate that the draft plan acknowledges the role of the Waterside Theatre, though not in any particular policy. Chapter 4, particularly paragraph 4.149 appears to suggest cultural facilities such as theatres, will be safeguarded and promoted by Policy I3, however, this is not clearly stated in the policy. It is further confused by the inclusion of a definition for cultural facilities in the glossary, but the term then does not actually appear anywhere else in the plan.

Recommendation: For clarity, and so that guidelines are clear and consistent, we recommend that the accompanying text and the Glossary contains an explanation for the term ‘community facilities’. We recommend this succinct all-inclusive description which would obviate the need to provide examples: community facilities provide for the health and wellbeing, social, educational, spiritual, recreational, leisure and cultural needs of the community. VALP16-08-12-00311 louise Rendle Policy I3 - I have received notification of some plans for additional homes within Winslow and the Horwoods and I would like to express my concern at this - the infrastructure within Winslow is already struggling with only 1 doctors and 1 pharmacy its laughable and not ideal for the size of the town, the school issue is/has been touched upon and changes are underway for those but access routes to/through Winslow already struggle during peak times with the residents we already have adding extra commuters to this will not have a positive effect on the town. The new station for the revival of the winslow line will also bring in commuters from surrounding villages/towns and their are concerns of how the roads will cope with this influx too as I mention above traffic is already difficult at peak times.

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ID Respondent Name Comment VALP16-08-15-00331 Will Dyer Policy I1 - Existing green infrastructure, such as allotments, should not be developed as it is counter to sustainable development.

VALP16-08-16-00341 Elaine Standen Policy I3 - The village has been assessed as medium sized by the points-based system which is an incorrect assessment. We are extremely low on community facilities, relying on surrounding towns and villages. Therefore we should be classed as a small village.

VALP16-08-16-00341 Elaine Standen Policy I4 - Part of the land at MAR003 suffers flooding/poor drainage during heavy rain. Not suitable to build on and is currently part of a working farm. VALP16-08-17-00359 Angela Lucas Policy I1 - p.192 11.1 I agree for the need of quality multi-functional green spaces. 11.3 agree.

VALP16-08-17-00361 Ella Jones (Wendover Policy I3 - 11.16: For Wendover to take on hundreds of extra houses there will need to be high quality additional facilities such as Parish Council) another primary school and additional GP services. These services in Wendover provide for the wider community and not just residents in the parish so extra houses in neighbouring villages will add extra burden to the already struggling education, leisure and health services in Wendover. VALP16-08-17-00362 Stephanie Lucas Policy I1 - Agree

VALP16-08-19-00374 Simon Milliken (National Policy I1 - Text: ‘The town will have an accessible, sustainable and well managed green infrastructure network, including a new linear Trust, Waddesdon park adjoining the HS2 line on the western edge of the town’ Estate and Hartwell Comment: Support in principle, subject to it not impinging on WE/NT/ HHH landowning interests House) Text: Aylesbury’s most valued assets such as…Hartwell House historic park and garden will be protected and enhanced, allowing communities to celebrate their history, their identity and their diversity Comment: WE/NT/HHH strongly support in principle the principle of Aylesbury evolving as a garden town and the contribution that assets like the Waddesdon Estate and Hartwell House and historic park will make to this process. As such, these cultural assets need to be afforded the highest level of policy protection from the impact of future development on the fringe of Aylesbury Town Text: It includes a number of countryside access gateways… notably Quarrendon Leas and, at a greater distance, the Waddesdon Estate (National Trust)… Comment:WE/NT/HHH would need to see and understand the detail behind any Linear Park proposals before any judgement on whether it needs to object or can support these proposals. As matters stand, it would appear from the proposals map, that these proposals could have a direct impact on Hartwell House historic house and parkland

VALP16-08-20-00400 jim woolgar Policy I3 - The school is already full.

VALP16-08-20-00400 jim woolgar Policy I4 - Every time there is heavy rain the sewers overflow from the manholes. The system cannot cope with any extra. The discharge pipe from pumping station to the treatment works is too small for the existing population at times of heavy demand.

VALP16-08-20-00402 Martin Armitstead Policy I4 - Ickford is already recognised as an area of possible flooding, the infrastructure is insufficient to allow water removal.

VALP16-08-20-00402 Martin Armitstead Policy I5 - Broadband is pathetic.

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ID Respondent Name Comment VALP16-08-21-00408 Dave Robinson Policy I3 - 11.18 Existing facilities are already stretched therefore additional schooling & health facilities need to be provided in advance rather than after new housing is developed. VALP16-08-21-00412 Tracy Filler Policy I4 - 11.21 WHA001 is situated at the edge of the village, which is currently laid to arable fields. This area is subject to a high water table and even in dry summer spells the ditches are not dry. We live directly next to this field and a lot of the year these fields are covered in large areas of water. Many of the gateways are impassable even with farm vehicles. Building in this area will exasperate this problem and we have a genuine concern of flooding of our home. VALP16-08-22-00417 Diane Phillips Policy I2 - The village hall facility provides some recreational facilities but there is no local gym for the community to enjoy – nearest being at Buckingham / Bicester or Aylesbury). To encourage a healthy community there also needs to be an increase in safe cycle paths and walks / places for people to safely run to keep fit. There also needs to be a library service which residents can enjoy. VALP16-08-22-00417 Diane Phillips Policy I3 - At present GU benefits from the Church, Village Hall, Real Ale Pub & Restaurant; Shop& PO; There is a weekly fish n chip van (Saturdays) & a community web site. With the expansion the village could benefit from additional facilities. Until the recent past there was a garage, sadly this closed some 18 months ago to make way for more housing. The carbon footprint is increased with people having to travel for essentials such as food, to Aylesbury, Bicester and Buckingham. Currently the capacity of the churchyard is almost full; pressure is therefore increased by additional households to use the already largely full or nearly full to capacity facilities in Bucks and Oxon. Developer consultations and contributions needs to fully consider this aspect. VALP16-08-22-00417 Diane Phillips Policy I4 - Currently the River Ray runs to the immediate north of Broadway and there are several ponds with Great Crested Newts; The capacity of the village for drainage / run off and sewers needs to be carefully considered to prevent future flooding and for hygiene reasons to ensure all drains are adequately dealt with at all times.

VALP16-08-23-00441 Alexander Matthews Policy I4 - I'd like more reassurance that the Great Ouse flood plain has been properly mapped. As Buckingham gets bigger more (Thornton Parish water is going to be sent down the river towards villages like Thornton and Thornborough. Meeting) VALP16-08-23-00445 Nigel Fletcher Policy I4 - Para 11.20. Quote:"As a consequence of climate change, parts of the district will be at increased risk from groundwater, fluvial and/or tidal flooding. It might not be possible to maintain hard defences in the long term. Development therefore need to be strongly restricted in areas at risk to flooding," Ickford main roads (Sheldon and Worminghall) already suffer from groundwater flooding which cannot be ameliorated. The installation of further drainage infrastructure will exacerbate the situation further with more serious flooding of the roads.

VALP16-08-23-00446 Arthur Evans Policy I2 - Each area needs such facilities, at a reasonable cost.

VALP16-08-23-00446 Arthur Evans Policy I3 - Essential.

VALP16-08-25-00529 Lucy Murfett (Chilterns Policy I1 - The Board supports this policy but suggests adding reference in the policy and the supporting text to the Chilterns AONB. Conservation Board) The potential for linking to the Chilterns and expanding its outstanding landscape-scale green network has not been recognised. There is scope to improve pedestrian and cycle links to the well-established routes in the Chilterns, which including national trails like the Ridgeway and strategic cycle routes like the Chilterns Cycleway. Contributions could be sought towards the delivering actions in the Chilterns AONB Management Plan.

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ID Respondent Name Comment VALP16-08-25-00529 Lucy Murfett (Chilterns Policy I3 - The Boards supports these policy controls on loss of facilities like pubs and villages shops, which are crucial both to local Conservation Board) people and visitors to the Chilterns AONB. VALP16-08-25-00529 Lucy Murfett (Chilterns Policy I5 - The Boards supports this policy to limit the damaging landscape impacts which can arise from telecommunications Conservation Board) development. The policy could usefully be expanded to cover similar impacts from other forms of utilities e.g. overhead electricity lines, associated poles or pylons and their ancillary buildings, and high rail and road structures such as overhead line equipment for rail electrification, and traffic cameras and overhead gantries. VALP16-08-28-00548 Nicola Page Policy I3 - We need schools and doctors surgeries on this plan! A 50% increase on population requires a lot of schools, infant, junior and secondary. To ignore this is a HUGE omission. We currently do not have enough doctors, please plan local centres. Internet shopping will never replace convenience shops and doctors! VALP16-08-28-00548 Nicola Page Policy I4 - The area between SM Hsp and Stoke Mandeville frequently floods. Is this being looked at?

VALP16-08-31-00576 Mary and Allan Policy I3 - We strongly object to the site of Croft Meadows being again looked at by the vale of Aylesbury for further building in our glendinning village of cheddington. It has been rejected for very good reasons in the past and those remain valid. A difficult site, one of the few remaining vistas from the village and f some historic interest in the village. we have already submitted our Cheddington Neighborhood plan fulfilling all the requirements asked of us. we should not lose this due to unmet needs of neighboring councils.

VALP16-08-31-00577 Val Jonas Policy I4 - It is very important that new housing and other developments focus on reducing flood risk across the district. There are problems with standing water such as Ickford, where the road through the middle of the village and near the pond at Little Ickford - which gets flooded during heavy rainfall and affects the sewage in the village. There must also be on a holistic view of flooding through joined up planning with other districts e.g. with South Oxfordshire District Council to agree policy fr the river Thame flood plain with all of the drainage flowing into it from Aylesbury Vale villages. See pictures attached. VALP16-08-31-00584 Bruce Gardner (Cherwell Policy I3 - Cherwell Gospel Hall Trust welcomes Policy I3, subject to the policy and supporting text being expanded to recognise that: Gospel Hall Trust) a.Voluntary sector organisations including faith communities may be willing and able to make community infrastructure investments without developer funding; b.Charitable organisations will be CIL exempt for development required in furtherance of charity objectives; c.Notwithstanding funding issues, adequate land allocations will be required to meet known infrastructure needs and/or deficiencies.

VALP16-08-31-00607 Eleanor Dolley Policy I3 - Plans for infrastructure are lacking in detail. The development of sites adjacent to MK will be a huge drain on MK resources, as it will be the nearest big town e.g. the nearest shopping centre, railway station, hospital and main places of employment. Traffic is already a big issue on the Bletchley / Whaddon side of the city - it currently takes 30 minutes to drive only 3 miles from Oxley Park to MKC Train Station during rush hour. An additional 4000+ homes cannot be sustained on these roads. Milton Keynes hospital cannot cope with existing demand. It will be decades before Aylesbury Vale can realistically hope to develop sufficient new local infrastructure to serve all these new houses - therefore the impact on MK's facilities and local residents will be massive.

VALP16-08-31-00609 Stephen Turner Policy I3 - Elderly may need adequate medical, nursing, physiotherapy, OT and other services, in their homes if required: this is not always available, so transport to surgeries and hospitals essential.

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ID Respondent Name Comment VALP16-09-01-00618 Jonathan Proctor Policy I3 - It seems questionable whether the existing infrastructure (in particular, rail and transport links and existing shopping, (Stephenson Harwood) educational and social facilities) can cope with development on this scale. This is further exacerbated by the construction of HS2 and seems to indicate a lack of "joined-up" planning. VALP16-09-01-00620 Jane Hennell (The Canal Policy I1 - Slight concern that paragraph 11.6 states GI improvements will be delivered through development proposals and will be & River Trust) obligated either on site or off site through the CIL regime or conditions to the planning permission as appropriate. It should also be made clear that in some cases S106 contributions may remain an appropriate way of achieving GI improvement or provision.

VALP16-09-01-00637 Viv Lynch (Wingrave with Policy I2 - 11.14 With the increase in housing numbers in rural areas existing sports and leisure facilities will need to be increased and Rowsham Parish in many cases enhanced and upgraded to meet the additional capacity. To enable this to happen it is recommended that S106/CIL Council) monies from developers is used. VALP16-09-01-00637 Viv Lynch (Wingrave with Policy I3 - Para 11.18 Many rural community facilities date back to the early fifties or prior eras. These facilities need to be brought up Rowsham Parish to current day standards and to have additional capacity. Again a good use for S106/CIL monies. Council) VALP16-09-01-00637 Viv Lynch (Wingrave with Policy I4 - Para 11.22 AVDC needs to acknowledge that there is local knowledge in parishes of flood risks which are not other wise Rowsham Parish documented in national or local data bases and such risks need to be considered whenplanning applications come forward. Council) VALP16-09-02-00641 Christopher Matthews Policy I1 - Paragraph 11.1 – Green infrastructure must include village greens, local ponds and streams and local nature reserves. These do not seem to be included. These are an essential feature of the character of Haddenham.

Paragraph 11.6 – I’m not sure how build lots of houses on green fields can ever ‘offer the opportunity to improve the green infrastructure network’. VALP16-09-02-00643 Angela Matthews Policy I1 - Paragraph 11.1 – Green infrastructure must include village greens, local ponds and streams and local nature reserves. These do not seem to be included. They are an essential feature of the character of Haddenham.

Paragraph 11.6 – I’m not sure how building lots of houses on green fields can ever ‘offer the opportunity to improve the green infrastructure network’.

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ID Respondent Name Comment VALP16-09-02-00648 Paul Edwards Policy I4 - Page 44 section infrastructure Vicarage road is already congested due to traffic coming and going from the village or just passing through. Stepnells was built as a cul-de-sac will it really be able to cope with another 100+ traffic movements a day. Section 3.43 the village is currently unable to full fill many of these criteria so how will it be able to support a further development of this size all in one location. Section 3.44 to 3.49 how much of this infrastructure will actually be included into the plan if it is not in place now then the developers will try to avoid including any of it at the time of build. Section 3.50 to 3.52 again as already mentioned the current sewer system is already straining so new pipes and facilities must be included to cater for the increase. Page 53 section previously developed land Section 3.80 why has this not been taken into account as they want to encourage the use of brownfield sites but this has been totally ignored for Marsworth. Section 3.87 even if a local plan was done would it of been adhered to as Pitstone’s local plan seems to of been ignored and they are being forced to accept many more dwellings than they planned for. Section 4.82 if the brownfield sites were taken into account for Marsworth then it would be necessary to rank the sites on suitability and preference. VALP16-09-02-00653 Quainton Parish Council Policy I1 - Agree. Fly tipping is a real problem along many village roads. Buckinghamshire has an important natural environment which, if developed for green infrastructure, should be done so with extreme sensitivity. Wildlife needs 'wild' areas. VALP16-09-02-00655 Frances Durkin Policy I3 - As set out in section I3, the need for additional facilities arising from the growth of a village such as Cheddington must be addressed. There is only one primary school to serve the village and this is already full to capacity. This must be taken into account when bringing more residents into the village who are bound to have need for more schooling. VALP16-09-02-00664 Ken Trew (Cuddington Policy I1 - The Parish Council welcomes the protection offered in housing policies D4, 5 , 6 and 7 to existing open space and green Parish Council) infrastructure. It is noted that the definition of Green infrastructure at Para 11.1 includes allotments :- "11.1 Green infrastructure is a strategically planned network of high quality multi-functional green spaces in both urban and rural areas. It is designed, developed and managed to meet the environmental, social and economic needs of communities. The term includes open green spaces such as parks and gardens, country parks, allotments, cemeteries, green corridors (potentially including cycleways and rights of way) , allotments and trees. It can also include informal amenity green spaces and accessible countryside such as river and canal corridors, woodland, natural grassland, wetlands, lakes and nature reserves".

The Parish Council supports Policy I1 Green infrastructure and its emphasis on the protection, enhancement and maintenance of green infrastructure (including allotments):- As part of this development proposals must demonstrate that the green infrastructure network would be maintained and, where appropriate, enhanced within the site as follows :- g. protect, create, and improve recreation, play, and local food cultivation opportunities for communities h. secure on-going management and maintenance of green infrastructure assets. VALP16-09-02-00666 Kate Curry (Aston Policy I3 - Community facilities such as village halls, pubs, shops, Pos and doctors surgeries must be taken into account as they all Abbotts Parish Council) make a valuable and vital contribution to village life.

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ID Respondent Name Comment VALP16-09-02-00667 Robert Barnes Policy I4 - Must be a critical consideration of all new developments across AVDC when land is taken for housing.

VALP16-09-02-00669 Sean Carolan Policy I3 - Para 11.16 Even this list doesn't include local council offices. This is a Plan that incorporates the localism agenda, but treats local councils like they don't exist. Please include local council premises in lists of buildings to be protected wherever possible.

VALP16-09-02-00675 Mr and Mrs Hudson Policy I4 - Flooding must be taken seriously. There are areas of low laying land which contain and hold back water after constant rain, these areas should not be developed upon. Some areas of flooding have been identified but not all have been identified on the maps. This is the case in and around Ickford - ICK003. Many of the surrounding fields are continually flooded throughout the winter. All new developments should have a thorough investigation before approval. Further information attached VALP16-09-02-00677 Steven Mitchell Policy I1 - Support.

VALP16-09-02-00677 Steven Mitchell Policy I2 - Support.

VALP16-09-02-00677 Steven Mitchell Policy I3 - Support.

VALP16-09-03-00679 Samita Kirve (Bucks Policy I2 - We need more places for recreation. I have suggested that we should have a Lido in section E7. Thanks. NHS Trust) VALP16-09-03-00726 Richard Dorrance Policy I1 - I like the proposals.

VALP16-09-04-00739 Pierre & Wendy Hibble Policy I3 - Paragraphs 11.16 and 11.17 Comments on the closure of the Lowndes Arms in Whaddon as a public house are made under Policy BE1. To reiterate, the Lowndes Arms is an important social asset to the village and its current closure significantly reduces village interaction and social events. Early re-openning of what can be a profitable business, with obvious benefits to the village, and rejection of any potential change of use developments are of critical importance to the village. VALP16-09-04-00750 Colin Read (Aston Policy I1 - We agree with the stated policy Clinton parish planning) VALP16-09-04-00750 Colin Read (Aston Policy I5 - High speed broadband a necessity in this day and age. Clinton parish planning) VALP16-09-04-00757 Steve Heath Policy I5 - Newton Longville which participated in the BT Long Reach ADSL trial, is split into the parts of the village that have fibre and the others that don't. BT need to make sure that all parts of the community are equally well served. VALP16-09-04-00788 David Dinsdale Policy I4 - The proposed garden village will have a significant negative impact on an already stressed infrastructure. Thames water is drafting a plan that will only deal with improving current provision, not taking into account such a large development which is over and above current planned developments in Longwick and the surrounding area. VALP16-09-04-00789 Angie Ravn-Aagaard Policy I4 - Para 11.27 - Bletchley residents have serious concerns regarding management and reduction of flood risk if developments (Bletchley Park Area on land adjacent to Milton Keynes take place, in particular, on-going/future flood management processes. Studies used by local Residents Association) authorities often under-estimate the risk of flooding. VALP16-09-05-00802 Ruth Hewitt (Admiral Policy I5 - All comms need to be improved particularly in rural locations and for rural businesses Costumes)

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ID Respondent Name Comment VALP16-09-05-00806 Jeff_ Deacon Policy I2 - Noted the absence of commitment to prevent the sale of more school playing fields.

VALP16-09-05-00806 Jeff_ Deacon Policy I4 - Please do let on where AVDC is at risk from tidal flooding ( Para. 11.20). Could be indicative of an unthinking cut and paste job. How much of the rest of this plan has been constructed in the same manner? It would seem that AVDC is fully supportive of the policies and actions that gave rise to the recent catastrophic flooding of the Somerset Levels, (first sentences of 11.28) and thereby supportive of the destruction of lives, housing, and employment. VALP16-09-05-00820 Christine Yates (EDaN Policy I4 - Be aware of these issues in the village when allowing big developments (more than 5 houses) (Edlesborough, Dagnall & Northall) community projects) VALP16-09-05-00827 Jenny Armitstead Policy I2 - We have a playing field with poorly maintained children's equipment,this was entirely funded by the local community.

VALP16-09-05-00827 Jenny Armitstead Policy I3 - We have a village hall,built in the 1950's by local residents,poorly equipped and lacks money.consists of a room with open kitchen at the back,a store room and two toilets. VALP16-09-05-00827 Jenny Armitstead Policy I4 - We live in a flood plain.The pumping station in the village has to remove water in tankers as it becomes overloaded.We all pay a premium for house insurance living in a flood plain.We also have waste and rain water combining.Many homes have been flooded and ditches are not maintained. We have inadequate removal of surface water,many homes have been flooded.

VALP16-09-05-00830 Manlet Group Holdings Policy I1 - Policy I1 Green Infrastructure 9.2 Manlet Group generally support draft Policy I1 which seeks to enhance existing green infrastructure as well as provide new features. However, the draft Policy should recognise that there are sometimes occasions where the retention of green infrastructure is not possible or appropriate and that a preferable solution might be to enhance off-site green infrastructure or provide replacement green infrastructure on site. 9.3 Land at Station Road contains an abandoned orchard. The trees are at least 30-40 years old and many are around 3-4m high. The initial Ecological Assessment of the site reports that the apple and plum trees have been unpruned and unmanaged for many years and with an area of rank grassland and encroaching limbs. It also advises that many of the trees have broken branches and some have split or broken limbs. As such, the trees are beyond their natural life and their removal and replacement with new quality trees would provide an enhanced landscape setting for any development on the site. 9.4 Land at Station Road forms a small part of a much larger orchard which was planted at the same time but has been managed and maintained and is a designated Local Wildlife Site. The loss of a small part of abandoned orchard and retention (and potential enhancement) of the remaining higher quality orchard should therefore be an appropriate strategy for this site. 9.5 Draft Policy I1 should therefore be amended to provide some flexibility for sites to be considered on their merits and for an appropriate approach to be taken to enhancing the green infrastructure through development proposals. It is therefore suggested that draft Policy I1 is amended as follows: “…As part of this, and where possible, development proposals should demonstrate that the green infrastructure network should be maintained and, where appropriate, enhanced within or close to the site as follows:…”

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ID Respondent Name Comment VALP16-09-05-00830 Manlet Group Holdings Policy I3 - We support draft Policy I3 which promotes the provision of community facilities where there is demonstrable local need. Land at Station Road has an existing Scout Hut building that has been identified by the Neighbourhood Plan as being a “Community Facility” and a “Cheddington Village Asset”. Development on Land at Station Road could include the replacement of the Scout Hut facility with a new and modern facility to meet the needs of Ist Cheddington Scout who have a membership of around 120 young people in the village. The replacement of the Scout Hut will therefore significantly benefit the local community of Cheddington.

VALP16-09-05-00842 Mrs Caroline Aston Policy I4 - Some parts are subject to flooding which needs to be taken into account

VALP16-09-05-00871 Mary Hunt (Aylesbury Policy I1 - Aylesbury Vale Green Party welcomes the proposals to create a “Green Infrastructure” and in particular the specifications Vale Green Party) contained in pages 194-195 (section 11.10). We wish to see robust guarantees of such improvements being introduced together with sound monitoring of these, hopefully in partnership with local interest groups. It is difficult for district council planning officers to effectively monitor new development and the potential for developers to dilute planning conditions in order to maximise their profit margins. We believe that developers must be required to enter into binding infrastructure obligations that are properly policed and with serious financial penalties for those that fail in their obligations.We note that the proposals are hedged with words such as “could” and “should” – better walking and cycling routes are urgently required already in response to the existing large-scale extensions to Aylesbury and other communities. A glaring example of walking and cycling infrastructure failing to keep pace with development is the continuing failure to build a cycle-/pedestrian-way between Haddenham & Thame station and Thame. Thame is recognised as providing important infrastructure for the people of Haddenham, but the County Council, which is leading on the possibility of building such a route, is acting with complacency. This further emphasises the need for the district, county and parish / town councils to work closely together. We believe that no Local Plan should be adopted before the Infrastructure Delivery Plan and the related CIL (Community Impact Levy) are in place. Section 3.54 of the VALP mentions adoption of this in 2017. Cycle and pedestrian routes have to be designed properly and maintained. Whilst the present system of cycle “gem routes” in Aylesbury is welcome, many cycle routes are not safe or wide enough, e.g. the one along the east side of Cambridge Street. When cycle paths are provided they should be state-of-the-art, not the narrowest that will serve. In order to achieve a significant shift from vehicles to more sustainable walking and cycling, there has to be a meaningful change in planning culture, comparable to the one that has taken place in London with the introduction of long-distance cycle routes that are separated from vehicles. At present, Aylesbury planners seem stuck in the past. For example, at Broughton Crossing the road serving the new housing has been re-opened “for vehicular traffic only / no pedestrian access”. This is shameful. Is it beyond the wits of planners / development control officers to insist that footpaths be constructed at the same time as roads? The proposals to link communities with cycle and pedestrian paths is commendable, but again past experience indicates blindness on the part of the local authorities, with paths between Aylesbury and Weedon or between Stone and Dinton, for example, being allowed to deteriorate to almost the point of invisibility.

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ID Respondent Name Comment VALP16-09-05-00871 Mary Hunt (Aylesbury We recommend that resources are re-prioritised from favouring vehicular traffic to giving an adequate share to walking and cycling, in Vale Green Party) order to ensure that sustainable transport remains sustainable and is fit for purpose. The more people who choose sustainable transport over motorised transport, the better things are for those who are required to use motor transport. Given the potential increase in motor transport, it would be irresponsible not to do as much as possible to limit its growth or, ideally, reduce the volume of motor transport, essential on health, environment and carbon reduction grounds. In 11.4 quoting the Aylesbury Vale Green Infrastructure Plan the VALP recognises the two areas in the Vale which least meet the ANGSt in terms of green infrastructure. We would welcome significant improvements in both these areas. We believe that it is important that responsibility is assigned for the delivery of the green infrastructure. VALP16-09-05-00871 Mary Hunt (Aylesbury Policy I4 - We welcome all plans to identify and mitigate flood risk. We urge the Council to take every precaution to prevent Vale Green Party) groundwater flooding and ask developers to use permeable surfaces wherever possible. VALP16-09-05-00871 Mary Hunt (Aylesbury Policy I5 - We welcome plans to improve the telecommunications infrastructure. It is important in order to suport home working and Vale Green Party) small businesses in rural areas. VALP16-09-05-00874 Philip Morley Policy I2 - Paragraph 11.14 - "New housing development are likely to create additional need for sport and recreation facilities". Where is this proposed to be provided for Wendover? I note that some of the Green Belt site to the west of Tring Road overlaps the playing fields on the school campus. Will these be maintained? Will Wendover swimming pool be maintained, or will this space be required for schools expansion. The schools issue must be considered early - not as an afterthought.

VALP16-09-05-00897 tim dorsett Policy I4 - No building should be built on areas susceptible to flooding.

VALP16-09-05-00900 Jennifer Kruppa Policy I4 - Flooding - The Sustainability Appraisal shows serious issues of flooding on the Woodlands site. This brings the whole strategy to develop Woodlands into question and especially the alignment of the road through the site. VALP16-09-05-00904 Christopher Wayman Policy I1 - GREEN INFRASTRUCTURE (Buckingham Town 11.3/4 Whaddon Chase should be made a Green Belt or an AONB. In addition it should be the River Great Ouse (rather than River Council) Ouse).

VALP16-09-05-00904 Christopher Wayman Policy I4 - FLOODING (Buckingham Town P199-202VALP comprehensively covers the flood risk in the Vale, working with the Environment Agency and underlining the need for Council) Sequential Tests as laid out in the latest Strategic Flood Risk Assessments on all development proposals, “other than sites allocated in the VALP”, and the design and use of Sustainable Urban Drainage Systems (SuDS) on all planning applications. The Plan at 2.47 notes that Buckingham is at risk with the River Great Ouse flowing through the town, and in its design, heritage and environment comments on Page 21 notes the need to prevent surface water flooding through design. Buckingham Town Councillors are proactive in raising flooding and surface water drainage issues when considering planning applications, making use of their local knowledge. BNDP Policy 14 adds: “Development is not permitted in Flood Zones 2 or 3 unless unless the conditions set out within the National Planning Framework (NPPF) and the NPPF Planning Practice Guidance are met.” This includes, since 6th April 2015, the NPPF order that it is now compulsory “for local planning policies and decisions on planning applications, which relate to major development, to ensure that Sustainable Drainage Systems for the management of runoff are put in place”. Developers also have an obligation to consult with their Lead Local Flood Authority.

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ID Respondent Name Comment VALP16-09-05-00928 Tim Northey (Rectory Policy I4 - The policy refers to the requirement that other than sites allocated in the VALP, all development proposals will be required Homes Limited) to demonstrate that the sequential test has been applied. The policy should though also refer to allocations in Neighbourhood Plans which also form part of the development plan once adopted, as this matter should have been considered as part of the early assessment of potential sites. VALP16-09-05-00966 Michelle Kidd (Area Policy I1 - Paragraph 4.23 must be amended to include the network of watercourses that form a network of corridors through the town Sustainable Places and out into the surrounding countryside. Reference should be made to the emerging Aylesbury Vale Watercourses Advice Note. Team The Environment Paragraph 4.24 should refer to the emerging Vision and Principles for the Improvement of Green Infrastructure in Buckinghamshire Agency) and Milton Keynes currently being produced by the Buckinghamshire and Milton Keynes Natural Environment Partnership.

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ID Respondent Name Comment VALP16-09-05-00966 Michelle Kidd (Area Policy I4 - Flood Risk Management - Site allocations Sustainable Places All site allocations and areas selected for development within Flood Zones 2 and 3 will need to be sequentially tested in order to be Team The Environment compliant with National Planning Policy Framework (NPPF) paragraphs 100 and 101. The strategic sequential test will need to be Agency) applied to site allocations within Flood Zones 2 and 3 and you will need to justify with evidence why sites for any development are proposed within Flood Zones 2 or 3. Otherwise we are likely to find your plan unsound at the pre-submission stage. A level 2 Strategic Flood Risk Assessment (SFRA) will also have to be completed as part of your evidence base including the new climate change allowances. Paragraphs 94 and 99 in the NPPF require local authorities to adopt strategies to mitigate and adopt to climate change taking account of flood risk. The new climate change allowances can be found on the GOV. UK website. Please use the following link https://www.gov.uk/guidance/flood-risk-assessments-climate-change-allowances The SFRA will inform the sequential test process and the local plan flood risk policy. The SFRA should be based on the most up-to-date information in order to be compliant with NPPF paragraph 165. Otherwise we are likely to find your plan unsound at the pre-submission stage. We understand the level 1 SFRA has been prepared and we are keen to see how this backs up the decisions made in your local plan. Cont/d.. 2 Functional Floodplain and Tables 1, 2 and 3 of the Planning Practice Guidance Please be aware of Tables 2 and 3 of the Planning Practice Guidance. Table three highlights what kind of development according to its vulnerability is compatible with each flood zone set out in Table 1. For example in Table 3 ‘more vulnerable’ development which includes dwellinghouses is not compatible with Flood Zone 3b. Therefore if you are allocating any dwellinghouses within Flood Zone 3b we will raise a policy objection at the planning application stage and at the site allocation stage we would say that the plan was unsound in accordance with Table 3 ‘Flood risk vulnerability and flood zone compatibility.’ Please use the following link to Tables 1-3 in the Planning Practice Guidance http://planningguidance.communities.gov.uk/blog/guidance/flood-risk-and-coastal-change/flood-zone- and-flood-risk-tables/ Section a of this policy says: “Other than sites allocated in the VALP, all development a. proposals must clearly demonstrate that the sequential test, as set out in the latest version of the SFRA, has been applied.” In order for sites within the local plan to be exempt from the sequential test or the exceptions test they will need to pass the strategic sequential test as part of Aylesbury local plan. Until this has been completed this policy is unsound as it is not compliant with NPPF paragraphs 100 and 101.

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ID Respondent Name Comment VALP16-09-05-00966 Michelle Kidd (Area Point b Sustainable Places This may well be acceptable, however, we cannot comment on this until we have seen the SFRA as part of your evidence base. Team The Environment Point c Agency) Footnote 20 of paragraph 103 of the NPPF states: “20 A site-specific flood risk assessment is required for proposals of 1 hectare or greater in Flood Zone 1; all proposals for new development (including minor development and change of use) in Flood Zones 2 and 3, or in an area within Flood Zone 1 which has critical drainage problems (as notified to the local planning authority by the Environment Agency); and where proposed development or a change of use to a more vulnerable class may be subject to other sources of flooding.” The wording you have in part c of the flooding policy is not clear and requires re-wording to ensure it is consistent with the national policy as above but does not repeat it. If the local plan is diverting from the above, the evidence base will need to justify why this is. Point d Regarding floodplain compensation, we recommend level for level compensation if at all possible and if this is not, then a justified reason will need to be submitted. Only then will it be acceptable to accept other forms of floodplain compensation such as volume for volume and voids. Point J We are pleased to see Climate Change has been included within this policy. However, we would recommend changing the wording of this section to: “Include an assessment of Climate Change” Point q We are pleased to see that groundwater quality will be protected when considering SUDS design. Please can you add that there shall be no infiltration in areas of contaminated land. This is in line with NPPF paragraph 119. Site allocations There do not appear to be policies against each of the site allocations, designating what each development will need to adhere to make it acceptable for that site. Section 1.28 does not make clear if the sites allocated will be accompanied with details or not or they will just refer back to the general policies within the local plan? As a large number of sites are proposed in Flood Zones 2 or 3, if this is found acceptable via your required sequential test and level 2 SFRA, you will need to include strict policies directly linked to these allocations to ensure flood risk is appropriately managed and mitigated. The level 2 SFRA will need to include an assessment of the new climate change allowances and may require modelling. In paragraph 11.28, we support the wording of the first two sentences from a nature conservation viewpoint. Such wording should be incorporated into one of the policies, perhaps into the specific policy relating to watercourses for Aylesbury Vale as we have highlighted earlier in this response.

VALP16-09-05-00977 John Brady Policy I1 - Para 9.3 of the Local Green Spaces policy states that proposals for Local Green Spaces can be put forward during the Draft Plan consultation. Clearly, Haddenham Airfield is a green space already used for sport and recreation and I therefore propose that the area north of HAD005 shown on the VALP be designated a green space within the plan.

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ID Respondent Name Comment VALP16-09-05-00977 John Brady Policy I2 - Haddenham airfield is in current use as a gliding site. Gliding is recognised as a sport by Sport England and airfields used for the sport of gliding are recognised by it as sports facilities in a similar category to playing fields. Aylesbury recognises the value of such facilities in its policy on sports and recreation as follows: 12. The council will encourage partnership working to ensure that sufficient quantity and quality of, and convenient access, to sport and recreation provision is secured through the following measures: To protect existing sites and facilities, planning permission a. will not normally be granted where this would result in the loss of sport and recreational facilities. When dealing with applications which involve this the council will consider its recreational and amenity value, existing provision compared to need in the local area and if equivalent or better quantity and quality replacement provision are provided. Haddenham airfield is an existing sport and recreation facility so the policy from this paragraph should be applied to it. I note that when questioned, planning officials seemed to suggest that they have no influence or control over the retention of such facilities where housing development is proposed. This is not the case. Indeed, in March 2015 the DfT wrote to local planning authorities to draw their attention to the important role of aerodromes in local and regional economies. That letter is relevant to the VALP. The NPPF requires in Paragraph 33 that: 33. When planning for ports, airports and airfields that are not subject to a separate national policy statement, plans should take account of their growth and role in serving business, leisure, training and emergency service needs. Plans should take account of this Framework as well as the principles set out in the relevant national policy statements and the Government Framework for UK Aviation. Haddenham Airfield is not subject to a national policy statement so paragraph 33 applies and the VALP should take that into account in its plan and subsequent decision. This paragraph also references the Government Aviation Policy Framework which must be taken into account. The NPPF also states in paragraph 74 that: 74. Existing open space, sports and recreational buildings and land, including playing fields, should not be built on unless: - an assessment has been undertaken which has clearly shown the open space, buildings or land to be surplus to requirements; or - the loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location; or -the development is for alternative sports and recreational provision, the needs for which clearly outweigh the loss. If the VALP proposes to develop site HAD005 or the airfield area north of it the Council must consider alternative provision.

VALP16-09-05-00986 Simon Maloney Policy I1 - I support all policies under this chapter

VALP16-09-05-00988 Sue Barber Policy I1 - Maintaining green areas in Halton is vital to maintain the peace and tranquillity. Land off Halton Lane is not suitable for development as the roads would not support an increase in traffic - 5,000 vehicles a day use Halton Lane, 80mph at 3.00 in the afternoon is the highest recorded speed (MVAS) 60-65 are common speeds during rush hour. The road has very limited pavement and is unsafe. The bridge is damaged due to traffic volume. VALP16-09-05-00988 Sue Barber Policy I2 - Good as long as it doesn't make noise close to housing.

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ID Respondent Name Comment VALP16-09-05-00988 Sue Barber Policy I3 - Within walking distance for locals, providing a point of contact, information and somewhere for activities to bring people together and form communities. MK is a good example of community facilities which are local and needs to be replicated in any new development. It also helps to reduce crime by helping people care about their neighbours. VALP16-09-05-00992 Helen Hyre Policy I1 - Para 11.9 I agree that green infrastructure should improve biodiversity. VALP16-09-05-00992 Helen Hyre Policy I4 - Para 11.21 - There are many low-lying areas in and around Aylesbury which could be subject to flooding if too many houses are built. Broughton Lane through Kingsbrook is one area which could be vulnerable. VALP16-09-05-00996 Mary Crowther-Alwyn Policy I4 - Para. 11.20 -The level of flooding around Ickford is bound to increase with climate change. Ickford becomes an 'Island' when water levels rise and from most directions can be difficult to access unless one has a larger/higher vehicle. Within the village, twice in the last 5 years, Worminghall Road outside my property has flooded over - too deep to walk through, as has Sheldon Road. This can only be made worse with more buildings displacing water. VALP16-09-05-00998 Charlotte Beadle Chapter 11 Infrastructure - All paragraphs: I do not support this draft plan for 33000 new homes in Aylesbury Vale. VALP16-09-05-01005 Andrew Phillips Chapter 11 Infrastructure - This email is specifically centred around the expansion plans for Haddenham, either by this village growing or a "new town" on its outskirts. Haddenham is a historic settlement with no natural commercial centre. It is a small residential area with one key selling point = which is the railway station. We have two oversubscribed infant schools and one primary school. We are some distance from any secondary school with the nearest in a neighbouring county and no right to send our children there. We have no shops of note other than a corner shop and minor mini market (McColls). We have four pubs and minimal eateries. To expand this village would be a major failing of AVDC. We have poor village roads which are already overcrowded and often accident blackspot (Staybridge Rd jnt Woodways). The S.E part of the village floods yearly and parking around the railway station is already blocking the residential roads. Princes Risborogh is also adding housing as is Thame (In Oxfordshire). These in conjunction with Haddenhams already approved housing will put a strain on the existing infrastructure and no additional resources. From attending the open days and seeing your reports. Winslow is the only viable option.

VALP16-09-05-01008 John Mortimer Policy I1 - It is important to protect the current landscape and in the case of Whaddon includes the provision of a defensible boundary’. It sould be noted in the case of WDA001 there is no foul drainage services in the area. This would need to be provided to enable the project to go ahead. As mentioned elsewhere, there are no footpaths or cycle routes and yet Milton Keynes has provided ample cycleways in Tatennhoe which borders on WDA001. Advantage should be taken of this cycleway by extending it into the AVDC area. In this way residents would be able to enjoy the pleasures of the countryside, which are steadily being eroded before their eyes. It should be noted also that the water table level is very high in the vicinity of WDA001 and account has to be taken of this in the context of flooding and flood-prevention.

VALP16-09-05-01008 John Mortimer Policy I2 - Sports facilites must be provided close to housing developments. AVDC cannot get away with leaving it all to Milton Keynes DC to provide ALL sport and recreation activity although there will be a great temptation to do so in the context of saving money.

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ID Respondent Name Comment VALP16-09-05-01008 John Mortimer Policy I5 - As mentioned elsewhere, provision of the fastest broadband will be expected in any development that will be running forward to 2033. VALP16-09-05-01015 Graham Woodroffe Policy I3 - Plans to build schools to accommodate growth are ill founded because the assumptions made depend on private investment which is not secured. VALP16-09-05-01016 Gordon Pell Policy I3 - There is insufficient provision for the delivery of substantial green space, community facilities and infrastructure. Aylesbury is already at gridlock during rush hour, high-speed broadband is not available in many villages in the local area and 20000+ new homes will only further contribute to the traffic chaos and over crowded infrastructure. VALP16-09-05-01022 Craig Harrison Policy I1 - Given scale of housing and growth planned, GI is vitally important and should be planned for, integrated and managed alongside more traditionally recognized infrastructure such as highways. Natural capital accounting and thinking should be used to better value the contribution GI makes to a sustainable and resilient economy and population. VALP16-09-05-01022 Craig Harrison Policy I4 - Targeted woodland planting in the right places could significantly reduce the risk of flooding events and improve water quality. VALP16-09-05-01028 Warren Whyte (AVDC) Policy I1 - Parish and Town Councils should be part of the early discussion relating to S106 as they may be suitable to adopt green spaces being provided, and can help shape the form of them VALP16-09-05-01028 Warren Whyte (AVDC) Policy I3 - It is important that large scale developments can contribute to extending and/or improving exiting community facilities so that community cohesion can be encouraged by using shared facilities. If this in not practical, or there is a lack of any suitable facilities to be improved, new facilities should be located carefully so that they can be used by a wide range of new and existing residents. The design of these facilities should be carefully considered to provide a sense of identity to an area.

VALP16-09-05-01028 Warren Whyte (AVDC) Policy I4 - Policies I4 n and o are very thin - the design of suds should be considered in conjunction with the green infrastructure and place making potential - be they streams, ponds, lakes or land forms, together with landscaping. VALP16-09-05-01031 Alison Timman Policy I3 - 11.18 Ref. "Similarly, new development creates an additional need for community facilities. The type of facilities needed depends on existing facilities in the locality, and the type of development proposed."

The local school in Stone is already over-subscribed. Building the number of new homes proposed on Site STO008 (42 homes proposed) would mean that new school facilities would be required, or families would need to travel further in order to obtain a school place for their child. This would go against the council's aim to reduce carbon emissions and would create added traffic - likely into Aylesbury - at a time when HS2 would already be causing major traffic problems. VALP16-09-07-01074 Jan Blackhall Policy I3 - Infrastructure needs I am concerned that the Plan appears not to cover infrastructure provision sufficiently seriously. The Plan needs to consider very carefully and honestly the impact of any planned development on public and private infrastructure, such as roads, footpaths, cycleways and bridleways, bus and other public transport services, health and education services and utilities before approving development of any kind. All too often it seems, in the rush to meet housing and employment targets the provision of sufficient infrastructure services to meet the combined needs of existing and proposed communities is of secondary importance. Consequently roads become overcrowded and schools and health facilities become over-subscribed whilst the developers walk away having paid a token Section 106 contribution which achieves a ‘sticking plaster’ solution whilst creating wider-based problems. The Plan must identify, I suggest by means of a dedicated AVDC Infrastructure Task Force, what infrastructure services and facilities will be required during the whole Plan period and make these requirements together with their funding binding on developers on a district-wide basis – not just site by site.

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ID Respondent Name Comment VALP16-09-07-01112 Michael Edmonds. Policy I4 - The River Thame one of two major rivers crossing the district receives and takes a massive input both surface and treated waste water, this has had and still has a detrimental affect on the quality of the water and the bulk at times of storm. A good storm at Aylesbury and our river rises two feet in a couple of hours, this is only going to worsen with vast more development. I would like to see something in the plan to help safeguard this. VALP16-09-07-01153 Sylvie Eames Policy I1 - Green infrastructure reads well. Would like to see the wording strengthened as to how this will be insured. I agree with sports and recreation policy. VALP16-09-07-01153 Sylvie Eames Policy I4 - The Flood policy does mention climage change and the extreme rains that are being experienced

VALP16-09-07-01159 Mandy Cliffe (Great Policy I1 - 11.1 I1 Green infrastructure Horwood Parish Council) 11.1.1 This policy is consistent with bullet point 1 of paragraph 114 of the NPPF. 11.1.2 GHPC considers that the detailed list of green infrastructure accessibility and quantitative standards provided at the end of this policy gives an inappropriate level of detail, and suggests that instead the paragraph introducing the itemised list should instead read "As part of this development proposals must demonstrate that the green infrastructure network would be maintained and, where appropriate, enhanced within the site to the standards set out in the Assessment of Leisure and Cultural Facilities (2012) or its replacement, as follows:"

VALP16-09-07-01159 Mandy Cliffe (Great Policy I2 - 11.2 I2 Sports and recreation Horwood Parish Council) 11.2.1 This policy is consistent with paragraph 73 and 74 of the NPPF, except insofar as the 2012 Assessment of Leisure and Cultural Facilities does not qualify as an “up-to-date assessment … of quantitative or qualitative deficits or surpluses ...” 11.2.2 GHPC considers that the first sentence in item (c) in the list in this policy should contain a reference to the SPG ready-reckoner, so that the phrase “commensurate to the need” can be quantified. VALP16-09-07-01159 Mandy Cliffe (Great Policy I3 - This policy is essentially a combination of saved AVDLP policies 93 and 94; it is consistent with bullet point 4 of paragraph Horwood Parish Council) 28 of the NPPF. GHPC considers that the final sentence of the policy should be extended so that it reads Conditions will be imposed on permissions, or planning obligations sought in order to secure appropriate community facilities, or financial contributions towards community facilities, reasonably related to the scale and kind of housing proposed and with appropriate facilities for access and use by disabled people.

VALP16-09-07-01159 Mandy Cliffe (Great Policy I4 - 11.4.1 This policy is consistent with paragraph 100 of the NPPF. The current version of the Strategic Flood Risk Horwood Parish Council) Assessment, although dated 2012 and prepared for the withdrawn Vale of Aylesbury Plan, is still appropriate as evidence to support this policy. 11.4.2 Paragraphs 11.31 and 11.32 of the supporting text appear in a section headed Water resources, after (rather than before) Policy I4. While there is some reference in the policy to development restrictions in order to maintain water quality, GHPC considers that the final three sentences of paragraph 11.32 should be incorporated with this policy.

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ID Respondent Name Comment VALP16-09-07-01159 Mandy Cliffe (Great Policy I5 - 11.5.1 This policy is a modification and extension of saved AVDLP Policy GP100, and is consistent with paragraph 43 of Horwood Parish Council) the NPPF. 11.5.2 There is a conflict between the wording of this policy, which is written as a list of conditions to be satisfied before permission is granted, and the aspirations expressed in paragraph 11.41 of the supporting text. The former appears to concern masts for wireless communication, whereas the latter includes ducting for wired communication. 11.5.3 GHPC considers that this policy should contain an additional paragraph, incorporating the aspirations from paragraph 11.41, along the lines of the following: All new housing and commercial development should incorporate high quality on-site communications infrastructure, including ducting to industry standards, for efficient connection to existing networks and including potential for future upgrades. If such infrastructure cannot be delivered, the developer will need to submit evidence to justify the reasons why this is the case, whether it be for viability or technical reasons. VALP16-09-07-01159 Mandy Cliffe (Great General Comment - 11.1 GHPC suggest that the labels for policies in this chapter might be typographically clearer if the label prefix Horwood Parish Council) was DI rather than I, rather as the prefix for policies in the Built environment chapter is BE.

VALP16-09-07-01172 Simon Proctor (Proctor Policy I4 - I4 - This policy should be amended to quantify developments over a certain size or quantum. If clarification is not given Surveyors (Stoke there is the risk of overcomplicating minor applications and generating unnecessary costs and bureaucracy. Hammond)) VALP16-09-07-01184 Michael Edmonds Policy I4 - The River Thame one of two major rivers crossing the district receives and takes a massive input both surface and treated waste water, this has had and still has a detrimental affect on the quality of the water and the bulk at times of storm. A good storm at Aylesbury and our river rises two feet in a couple of hours, this is only going to worsen with vast more development. I would like to see something in the plan to help safeguard this.

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ID Respondent Name Comment VALP16-09-08-01204 Mark Furnish (Sport Policy I1 - Detailed Infrastructure England) Sport England is encouraged with the acknowledgment in paragraph 11.2 that green infrastructure can increase recreation opportunities and healthy living and that development proposals on larger sites can improve green infrastructure. As mentioned above, this ethos is included within Active Design. However, it is advised that point ‘e’ of Policy I1 refers to formal and informal sport playing pitch and sport provision.

Sport England do not advocate the use of standards as standards are a generic approach that fail to consider how and where sport is played, such as where participants travel and where the supply of playing pithes and sport facliites should be located. The use of standards does not result in provision of facilities that are based on a robust need assessment and stragegy indicating what is required and where to meet existing and future demand. In consquence, Sport England objects to the use of standards in the last bullet point I1 and advise that the Local Authority use a needs/evidence bassed approach.

While Sport England welcomes the inclusion of the sport and recreation section, the content of this section and Policy I2 is considerably concerning. Local Plans and its policies should address the spatial implications of economic, social and environmental change and should be based on an adequate, up-to-date and relevant evidence base. Indeed, paragraph 73 of the NPPF requires that:

“Planning policies should be based on robust and up-to-date assessments of the needs for open space, sports and recreation facilities and opportunities for new provision. The assessment should identify specific needs and quantitative deficits or surpluses of open space, sports and recreational facilities in the local area.”

Aylesbury Vale does have a Playing Pitch Strategy that was drafted in 2010 but it does not appear to have been reviewed therefore Sport England considers that the document is out of date. Furthermore, the Local Authority does not appear to have any other up to date indoor/outdoor sports strategy. These strategies would need to be undertaken to identify current and future supply and demand as well as identifying what provision would be required and where in the future. The conclusions, recommendations and Action Plan in these documents would provide the robust evidence base that should then inform the Local Plan, and in particular its Polices, on what is required and where. Furthermore, earlier in the document, at paragraph 1.21 and 122, there is no mention of any playing pitch or built facility documents having been used to inform the Draft Local Plan which further evidences that the Policies have not been based on thorough, robust and up to date assessments and strategies.

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ID Respondent Name Comment VALP16-09-08-01204 Mark Furnish (Sport Policy I2, and the proceeding paragraphs are lacking in detail of the exact playing pitches and sport/leisure facilities are required and England) where thus indicating that the Policies are not based on a robust and up to date strategy. It states that facilities will be protected, that proposals to expand and enhance existing provision would be supported and new developments should include sufficient sport provision but without an evidence base to inform this policy it is unknown whether these courses of action are required to meet the current and future demand and also where each course of action are required. In consequence, Sport England considers that the Policies are not compliant with the NPPF, paragraph 73.

In addition Policy I2 states that when considering applications which involve the loss of playing field the Local Authority would consider its recreational and amenity value, existing provision compared to need and if equivalent or better quantity and quality replacement provision is provided. Sport England, in line with principles of the NPPF, would object to any loss of playing field where there is no identified surplus and the proposals sporting benefits do not outweigh its sporting detriment, unless a provision at least of equivalent quantity, quality and accessibility is provided. These form part of Sport England’s Exceptions that are considered when advising on planning applications that require statutory consultation which also reflects the content of paragraph 73.

Therefore, for these reasons, Sport England objects to the Draft Local Plan. To overcome this concern, the Local Authority are again advised to undertake an up to date Playing Pitch Strategy and a Built Facility Strategy to inform its Local Plan Policies. It is also strongly advised that Policies I1 and I2 is re-worded to overcome the issues raised and are specific to identify what is required and where to meet demand (existing and future), this of course, would be informed by the Playing Pitch Strategy and Built Facilities Strategy.

Sport England would be happy to provide further advice on how local authorities can strategically plan for sports facilities. There are a number of tools and guidance documents available, which can be found on Sport England’s website.

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ID Respondent Name Comment VALP16-09-08-01209 Tim Coleby (Peter Brett Policy I1 - Green Infrastructure (GI) Associates LLP on 3.4.38 The wider eastern context of Aylesbury includes a number of strategic assets particularly relevant within the context of the behalf of Aylesbury Woodlands site, including the Grand Union Canal and its towpath. There is an under-provision of accessible green space Buckinghamshire within this area for existing residents of Aylesbury and this will be further exacerbated by urban growth unless new accessible GI is Advantage) provided. 3.4.39 The Aylesbury Woodlands site occupies a key strategic location and would provide: A strategic ‘GI Opportunity Zone’ conjoined with open space within the Barratt Homes development across the Aylesbury Arm of the GUC (Access Link L3); An element of the Strategic Access Link connecting Aylesbury to Wendover (Access Link L4); and A key component within the Aylesbury Linear Park. 3.4.40 The Aylesbury Woodlands proposals have identified, retained and enhanced strategic green infrastructure assets in line with the Buckinghamshire Green Infrastructure Delivery Plan (August 2013), Buckinghamshire Green Infrastructure Strategy (2009) and the Aylesbury Vale Green Infrastructure Strategy (2011). Water Courses, Flood Plain and SuDS 3.4.41 The Bear Brook and Burcott Brook will be retained and buffered from development. Limited reaches of these watercourses will have public access as part of a new linear park. Development has been restricted to be outside the flood zones with areas within the flood zone allocated as formal and informal open green space. Surface water will be attenuated on site in open channels and form linear features in a geometric grid through the development, adding to its character and enhancing its distinctive ‘sense of place’. Grand Union Canal 3.4.42 The GUC is a strategic link between Aylesbury and Tring Reservoirs Complex and a key component of AVDC’s Grand Union Triangle project. The Aylesbury Woodlands scheme would create access points to the GUC and towpath which is also an objective of the Canals and Rivers Trust (CRT). Any active frontage created alongside the GUC would be limited and include a deep green apron of public open space, buffering the canal from built development and respecting its value as an ecological corridor.

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ID Respondent Name Comment VALP16-09-08-01209 Tim Coleby (Peter Brett Woodland, Hedgerows and Trees Associates LLP on 3.4.43 The single existing plantation woodland would be retained and better managed. New linear woodland planting is proposed behalf of around the eastern and southern edges. An orchard is proposed close to residential areas and allotments and would form a useful Buckinghamshire element as part of Advantage) a ‘Healthy Towns’ initiative. In general, trees will be retained, protected and managed where possible. To compensate for any unavoidable losses, significant new tree planting is proposed within built areas and open spaces – the latter including significant planting of Black Poplar specimens which are a characteristic, but declining, feature of the local landscape. Although there would be a major loss of non-important hedgerow, a significant amount of new linear planting is proposed to offset for the loss. Ecology 3.4.44 Existing features will be protected and enhanced, such as the ecologically sensitive corridors of the GUC and Bear Brook. These and other important bat movement and foraging corridors have been retained and enhanced. Loss of habitat for important species which may be displaced would be compensated for. Open Space and Recreation 3.4.45 Open space within Aylesbury Woodlands will provide a significant contribution towards Aylesbury’s needs for amenity open space comprising: Open parkland either side of the ELR(S) and linked beneath it via the proposed Burcott Brook bridge; Amenity space forming a key link within the County’s proposed Aylesbury Linear Park; A ‘Blue Grid’ network of incidental amenity space throughout the heart of the built development, incorporating linear SuDS attenuation and conveyance features and forming a grid pattern which includes canalside development; A primary flood conveyance corridor and woodland which forms the main ‘setting’ for the Woodlands development when viewed from the ELR(S); and A Wildlife Area along the Bear Brook, some of which would be accessible by the public in a controlled manner so as not to overly disturb wildlife.

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ID Respondent Name Comment VALP16-09-08-01209 Tim Coleby (Peter Brett Policy I3 - Community Infrastructure Associates LLP on 3.4.33 Aylesbury Woodlands will deliver significant community facilities and other infrastructure which will support the proposed behalf of housing, retail and employment development whilst enabling sustainable living and working. The development offers an opportunity to Buckinghamshire deliver much needed local facilities for the eastern edge of Aylesbury including sports pitches, employment opportunities, a new Advantage) school, residential extra care and local centre uses such as a GP surgery, crèche and local retail. Cycle Routes and Footpaths 3.4.34 One of the key principles of the Aylesbury Woodlands strategy is to maximise pedestrian and cycle accessibility within the development. A range of measures will be implemented across the development to encourage walking and cycling, both within the site and to nearby destinations off-site. Measures that will be implemented on-site to encourage walking and cycling include: A comprehensive on-site footpath and cycle network including provision of secure, covered cycle parking facilities on-site for the key facilities; A combined footway/cycleway on the western side of the Eastern Link Road (South) and a continuous footway along the length of the eastern side of it with a safe connection to the south via a controlled crossing across the A41; and The provision of strategic routes including links to the existing towpath along the Grand Union Canal. Education 3.4.35 Aylesbury Woodlands will deliver space for a two form entry primary school on a 2.0ha site. The following design requirements from AVDC ‘School Site Specifications’ have been considered within the illustrative masterplan and key points include that the school would: Be located in the heart of the community, encouraging walking or other environmentally friendly means of pupils going to and from school; and Be proximal to other local community facilities (which pupils can visit as part of their learning and development) and close to associated parking areas (separate from staff car parking). Healthcare 3.4.36 The local centre lies at the heart of the development connected to the surrounding residential areas by the primary road and a network of cycle-ways and footpaths. The 1.6ha local centre has space to accommodate: a mix of shops; convenience store; a community hall/crèche; and GP surgery/local health centre. Open Space 3.4.37 The Aylesbury Woodlands proposals offer a significant contribution towards Aylesbury’s needs for open space and would provide easy access to different types and sizes of semi-natural green spaces close to existing Aylesbury residents as well as new Woodlands residents. The proposals include approximately 116 ha of open space, or approximately 58% of the site and comprise 97 ha of amenity space and 18 ha of playing space.

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ID Respondent Name Comment VALP16-09-08-01209 Tim Coleby (Peter Brett Play and Sport Associates LLP on 3.4.46 The Aylesbury Woodlands site will enable the development of a range of sporting and recreational facilities serving the needs of behalf of the whole of Aylesbury Vale. A key feature of the Woodlands application is the ‘Sports Village’ – centred on an outdoor velodrome and Buckinghamshire community sports arena. This facility will enhance Aylesbury’s potential to host international multi-sport events and form an important Advantage) element in the wider eastern expansion of the town. Providing 15 ha of sports fields to the west of the ELR(S). The main elements of the Sports Village are envisaged to be as follows: 12no. 5-aside all-weather courts 2no. full sized grass rugby / football pitches Outdoor velodrome 400m BMX track 150m junior pump track Wheeled Sports and ramp demonstration area 2km closed road circuit 16 J:32113 - Aylesbury EastPlanningVale of Aylesbury Local Plan consultation final.docx 3.4.47 In addition to the dedicated sports areas, the Sports Village will also provide: Hotel and conference facilities Athletes accommodation Parking for 200 cars and 8 coaches 3.4.48 In addition, within the main development area, east of the ELR(S) the development will provide a cricket pitch, Bowling Green and four tennis courts; a Neighbourhood Equipped Area of Play (NEAP) and two Local Equipped Areas of Play (LEAPs).

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ID Respondent Name Comment VALP16-09-08-01209 Tim Coleby (Peter Brett Policy I4 - Flood Risk Assessment Associates LLP on 3.4.2 The Eastern Link Road (south) (ELR(S)) is classified as Essential Infrastructure. The Flood Risk Sequential Assessment, which behalf of is appended to the Flood Risk Assessment submitted with the Aylesbury Woodlands planning application in March 2016, Buckinghamshire demonstrates that the ELR (S) satisfies the Sequential Test. As the road crosses the two watercourses and the floodplain, a flood Advantage) mitigation scheme is required to ensure the ELR(S) meets the requirements of the Exception Test and national planning policy and does not increase flood risk to third parties. 3.4.3 The Flood Zones following the implementation of the ELR(S) flood mitigation scheme have been used to advise the master- planning of the Aylesbury Woodlands site and the sequential approach advocated by NPPF has been followed. All More Vulnerable and Less Vulnerable land uses are proposed within Flood Zone 1 ‘Low Probability’ (less than 1 in 1000 (0.1%) annual probability of fluvial flooding), with only Water Compatible Development and Essential Infrastructure located within areas with a higher probability of flooding. 3.4.4 Thus the Sequential Test and Exception Test have been met for the development. 3.4.5 Hydraulic modelling has been carried out to quantify the impact of the ELR(S) and its Flood Mitigation Scheme on flooding within the site and surrounding area. Flood risk will be appropriately mitigated through measures including: Development will be located within the Flood Zones in which they are most appropriate. The ELR(S) Flood Mitigation Scheme (FMS) ensures that there is no increase in flood risk offsite as a result of the construction of the ELR(S) and model results indicate a small (<20mm) reduction in extreme flood levels on the Bear Brook downstream of the site. Proposed ground floor levels set a minimum of 300mm above the modelled 1 in 100 (1%) annual probability plus climate change level, in accordance with EA and AVDC requirements. Continuous safe access arrangements provided at the modelled 1 in 100 (1%) annual probability plus climate change flood level. Surface water drainage strategies for the ELR(S) and the development, based around on-site attenuation measures and controlled discharge rates, designed to the 1 in 100 (1%) annual probability plus 30% allowance for climate change storm event. The sports facilities to the west of the development are located within Flood Zones 3a and 3b, in accordance with the sequential approach and planning policy. At this outline stage, recommendations are made to ensure the sports facilities will be safe and do not increase flood risk for third parties.

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ID Respondent Name Comment VALP16-09-08-01209 Tim Coleby (Peter Brett 3.4.7 In summary, the FRA accompanying the planning application confirms that the development is safe, it does not increase flood Associates LLP on risk and does not detrimentally affect third parties, in accordance with the objectives of the NPPF. The measures above are also behalf of compliant with Policies S5 ‘Infrastructure’, S1 ‘Sustainable Development’ and I4 ‘Flooding’ of the VALP. As set out within the Water Buckinghamshire Resources and Flood Risk Chapter of the Environmental Statement submitted with the planning application, the proposals also comply Advantage) with Policy S5 with regard to water supply and treatment, sewerage, flood prevention and drainage. Modelling and climate change allowances 3.4.8 As part of the Aylesbury Woodlands application, the EA strategic level model was reviewed and refined appropriate for a detailed site specific assessment. The model was submitted to the EA for review and we are currently liaising with the EA. Climate change was assessed as part of the application assuming a 20% increase in flow, as appropriate based on now superseded guidance. In February 2016 the EA issued updated guidance, which requires 70% increase in flow for Essential Infrastructure and 35% and 70% for More Vulnerable development to be considered. Post submission, the 70% allowance has been assessed and the results have been shared with the EA. This demonstrates that the ELR(S) Flood Alleviation Scheme recommended within the FRA ensures no detriment to third parties and that the proposed road is safe even when a 70% increase in peak flow is assumed. The scheme, and thus the ELR(S) and the Aylesbury Woodlands development, are deliverable with respect to flood risk. 3.4.9 In terms of surface water management, a 30% allowance for increased rainfall intensity as a result of climate change has also been included within the proposed outline surface water drainage strategy. The updated guidance recommends that peak rainfall should be increased by 20% and 40% to understand the impacts. The Aylesbury Woodlands FRA recommends that the ‘central estimate’ of 20% should be used for design purposes to assess the performance of the drainage system and ensure it can cope with the critical duration design rainfall event and the ‘upper end’ of 40% should be used in sensitivity analysis to assess the potential flood risk implications both on and off-site in terms of flow routes, flood hazard and freeboards. Flood Risk Summary 3.4.10 The planning application proposals for Aylesbury Woodlands comply with the flooding and drainage requirements set out in policies S1, S5 and I4 of the VALP. A sequential approach has been applied and a Flood Risk Assessment prepared, compliant with Policy I4 parts a-c. The Flood Risk Assessment addresses all parts of policy I4 d-r. Where detail is not fixed at this outline stage in the development, the Aylesbury Woodlands FRA and drainage strategies recommend that this is addressed at Reserved Matters stage or by discharging conditions on any outline permission. 3.4.11 It is therefore concluded that in flood risk terms there are no barriers to delivery of the Aylesbury Woodlands proposals.

VALP16-09-08-01225 Frazer Hickling (Phillips Policy I1 - This chapter sets out policies in enhancement and provision of ‘green infrastructure’, sports and recreation facilities, Planning Services community facilities, flooding and telecommunications. Limited) 2.42. As set out above, it is considered that renewable energy generating development policy would be better suited to be located in this chapter. 2.43. We do however have no specific comments to make in relation to this chapter.

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ID Respondent Name Comment VALP16-09-08-01233 Mark Hyde MRTPI Policy I4 - Flooding: The Flood Risk Assessment prepared for the SWMK Consortium’s application demonstrates that the majority of AIEMA (South West the site lies within Flood Zone 1 and therefore is at low risk of flooding. All buildings will be located within Flood Zone 1. The proposed Milton Keynes development will include sustainable drainage systems to attenuate surface water run-off to green field rates. Consortium) VALP16-09-08-01262 Geoff Gardner Policy I1 - Green Belt (Gardener Planning Ltd It is noted and supportd tht: as well as these removals of land from the Green Belt, there is an area of land to the west of Leighton on behalf of Arnold Linslade that is proposed for inclusion. This will help to balance the loss of the Green Belt land in other areas (including land removed White Estates Ltd) from the Green Belt around Leighton Buzzard) and will provide a more recognisable boundary than what currently is used.

Infrastructure It is noted that HS2 ‘contributes little if anything to the overall infrastructure need of the district’ . This may or may not be true. However, the impact of HS2 on development proposals is not mentioned, a major omission which means that the Plan is unsound in not being based on proportionate evidence. This is particularly important to the site proposals to the South of Aylesbury, and the opportunities for development at Waddesdon. This Report supports the following (emphasis added): •Infrastructure should be delivered in a timely manner and integrated alongside new development, with the specific phasing to be determined in agreement with the local planning authority. •All new development must provide appropriate on- and off‐site infrastructure (in accordance with the Infrastructure Delivery Plan) in order to: a. Avoid placing additional burden on the existing community b. Avoid or mitigate adverse social, economic and environmental impacts and c. Make good the loss or damage of social, economic and environmental assets In planning for new development, appropriate regard will be given to existing deficiencies in services and infrastructure provision. Development proposals must demonstrate that these have been taken into account when determining the infrastructure requirements for the new development. The provision of infrastructure should be linked directly to the phasing of development to ensure that infrastructure is provided in a comprehensive way in line with new development. Comment: The infrastructure proposals of East-West Rail, and the Oxford to Cambridge Expressway are noted, to which should be added the current study on the Cambridge - Milton Keynes - Oxford Corridor, but these need to be assessed for their impact on opportunities for development in the District along the proposed routes.

VALP16-09-08-01283 Simon Proctor (Proctor Policy I4 - I4 -This policy should be amended to quantify developments over a certain size or quantum. If clarification is not given Surveyors (Stoke there is the risk of overcomplicating minor applications and generating unnecessary costs and bureaucracy. Hammond 2))

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ID Respondent Name Comment VALP16-09-08-01291 Martin Small (Historic Policy I5 - Policy I5 – we welcome criterion d. as part of the positive strategy for the conservation and enjoyment of, and the clear England) strategy for enhancing, the historic environment required by the NPPF.

Glossary – conservation areas are designated for their special architectural or historic interest. Heritage assets are either designated or non-designated. Designated assets are listed buildings, scheduled monuments, registered historic parks and gardens, registered battlefields and conservation areas.

Appendix A – we have unfortunately not been able to visit or undertake a full desk-based assessment all the potential housing sites. However, we note from the Reasonable Alternatives Sustainability Appraisal Report that many of the potential housing sites would be likely to adversely affect heritage assets, both designated and non-designated, most notably listed buildings, scheduled monuments, conservation areas and Archaeological Notification Sites. Many of the sites would also be likely to cause the loss of historic ridge and furrow earthworks. Although many of the sites are considered to have a moderate adverse effect on cultural heritage and none a major adverse effect, from the information in the Sustainability Appraisal two sites in particular appeared to be likely to cause significant harm to important heritage assets: BUC051 and DAD001. We are somewhat dismayed to find that BUC051 is a commitment but are pleased that DAD001 is not being proposed as a potential housing site in the Plan. Historic England will expect the final selection of sites to be allocated for housing (or any development) to be based on, inter alia, full and proper consideration of the potential impacts of development on the historic environment; in particular on heritage assets and their setting, and the need to conserve and enhance those assets. (This will require the use of a comprehensive historic environment evidence base as explained earlier in this letter, including specific studies to understand the significance of assets that may be affected). If sites are proposed to be allocated in the next version of the Plan that may adversely affect heritage assets without mitigation, we will expect to see that mitigation reflecting in the allocation itself and in the policy allocating it. Our lack of specific objection to any of the potential sites at this stage should not be taken as support for the sites, and is without prejudice to any comments we may wish to make on the sites that are taken forward in the next version of the Plan or on any application that may be forthcoming on any of the sites. We have prepared specific advice on The Historic Environment and Site Allocations in Local Plans, http://www.historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/. Advice on the setting of heritage assets is given in Historic England’s Good Practice Advice in Planning Note 3: The Setting of Heritage Assets (http://www.historicengland.org.uk/images-books/publications/gpa3-setting-of-heritage-assets/).

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ID Respondent Name Comment VALP16-09-08-01291 Martin Small (Historic In conclusion, we return to the requirements of local plans as regards the historic environment in the NPPF as set out at the beginning England) of this letter. We consider that there are a number of examples of a positive strategy for the conservation and enjoyment of, and a clear strategy for the enhancing, the historic environment in the Draft Plan that we have welcomed, but also a number of instances we have identified where those strategies could be reinforced.

We have noted that, in our opinion, Policy BE1 is not a strategic policy to deliver the conservation and enhancement of the historic environment, although we welcome it, in principle and subject to revision, as a development management policy. It is for the Council to decide whether it is appropriate for the local plan to identify land where development would be inappropriate for its historic significance, and we have expressed our view that the Council should have an adequate, up-to-date and relevant historic environment evidence base and demonstrate in the Local Plan how that historic evidence base has informed and influenced the Plan’s policies and site allocations.

We hope these comments are helpful. Please contact me if you have any queries. VALP16-09-09-01397 Delia Shephard Policy I4 - Finally this council is concerned about potential development of sites in areas prone to flooding. The council has noted the (Bletchley and Fenny aspirations expressed in S 11.19 - 11.30 and does not object to 14 Flooding but is concerned that the requirement for long term Stratford Town Council) maintenance of site specific flood defences should be considered within the plan as this is critical to minimise the flood risk.

VALP16-09-09-01399 Cllr Phil Yerby Policy I1 - Comments regarding the delivery of Green Infrastructure in Aylesbury are at paragraphs 56-58 of this submission. 118.126. In addition green corridors need to be defined to ensure they are meaningful green spaces and do not become merely connecting pathways with no feeling of open space. 119.127. The policy recognizes the need for a “range of types” of Green Infrastructure for new GI but it should also seek to protect existing natural habitat. Countryside and open unmaintained land should not simply be exchanged for Green Infrastructure. Also “in appropriate proportions” needs to be defined. Informal open space should be the priority along with children’s play areas. Large, soon to be unused, sports pitches should be avoided. 120.128. We agree that the developer must ensure as part of the proposals how the GI network will be maintained in perpetuity.

VALP16-09-09-01399 Cllr Phil Yerby Policy I2 - We support the policy. At bullet point a. when considering its “recreational and amenity value” the policy should make it clear that “equivalent or better quantity” means the total useable quantity of area and not (only) the number of sports catered for.

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ID Respondent Name Comment VALP16-09-09-01399 Cllr Phil Yerby Policy I4 - Flooding The section should be read in conjunction with the Technical Note issued by THDA Shortcomings of the HELAA and VALP in assessing flood risk 130. The following are specific comments on the approach taken in assessing flood risk in the overall plan. They should not be confused as a comment on the policy itself, which is made below. 131. The final VALP will form the definitive strategic plan for AVDC and as such the sites, which it identifies for development normally, would be exempt from Sequential Test. The reason for this is that national planning policy expects the Sequential Test to have been undertaken in the preparation of VALP. 132. The only mention of Sequential Test found in the consultation draft VALP is in Policy I4 Flooding where it says that "other than sites allocated in VALP, all development proposals must clearly demonstrate the sequential test, as set out in the latest version of the SFRA, has been applied", and goes on to say that following the application of the Sequential Test, an Exception Test might be required. 133. Sequential Test is not mentioned in the HELAA. 134. The Sustainability Test is mentioned at para 3.3.10 of the Sustainability Appraisal in connection with proposed work for AYL051, 0554 ad 073. This is the only mention of the test. 135. It is not at all apparent, therefore, that the sites included in the HELAA draft report have been sieved to remove ones that have flood risk in accordance with the Sequential Test policy/principle. 136. As such, there are sites upon which consultation has been asked which could not be developed. WTV018 appears to be one such site. Arguably the public consultation is premature pending execution of sequential testing. 137. Paragraphs 138 - 142 include flood risk relevant quotes from SFRA Level 2 VALP16-09-09-01399 Cllr Phil Yerby 143. From the foregoing it would appear that the Consultation Draft Local Plan does not take sufficient account of AVDC's own SFRA Level 2. 144. Accordingly, the allocations of some sites in the VALP, in particular Woodlands, are completely inappropriate as it is most likely they would fail both the sequential and the exception test. As THDA comment that “It is implausible that no suitable land in Flood zone 1 is available for development elsewhere in Aylesbury Vale” 145. It is extremely confusing as to what is actually proposed for the Woodlands site as a result of the significant issues in relation to flooding. The relevant HELAA extract is shown below. It is unclear whether “further development potential may be released” means in relation to any or more employment land, or housing, or sports facilities. The quantities of housing appear to be have been taken out of the plan but the site is clearly marked as a “proposed new garden community” on the proposals maps. 146. The claim that the site “has the potential to deliver a much needed strategic link road which would increase connectivity” is unproven. There is very limited evidence that the “orbital strategy’ of which this road forms part will make any significant improvement to the road network or that without it, considerable adverse impact will happen to the road network by considering alternative sites for development. Accordingly, the claim that the road through Woodlands (the Eastern Link Road South) is “much needed” has not been substantiated and is contested. On this point THDA comment: No evidence is given in the FRA that the ELR (S) is indeed essential infrastructure, and thus it is not proven that the derogation applies. Even it is agreed that the ELR (S) is essential infrastructure, NPPF only gives dispensation for essential infrastructure to “cross” Flood Zone 3B. It is debatable if the word “cross” includes following a flood route as is proposed. It can be argued that such interpretation is wrong; particularly where an alternative route might be available that avoids such conflict and risk.

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ID Respondent Name Comment VALP16-09-09-01399 Cllr Phil Yerby b) No options for routes which have a lower impact on Flood Zone 3B and indeed upon Flood Zones 2 and 3 have been explored within the FRA. There is a presumption that the route must be either within the site or on land, which is being offered for sale. If the ELR (S) were essential, it would qualify for CPO, in which case the ownership limitation no longer constricts route options

As a result of our general comments on flooding above, We strongly resistwe oppose bullet points a. and b. It is not acceptable for the Council to simply state that this policy does not apply to sites already allocated in the VALP. Of course this would be a reasonable policy had the correct Sequential and Exception testing been carried out. 123.148. Policy I4 is over long and there it is not clear to the lay reader which parts are drawn from national planning policy, planning guidance and codes of practice, and which parts relate to AVDC special requirements. It would be best if Policy I4 starts with a clear statement of which national policy, guidance and codes of practice apply, listing them in order of hierarchy, for instance:

VALP16-09-09-01399 Cllr Phil Yerby • NPPF • National Planning Practice Guidance • Non statutory technical standards for sustainable drainage • SuDS Manual 2015 • Environment Agency standards for control of development run off. • Doing this would avoid duplication of policies and practices derived from different sources. A clause dealing with using updates of these documents would render the policy future proof. 124.149. The SFRA flood maps should be updated so that they reflect the current climate change prediction for the usual development lifetimes; 125.150. Pending such update, major developments should demonstrate that they would not be affected by climate change flooding. 126.151. Any development proposal the site of which is shown as flooded by any source by SFRA maps should include a flood risk assessment with the planning application. 127.152. Flood compensation must be supplied on a level for level volume for volume basis where filling of the flood plain is proposed within climate changed Flood Zone 3. Flood compensation excavation should be contiguous with the flood plain and unless special circumstances are agreed should not be created in a building basement or amongst its foundations. 128.153. Change of use development to one having a higher flood vulnerability should be required to pass the Sequential Test. 129.154. Exception Tests must include measures for flood resistance and or resilience, which together with a Flood Management and Evacuation Plan should be submitted for approval. 130.155. Proposals to alter flood plains by engineering operations must demonstrate significant wider benefits to the community and/or nature conservation.

VALP16-09-09-01402 Stephen Beal Policy I1 - Agree - Enough now - intrusive parking - How will this be policed - Fly tipping, illegal squatting.

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ID Respondent Name Comment VALP16-09-09-01413 Michelle Thompson Policy I1 - Agree so long as fly tipping and illegal camping is policed and special conditions imposed of immediate eviction rather than 7 days? Parking very important. It feels like you are giving us this as a trade for massive development, however this land already being useful in agriculture, environmentally and especially wildlife. What are you doing to replace this land you are taking for basically recreation?

VALP16-09-09-01416 Kathryn Hedges Policy I1 - How do you police this policy? Add all the swages of land between rural communities nto this policy using a wider view on amenities - just protect to stop coalescence

VALP16-09-09-01417 David Wilson Policy I4 - The Sustainability Appraisal shows serious issues of flooding on the Woodlands site. This brings the whole strategy to develop Woodlands into question and especially the alignment of the road through the site. VALP16-09-09-01427 Phil Yerby (Hampden Policy I1 - Comments regarding the delivery of Green Infrastructure in Aylesbury are at paragraphs 56-58 of this submission. Fields Action Group) In addition green corridors need to be defined to ensure they are meaningful green spaces and do not become merely connecting pathways with no feeling of open space. The policy recognizes the need for a “range of types” of Green Infrastructure for new GI but it should also seek to protect existing natural habitat. Countryside and open unmaintained land should not simply be exchanged for Green Infrastructure. Also “in appropriate proportions” needs to be defined. Informal open space should be the priority along with children’s play areas. Large, soon to be unused, sports pitches should be avoided. We agree that the developer must ensure as part of the proposals how the GI network will be maintained in perpetuity. VALP16-09-09-01427 Phil Yerby (Hampden Policy I2 - We support the policy. At bullet point a. when considering its “recreational and amenity value” the policy should make it Fields Action Group) clear that “equivalent or better quantity” means the total useable quantity of area and not (only) the number of sports catered for.

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ID Respondent Name Comment VALP16-09-09-01427 Phil Yerby (Hampden Policy I4 - Flooding - The section should be read in conjunction with the Technical Note issued by THDA Shortcomings of the HELAA Fields Action Group) and VALP in assessing flood risk. The following are specific comments on the approach taken in assessing flood risk in the overall plan. They should not be confused as a comment on the policy itself, which is made below. The final VALP will form the definitive strategic plan for AVDC and as such the sites, which it identifies for development normally, would be exempt from Sequential Test. The reason for this is that national planning policy expects the Sequential Test to have been undertaken in the preparation of VALP. The only mention of Sequential Test found in the consultation draft VALP is in Policy I4 Flooding where it says that "other than sites allocated in VALP, all development proposals must clearly demonstrate the sequential test, as set out in the latest version of the SFRA, has been applied", and goes on to say that following the application of the Sequential Test, an Exception Test might be required. Sequential Test is not mentioned in the HELAA. The Sustainability Test is mentioned at para 3.3.10 of the Sustainability Appraisal in connection with proposed work for AYL051, 0554 ad 073. This is the only mention of the test. It is not at all apparent, therefore, that the sites included in the HELAA draft report have been sieved to remove ones that have flood risk in accordance with the Sequential Test policy/principle. As such, there are sites upon which consultation has been asked which could not be developed. WTV018 appears to be one such site. Arguably the public consultation is premature pending execution of sequential testing. Paragraphs 138 - 142 include flood risk relevant quotes from SFRA Level 2 From the foregoing it would appear that the Consultation Draft Local Plan does not take sufficient account of AVDC's own SFRA Level 2. Accordingly, the allocations of some sites in the VALP, in particular Woodlands, are completely inappropriate as it is most likely they would fail both the sequential and the exception test. As THDA comment that “It is implausible that no suitable land in Flood zone 1 is available for development elsewhere in Aylesbury Vale”. It is extremely confusing as to what is actually proposed for the Woodlands site as a result of the significant issues in relation to flooding. The relevant HELAA extract is means in relation to any or more employment land, or housing, or sports facilities. The quantities of housing appear to be have been taken out of the plan but the site is clearly marked as a “proposed new garden community” on the proposals maps. The claim that the site “has the potential to deliver a much needed strategic link road which would increase connectivity” is unproven. There is very limited evidence that the “orbital strategy’ of which this road forms part will make any significant improvement to the road network or that without it, considerable adverse impact will happen to the road network by considering alternative sites for development. Accordingly, the claim that the road through Woodlands (the Eastern Link Road South) is “much needed” has not been substantiated and is contested. On this point THDA comment: No evidence is given in the FRA that the ELR (S) is indeed essential infrastructure, and thus it is not proven that the derogation applies. Even it is agreed that the ELR (S) is essential infrastructure, NPPF only gives dispensation for essential infrastructure to

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ID Respondent Name Comment VALP16-09-09-01427 Phil Yerby (Hampden “cross” Flood Zone 3B. It is debatable if the word “cross” includes following a flood route as is proposed. It can be argued that such Fields Action Group) interpretation is wrong; particularly where an alternative route might be available that avoids such conflict and risk. b) No options for routes which have a lower impact on Flood Zone 3B and indeed upon Flood Zones 2 and 3 have been explored within the FRA. There is a presumption that the route must be either within the site or on land, which is being offered for sale. If the ELR (S) were essential, it would qualify for CPO, in which case the ownership limitation no longer constricts route options. Policy I4 Flooding- As a result of our general comments on flooding above, we oppose bullet points a. and b. It is not acceptable for the Council to simply state that this policy does not apply to sites already allocated in the VALP. Of course this would be a reasonable policy had the correct Sequential and Exception testing been carried out. Policy I4 is over long and there it is not clear to the lay reader which parts are drawn from national planning policy, planning guidance and codes of practice, and which parts relate to AVDC special requirements. It would be best if Policy I4 starts with a clear statement of which national policy, guidance and codes of practice apply, listing them in order of hierarchy, for instance: NPPF; National Planning Practice Guidance; Non statutory technical standards for sustainable drainage; SuDS Manual 2015; Environment Agency standards for control of development run off. Doing this would avoid duplication of policies and practices derived from different sources. A clause dealing with using updates of these documents would render the policy future proof. The SFRA flood maps should be updated so that they reflect the current climate change prediction for the usual development lifetimes. Pending such update, major developments should demonstrate that they would not be affected by climate change flooding. Any development proposal the site of which is shown as flooded by any source by SFRA maps should include a flood risk assessment with the planning application. Flood compensation must be supplied on a level for level volume for volume basis where filling of the flood plain is proposed within climate changed Flood Zone 3. Flood compensation excavation should be contiguous with the flood plain and unless special circumstances are agreed should not be created in a building basement or amongst its foundations. Change of use development to one having a higher flood vulnerability should be required to pass the Sequential Test. Exception Tests must include measures for flood resistance and or resilience, which together with a Flood Management and Evacuation Plan should be submitted for approval. Proposals to alter flood plains by engineering operations must demonstrate significant wider benefits to the community and/or nature conservation.

VALP16-09-09-01440 Nick Butler Policy I1 - Green infrastructure should be linked with footpaths, cycle routes and have lots of parking to encourage use.

VALP16-09-09-01451 Geoff Culverhouse Policy I1 - This policy is supported (North Bucks Parishes Planning Consortium) VALP16-09-09-01451 Geoff Culverhouse Policy I2 - 11.2 In line five insert ‘net’ between ‘the’ and ’loss’. This would help to ensure that at least equivalent alternative facilities (North Bucks Parishes need to be provided where development on existing sports and recreation areas is permitted. Planning Consortium) VALP16-09-09-01451 Geoff Culverhouse Policy I3 - Policy I3 Community facilities (North Bucks Parishes 11.3. We believe that this policy does not adequately cover situations where new development may result in the loss of community Planning Consortium) buildings and/or sports facilities. The policy should make it clear that such proposals will require replacement facilities of at least equal level or a financial contribution to the provision of such facilities.

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ID Respondent Name Comment VALP16-09-09-01451 Geoff Culverhouse Policy I4 - Policy I4 Flooding (North Bucks Parishes 11.4 This policy is supported. We would also refer you to the comments on this matter in the submission of Buckingham Town Council Planning Consortium) which is a member of NBPPC. VALP16-09-09-01451 Geoff Culverhouse Policy I5 - Policy I5 Telecommunications (North Bucks Parishes 11.5 This policy is supported Planning Consortium) VALP16-09-09-01468 Sarah Hamilton-Foyn Policy I1 - Reference has been made in Section 4 of these representations to our concerns about the designation and delivery of (Pegasus Group (Revera Green Infrastructure to the north of Bierton. Policy 11 Green Infrastructure (GI) addresses how the delivery of GI will be undertaken. It Limited on behalf of is proposed that GI will be delivered through development proposals and will be obligated either on site or off site through CIL regime M&G Property Limited or conditions to the planning permission as appropriate. Partnership)) The deliverability of GI outside the Council’s ownership or control must be questioned. VALP16-09-09-01477 Jane Eden (Aylesbury Policy I4 - The effects of climate change, increased potential flooding and the development and potential creation of new flood areas Town Council.) must be addressed.

Areas of Aylesbury have already suffered from unnecessary flooding, areas such as Walton Court and the Willows, as well as other residents living close to water courses should not have to face the increased threat from the building of more homes, there has to be adequate protection not just for new residents but for existing. VALP16-09-12-01514 Simon Proctor (Proctor Policy I4 - I4 - This policy should be amended to quantify developments over a certain size or quantum. If clarification is not given Surveyors (Gawcott)) there is the risk of overcomplicating minor applications and generating unnecessary costs and bureaucracy. VALP16-09-12-01515 Cameron Austin-Fell Policy I1 - The requirements of the policy to ensure complete compliance with the Council’s Leisure and Cultural Facilities (2012) (RPS Planning & should be amended and refer to this document merely as an evidence base (as per the approach in policy I2). The 2012 study does Development (on behalf not look into the impacts of this policy on development sites (SHLAA) across the district and whether they can be achieved. This may of Richborough Estates well rule out otherwise suitable sites. There is also no planning balance to this policy as per NE1. Site - Churchway, Haddenham)) VALP16-09-12-01515 Cameron Austin-Fell Policy I2 - The correct approach is to include standards in SPD as evidence base. However, at the present time, there is no up-to-date (RPS Planning & standard to be able to assess. It is advised that further and specific consultation is undertaken on this prior to moving to the Development (on behalf submission consultation as the policy suggests. of Richborough Estates Site - Churchway, Haddenham)) VALP16-09-12-01515 Cameron Austin-Fell Policy I3 - The policy lacks precision as it simply indicates the Council will consider the need for community facilities. It needs to (RPS Planning & indicate (for consultation) what sorts of sites may require community facilities and how the Council will establish what those facilities Development (on behalf will be. of Richborough Estates Site - Churchway, Haddenham))

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ID Respondent Name Comment VALP16-09-12-01515 Cameron Austin-Fell Policy I4 - The policy needs to have a planning balance element included, as per policy NE1. (RPS Planning & Development (on behalf of Richborough Estates Site - Churchway, Haddenham)) VALP16-09-12-01523 Cameron Austin-Fell Policy I1 - The requirements of the policy to ensure complete compliance with the Council’s Leisure and Cultural Facilities (2012) (RPS Planning & should be amended and refer to this document merely as an evidence base (as per the approach in policy I2). The 2012 study does Development (on behalf not look into the impacts of this policy on development sites (SHLAA) across the district and whether they can be achieved. This may of Richborough Estates well rule out otherwise suitable sites. There is also no planning balance to this policy as per NE1. Site - Lower Road, Aylesbury)) VALP16-09-12-01523 Cameron Austin-Fell Policy I2 - The correct approach is to include standards in SPD as evidence base. However, at the present (RPS Planning & time, there is no up-to-date standard to be able to assess. It is advised that further and specific Development (on behalf consultation is undertaken on this prior to moving to the submission consultation as the policy of Richborough Estates suggests. Site - Lower Road, Aylesbury)) VALP16-09-12-01523 Cameron Austin-Fell Policy I3 - The policy lacks precision as it simply indicates the Council will consider the need for community facilities. It needs to (RPS Planning & indicate (for consultation) what sorts of sites may require community facilities and how the Council will establish what those facilities Development (on behalf will be. of Richborough Estates Site - Lower Road, Aylesbury)) VALP16-09-12-01523 Cameron Austin-Fell Policy I4 - The policy needs to have a planning balance element included, as per policy NE1. (RPS Planning & Development (on behalf of Richborough Estates Site - Lower Road, Aylesbury))

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ID Respondent Name Comment VALP16-09-12-01538 Jon Gateley (Savills (on Policy I1 - Paragraph 11.4 behalf of Crest Strategic Paragraph 11.4 refers to The Aylesbury Vale Green Infrastructure Strategy (2011), the 2009 Buckinghamshire Green Infrastructure Projects)) Strategy and the Buckinghamshire Green Infrastructure Delivery Plan (2013). The later document sets out two specific proposals in Aylesbury Vale including Whaddon Chase. The Draft VALP states that, ‘there are also MDAs [Major Development Areas] proposed at the edge of Milton Keynes which should, where possible, deliver Green Infrastructure in line with the Whaddon Chase proposal.’ The Buckinghamshire GI Delivery Plan (pages 87-97) provides analysis of the Whaddon Chase Project and the GI Proposals plan. While the principle of GI enhancements within the Whaddon Chase is supported in principle, there are a number of significant discrepancies with the Whaddon Chase GI Proposals plan and the current situation. For example, areas of proposed woodland, grassland and heathland are now developed within Milton Keynes. Current areas for planned growth including WHA001 are only shown for woodland planting and grassland/heathland and community orchards. The delivery of the Whaddon Chase GI proposals will depend in part on the support of landowners and developers, yet it is unclear how this will be achieved with limited development shown on Whaddon Chase GI Proposals plan. The GI study was produced in 2013 since which there has been a number of changes in housing supply requirements. This change should be reflected by either an updated Whaddon Chase GI Proposals plan that accords with the Draft VALP, or the reference being dropped from the VALP, or for the reference in Paragraph 11.5 for a future joint review of the Bucks GI strategy to be sufficient as the directional lead. Modifications to Paragraph 11.4 sought by CSP Three alternative means of updating the wording are identified in the preceding paragraph.

Policy I1 – Green Infrastructure This Policy is broadly supported. However, the reference to implementing the ‘most up to date Green Infrastructure Strategy’ should be deleted or reworded. As set out above in relation to paragraph 11.4 the most current up to date strategy in terms of published date is the Buckinghamshire Green Infrastructure Delivery Plan (2013) . However, this document is significantly outdated and in conflict with the emerging VALP.

Modifications to Paragraph I1 sought by CSP The sentence: ‘Green infrastructure accessibility and quantitative standards as set out in the Assessment of Leisure and Cultural Facilities (2012)’ should be deleted, or amended. It should (presumably) read: ‘are set out’; and the bullet points following should be referenced correctly, but preferably be located in a supporting document instead of being listed in the Policy. This is because they may not be achievable for individual developments due to scale, land control etc.

VALP16-09-12-01566 Chris & Shirley Bull Policy I4 - Flood Risk Alleviation All of the proposed new development areas around Aylesbury are subject to flooding. So sustainable water management strategies are required. In our view, flood management and mitigation measures would need to be provided in advance of each development, and each proved to be successful before the next tranche of construction starts. This would require careful phasing. Moreover, new flood water retention areas will need to be monitored and managed in perpetuity in accordance with Natural England and Environment Agency guidelines. The developers of each of the proposed new garden communities must work together to produce integrated flood management strategies, because the concurrent emptying of flood storage sites could cause flooding downstream.

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ID Respondent Name Comment VALP16-09-12-01606 Stuart Twigg Policy I1 - Wildlife – The southern arc is rich in a diverse range of flora and fauna. I observe Skylarks in the fields who would not return to breed in a small patch of allocated land. Bats are a regular sight outside my house, coming from their roosts in the mature trees in the land between Aylesbury and Weston Turville. All will be wiped out by development. VALP16-09-12-01606 Stuart Twigg Policy I3 - Infrastructure – Where are the secondary schools? Where are the hospitals? It is well known that Stoke Mandeville Hospital is coping at present; will it cope with a 50% increase in Aylesbury’s population? VALP16-09-12-01606 Stuart Twigg Policy I4 - Flooding – much is made in various recent planning applications for flood mitigation. The fact that mitigation and balancing ponds etc are needed is a sure indicator that you are planning on building in the wrong place i.e. on a flood plain. For example, looking at the Environment Agency maps, Woodlands has a high risk of flooding as does the land between woodlands and Stoke Mandeville. This low lying land is frequent waterlogged but that, I would suggest, is a good thing. The land slowly releases the retained water into the streams and ditches. An observable measure and effect of the water in this southern quarter of Aylesbury is the flooding two winters ago where the A41 was flooded at the then new lights at Broughton/Bedgrove. At that same time, Bedgrove Park was flooded across by several inches. That park water drained away over time. During that winter, the Ellen Road are of town was flooded, causing damage to housing. Only recently, drains have been blocked in Friarscroft Way nearly causing a flooding event which was remedied by locals. Councillor Mark Winn reports that a similar rescue was performed in his ward of Bedgrove. This was after exceptionally heavy rainfall but that kind of weather event is now more likely as the climate changes. The point of the above is, that regardless of what mitigation is put in, and flooding will occur as the drains have not and will not be monitored and maintained. The low lying land in your Woodlands to Stoke Mandeville arc self maintains. Building on it will cause long term flooding. VALP16-09-12-01621 Stewart Patience Policy I4 - Paragraph 11.32 (Anglian Water Services Reference is made to development being phased to enable water infrastructure being put in place prior to development. However this Limited) requirement does not appear in the policies of the Local Plan. It is considered that this should be included in an appropriate policy in the Local Plan. Policy I4 Flooding Anglian Water support the requirement to use SuDS so as not to increase flood risk and to reduce flood risk where possible and that this should be reflected in the development layout. Reference is made to the need to consider the risk from all potential sources of flooding. It is considered it would be helpful if the policy explicitly refers to foul drainage and sewage treatment. It is therefore suggested that Policy I4 should be amended as follows: o. All development will be required to design and use sustainable drainage systems (SuDS) for the management of surface water run- off, as part of the submitted planning application. p. Surface water connections to the combined or surface water system are only made in exceptional circumstances where it can be demonstrated that there are no feasible alternatives (this applies to new developments and redevelopments) and where there is no detriment to existing users; q. All development will be required to demonstrate that no surface water connections are made to the foul system; r. that no combined sewer overflows are created in areas served by combined sewers, and that foul and surface water flows are separated; s. that adequate foul water treatment and disposal already exists or can be provided in time to serve the development;

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ID Respondent Name Comment VALP16-09-12-01633 Neil Rowntree (Berks, Policy I4 - We welcome the inclusion of this policy and the accompanying text. However we do not consider that it includes sufficient Bucks & Oxon Wildlife content to fully reflect the NPPF. Trust) Flood risk can be reduced with measures that can also benefit biodiversity such as creation of wetlands, wet grasslands and wet woodlands and restoring of natural river flows and floodplains. By retaining water these measures can also help in the provision of water resources.

The text below should be included within the full text of such a Policy, in order to comply with paragraphs 99 of the NPPF (which states, with our underlining, “99. Local Plans should take account of climate change over the longer term, including factors such as flood risk, coastal change, water supply and changes to biodiversity and landscape. New development should be planned to avoid increased vulnerability to the range of impacts arising from climate change. When new development is brought forward in areas which are vulnerable, care should be taken to ensure that risks can be managed through suitable adaptation measures, including through the planning of green infrastructure.”):

Policy I4 should be amended to include: “In addition to safeguarding floodplains from development, opportunities will be sought to create wetlands, wet grasslands and wet woodlands, and restore natural river flows and floodplains, increasing amenity and biodiversity value. Building over or culverting of watercourses should be avoided and the removal of existing culverts will be encouraged.” We welcome o.- r. including the reference to groundwater quality and to wildlife in the context of SuDS schemes. VALP16-09-12-01635 Rod MOULDING Policy I3 - Transport Infrastructure: The Draft Plan correctly notes that “There will also need to be a focus on improving north / south connectivity to enable the district to function better in relation to national highway networks.” (Para 1.18) The District is poorly served by road and rail. It is ironic that of the three potential major projects that could impact on the District in the medium term two are primarily oriented east-west and the third, although running north-south, will have no useable effect. East-West Rail has been mooted for years, with start and complete dates moving successively backwards. It would be foolhardy to rely upon East-West Rail ever coming to fruition. It is important to emphasise first that any elements of the project east of Bedford are unlikely ever to be implemented, given that the former trackbed has now been built on, and second that the prime use of the potential line would be for freight movements rather than for passengers. It would be most unwise to expect that East-West Rail would take up a significant amount of north-south (Aylesbury/Winslow/Milton Keynes) passenger traffic given the roundabout route of its southern extension. Specifically, development proposals in and around Winslow must not rely on this. The A421 Expressway project is no more than a gleam in a transport planner’s eye, and is even further in the future. The suggested routes would provide no benefit to the district; a modified route via Aylesbury could, however, open up communications with Milton Keynes. Again, reliance on any part of this project being implemented in a realistic time frame would be unwise. High Speed Rail 2 (HS2) is effectively irrelevant for the District since no stops are envisaged. “Mitigation” must not be allowed to swallow excessive funding.

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ID Respondent Name Comment VALP16-09-12-01641 MICHAEL KNOTT Policy I1 - We support the council's desire to work with partners to ensure that existing and new green infrastructure is planned, (Gallagher Estates) delivered, enhanced and managed as an integral part of supporting sustainable communities and sustainable growth. As described in Appendix 6.6 of the Environmental Statement submitted in support of the existing outline planning application for Land at Eaton Leys, of the existing approximately 108.8ha of agricultural fields within the Site, only approximately 53.8ha (approximately 49.4%) would comprise built development (permanent loss). The remainder (approximately SSha/50.6%) would form green infrastructure, largely comprising multi-functional open space, in addition to the reinforcement of existing treebelts and small areas of woodland, as part of a more varied structure of landscape components than currently existing. It is considered that this beneficial change, of low magnitude would partly offset the medium magnitude of adverse change resulting from the loss of the fields, to lead to adverse effects of moderate significance.

VALP16-09-12-01641 MICHAEL KNOTT Policy I2 - Gallagher Estates support the inclusion of sports and recreation provision in development proposals which are (Gallagher Estates) commensurate to the scale of the development being proposed. VALP16-09-12-01641 MICHAEL KNOTT Policy I3 - Policy L3: Community Facilities (Gallagher Estates) No comment. VALP16-09-12-01641 MICHAEL KNOTT Policy L4: Flooding (Gallagher Estates) bartonwillmore.co.uk Sth September, 2016 Gallagher Estates support the use of sustainable drainage systems for the management of surface water run-off, as proposed in the planning for Land at Eaton Leys.

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ID Respondent Name Comment VALP16-09-13-01674 Nicola Thomas (Milton Policy I1 - The NEP welcomes the recognition in the draft Vale of Aylesbury Local Plan ("VALP") of the potential for GI to deliver multi- Keynes Natural functional, accessible and connected open spaces, important for biodiversity, the historic environment, wildlife and landscape. We also Environment welcome recognition of the GI link to engaging the community to build a strong sense of place, and to provide health and recreational Partnership) benefits at little or no cost to users. (Para 9.7, pg 163; and Policy I1).

To strengthen the opportunities through the Local Plan to maximise the benefits from Green Infrastructure in the Vale of Aylesbury, the NEP considers that the draft Local Plan should look to support more strongly and explicitly the NEP's document, the "Vision and principles for the Improvement of Green Infrastructure in Buckinghamshire and Milton Keynes". The NEP believes it will be necessary to apply the Green Infrastructure (GI) Principles locally, fully, and at all spatial scales of development in the Wycombe District, to achieve the county-wide Vision for GI in Buckinghamshire and Milton Keynes by 2030. We have highlighted below where the Local Plan’s application of the Principles could be strengthened and made more specific to achieve this aim.

We would also encourage the draft Local Plan to take on board the NEP’s standard response to Local Plans (previously submitted) in respect of biodiversity, green infrastructure, energy and the economy. NB - The NEP's GI Vision and Principles document has case studies and workable examples to illustrate how the Principles can be / have been applied in practice.

Green Infrastructure (I1) – pg 194 Welcome reference that the “council will implement the most up to date GI Strategy”, and many other aspects of the policy. Please make explicit reference to NEP’s GI Vision and Principles, which includes the definition of GI, and support for the county-wide Vision, and the need to translate it to apply in the District. This should include support and commitment to providing GI for local needs and for higher-level, strategic needs.

Development proposals should look not just “within the site” but beyond it – in line with the NEP’s GI Principle 7 regarding the coordinating GI creation and improvement with activities and existing networks cross-border. In addition – recognition of the order of biodiversity mitigation hierarchy – should provide for mitigation off-site where not possible on-site.

“No net loss and where possible a net gain” This needs to be stronger e.g. " all developments must deliver a net gain in biodiversity where possible". Commitment should be made to using a suitable metric to ensure proposed and actual net gains in biodiversity.

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ID Respondent Name Comment VALP16-09-13-01674 Nicola Thomas (Milton How does ANGSt – supported in Para 11.10, relate to the “Assessment of Leisure and Cultural Facilities, 2012 criteria – noted in Keynes Natural Policy I1 on Green Infrastructure – pg 194)? Environment Need to make clear if seeking ANGSt criteria or the Assessment of Leisure and Cultural Facilities criteria - with appropriate Partnership) justification.

Secure ongoing maintenance – we would welcome a stronger requirement for GI to be managed into the long-term in line with the NEP’s GI Principles – which would help protect GI into the future including against cumulative pressures. The aim would be secured GI management into perpetuity – with the developer securing maintenance for 25-30 years and making provision beyond that. Principle 5 provides example mechanisms.

ALL development should apply the principles and look for opportunities – within site and surrounding it – to protect, enhance and create GI for its multiple benefits. Protecting, enhancing and providing green infrastructure should be considerations in all development decisions, at all scales. In particular we would welcome more emphasis on: Early and strategic planning of GI for its value and benefits – both at the strategic scale and at all other spatial scales of development. Recognition of the importance and necessity of GIas equal to that of constructed, grey infrastructure such as road and rail networks. For example, GI can support the Buckinghamshire economy, as well as health and climate change initiatives. NEP’s Principle 3 lists some of the benefits provided by GI. Connected networks are necessary to maximise the benefits of GI for wildlife and for people. This should be a goal at both the landscape and local scale, aiming for sustainable means for access and movement within and outside urban areas, with sufficient buffers to protect the wildlife value of GI. Connected networks are mentioned at bullet a, policy I1 on GI - but could be stated more precisely and explain how this relates to “within the site”. Suggest separate acknowledgement of the need to contribute to goals at the landscape scale as well as the District and local scales. We would request an explanation is provided at “connected open spaces” (I1, pg 194) – and for this section to explicitly support the NEP’s GI Principle 6 – that connected networks of GI are necessary both at the landscape and local level, to maximise the benefits. GI improvement and provision should be prioritised in locations where it can deliver most benefits. Opportunities to maximise the benefits of GI across Buckinghamshire’s and Milton Keynes’ environment, health and economy, should be explored both strategically, when planning for GI provision ahead of growth and development, and when mitigating the impacts of development.

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ID Respondent Name Comment VALP16-09-13-01674 Nicola Thomas (Milton For example – certain locations may maximise multiple benefits: e.g. within and through urban areas and development, to link urban to Keynes Natural rural areas, in built design to include biodiversity requirements, and to provide access to countryside on your doorstep (compare Environment ANGst with Leisure and Cultural Facilities) (pg 192), including in areas with high indices of multiple deprivation. Partnership) Alongside provision, providing for the encouragement to use local green spaces (within Principle 5, NEP GI Principles document) GI planning and development should be linked and relevant to, informed by and coordinated with, other policy areas, strategies, activities and reviews that could affect GI provision and quality in Buckinghamshire (Principle 9).

3 [The Plan should include] a commitment to work in both the planning and delivery-phase cross-border with neighbouring authorities to seek opportunities to maximise benefits from GI through growth and development. (NEP GI Principle 7). For example, connected networks are necessary to maximise the benefits of GI – and this should be a goal at both the landscape and local scale. Although mentioned at bullet a, policy I1 on Green Infrastructure, this could be stated more precisely. We suggest separate acknowledgement of the need to contribute to goals at the landscape scale as well as the District and local scales, and a commitment to look beyond the boundaries - at both a site level and District level, to maximise opportunities arising from GI. We would also suggest the reference to “within the site” should include "and beyond".

5 The plan should make provision for the management and maintenance of GI into the long term – in line with the NEP’s GI principle 5. This requires developers to secure management for 25-30 years post completion, and during that time secure a mechanism to manage into perpetuity. This is more specific, and goes beyond the statement in the current draft Local Plan Policy I1 to secure “on- going” management and maintenance of GI assets (pg 194). Close working with community groups should also be explored to help engage local residents in taking a closer interest in their local green space and in encouraging its use. The Plan should also make it clear that CIL and s106 / developer contributions monies, as well as other sources, are being considered to fund GI – as is implied in the inclusion of GI in the definition of infrastructure at Para 3.43.

6. We would expect Local Plans to require ALL DEVELOPMENT to: - Contribute towards translating the future vision of GI in Buckinghamshire and Milton Keynes and the Principles for GI advocated by the NEP, to meaningful development and GI projects locally. Focusing on protecting, improving and providing GI in line with the Principles will turn the vision into reality and create a multi-functional GI network in Bucks and MK that improves economic, environmental and quality of life benefits.

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ID Respondent Name Comment VALP16-09-13-01674 Nicola Thomas (Milton - Seek opportunities to protect, enhance, extend, create and connect GI for all its benefits (including landscape-scale connectivity of Keynes Natural habitats for biodiversity outcomes) from an early stage, including surrounding the site or area. This requires cooperation with broader Environment policy objectives, and at a practical level, with neighbouring land-owners. Partnership) - Place emphasis on adequate access to high quality green recreation and productive space for community health and wellbeing (at least conforming to ANGSt standards at the strategic scale), and other services as outlined at Point 6, above). Connected to this, the NEP recognises the many potential benefits to house builders through incorporating appropriate GI in their developments. Many potential buyers will want the benefits of GI, which could therefore be used as a marketing tool. - Ensure the size and location of GI is suitable for the function it is intended to fulfil. - Require GI management into the long-term, to ensure that it develops in accordance with its stated intention. Mechanisms to achieve this must be outlined in development proposals. - Require the monitoring of GI improvement, and remedial measures if not achieving satisfactory GI condition within stipulated timeframes. - Allocate and develop sufficient funding mechanisms to improve the quality, location and functions provided by GI, including into the long-term. This could include developer contributions, biodiversity offsetting, CIL payments, and long-term provision for example through endowment or similar arrangements. This approach would require identifying where current GI is, the functions it serves (to understand its potential importance), gaps in provision, and opportunities for how and where it should be improved (e.g. via mapping work).

The Local Plan should include a map of GI at the District-wide level to show very clearly how the District will contribute overall to the Buckinghamshire-wide Vision and Principles for the Improvement of GI, including connected networks of GI showing the Vision for what the District aims to protect, provide for or improve and where. So - in addition to maps for specific areas (in Section 5 of the draft Local Plan) - the District-wide map of GI should show: a. Existing GI features of value. This should go beyond identifying the AONB, green belt and flood zones - to identify which GI features and areas are important (e.g. canals, major rights of way, BOAs, designated sites and priority habitats, valued landscapes, wildlife corridors, accessible green space, woodlands, etc) b. How the Vale of Aylesbury will apply and contribute to the overall Vision and Principles for the Improvement of Green Infrastructure in Buckinghamshire and Milton Keynes. c. Where there are deficiencies in GI; and d. Where new / improved provision is required, for example in comparison with pressures from growth and development. This exercise should take into account the need for the protection of existing GI assets in the face of change or growth, provision for future GI assets and planning to relieve pressure on existing assets; the need for connected GI networks; ad it should also seek opportunities to maximise the benefits from GI [and apply the other GI Principles]. VALP16-09-13-01696 Mark Owen (Barton Policy I1 - We agree with Draft Policy I1 (Green Infrastructure) which emphasises the need to provide green infrastructure to deliver Willmore (on behalf of high quality, multi-functional, accessible, and connected open spaces that are integral to new and existing development. We would like Hampden Fields to take this opportunity to remind the Council that the Hampden Fields proposal would provide 108.65 hectares of green infrastructure Consortium)) (circa 50% of the total area of the site) which supports the Green Infrastructure Network that is proposed for Aylesbury Garden Town (as illustrated on the plan on page 49 of the ‘VALP Policy Map Insets’).

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ID Respondent Name Comment VALP16-09-13-01696 Mark Owen (Barton Policy I2 - We agree with the objective of sport and recreation provision across the District as indicated by Draft Policy I2 (Sport and Willmore (on behalf of Recreation). The Hampden Fields proposal includes recreational opportunities, including additional sport pitches and indoor provision Hampden Fields as part of the proposed multi-use community facility, to the advantage of both existing and future residents. Consortium)) VALP16-09-13-01696 Mark Owen (Barton Policy I3 - We agree that applications for residential development should consider new community facilities arising from proposals as Willmore (on behalf of indicated through Draft Policy I3 (Community Facilities). The proposed Local Centre as part of the Hampden Fields proposal includes Hampden Fields a multi-use community facility to the advantage of both existing and proposed residents. Consortium)) VALP16-09-13-01696 Mark Owen (Barton Policy I4 - We agree with the need to consider flood risk appropriately as indicated by Draft Policy I4 (Flooding) and also agree that Willmore (on behalf of developments should be required to design and use sustainable drainage systems (SuDS). The risk of flooding was appropriately Hampden Fields considered as part of the Hampden Fields proposal as indicated within the Flood Risk Assessment submitted as part of the planning Consortium)) application. Furthermore the proposed framework masterplan incorporates a Strategic Flood Alleviation Scheme and integrates SuDS as part of the green infrastructure network across the site. VALP16-09-13-01708 Rachel Wileman Policy I1 - Green Infrastructure (Buckinghamshire (p 194) This policy links well with C4 so BCC suggests the following is added: County Council) c. green corridors and public rights of way to link with the wider green infrastructure network; providing walking, cycling and other exercise opportunities and avoid habitat or linear network fragmentation (linked with Policy C4). 8.25 Delivery of the Grand Union Triangle cycle path is proposed over the next few years. The section outside the canal towpath, running between Wendover and Aylesbury, needs protecting and developments need to contribute to its delivery. In all areas developments should provide connections to it. This could be acknowledged in the Green Infrastructure chapter or within Policy I1. If you consider the latter appropriate, I would suggest a new item on p 194: j. Developments close to the Grand Union Triangle cycle path should provide connections to it and contribute to structural delivery, as outlined in the Aylesbury garden town green infrastructure network map (p 52). 8.26 Note: It may be better to prefix the title these policies G1, G2 etc. as the letter I (eye) is confusing with l (el) and 1 (one).

There is a focus on Aylesbury’s ‘Garden Town’ initiative, with proposals including a green infrastructure network around the new ‘garden communities’. However it is not clear as to what existing green space is and what new accessible green space is. There also does not seem to be any green infrastructure to offset the developments in the north of the Vale, particularly around Buckingham. Mapping comments: •There needs to be a differentiation between existing green space and new green space; •The approach applied to Aylesbury for green infrastructure needs to be applied to the other significant developments – VALP to confirm what constitutes ‘significant’ but where there are developments, particularly around towns, existing green space and new green space should be clearly mapped.

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ID Respondent Name Comment VALP16-09-13-01708 Rachel Wileman Policy I3 - Appendix 1 Education (Buckinghamshire BCC’s School Place Commissioning team have reviewed the key elements as part of the draft VALP housing plan and assessed the County Council) potential impacts this could have on the County Council’s obligation to ensure sufficient school places. From a school place planning perspective, development is preferred in and around the principal settlements. There may also be scope for some limited infilling in rural villages/towns where there is a school, listed below: •StoneWestcott •Waddesdon•Great Horwood •Marsh Gibbon•Padbury •Grendon Underwood•Quainton •Steeple Claydon•Whitchurch •Winslow•Stoke Hammond •Edlesborough•Stewkley •Wingrave•

Schools which are located in rural areas that are already close to capacity are listed below: •Haddenham•Long Crendon •Aston Clinton•Wendover/Halton •Pitstone/Ivinghoe•Twyford/Calvert Newton Longville

Further investment would be needed in Haddenham if this settlement was intended to become a strategic focus for housing growth. The Local Authority (LA) would need to rely on sufficient housing growth coming forward to justify any school expansion (to avoid the introduction of surplus places which can prejudice the provision of efficient education or the efficient use of resources) as schools tend to expand their intake in steps of 30 pupils (i.e. 1 form of entry). Moreover, due to the recently introduced Government legislation which limits the pooling of more than five contributions, developments will need to be sufficiently large enough to ensure sufficient funding to pay for the infrastructure works. Based on BCC pupil yield estimates, approximately 700 homes would generate an additional form of entry of primary aged pupils. Furthermore the LA will need to consider the cumulative impact of all relatively large scale applications (of less than 700 homes). This may mean combining school place provision through more strategic allocations in order to provide larger, more sustainable primary schools.

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ID Respondent Name Comment VALP16-09-13-01708 Rachel Wileman Paragraph 55 of the National Planning Policy Framework indicates that Local planning authorities should avoid new isolated homes in (Buckinghamshire the countryside. Increased development in rural areas is likely to provide fewer opportunities for school expansions (due to fewer County Council) housing numbers/pupil demand and limited schemes in which to pool contributions) and can result in increased home to school transport distances and costs as well as reduced social cohesion if the local school becomes oversubscribed.

The Education and Inspections Act 2006 places a duty on local authorities to promote choice and diversity in relation to provision of school places. Forecasting at planning area level also has the effect of cancelling out the effect of changes in parental preference (and ensuring uniform trends in pupil numbers) which allows local authorities to make more effective decisions about adding and removing capacity.

AVDC’s housing needs assessment has identified the need for over 30,000 homes in the district over the next 20 years which is likely to present a number of new school opportunities on major sites. It may be possible for the capacity of these new schools to be future proofed to accommodate demand from other development. Alternatively, BCC could work with the Department for Education to identify land and seek proposals for new schools in those areas which are likely to experience oversubscription for places.

The number of strategic sites identified in and around Aylesbury town where existing schools are at capacity and the new settlement areas (e.g. Haddenham or development near to Milton Keynes) will also require the provision of on-site new schools (in line with the pupil generation rates quoted above) in addition to the current planned expansion of existing schools (e.g. Oak Green, St Louis RC, William Harding, Bierton CE, Haydon Abbey). In Aylesbury there are currently pending planning applications for over 5000 homes including 3000 at Hampden Fields (16/00424/AOP and WTV022 in the plan), 400 on Aston Clinton Road (15/03806/AOP – not included in plan), 1100 at Woodlands (16/01040/AOP – not included in plan) and 190 at Lower Road Stoke Mandeville (15/01619/AOP and SMD012 in the plan).

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ID Respondent Name Comment VALP16-09-13-01708 Rachel Wileman Options to meet the above housing identified in the Vale of Aylesbury plans include: (Buckinghamshire County Council) 1. Provision of 2fe and 3fe primary school on Hampden Fields; 2. Provision of 2-3fe school to accommodate development in the south within the Stoke Mandeville Parish (approx. 2000 homes) – 2- 3 hectare school site to be identified; 3. Provision of 1fe school on 1 hectare site within development for 808 homes in the Stone Parish (STO016) 4. Expand Bierton CE School by half a form of entry; 5. Expand second Berryfields Primary School from 2fe to 3fe primary school; 6. Provision of 2fe school on Woodlands (although not included in plan this could address the shortfall of 1325 homes left to identify in Aylesbury);

Secondary schools across Aylesbury Vale are all at capacity and close to the limits of their sites. Estimated pupil growth from over 8000 dwellings with outstanding housing permission is projected to put increased pressure on secondary schools. There are already plans for a new secondary school up to 10fe on the Broughton Crossing development (2450 homes) where a site has been reserved although further expansion/new school options are currently being explored. Any major scheme (of around 2000+ homes) would be required to make either on-site provision for a new school or else contribute towards the expansion of a new school. Other smaller scale schemes would be expected to contribute towards additional secondary school provision provided no more than five planning obligations are allocated towards a single scheme.

BCC is currently expanding Sir Henry Floyd Grammar School to meet the increased demand for grammar school places. However, if significant expansion of existing grammar schools is not possible, then the increase in housing growth across the district is likely to reduce the number of out county pupils taking up grammar places. This is likely to require the expansion of existing/new upper schools with Bucks resident children who currently access out county provision.

With regard to the need for additional special school provision – this will be informed by review currently being carried out by the SEND team.

BCC supports draft policy S5 and policy 13 which requires all development to make appropriate on-site (via S106) and off-site (via CIL) infrastructure.

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ID Respondent Name Comment VALP16-09-13-01708 Rachel Wileman 1.15 Requirement for S106 Contributions (Buckinghamshire County Council) 1.16 Education contributions are calculated by multiplying the number of children likely to be generated by the net dwellings on the development by the costs of providing additional school places.

1.17 The cost per pupil for building additional accommodation is based on the DfE build cost multipliers: Type Building Costs Site Works Fees Furniture & Equipment Abnormals ICT Infra-structure ICT Hardware Total Cost Multiplier Primary £9,551 £1,137 £1,466 £962 £669 £225 £906 £14,915

Provision Type Cost per dwelling Flats Houses Bucks Average 1 Bed 2 Bed 3+ Bed 1 Bed 2 Bed 3 Bed 4+ Bed Primary £403 £1,298 £2,640 £1,715 £3,296 £5,787 £6,965 £4,564 1.18 Based on BCC pupil yield rates and build cost multipliers, the following primary school contributions would be required to meet the need arising from the reserved sites: 1.19 The approximate cost for each additional form of entry is £3.1m based on the above cost multipliers.

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ID Respondent Name Comment VALP16-09-13-01708 Rachel Wileman Policy I4 - Strategic Flood Managemnt (Buckinghamshire - Section c – should set out in a list/bullet points, rather than a series of separate sentences. County Council) - Section q - BCC are not a SUDS approval body; we are a statutory consultee for planning. 8.28 For any sites where a watercourse is altered or diverted for the development Land Drainage Consent will be required under Section 23 of the Land Drainage Act 1991, we ask that this is promoted to ensure that developers are aware.

Updated Strategic Flood Risk Assessment Although we are aware that an updated Level 1 Strategic Flood Risk Assessment (SFRA) is being prepared, this document is not yet available to support or inform the Local Plan. Without a SFRA, BCC cannot be confident that flood risk has been fully taken into account in the consideration of allocation options and in the preparation of plan policies. There are two levels of SFRA; a Level 1 assessment should allow application of the Sequential Test to the location of development and to identify whether development can be allocated outside high and medium flood risk areas, based on all sources of flooding, without application of the Exception Test. Where a Level 1 Assessment shows that land outside flood risk areas cannot appropriately accommodate all the necessary development, the scope of the Assessment should be increased to a Level 2 to provide the information necessary for application of the Exception Test where appropriate. A Level 2 Strategic Flood Risk Assessment should consider the detailed nature of the flood characteristics within a flood zone including probability, depth and velocity, rate of onset and duration of flooding. T he updated Level 1 SFRA should determine and recommend whether a Level 2 SFRA is required. Given that a Level 2 SFRA was previously undertaken in 2009, it is highly likely that a Level 2 SFRA will be required again. It is important that this is confirmed early. This may be a substantial piece of work, potentially involving additional hydraulic modelling, which will take time to complete. We have a high level of concern as to the timeframe for undertaking a Level 2 SFRA within the timeframe of the Local Plan being published in final form. We would wish to be involved in discussions on the scope and detail of the Level 2 SFRA; for example, to discuss cumulative impacts of development, potential opportunities and options, etc.

Several Section 19 Flood Investigation Reports for different locations in Aylesbury have been published by Buckinghamshire County Council on our website. As some Reports cover areas where there are housing allocations identified in the Draft Local Plan, we would expect the latest version of Aylesbury Vale’s SFRA to refer to the S19 Reports.

We understand that the Updated Level 1 SFRA will include recent changes to the policy on Climate Change allowance. We would also ask AVDC to consider including policies that give surface water flood mapping equal weight to the fluvial flood zones in the application of the sequential test, and would be pleased to discuss further.

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ID Respondent Name Comment VALP16-09-13-01708 Rachel Wileman With regard to the content of the Draft Local Plan document itself, there is inconsistency across the Local Plan in that in some places (Buckinghamshire there is reference to the draft SFRA, which is not yet available, and in other places it refers to the previous (2012) version of the SFRA. County Council) A water advice note has been prepared by a group of organisations – BCC, AVDC, Environment Agency, BBOWT, RSPB, Thanes Water, Thame Conservation Trust and is attached in draft. BCC as part of the group who prepared this advice note and after discussion with David Broadley request that the advice note itself adopted by Aylesbury Vale District Council as a Supplementary Planning Document (SPD). Other flood management comments: Paragraph 1.9 – needs to refer to SFRA Paragraph 1.21 – SFRA – please mention that Level 1 is being prepared but this may well lead to Level 2 SFRA which will be more detailed in a number of areas identified to be more at risk. Paragraph 1.64 states that “most areas are in Flood Zone 1” - this needs to be clarified as to which areas it is referring to and what “most” means. Statement is too vague and could be misleading and mis-representative of the flood risk and needs some context. Paragraph 2.4d – how will the growth bring flood protection measures? Consider it unwise to suggest this when the mechanism for undertaking these measures is not clear. Should not refer to “flood protection measures” but rather “flood management measures”, as flood protection measures suggest that measures can always protect against floods; instead, they will only reduce/manage the risk up to a particular frequency of flooding Paragraph 2.6 – objective 7 part 2 - flood management measures, not flood protection or flood control measures – for reasons given above. In this section there needs to be some reference to Sustainable Drainage principles to mitigate the impact of surface water runoff from developments. Paragraph 3.4.3 Flood management, not flood protection or prevention Paragraph 4.8 – how are increased levels of protection going to be achieved? Good aspiration but is there a plan? Paragraph 4.26 – the current plan does not adequately take flood risk into account: the SFRA Level 1 is not a supporting document and it is likely that in those areas of higher flood risk a more detailed SFRA level 2 will be required, as was the case in 2009. Paragraph 4.37 – We believe that a decision on which settlement should go forward should also depend on the results of the SFRA Level 1 and if required Level 2. Paragraph 4.49 – Flood mitigation measures should ensure that flooding is no worse downstream of developments and ideally measures will be taken to improve flood management in this area of the catchment. Paragraph 4.50 – should include as set out in the Aylesbury Vale Strategic Flood Risk Assessment and Water Cycle Study – where is the supporting documentation/evidence?

VALP16-09-13-01717 Michael Brown Policy I2 - There is a playing field and a dilapidated pavilion, with play equipment paid for by local people

VALP16-09-13-01717 Michael Brown Policy I3 - The village hall was built by the villagers themselves in the 1950s. It is maintained by subscription and fundraising events by the villagers, but, has only one main room and a poorly equipped kitchen. VALP16-09-13-01717 Michael Brown Policy I4 - A major problem and concern in this village. Villagers have to cope with roads that turn to rivers in the wet season, and some suffer by having their homes flooded and possessions destroyed as the drains and sewers fail to meet the needs of current housing. The village drainage systems could not cope with more houses. Date: 25/11/2016 Project Number: 1664569/A0 Page 55 of 56 VALP Summer 2016 Consultation Responses – Chapter 11 Infrastructure

ID Respondent Name Comment VALP16-09-13-01722 Sarah James Policy I3 - Our villages have amenities for the locals, some more than others like us in Whaddon. We have no bus service,shop or pub but that is what we live with and forsome the way we like it. I see no gain from increasing population around us to add amenities and claim it's a gain forvillagers. VALP16-09-13-01731 Stephanie Schneider Policy I4 - FLOODING The Sustainability Appraisal shows serious issues of flooding on the Woodlands site. This brings into question the whole strategy to develop Woodlands. VALP16-09-13-01734 Charles Routh (Natural Policy I1 - I1 Green infrastructure England) One elements of the policy is unclear and we suggest should be rephrased as follows: a.biodiversity mitigation where warranted, development should result in no net loss, and where possible a net gain, in biodiversity (linked with Policy NE2)... Point b. does not seem to make grammatical sense, and we suggest is reviewed. A statement is made about “Green infrastructure accessibility and quantitative standards” in the policy, but it is not clear how these standards will bear on the determination of planning applications. This should be made clear. We understand that Buckinghamshire and Milton Keynes Natural Environment Partnership are about to publish a document entailed Vision and Principles for the Improvement of Green Infrastructure in Buckinghamshire and Milton Keynes. This is likely to be of relevance to this plan. VALP16-09-13-01817 Simon Proctor (Proctor Policy I4 - I4 - This policy should be amended to quantify developments over a certain size or quantum. If clarification is not given Surveyors (Newton there is the risk of overcomplicating minor applications and generating unnecessary costs and bureaucracy. Longville)) VALP16-09-19-01837 Ann Alcock Policy I1 - I agree with the plan to make the Berryfields/River Thame area a natural amenity with cycle ways. It is important to attract wildlife back, such as peewits. I approve of the introduction of barn owls and buzzards. VALP16-09-19-01838 Phyllis Simms Policy I1 - I support this policy.

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