Responses to the Buckinghamshire Council Local Validation List consultation The former councils in Buckinghamshire (Aylesbury Vale District Council, Buckinghamshire County Council, Chiltern District Council, South Bucks District Council and Wycombe District Council) consulted on the Local Validation List for Buckinghamshire Council between 2 – 16 March 2020. We received 12 responses in total. Below is a summary of the comments received and the agreed action resulting from those comments. If you have any questions on the Local Validation List or the consultation process, please email [email protected]. Table 1 Schedule of comments and responses to the Local Validation List Name Organisation (if Document / section Comment Agreed Action relevant) Information required is guesswork, Leave document as is - applicants won’t know what trial for 3 months and buildings are within 200m of the review site. Ecology and Trees Checklist It’s planning officer’s job to decide if trees / ecology is affected by proposal Matt Trotter MWT Architecture . A lot of work and additional cost for The rationale is to try and owners. ensure consistency across all the previous councils Needs assessing on each application and to simplify the list. It Site sections with negotiation with the agents is an attempt to try and once applications and received and provide certainty to the before they are validated. Validators documentation that would send applications back without be required to support and 1 Name Organisation (if Document / section Comment Agreed Action relevant) thinking about the real need for the application in the new document. Buckinghamshire Authority Why are these needed for all No changes – the applications (e.g. lean-to porch)? If document is not required the roof is complicated or difficult to for all applications understand then this can be Roof plans requested during the application, but applying to all adds unnecessary work for agents and extra cost to owners Unclear precisely what supporting See the comment about information is required for each the rationale for the new General application – provides officers with validation list a license to demand whatever they want Current inconsistent practices with Use the statutory certificates (e.g. demanded notice definition. Adrian ACH Planning be given to someone holding ‘right of way’ as an owner / give notice to With highway matters the highway authority as an ‘owner’ highway authority is an Ownership certificates because application related to a owner. new access to highway. Need confirmation on what is considered ‘owner’ Unsure whether requirements vary See the comment about Neil Cottrell CALA General across local areas the rationale for the new validation list Commissioner Schools Will Buckinghamshire Council be Internal practice not a Paula Campbell- – Buckinghamshire General considering outline applications and validation issue Balcome County Council appeals for schools? 2 Name Organisation (if Document / section Comment Agreed Action relevant) Are schools exempt from CIL? Each CIL scheme is different. CIL additional questions Ensure appropriate CIL documents are set out on page for referral. Internal sections through a property Agreed. New document where floor levels being altered, or added to Local Validation changes in make up to ceiling or List. *New document* Chiltern and South floors or timber frames Bucks District Council (Principal LBC applications only Matthew Crook Conservation and Internal elevations to show how Agreed. New document Listed Buildings alterations will appear / be formed added to Local Validation Officer) on site when viewed on the inside List. *New document* of a property LBC applications only Validation should be thoroughly and See the comment about General properly overseen by a professional. the rationale for the new validation list Should state how planning policies Add bullet point: Design and Access are met, not just on access (some - Can state how Statement applicants address this in planning planning policies Beaconsfield Town statements) are met Patrick Hogan Council Should be a requirement of all Add text to ‘there may be Sections / levels applications (especially in hilly areas other proposals where we e.g. High Wycombe) ask this form you’ Should be a requirement of all Add bullet point applications (especially in hilly areas - Show relative Elevations e.g. High Wycombe) to show heights / levels in relative heights/levels in street street context 3 Name Organisation (if Document / section Comment Agreed Action relevant) context (where relevant, e.g. hilly areas) Definition of ‘non-material The Validation List is not General amendment’ should be made clear the appropriate location as is currently open to abuse for such a definition. Need to agree when this list will be List will apply for all new introduced: is it all applications applications received from received on 1 April onwards? Or are 1 April. applications submitted before 1 General April but validated after 1 April All backdated applications going to use the new list? will use previous versions of Lists specific to the individual Councils Definitions of major / minor are Change text to statutory more complicated in light of recent definition. legal case with C&SB. NPPF has broader definitions but The Town & Chiltern and South Country Planning (General Bucks (Team Leader – Daniel Gigg Management Procedure) (England) Strategic Sites and Order 2015 (as amended) is Specialists) different. Definition of minor / Suggested amendments: major / householder Minor – ‘under 1000 sqm’ (all floorspace including resi) ‘below 1ha) (whole site, any development including resi) Major – - 0.5ha (where number of dwellings isn’t specified) 4 Name Organisation (if Document / section Comment Agreed Action relevant) - 1000 sqm (any building, including residential), e.g. 9 dwellings over 1100 sq m would be major - 1ha (all development), e.g. 9 dwellings on a site of 1ha would be major Should list of applications include No changes proposed ‘Reserved matters’ and ‘variation / removal of conditions’? For other applications customers No changes proposed General were advised to see the checklist that is at the end of the standard application form for that application type. On guide to completion. Should Q6 Make change to Q6. Application form say ‘trees on site as well as those within falling distance’ Chiltern and South Potentially misleading, disparity Make change. Bucks District Council Jeanette Collins between Application Form guidance (Senior Improvement / Ownership certificate entry. Officer) Change to: A sole owner Ownership certificates B EITHER not the owner but know who is OR they are not the sole owner but they know who the other owners are C EITHER not the owner but they 5 Name Organisation (if Document / section Comment Agreed Action relevant) know some of the other owners OR they are an owner but only know some of the other owners D EITHER not the owner and don’t know who is the owner(s) OR they are an owner but don’t know any other owner(s) Existing and proposed Should this say this is a national and Fully considered but no elevations local requirement, not just local? change required Gross floor area put under ‘Dos’ but New document to be Floor plans CSB currently require this as a new created (see below) document. Is there value in this? New dwellings schedule. New document added to Local Validation List. Where the proposal involves new dwellinghouses or flats, give floor area in sqm of internal and external gross floor space to be provided for all floors including basements for each dwelling unit and an overall *New document* total for all new dwelling units proposed Our reasoning for requiring this information is that applicant has appropriately identified the floor space for fee calculation and CIL liability, as well as whether their proposal falls within major category or not. 6 Name Organisation (if Document / section Comment Agreed Action relevant) Does this require ‘critical drainage’ Add text to ‘there may be SuDS Statement areas in South Bucks? other proposals where we ask this form you’ Waste and recycling Is this a national or local Noted. Change to ‘local strategy requirement? Currently missing. requirement’. Says needed on ALL LBC There is a need to ensure applications. Not part of national consistency in approach Design and Access requirement, just major and therefore no change Statement conservation area. Suggest adding proposed. ‘local’ if that is the case. CSB currently use an Affordable New document added to Housing Form. Local Validation List. Suggested criteria: Requirements will be local area affordable housing 5 or more self-contained homes in thresholds. an Area of Outstanding Natural Beauty and/or · 10 or more self-contained homes and/or *New document* · Site area is 0.5 hectares or more. There may be sites that are capable of providing 10 or more homes, where the requirement may apply. These will be identified on an individual basis and the applicant advised accordingly. This was an IMPORTANT inclusion in our local list when we did it last 7 Name Organisation (if Document / section Comment Agreed Action relevant) year. Not sure if this has been discussed and dismissed or is covered somewhere that I didn’t spot. Do we still want to have this, maybe a Chiltern/South Bucks only one? Email includes suggested form and text. Hydrology Report, already on radar New document added to but requires GIS extent. Local Validation List. ‘Applications within 500 metres