Consultation Point: Building-Infrastructure

Person ID 1214611 Full Name Mrs Frances Reynolds ID 891 Order 233 Number 11.1 Title Building-Infrastructure Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-12-10 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as

9 precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do There is also a significant infrastructure funding gap acknowledged within the Community Infrastructure Levy evidence that supports this Local Plan, of between £179m & not believe this policy to be £231m. Given this infrastructure is vital to ensure that development is sustainable (as also required by the NPPF) this further demonstrates the Plan is both unsound and positively prepared please not legally compliant. explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as

10 possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

Person ID 1211260 Full Name Mrs Sue Moffat ID 6372 Order 233 Number 11.1 Title Building-Infrastructure Organisation Details Town Clerk Gerrards Cross Town Council Consultee Type - Please Parish Council select the type of consultee: Date Received - Date 2016-02-09 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please

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

12 modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do SP BP1 Developer Contributions to Support Growth not believe this policy to be We welcome the proposal to ensure that developers contribute to new or improved infrastructure, but the infrastructure necessary is too vague and needs to be well defined. positively prepared please Current infrastructure already falls well short due to new developments, no medical facilities in Gerrards Cross, overloaded water and sewage services, lack of school places. explain why Infrastructure should embrace the broadest definition of access to transport (of all means), water, communications, power and healthcare. Greater consideration should be given to these and the burden placed on existing systems in the race to providing an increase in dwellings. New plans need to address these requirements directly. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

Person ID 1211260 Full Name Mrs Sue Moffat ID 6371 Order 233 Number 11.1 Title Building-Infrastructure Organisation Details Town Clerk Gerrards Cross Town Council

13 Consultee Type - Please Parish Council select the type of consultee: Date Received - Date 2016-02-09 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible.

14 Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do 11.1.5 and 11.1.6 need to be contingent on each other. As written, it appears that developers may contribute to infrastructure as directed and this should be a “must” if not not believe this policy to be contributing to CIL. positively prepared please Openness and clarity should be given to all developers’ contributions so that it can be seen how much is given for each project and that any variations to the policy are explain why explained fully. It is vital to note that, at least currently, once a Neighbourhood Plan is ‘made’, CIL contributions to a Town/Parish Council rise from 15% to 25%. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.

15 Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

Person ID 1211260 Full Name Mrs Sue Moffat ID 6373 Order 233 Number 11.1 Title Building-Infrastructure Organisation Details Town Clerk Gerrards Cross Town Council Consultee Type - Please Parish Council select the type of consultee: Date Received - Date 2016-02-09 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally

16 compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do 11.1.5 and 11.1.6 need to be contingent on each other. As written, it appears that developers may contribute to infrastructure as directed and this should be a “must” if not not believe this policy to be contributing to CIL.

17 positively prepared please Openness and clarity should be given to all developers’ contributions so that it can be seen how much is given for each project and that any variations to the policy are explain why explained fully. It is vital to note that, at least currently, once a Neighbourhood Plan is ‘made’, CIL contributions to a Town/Parish Council rise from 15% to 25%. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

Person ID 1214645 Full Name Mr George Eykyn ID 3637 Order 233 Number 11.1 Title Building-Infrastructure Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-12-11 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID

18 Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any

19 non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The proposals re site BP 8 under the draft Local Plan are not sound, and not legal. They do not contribute toward sustainable development as required by the NPPF and also not believe this policy to be by the council’s own Local Plan Policy SP1. positively prepared please Re Site BP8, the area's needs and capability to sustain the proposed development are inadequately considered, and in fact these considerations are largely ignored. explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.

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

Person ID 1214645 Full Name Mr George Eykyn ID 3639 Order 233 Number 11.1 Title Building-Infrastructure Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-12-11 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or

21 regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why

22 Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not The draft Local Plan violates numerous criteria of the NPPF. believe this policy in It has no strategic policy setting out spatial strategy, as required under para 35 of the NPPF. consistent with the National Planning Policy For Green Belt Development Options (2017) it seems only sites in the Green Belt have been assessed. It is therefore impossible to say whether there are other sites which Framework Feb 2019 would have less impact on the environment and would be better suited to development. please explain why Para 136 of the NPPF 2019 says Green Belt boundaries should only be altered “where exceptional circumstances are fully evidenced and justified”. This has not been satisfied, and the proposal on the Green Belt is thus in violation of core NPPF requirements. SP BP8 fails against all three of the key NPPF criteria: • Social - the social objective states that in order to achieve sustainable development, developments must have “accessible services and open spaces that reflect current and future needs and support communities’ health, social and cultural well-being”. The site is not in a location which provides access to public transport and does not have sufficient access to shops and services. • Environmental - the environmental objective in the NPPF states that the planning system should “contribute to protecting and enhancing our natural, built and historic environment”. Site BP8 is adjacent to Paccar Scout Camp, which is a thriving rural camp site. There are over 50,000 visitors to the camp site every year. It would be forced to close. Safeguarding risks would be increased to unacceptable levels by the proximity of the proposed housing, changing entirely the nature of the PACCAR site. This would force Scout Camp administrators to reduce attendance numbers to such low levels as to become unviable, and would lead to the inevitable closure of this asset that benefits so many young people, many from deprived backgrounds • Economic sustainability - site BP8 contains the site of Winkers nightclub. The nightclub is a popular venue for students and local residents alike. The likely closure of the nightclub were the proposals approved, would have a significant negative effect on the night-time economy of the area. The loss of this community amenity would not conform with the economic objective of sustainable development as detailed in the NPPF, as it would result in the loss of a unique type of employment within the local area. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

Person ID 1214645 Full Name Mr George Eykyn ID 3638 Order 233 Number 11.1 Title Building-Infrastructure Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-12-11 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID

23 Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any

24 non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not On altering Green Belt boundaries, there is a flawed evidence base. For Green Belt Development Options (2017) it seems only sites in the Green Belt have been assessed. It believe this policy to be is therefore impossible to say whether there are other sites which would have less impact on the environment and would be better suited to development. justified please explain why The Local Plan says Green Belt boundaries may be altered “where exceptional circumstances exist”. These “exceptional circumstances” have not been adequately demonstrated, and this key qualification and constraint has been breezily bypassed by the proposal. In addition, para 136 of the NPPF 2019 says Green Belt boundaries should only be altered “where exceptional circumstances are fully evidenced and justified”. This has not been satisfied, and the proposal on the Green Belt is thus in violation of core NPPF requirements. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.

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

Person ID 1218710 Full Name Lana Chahil ID 6786 Order 233 Number 11.1 Title Building-Infrastructure Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as

26 precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Local traffic and rail infrastructure is already heavily congestedand at capacity. The impact on traffic if Beaconsfield green belt is released for development would be untenable. not believe this policy to be Neither do we have enough local supermarkets for a rise in residents nor land to build more supermarkets and shops which would lead to too much disruption and again positively prepared please impact the local infrastructure. Increased supermarkets and services would again lead to increased traffic from delivery vehicles. explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as

27 possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

Person ID 1218377 Full Name Pamela Jones ID 6772 Order 233 Number 11.1 Title Building-Infrastructure Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible.

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

29 participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Our town does not have the local services ie schools, infrastructure, health care, police to cope with Chesham as it stands. We are residents on Chartridge Lane which badly not believe this policy to be needs a new road surface, properly executed, and not piece-meal as seems to be the current plan. positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

Person ID 1219926 Full Name Pooneh Roney ID 6769 Order 233 Number 11.1 Title Building-Infrastructure Organisation Details Consultee Type - Please select the type of consultee:

30 Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence

31 Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do There is no local A & E dept. at Wycombe Hospital. GPs’ surgeries and hospitals are under severe stress. Schools are at capacity. not believe this policy to be This level of development that the local plan proposed for Beaconsfield is completely positively prepared please explain why unsustainable given how the current resources are stretched: o Poor access to doctor’s appointments (it take over a week to get a blood test and 2 weeks or more to see our GP). o The roads are gridlocked at lunchtime and morning and evening rush hour. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.

32 Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

Person ID 1222309 Full Name Gemma Thomson ID 3683 Order 233 Number 11.1 Title Building-Infrastructure Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be

33 as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Broadly the language used is acceptable. not believe this policy to be positively prepared please explain why

34 PP Mods - Please specify as Commitments around green and communal space should be sought as part of the developers contribution. This should include (in the case of housing development) provision precisely and succinctly as for healthy spaces/ gyms etc. possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not No comment believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not No comment believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not No comment believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

Person ID 1213657 Full Name Mr Bill Richards ID 6075 Order 233 Number 11.1 Title Building-Infrastructure Organisation Details Clerk Chesham Town Council Consultee Type - Please Parish Council select the type of consultee: Date Received - Date 2016-04-06 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details

35 Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is

36 incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Plan to provide capacity for the whole of the duration of the Local plan. The Draft IDP says that Chesham STW may need improvements to cope with the strategic allocation not believe this policy to be for Chesham, but is not definitive about this. It should also be borne in mind that Chesham TW does not just deal with wastewater from Chesham, but from a broader positively prepared please catchment including the villages of Bellingdon, Botley,Buckland Common,Chartridge,Chesham Bois, Cholesbury and Flaunden. What plans are in place to cope with increased explain why housing at these sites? We are also concerned that there is no reference to wastewater in policy BPSP2 dealing with the site at the North-East of Chesham, whereas flooding, air quality, roads and health provision have been included. The Town Council notes the potential funding gap estimated to be between £179-£231m for infrastructure delivery and questions how this gap will be reaches. Part of evidence base, the interim Draft Infrastructure delivery Schedule (IDIDS) of November 2017is out of date and fundamentally flawed. As a 'living document' it should be continually reviewed and updated and we feel that the following amendments need to be made: - secondary education: expansion of Chiltern Hills Academy : a recent planning application was submitted to Bucks County Council's planning team detailing an ambitious expansion and improvement project. The cost and timescale details are therefore available for inclusion in the Interim Draft IDS. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to

37 improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

Person ID 1213773 Full Name Mr Byron Thorne ID 5811 Order 233 Number 11.1 Title Building-Infrastructure Organisation Details Owner The Park Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-04-18 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID 1210943 Full Name Mr Bob Newell Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness?

38 Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do For the reasons herein, we believe that the Plan is not positively prepared, not justified, not effective, and is not consistent with National Policy, namely the NPPF. not believe this policy to be The plan is insufficiently informed by agreements with other authorities so that unmet need from neighbouring areas is accommodated where it is practical to do so and is positively prepared please consistent with achieving sustainable development. Specifically, it should have accommodated the unmet needs of Slough - a large town directly on the border of the plan explain why area, which has issues of capacity which it cannot meet. The plan does not accommodate in any way the housing need from Slough, despite Slough’s request for it to do so. The Councils simply will not engage with Slough Borough Council. The plan is not based upon joint working on a critical cross-boundary strategic matter. The development needs of Slough is a cross-boundary strategic matter and a request from Slough Borough Council to assist with meeting this need has been rejected by the Councils. A joint Growth Study has recently been commenced but this is not taken account of in the Publication Plan. It defers the housing needs of Slough and the associated Green Belt implications. The approach of the Councils has been to assume the export of unmet need to Aylesbury Vale despite agreeing that the need would only be exported if it were impossible to find within the plan area. This is very simply not viable means of preparing a Plan.

39 The plan is not sufficiently informed by agreements with other authorities so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development. Specifically, it should have accommodated the unmet needs of Slough - a large town directly on the border of the plan area. The plan should have reviewed Green Belt to consider the longer term requirements of Slough rather than defer this decision to a future plan. The plan does not provide a strategy which meets area’s objectively assessed needs due to errors in its calculation of housing land supply. There are whole population centres within the District, for example in which the subject Great Kingshill Farm is sited, which don't have a viable means of growth. PP Mods - Please specify as We represent a property known as Great Kingshill Farm, which is in the Green Belt, and which we believe exemplifies the Council's lack of consideration to the proper location precisely and succinctly as of Housing development, and its lack of engagement with other parties to the Local Plan process. It needs to be included in Local Plan Section 11 - Building Places. The Plan possible how you would does not even currently have a positive proposal for additional Housing in this area of the District. modify this policy to The Plan is fundamentally unsound, and needs to be positively prepared, properly justified, effective, and consistent with National Policy, namely the NPPF. We explain what improve its alignment to is required in the next sections, by reference to the issues which we have identified. this test of soundness. Parts of the Plan and the evidence base require rewriting, particularly the Part 2 Green Belt Assessment, Options Appraisal and Exceptional Circumstances Report. Policy 1 - If you do not The Councils' approach is to assume the export of unmet need to Aylesbury Vale despite agreeing that the need would only be exported if it were impossible to find within believe this policy to be the plan area. This is not a viable means of Plan preparation. justified please explain why The plan does not accommodate any housing need from Slough, despite Slough’s request for it to do so. The plan fails to demonstrate that the development sites, and thus the overall spatial strategy, have been selected for inclusion in the plan on a robust, consistent and objective basis. Potential sites have been rejected and sites have been selected without adequate evidence and reasoning. The influence of the town of Slough, adjoining the southern border of the plan area, has insufficiently influenced the spatial strategy. In particular, sustainable settlements close to Slough are not given sufficient consideration for growth, based on this proximity. The influence of the transport nodes into London has insufficiently influenced the spatial strategy. In particular, the new Elizabeth Line into London is not given sufficient recognition in terms of opportunities for growth. Policy 2a - Please specify as Parts of the Plan and the evidence base require rewriting, particularly the Part 2 Green Belt Assessment, Options Appraisal and Exceptional Circumstances Report. precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not The plan simply isn't based upon adequate joint working on a critical cross-boundary strategic matter. The development need of Slough is a cross-boundary strategic matter believe this policy to be and a request from Slough Borough Council to assist with meeting this need has been rejected. A joint Growth Study has recently been commenced but this is not taken effective please explain account of in the Publication Plan. It defers the housing needs of Slough and the associated Green Belt implications. why. PAa - Please specify as Parts of the Plan and the evidence base require rewriting, particularly the Part 2 Green Belt Assessment, Options Appraisal and Exceptional Circumstances Report. precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not The plan is inconsistent with National Policy, in that it conflicts with the NPPF, which represents National policy and advice that the Councils must have regard to when believe this policy in preparing their plan (Section 19(2) of the Planning and Compulsory Purchase Act 2004). The plan is inconsistent with the NPPF in the following regards: consistent with the · It fails to deliver sustainable development, which is the NPPF’s core concept and is set out in Paragraphs 7 and 8 of the NPPF, particularly in terms of providing sufficient National Planning Policy numbers of homes and sufficient land of the right type and in the right place. Framework Feb 2019 please explain why · It fails to meet NPPF paragraphs 136-138 that alteration of Green Belt boundaries are not fully evidenced and justified (having regard to their intended permanence in the long term so they can endure beyond the plan period) and in terms of promoting sustainable patterns of development. Policy 3a - Please specify as Parts of the Plan and the evidence base require rewriting, particularly the Part 2 Green Belt Assessment, Options Appraisal and Exceptional Circumstances Report. precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5490279 Please attach any supporting evidence

Person ID 1214236 Full Name Mr Richard Brock ID 6123 Order 233 Number 11.1 Title Building-Infrastructure Organisation Details Consultee Type - Please Individual/Resident select the type of consultee:

40 Date Received - Date 2016-11-21 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence

41 Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The low priority given to infrastructure given that Chesham can expect a huge number of new dwellings and probably a 20% growth in population. No real details are shown not believe this policy to be relating to increasing the number of doctor and dental surgeries and school places. Water supplies, sewage capacity and roads are also dealt with only fleetingly. positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy

42 Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

Person ID 1215325 Full Name Mr Anthony King ID 6002 Order 233 Number 11.1 Title Building-Infrastructure Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-12-12 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible.

43 Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as

44 possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not Infrastructure in the area is already stretched to breaking point.Over 700 dwellings were allocated to CSP under the Core Strategy, which was meant to run until 2021. These believe this policy in have already been built or have planning permission and the strain is already being felt. Road conditions and upkeep have already deteriorated, parking availability has consistent with the reduced and with people now parking more frequently, dangerously and in greater numbers on main roads, driving and pedestrian safety is compromised. Further development National Planning Policy is unfair and unsustainable. Framework Feb 2019 What about access to hospitals, doctors ( access to which is already a challenge with current numbers ), adequate bus services or trains ? Both sites fail regarding specified please explain why sustainable distances. Policy SP SP1 states ‘Development of all sizes and uses must accommodate walking and cycling as a primary means of transport to serve the development’. The identified sites are at the peak of the adjacent very steep hill making access to and from amenities on foot or cycle extremely difficult. They are outside the village centre, which is in a valley. Consequently it is untrue when the the local plan says that the two Chafont St Peter (CSP) sites are in ‘a highly sustainable location’; The reality is that the local plan fails to comply with paragraph 84 of the National Planning Policy Framework (NPPF), which emphasises the need to promote a sustainable pattern of development. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

Person ID 1213372 Full Name Mr Peter Keane ID 5679 Order 233 Number 11.1 Title Building-Infrastructure Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-03-14 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID

45 Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any

46 non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not The proposals to release Green Belt land to meet housing targets (Generally, Spatial Policy SP SP1 & specifically Policy SP BP2 at Lye Green NE of Chesham) are not justified believe this policy to be from the evidence submitted by the Councils. justified please explain why The development of such Green Belt sites involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient and unfunded. In Chesham, the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham cannot accommodate any significant highways improvements anyway due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion, with further worsening air quality. Air pollution is a particular concern in Chesham due to the already poor air quality along Bekhampstead Road where there is a designated Air Quality Management Area (since 2007) that already is recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will generate more traffic will make the air quality even worse and insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable nor justified nor is it in accordance with Government policy. The supporting Sustainability Appraisal (SA), states there are no Air Quality issues near the site, but this is factually incorrect as the Chesham AQMA is just 1Km from the southern boundary of the site Water Pollution. The site has the potential to pollute the chalk streams that provide Chesham's water, as noted in the SA, the policy on mitigation, is inadequate. There is also an inadequate policy to mitigate the effects on the Chesham Water Treatment works, which is struggling to meet current demand for Chesham. It is admitted in the SA that the Chalk streams in the Chilterns, and in particular Chesham are in Crisis, through climate change and over extraction by Affinity Water, but the plan provides no mitigation strategies. The site also has flooding issues, and again the plan provide no mitigation strategies. Therefore the plan is unsound with these major issues still outstanding. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.

47 Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

Person ID 1214012 Full Name Mr Stewart Pomeroy ID 6216 Order 233 Number 11.1 Title Building-Infrastructure Organisation Details Managing Agent Colne Valley Park CIC Consultee Type - Please Local Interest Group/Amenity Society select the type of consultee: Date Received - Date 2016-07-01 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally

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

49 positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as This policy must include specific reference to Green Infrastructure. This is to ensure compliance with NPPF para 138: “ Where it has been concluded that it is necessary to precisely and succinctly as release Green Belt land for development, plans should… also set out ways in which the impact of removing land from the Green Belt can be offset through compensatory possible how you would improvements to the environmental quality and accessibility of remaining Green Belt land”. modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

Person ID 1214522 Full Name Mr David Meacock ID 6079 Order 233 Number 11.1 Title Building-Infrastructure Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date 2016-12-12 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name

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

51 incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The local infrastructure was already creaking at the seams prior to the recent hundreds of additional dwellings currently being constructed at the Holy Cross Convent and not believe this policy to be Newland Park sites. The potholed crumbling unclassified roads are now regularly clogged up, we have had raw sewerage in the main Chalfont St Peter High Street following positively prepared please heavy rainfall, we already have to fight for an appointment with a GP and parking at local hospitals is over capacity. Local schools’ pupil numbers have already expanded so explain why much that the sites have become concrete jungles, losing much of their break/lunch time run-around play areas – no wonder we’re facing an obesity crisis in the young. As this is the situation before these two sites have been fully completed and occupied, any further dwellings such as on the proposed Greenbelt sites would be the final ruination of Chalfont St Peter as I have known it for the past 50 years, since my early childhood. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.

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

Person ID 1222837 Full Name Gary Heneage ID 4335 Order 233 Number 11.1 Title Building-Infrastructure Organisation Details Chief Finance Officer Clinical Commissioning Group (CCG) Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or

53 regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Primary Health Care Facilities not believe this policy to be NHS England’s Five Year Forward View illustrates the changing role of general practice and the drive towards integrated health hubs, utilising technology and working ‘at positively prepared please scale’ to accommodate these transformations in the delivery of primary health care. Larger practices allow for a greater range of services to be delivered under one roof. For explain why example, ‘at scale’ provision allows flexibility for providers to consider accommodating social care services, minor-injury centres and social prescribing facilities. It also supports longer GP surgery opening hours. Primary health care delivered in this way has a knock-on reduction in hospital admissions (which cost significantly more than primary health services), saving the NHS considerable sums of money (making the already tight NHS budget go further in delivering patient care). The NHS Long Term Plan is places a similar emphasis on supporting fewer, larger primary care services that can improve the offer to patients. Dispersed, smaller, ‘single-use’ GP surgeries, cannot offer such improved services to patients. The CCG there has committed to the following principles: - The CCG will strive to develop modern, fit for purpose services that are accessible to local populations. - To ensure that practices remain resilient and sustainable, CCGs will no longer support the establishment of new single-handed GP practices and would only wish to fund new practices that can cater for at least 10,000 population (5 GPs). - Wherever possible, CCGs will promote the consolidation of services onto fewer sites to maximise the use of existing infrastructure and to promote joint working.

54 - The CCG will increasingly commission services that can be delivered in primary care that have traditionally been delivered in secondary care, thus promoting care closer to home. CCGs are exploring the development of out of hospital services provided in a community hub-type setting. - Development plans need to be in line with the BOB ICS Primary Care Strategy (currently in draft). Support paragraphs 11.1.1 - 11.5.1, however, the list of Health Section 106 sites as shown on pages 9 to 17 of the Infrastructure Development Plan appear to relate to only funding business cases. They include: • Beaconsfield Developer contributions to relate to Practice / CCG Business Case. • Amersham Developer contributions to relate to practice / CCG business case (£100k) • Little Chalfont Developer contributions to relate to practice / CCG business case (£TBA) • Chesham (Chess Medical Centre and Lion Street Surgery) – extension and modification of Surgeries - Developer contributions to relate to practice / CCG business case (£500k) • New healthcare facilities on National Epilepsy Centre (BP SP 7) or contribution so that provision of services can be catered for elsewhere – see below. Developer contributions to relate to practice / CCG business case (£TBA) • Expansion / modification of existing primary care services in Chalfont St Peter and depending on the scale of development in Chalfont St Peter and Gerrards Cross this may require the expansion of the Calcott Medical Centre or relocation to the Gerrards Cross Memorial Hospital site. Developer contributions to relate to practice / CCG business case (£TBA). • Additional primary care facilities in the Iver area. Appropriate financial contribution from new development needed. Developer contributions to relate to practice / CCG business case (£TBA) • Provision relating to the site allocation at Holmer Green – appropriate financial contribution from new development needed. Developer contributions to relate to practice / CCG business case (£TBA) • Burnham Health Centre – extension and additional parking spaces (no mention under comments re Developer contributions to relate to practice / CCG business case) as capital funding expected from NHS England. • The Chalfont St Giles Surgery – extension (no mention of anything, just this surgery name) • Threeways Surgery Stoke Poges – modification of existing premises (appropriate financial contribution from new development needed, CCG not requesting funding for whole cost). Funding gap identified as £50k. We would like to recommend that the wording in these sections of the IDP is changed to reflect the discussions held between CCG and District Council Planners on these matters. In some cases e.g. Threeways Surgery and Beaconsfield, the CCG has been fortunate in securing a capital allocation from NHS England to help fund these two projects however that does not mean that public funding should meet these costs if developer contributions are available. Where we are yet to identify the true cost of additional infrastructure to meet demand, we explained to our Planning colleagues that costed information would only be available once the business case had been completed. Can we therefore suggest that within the “funding source” column of the IDP schedule that the following statement is used “level of developer contributions to be established once practice/CCG business case completed”. Section 11.1.6 states that Developer Contributions for certain sites are excluded from CIL (i.e. only recourse to Health infrastructure contributions is via Section 106 Agreements). These sites are: - More than 10 Ha in area - Sites of more than 400 homes - Sites of more than 10,000 m2 in floor area. The document (under Section 11.2 – Site Allocations) goes onto describe the following sites: 1. NE of Chesham – 500 homes 2. Holmer Green – 300 homes 3. Amersham Old Town (London Road West) – 40 homes 4. Amersham Old Town (Whieldon Street) – 50 homes 5. Little Chalfont – 700 homes 6. Chalfont St Peter – NE – 360 homes (40 % care/retirement homes) 7. Chalfont St Peter – SE – 200 homes 8. Beaconsfield – 1600 homes (on page 180 it mentions that financial contributions for primary health care facilities within the local area as agreed with the Clinical Commissioning Group) 9. Land west of Iver Heath – 360 homes Land to the north of Iver Station - mixed use development to include approximately 1,000 homes 11. Land to the east of Ridgeway Business Park, north of Iver railway station - mixed use development to include approximately 90 homes In our opinion, the problems with the above are: a. The low threshold of CIL not applying (i.e. only for 400 residential units or less) and by default S106 being the method of developer contribution above that threshold, coupled with the current inability to pool more than 5 no. Section 106 contributions means that it will be very difficult for the CCG to pool enough Section 106 contributions together to make a difference to any particular GP surgery in terms of a meaningful extension. b. Even when the cap on pooling Section 106 Contributions is lifted (understood to be September 2019), it will still be problematic to obtain enough developer contributions within a “local” area to satisfy the 3 tests for developer contributions funded by S106 Contributions (be necessary to make the development acceptable in planning terms, directly related to the development and fairly and reasonably relate in scale and kind to the development) and to fund new Primary Care facilities through these contributions. Please note that BCCG wish to agree with you the adoption of the “West Kent Model” for developer contributions or primary care health infrastructure, which would result in funding of £360 per person in each of the new developments that are described in the Site Allocations. Conservatively (on the assumption of 2.4 persons per home), this would reasonably require £4.415M of contributions, which would mainly be via Section 106 Contributions (as the majority of houses allocated are in sites of more than 400 homes) and the minority via CIL contributions. c. CIL is more flexible and provided the threshold for CIL can be increased to a minimum of say 700 homes, then all bar one of the allocations described above could potentially contribute CIL monies to the Councils who, provided there was a policy in place to do so, could pass on some of that CIL to the CCG for health infrastructure spend (so far I can’t see anything from the Councils on such a policy or draft policy in their documentation). Thus far, we cannot see anything from you in respect of any policy/draft policy that states that a percentage of CIL payments will be directed towards Health infrastructure, but we would want a contribution from Developers from CIL that would equate to the above-mentioned £360 per person for primary health care provision. We would also like to comment on two of the non-residential schemes.

55 1. Land to the north of Denham Round-about - 16,000m2 of office space, a hotel and ancillary uses; 2. Land adjacent to Taplow Station - 4,000m2 of office space. Office workers will require some primary care provision in the locality even if they live elsewhere and therefore developers should provide a proportionate contribution to health infrastructure. In the case of the latter scheme, developer contributions currently can only come from Section 106. We would contend that as office workers would utilise local GP surgeries, a Section 106 Agreement should address some health infrastructure nearby. By way of comparison, please see the link http://www.southoxon.gov.uk/sites/default/files/South%20Oxfordshire%20Infrastructure%20Delivery%20Plan-%2004%2001%2019%20-%20final%20for%20website.pdf to see examples of where a Council (in this case, South Oxfordshire District Council) has been helpful in terms of outlining Health Infrastructure funding. Please see particularly Chapter 4 (Infrastructure and Types and Assumptions) and the specific health infrastructure mentioned for: Berinsfield - £1.468 M for “new and expanded premises for a health centre” (1700 homes) Chalgrove Airport - £3 M S106 for “new GP surgery” (3000 homes) Culham Science Centre - £3.024 M S106 for “new GP surgery” (3,500 homes) Grenoble Road - £2.592 M S106 for “contribution towards GP provision” (3,000 homes) North of Bayswater Brook - £950k S106 for “contribution towards GP provision” (1,100 homes) Northfield, SE Oxford - £1.555 M S106 for “contribution towards GP provision” (1,800 homes) Wheatley Campus - £TBC for expansion/reconfiguration of Morland House Surgery, Wheatley PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

Person ID 1222838 Full Name Mr Malcolm Whittall ID 4258 Order 233 Number 11.1 Title Building-Infrastructure

56 Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as

57 precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Points raised in a recent consultation have not been properly considered or addressed. I cannot see a CDC response to the points raised. The whole process is therefore not believe this policy to be questionable suggesting it is in breach of the National Planning Practice Guidance paragraph 84. positively prepared please The local plan states that the 2 proposed sites in Chalfont St Peter are in a sustainable location. This is untrue. There are hills making walking and cycling difficult which goes explain why against policy SP SP1 which states ‘development of all sizes and uses must accommodate walking and cycling as a primary means of transport to serve the development’. Exception Circumstances for removal of land from Green Belt Status has not been shown. The National Planning Practice Guidance specifically relates to sustainable development in urban areas inside Green Belt. The two sites proposed in Chalfont St Peter are outside of the centre and at the edge of developments. This is not sustainable as there are no (or poor) train or bus services in the area. One bus every 2 hours from the village is not a bus service! Again no ‘Exceptional Circumstances” are not shown. The Green Belt Exception Circumstances Report created by Chiltern & South Bucks in May 2019 is poorly constructed. Green Belt alone, does not constrain possibilities of meeting housing needs in Chalfont St Peter. There are in existence brownfield and poorly used Green Belt sites that could meet the requirements. The guidance and emphasis shown in the National Planning Practice Guidance documentation seems to have either been ignored or not understood. ‘Sustainable’ patterns of development are required which is not proven in the plan. The loss of the national Paccar scout camp (1 of a handful in the country offering this experience to children from all over the world and from every background) is an unacceptable outcome of this plan not to mention the loss of community employment. The Arup assessment carried out in 2016 shows inconsistent and potentially biased scoring. Many areas scoring lower the 2 proposed sites but no justification has been given for not including them for consideration of removal from Green Belt. Over 700 new homes were allocated to Chalfont St Peter under the Core Strategy. These have either already been built or are in the planning process. More is unfair and unsustainable in a village this size. All 5 requirements for Green Belt are valid for these two sites: 1: to check unrestricted sprawl of large built up areas. 2: To prevent neighbouring towns merging. The Epilepsy Site joins with the Colne Valley Park with a wooded buffer with Newlands Park, Chalfont St Giles and Horn Hill. 3: To assist in safeguarding the countryside from encroachment. As above with joining a park and woodland and rural areas. There should have been a much higher score regarding this. 4: To preserve the setting and special character of historic towns. The awarded score of 0 is wrong. How is this possible with 4 listed buildings on the site? C&SB have ignored the 2014 Buckinghamshire and Milton Keynes Historic Towns Project (BMHT) and the 2011 Chalfont St Peter Buckinghamshire Historic Towns Assessment showing the important historical character of the ‘Chalfont Colony’ and states the site is of ‘high heritage value’. It also denotes that it achieves a high score on historical and commercial values and a medium score for aesthetic values. The BMHT gives the ‘Chalfont Colony’ a ‘high’ heritage value.

58 5: To assist in urban regeneration by enforcing the recycling of derelict and other urban land. No prioritised consideration has been given to other sites over Green Belt. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

Person ID 1215583 Full Name Mr Roger Smith ID 7001 Order 233 Number 11.1 Title Building-Infrastructure Organisation Details Director Chesham Renaissance Community Interest Company Consultee Type - Please Local Interest Group/Amenity Society select the type of consultee: Date Received - Date 2018-12-06 Received: Duty to Cooperate Body - Is No this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID 1211027

59 Full Name Mr Colin Wilson Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory

60 Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not The proposals to release Green Belt land to meet housing targets (Generally, Spatial Policy SP believe this policy to be SP1 & specifically Policy SP BP2 at Lye Green NE of Chesham) are not justified based on the evidence submitted by the Councils. justified please explain why The Councils have stated that release of some Green Belt is necessary as part of an overall three part strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. We question the soundness of such a general policy given that the council has repeatedly failed to demonstrate that it has sought to identify and rigorously assess the suitability of brownfield land opportunities, and the desirability of achieving higher densities of development on these sites, which are generally closer to the town centre and more consistent with the Councils’ strategic objectives. The development of Green Belt sites to the north of Chesham involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient, unfunded and not planned for completion before development of the sites. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity with air pollution already a significant issue. The Councils are aware that Air pollution is a particular concern in Chesham due to the already poor air quality along Berkhamsted Road. The designated Air Quality Management Area there is already recording air quality levels considerably worse than legal safe levels. The traffic associated with additional housing will further exacerbate this issue unless significant remodelling of local roads and transport infrastructure is carried out. Again, these changes need to be made in advance of any significant addition to housing and local populations. In particular, from the point of view of transportation and travel the Green Belt site NE of Chesham (SP BP 2) is not a sustainable location. It is over 2Km away from the train station and slightly further still from the town centre. The Councils declared intent to increase use of, for example, cycling or walking in order to reduce environmental impact are unrealistic given the steep hill that separates the planned development from the town centre’s shops, health services, schools, sites of employment and transportation links. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to

61 improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

Person ID 1223003 Full Name Sandy Saunders ID 4511 Order 233 Number 11.1 Title Building-Infrastructure Organisation Details Consultee Type - Please Local Authority select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - South Bucks Association of Local Councils Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally

62 compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do 2.INFRASTRUCTURE not believe this policy to be

63 positively prepared please Insufficient detail has been published on the action to be taken to improve the Infrastructure in this Southern region of Buckinghamshire, and no significant information explain why has been published on consultations with the Transport Minister on the possible need to introduce new entry or exit points, or traffic control actions on the two major Trunk roads/Motorways in the Region. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

Person ID 1223349 Full Name Chalfont St Peter Parish Council ID 6188 Order 233 Number 11.1 Title Building-Infrastructure Organisation Details Consultee Type - Please Parish Council select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Chalfont St Peter Parish Council Consultee is an agent on behalf of: Person ID 1223348 Full Name Maggie Baddeley

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

65 incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do 8.5 Policy BP SP1 should be removed, as it is not justified to include a CIL policy in the Local Plan when the Charging Schedule has not yet been examined or adopted. We not believe this policy to be have provided separate representations to the current CIL Draft Charging Schedule consultation. A key part of our representations is the lack of evidence to justify the arbitrary positively prepared please threshold of 400 units or 10 hectares for large sites, in order to apply a zero-rated CIL. We raise the same points in relation to Policy BP SP1 as in the CIL representations. explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

Person ID 1223534

66 Full Name David Skepper ID 5093 Order 233 Number 11.1 Title Building-Infrastructure Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to

67 strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not The proposals to release Green Belt land to meet housing targets (Generally, Spatial Policy SP SP1 and specifically Policy SP BP2 at Lye Green. The Councils have stated that believe this policy to be release of some Green Belt is necessary as part of an overall three part strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an justified please explain why exported proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. I question the soundness of such a general policy and whether all the brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites and in particular the Green Belt site NE of Chesham at Lye Green. The development of such Green Belt sites involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient and unfunded. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham cannot accommodate any significant highways improvements anyway due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion, with further worsening air quality.

68 Air pollution is a particular concern in Chesham due to the already poor air quality along Berkhampstead Road where there is a designated Air Quality Management Area that already is recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will generate more traffic will make the air quality even worse and insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable nor justified nor is it in accordance with Government policy. NE of Chesham) are not justified from the evidence submitted by the Councils. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not For this Plan to sound it must also be effective. Unfortunately, further review of the proposal to remove land NE of Chesham at Lye Green from Green Belt designation is not believe this policy to be effective as there are serious questions about the deliverability of this land. The main landowner is a farmer who has asserted publicly and in a letter to the editor of Your effective please explain Chesham, that he is not prepared to release all of the land in his ownership for development. why. The land is an Asset Of Community Value and upon confirmation of this designation it would afford a community group the right to bid for the land. The community group (Brown Not Green) have stated their intention is to preserve the land given that many hundreds of local people have habitually used the fields at Lye Green as of right for various informal outdoor recreational purposes. These uses themselves may mean that many local individuals may have acquired easements over and across the land through prescription (20 years uninterrupted use) not least of whom would be the many private residences bordering the fields that have rear garden gates onto the fields at Lye Green. These easements and prescriptive rights may render the land very difficult to develop and make it undeliverable in planning terms. I and my family have used this area for 25 years. As a father of an 18 month old, I believe that this area should continue to be available for future generations. This land also provides an important habitat for wildlife that will be threatened by development of this land. It is perverse that the Local Authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Plan is unsound. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

Person ID 1223596 Full Name Mrs Sarah Hannen ID 5753 Order 233 Number 11.1 Title Building-Infrastructure Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID

69 Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any

70 non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The proposals to release Green Belt land to meet housing targets (Generally, Spatial Policy SP SP1 & specifically Policy SP BP2 at Lye Green NE of Chesham) are not justified not believe this policy to be from the evidence submitted by the Councils. positively prepared please The Councils have stated that release of some Green Belt is necessary as part of an overall three part strategy involving (1) focus on built-up areas, to build dwellings on explain why previously developed land, (2) an exported proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. I question the soundness of such a general policy and whether all the brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites and in particular the Green Belt site NE of Chesham at Lye Green. The development of such Green Belt sites involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient and unfunded. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. This is clear to see during rush hours! Chesham cannot accommodate any significant highways improvements anyway due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion, with further worsening air quality. Air pollution is a particular concern in Chesham due to the already poor air quality along Berkhampstead Road where there is a designated Air Quality Management Area that already is recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will generate more traffic will make the air quality even worse and insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable nor justified nor is it in accordance with Government policy. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in

71 consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

Person ID 1223544 Full Name Mrs Tricia Wilson ID 5137 Order 233 Number 11.1 Title Building-Infrastructure Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be

72 as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why

73 PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not The proposals to release Green Belt land to meet housing targets (Generally, Spatial Policy SP SP1 & specifically Policy SP BP2 at Lye Green NE of Chesham) are not justified believe this policy to be based on the evidence submitted by the Councils. justified please explain why The Councils have stated that release of some Green Belt is necessary as part of an overall three part strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. We question the soundness of such a general policy given that the council has repeatedly failed to demonstrate that it has sought to identify and rigorously assess the suitability of brownfield land opportunities, and the desirability of achieving higher densities of development on these sites, which are generally closer to the town centre and more consistent with the Councils’ strategic objectives. The development of Green Belt sites to the north of Chesham involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient, unfunded and not planned for completion before development of the sites. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity with air pollution already a significant issue. The Councils are aware that Air pollution is a particular concern in Chesham due to the already poor air quality along Berkhamsted Road. The designated Air Quality Management Area there is already recording air quality levels considerably worse than legal safe levels. The traffic associated with additional housing will further exacerbate this issue unless significant remodelling of local roads and transport infrastructure is carried out. Again, these changes need to be made in advance of any significant addition to housing and local populations. In particular, from the point of view of transportation and travel the Green Belt site NE of Chesham (SP BP 2) is not a sustainable location. It is over 2Km away from the train station and slightly further still from the town centre. The Councils declared intent to increase use of, for example, cycling or walking in order to reduce environmental impact are unrealistic given the steep hill that separates the planned development from the town centre’s shops, health services, schools, sites of employment and transportation links. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

Person ID 1223550 Full Name Mr Naresh Mistry ID 5695 Order 233 Number 11.1 Title Building-Infrastructure Organisation Details Consultee Type - Please select the type of consultee:

74 Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence

75 Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not The proposals to release Green Belt land to meet housing targets (Generally, Spatial Policy SP SP1 & specifically Policy SP BP2 at Lye Green NE of Chesham) are not justified believe this policy to be from the evidence submitted by the Councils. justified please explain why The Councils have stated that release of some Green Belt is necessary as part of an overall three part strategy involving (1) focus on built-up areas, to build dwellings on previously developed land, (2) an exported proportion of housing need to go to the Aylesbury District and (3) through Green Belt releases where sustainable built area extensions can be achieved without unacceptably harming the purposes or integrity of the Green Belt. I question the soundness of such a general policy and whether all the brownfield land opportunities have been identified and/or whether the Council should be looking at higher densities of development on such sites which are generally closer to the town centre that are more sustainable locations than Green Belt sites and in particular the Green Belt site NE of Chesham at Lye Green. The development of such Green Belt sites involving many hundreds of homes will generate increased traffic, and although some highways improvements are suggested, they are insufficient and unfunded. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. Chesham cannot accommodate any significant highways improvements anyway due to the already limited verges and space beside the highway and combined with the topography of the town this means that there will be increased traffic congestion, with further worsening air quality. Air pollution is a particular concern in Chesham due to the already poor air quality along Berkhampstead Road where there is a designated Air Quality Management Area that already is recording air quality that is considerably worse than EU safe levels. Adding more homes outside the town on the Green Belt will generate more traffic will make the air quality even worse and insofar as this relates to the Green Belt site at Lye Green NE of Chesham, this cannot be sustainable nor justified nor is it in accordance with Government policy. For this Plan to sound it must also be effective. Unfortunately, further review of the proposal to remove land NE of Chesham at Lye Green from Green Belt designation is not effective as there are serious questions about the deliverability of this land. The main landowner is a farmer who has asserted publicly and in a letter to the editor of Your Chesham that he is not prepared to release all of the land in his ownership for development. The land is also potentially an Asset Of Community Value and upon confirmation of this designation it would afford a community group the right to bid for the land. The community group (Brown Not Green) have stated their intention is to preserve the land given that many hundreds of local people have habitually used the fields at Lye Green as of right for various informal outdoor recreational purposes. These uses themselves may mean that many local individuals may have acquired easements over and across the land through prescription (20 years uninterrupted use) not least of whom would be the many private residences bordering the fields that have rear garden gates onto the fields at Lye Green. These easements and prescriptive rights may render the land very difficult to develop and make it undeliverable in planning terms.

76 This land also provides an important habitat for wildlife that will be threatened by development of this land. It is perverse that the Local Authority would promote such a valued community asset for development and undermines the objectives of the Localism Act 2011. As such this aspect of the Plan is unsound. These comments apply equally to proposals affecting the villages in the Green Belt – policies SP PP1 & DM PP1) Another aim of Green Belt land stated in NPPF paragraph 134, is to prevent neighbouring towns and settlements from merging into one another. The Green Belt land NE of Chesham performs exceptionally well in maintaining a distinct separate between settlements of Chesham & Lye Green as well as helping to maintain separate identities of other nearby communities at Orchard Leigh, Botley, Whelpley Hill, Ashley Green. It is perverse and inconsistent with national guidance to allocate this land for removal from Green Belt in light of these facts especially when the land also represents good quality agricultural land and an environment for many species of wildlife that will be lost if earmarked for development. The Council have asserted that Government planning policy requires local councils to review Green Belt boundaries when considering how to accommodate the development needed in their areas. Just because the Council may be required to look, does not mean the Council should review Green Belt boundaries which as previously stated should only be modified in “exceptional circumstances”. National Planning Policy Framework (NPPF) as revised only last year, states in paragraph11 (b) I, directs “plan makers” to create policies that are required in Local Plans for housing and other uses unless Framework policies (expressly including Green Belt) “provides a strong reason for restricting the overall scale type or distribution of development in the plan area” Accordingly, I submit that given all of the above the land being proposed for release from Green Belt designation around Chesham is unjustified and contrary to national guidance. I am supportive of the Brown Not Green organisation’s initiative to have the land listed as an Asset of Community Value and I feel they speak for me in respect of their objections to the draft Local Plan. Accordingly, I request that any representations made by them at any future examination in public regarding the soundness of this Local Plan be considered as an extension of my own comments herein. I feel the land NE of Chesham is an unsustainable location for development, that has been habitually used by the community for improved health & wellbeing for decades and the land performs well against Green Belt aims and objectives. Exceptional circumstances for reviewing Green Belt boundaries at this location, either do not exist or are insufficient to warrant the removal of this land from Green Belt designation as required by Government Policy and therefore the plan is unsound. Policy 2a - Please specify as I refer to the comments previously submitted but in summary would advocate that; precisely and succinctly as All other options are fully explored including increased density of development of brownfield land and the policies emerging from Chesham Masterplan. possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not There is also a significant infrastructure funding gap acknowledged within the Community Infrastructure Levy evidence that supports this Local Plan, of between £179m & believe this policy in £231m. Given this infrastructure is vital to ensure that development is sustainable (as also required by the NPPF) this further demonstrates the Plan is both unsound and consistent with the not legally compliant. National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

Person ID 1224518 Full Name Geltex Properties Limited ID 6281 Order 233 Number 11.1 Title Building-Infrastructure Organisation Details Consultee Type - Please Other select the type of consultee: Date Received - Date Received:

77 Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Geltex Properties Limited Consultee is an agent on behalf of: Person ID 1210980 Full Name Mr Gary Thomas Organisation Details Director Planning Works Ltd Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence

78 Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not 2.82 The explanatory text to the Policy at paragraphs 11.1.5 and 11.1.6 sets the thresholds for believe this policy to be developments that are to be excluded from the CIL and in these circumstances says that they are effective please explain why. required to deliver infrastructure directly or make financial contributions towards mitigation. The threshold would apply to some but not all of the proposed allocations in the Plan. 2.83 However, to ensure that the Policy wording explicitly reflects that of the explanatory text and for clarity a further bullet point should be added listing those allocations that are specifically excluded from CIL, which would include the site at Chesham Policy SP BP2. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.

79 Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

Person ID 1224537 Full Name Holmer Green Village Society ID 6749 Order 233 Number 11.1 Title Building-Infrastructure Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID 1224536 Full Name David Holmes Organisation Details Associate Director Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its

80 legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do 3. Soundness not believe this policy to be

81 positively prepared please The Council’s emerging Local Plan is scant in its approach to infrastructure to support the growth of the District’s. This is off particular concern to the HGVS. Holmer Green explain why suffers from a deficient access to local services, most notably health and education facilities. The plan is not underpinned by an infrastructure delivery schedule, which should be developed to provide comfort that the growth of the District can be supported by the appropriate infrastructure. 4.2 The Council’s (only) policy in regard to infrastructure rests in BP SP1 – Building – Developer Contributions to Support Growth. It is considered that this policy is overly ambiguous insofar as its relationship with the specific requirements of Policy SP BP3. On first reading Site Allocation SP BP3 would be absolved from the requirements of CIL, due to the size of the site (17ha). However, in practice, the site is likely to come forward with smaller parcels of land, under the threshold, which realises a very significant risk that the infrastructure needs of Holmer Green will remain unmet. 4.3 Furthermore, it is a little unusual to see a policy restricting the ability to collect the levy on certain sites within a Local Plan, when such exclusions are dealt with in the Community Infrastructure Levy Draft Charging Schedule. The plan should identify the shortfall of infrastructure delivery in respect to Holmer Green and indeed the plan area and include provision to meet this shortfall PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

Person ID 1224559 Full Name Lousada Plc ID 6417 Order 233 Number 11.1 Title Building-Infrastructure Organisation Details Consultee Type - Please Other select the type of consultee: Date Received - Date Received:

82 Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Lousada Plc Consultee is an agent on behalf of: Person ID 1224558 Full Name Miss Leonie Stoate Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence

83 Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Policy BP SP1: Building – Developer Contributions to Support Growth not believe this policy to be The policy confirms that the Councils will only be seeking S106 contributions from sites which are over 10ha in size or 400 homes or greater and they will be exempt from positively prepared please CIL. This is presumably on the basis that the larger strategic sites will be able to provide some of the planning obligations requirements on site. explain why Therefore, smaller sites will potentially be subject to both CIL and S106 and there could be potential for double counting. The Community Infrastructure Levy Regulations 2019 come into force on 1 September 2019 which have removed the pooling limit of five developer contributions, but Authorities are required to publish Infrastructure funding statement to explain how the money has been raised and spent. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in

84 consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

Person ID 1224167 Full Name Mr Rob Smith ID 5942 Order 233 Number 11.1 Title Building-Infrastructure Organisation Details Director Growth, Strategy and Highways Buckinghamshire County Council Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be

85 as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do 11.2.1 not believe this policy to be Any developments proposed re site allocations must be assessed for their impact on the highway network. This would incorporate; but not limited to, assessment of access positively prepared please points to the network, junctions, traffic flows, proposed trip rates etc. explain why

86 PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

Person ID 1224500 Full Name Kebbell Homes ID 6530 Order 233 Number 11.1 Title Building-Infrastructure Organisation Details Consultee Type - Please Other select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Kebbell Homes Consultee is an agent on behalf of: Person ID 1211010 Full Name Mr Thomas Rumble Organisation Details Associate Woolf Bond Planning

87 Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is

88 incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not The Regulation 19 consultation is also supported by a draft CIL charging schedule. We repeat comments submitted in relation to the CIL consultation below: believe this policy to be We act for Kebbell Homes who control a proportion of the proposed strategic allocation at South East Chalfont St Peter in the Regulation 19 Local Plan under Policy SP BP8. justified please explain why The draft Charging Schedule and Policy BP SP1 explain that on sites of over 10ha in size applications will be CIL exempt and infrastructure contributions will be agreed through the S106 and S278 process. We would request that clarity is inserted into the charging schedule to specifically confirm that strategic sites (including the Policy SP BP8 allocation) are to be CIL exempt. We therefore request that the Charging Schedule and Policy BP SP1 are made clear in relation to this point prior to submission for examination. It is suggested that Policy BP SP1 is amended to clarify that applications on sites inside the allocations set out in Policy SP LP1 (Homes Site Allocations) are CIL exempt. Such an amendment is necessary in order to enable a justified and effective plan. Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to

89 improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

Person ID 1224560 Full Name Dylon 2 Limited ID 6416 Order 233 Number 11.1 Title Building-Infrastructure Organisation Details Consultee Type - Please Other select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Dylon 2 Limited Consultee is an agent on behalf of: Person ID 1224558 Full Name Miss Leonie Stoate Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is

90 not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do Policy BP SP1: Building – Developer Contributions to Support Growth not believe this policy to be The policy confirms that the Councils will only be seeking S106 contributions from sites which are over 10ha in size or 400 homes or greater and they will be exempt from positively prepared please CIL. This is presumably on the basis that the larger strategic sites will be able to provide some of the planning obligations requirements on site. explain why Therefore, smaller sites will potentially be subject to both CIL and S106 and there could be potential for double counting. The Community Infrastructure Levy Regulations 2019 come into force on 1 September 2019 which have removed the pooling limit of five developer contributions, but Authorities are required to publish Infrastructure funding statement to explain how the money has been raised and spent. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.

91 Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

Person ID 1225521 Full Name Anthony and Christina Meaden ID 6726 Order 233 Number 11.1 Title Building-Infrastructure Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is

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

93 precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do With the size of this development, we believe that Island Homes, with the density of development should be required to provide schools and a medical centre*. Our surgery not believe this policy to be (Millbarn) in the Old Town and The Simpson Centre in Gregories Road, Beaconsfield are already full, without any ability to expand. The three Primary Schools in Beaconsfield positively prepared please are bursting at the seams. The Beaconsfield High School and the Beaconsfield School are also fully subscribed and their coaches and parents/pupils cars already block explain why Wattleton Road, morning and evening. We understand that Island Homes are offering a token payment of £150,000 towards the cost of education and healthcare provision, but at present there appears to be nowhere on their site. Where they should be built, where they will actually be required. Presumably they are expecting them to be built elsewhere in Beaconsfield. Why? Where?” • Presumably their answer to the final question “Where do they think the Medical Centre should be built is between Wattleton Road and the A40. Wattleton Road is already jammed with cars, coaches from three schools, not forgetting traffic going to and from the Garden Centre. Kerbside patient parking is also proposed for part of two sides of Wattleton Road. (We have just today sent an Objection to this PL/19/1954/FA). Wilton Park would seem the correct place for the Medical Centre.. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

Person ID 1226454 Full Name G F Parr

94 ID 6998 Order 233 Number 11.1 Title Building-Infrastructure Organisation Details Consultee Type - Please Individual/Resident select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness?

95 Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The infrastructure of the proposed development at Lye Green could prove to be a disaster. not believe this policy to be a. The main approach from Chesham to the proposed development would be via White Hill and Eskdale Avenue, both very deep with dangerous bends. The proposed positively prepared please developments would attract at least 500 cars. explain why b. The adverse effect on air pollution in the town would be great c. The chaos caused to nearby schools e.g. Brushwood school by the arrival of so many school ages children PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be

96 effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

Person ID 1228031 Full Name Liz Pickering ID 7197 Order 233 Number 11.1 Title Building-Infrastructure Organisation Details Forward Planning Manager Department for Education Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant

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

98 examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do The Department for Education (DfE) welcomes the opportunity to contribute to the development of planning policy at the local level. not believe this policy to be 2. Under the provisions of the Education Act 2011 and the Academies Act 2010, all new state schools are now academies/free schools and DfE is the delivery body for many positively prepared please of these, rather than local education authorities. However, local education authorities still retain the statutory responsibility to ensure sufficient school places, including explain why those at sixth form, and have a key role in securing contributions from development to new education infrastructure. In this context, we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools. We have published guidance on education provision in garden communities and securing developer contributions for education, at https://www.gov.uk/government/publications/delivering-schools-to-supporthousing-growth. You will also be aware of the corresponding additions to Planning Practice Guidance on planning obligations, viability and safe and healthy communities. 3. We would like to offer the following comments in response to the above consultation document. Please consider these comments in conjunction with our response to the CIL Draft Charging Schedule.Soundness 4. As you will be aware, the primary focus at this stage of the Local Plan’s preparation is on the soundness of the plan, with regard to it being positively prepared, justified, effective and consistent with national policy. The following detailed comments set out DfE’s view of the plan’s soundness in respect of education provision. 5. DfE supports the Council’s allocation and safeguarding of land for schools in the relevant site allocation policies, and reference to financial contributions where no onsite schools are required. However, there appears to be some disparity between the emerging Local Plan and CIL charging schedule. The site allocation policies imply that financial contributions will be sought specifically for education, which would be achieved by planning obligations, even though some of the sites fall below the 400 dwelling threshold that is being proposed for CIL. We recommend that this is clarified to explain that planning obligations will be sought for these developments, notwithstanding the provisions of the CIL Charging Schedule. The revised CIL Regulations coming into force on 1st September will allow both CIL and Section 106 funding to be used to fund the same type or item of infrastructure, without any restriction on the number of planning obligations that can be pooled. While DfE supports the use of planning obligations wherever justified in accordance with Regulation 122 of the CIL Regulations, clarifying the relationship between CIL and Section 106 in the site allocation policies or supporting text would help to demonstrate that the Local Plan is consistent with national policy and effective in delivering the proposed growth over the plan period. 6. No consideration appears to have been given to the potential long-term need to expand schools proposed on the allocation sites, particularly in view of their relatively small size when only one form of entry is being proposed. At this stage in the Local Plan’s preparation it may be too late to safeguard additional land for education as a specific policy requirement, but in the interests of demonstrating positive preparation of the plan, we recommend an addition to the supporting text which refers to open space being designated adjacent to school sites to allow for future expansion if required. This would then be explored in more detail through the masterplanning process, and would be consistent with Planning Practice Guidance on healthy and safe communities. 7. Planning Practice Guidance advises local authorities to plan for all phases and types of education, including special educational needs, but the Local Plan makes no provision for special educational needs despite the IDP stating that special schools are close to capacity (paragraph 79). We understand there is a review in progress, and recommend minor amendments before or during the examination to ensure that developer contributions are secured where appropriate, in response to an up-to-date IDP. This would help to demonstrate that the plan has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements, and that the approach to the planning and delivery of education infrastructure is justified based on proportionate evidence. Developer Contributions and CIL 8. DfE welcomes the approach taken in the viability assessment underpinning both the CIL charging schedule and the Local Plan, giving proper consideration to the costs of education provision and making reference to the DfE guidance on securing developer contributions and local evidence of pupil yields and the costs of provision. We support the interrelationship between the IDP and the viability assessment, so that site-specific project costs are incorporated into the viability assessment when onsite schools are known to be required. 9. We note that the proposed site allocations (with specific education requirements) only account for 5,200 homes out of a supply of 11,099. It may be expected that a significant part of this remaining housing requirement will come forward in the form of small developments (below the 400 dwelling threshold for CIL) as windfalls or sites from the HELAA. It is important to consider the size of the CIL funding gap and whether there will be sufficient CIL funds available to cover the cost of the school places required a result of these smaller developments. If CIL will be insufficient or unavailable at the point of need, it would be preferable to seek developer contributions through a planning obligation, to mitigate the direct impacts of development. Government basic need grant for the creation of new school places does not include funding for land acquisition, so it is particularly important that pooled developer contributions (Section 106 and/or CIL) are secured for the purchase of standalone sites for new schools or school expansions when required, provided such planning obligations would comply with the Regulation 122 tests. We request that you consider carefully the appropriate balance of CIL and Section 106 funding for education, to ensure that new schools and school expansions can be delivered when they are needed, in step with housing development. 10. While DfE supports Policy BP SP1 (developer contributions to support growth), we request a minor amendment either to the policy or its supporting text, to clarify that developer contributions may be secured retrospectively, when it has been necessary to forward fund infrastructure projects in advance of anticipated housing growth. An example of this would be the local authority’s expansion of a secondary school to ensure that places are available in time to support development coming forward. This minor amendment would help to demonstrate that the plan is positively prepared and deliverable over its period. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness.

99 Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - 5498620 Please attach any supporting evidence

100 Consultation Point: Connected - Area of Change

Person ID 1219453 Full Name Anne Hayton ID 1116 Order 156 Number 7.6 Title Connected - Area of Change Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why

101 Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

Person ID 1211260 Full Name Mrs Sue Moffat ID 6364 Order 156 Number 7.6 Title Connected - Area of Change Organisation Details Town Clerk Gerrards Cross Town Council Consultee Type - Please select the type of consultee: Parish Council Date Received - Date Received: 2016-02-09 Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? No Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why DM CP6 – Area of Change Gerrards Cross Gyratory System is not defined. What is this and why is it needed? Why is the Sustrans GX and Chalfonts Station Travel plan not included? This has been produced for increasing cycle and pedestrian access for Gerrards Cross Railway Station, thereby reducing the dependence on private cars, but it has been completely ignored.

102 PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

Person ID 1215481 Full Name Joanna Cox ID 3138 Order 156 Number 7.6 Title Connected - Area of Change Organisation Details Crime Prevention Design Advisor South East Regional Organised Crime Unit Consultee Type - Please select the type of consultee: Services/Infrastructure Date Received - Date Received: 2017-12-04 Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Yes Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public?

103 Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Section 7.9.2 Framework Feb 2019 please explain why The fear of crime and anti-social behaviour could have a detrimental impact on the up take of those willing to cycle instead of using a vehicle especially when the storage and security of cycles in some large developments is often outside of the users control. Guidance is available regarding appropriate security standards for safe storage in terms of physical security and the location of cycle parking can also have a significant impact on security. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this I would ask that the following additional wording policy to improve its alignment to this test of soundness. is provided Where ever possible, cycle parking should be provided within a secure store that meets the police recommended security standards. Where it is not possible to provide residents or employees with a secure store it should be located away from areas of public access and where possible within view of the user. Also refer to the policies in the Designing Places section. Policy-level file upload - Please attach any supporting evidence

Person ID 1220364 Full Name David Frith ID 1584 Order 156 Number 7.6 Title Connected - Area of Change Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness?

104 Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why A rare beacon of light in the plan in encouraging a public transit interchange at Chesham Tube Station. How does that square though with putting new retail development here without extra car parking space to serve the additional demand? This plan is contradicting self in different places. The current car park is already full many days. Going further, what has the plan done to address the question of frequency and capacity of the tube service itself? This appears to be a glaring omission for a long term plan such as this. PP Mods - Please specify as precisely and succinctly as possible how you would modify this Cycle routes and parking, while stated as policy is policy to improve its alignment to this test of soundness. often implemented badly and frequently underused and a waste of resources - how many offices do you see with empty bike sheds, required to be provided by planning. People will get to work as it suits them best ... and Chesham is a poor area for the incorporation of good quality, safe, cycle routes. Another aspiration that is effectively doomed to failure without more work to properly implement where it can actually work. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

Person ID 1220710 Full Name Lyndsey Oliver ID 2124 Order 156 Number 7.6 Title Connected - Area of Change Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body?

105 Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why consider parents with children. how realistic is it that they will be able to walk/cycle to do the school drop offs and get to work before 9am? When considering transportation the school run has a massive impact on how people move. Also, when cosnidering environmental impact it does not make sense that the government is expanding the M4 (smart motorway) and Heathrow. This does not impact the majority of people living in these spaces. how many people are employed within cycling distance to their jobs? How many offices are set up for cyclists? How many have facilities for people cycling? How many roads have safe cycle routes? How many villages have schol trasnport links? PP Mods - Please specify as precisely and succinctly as possible how you would modify this Look at transport and living in terms of user cases. policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

Person ID 1221260

106 Full Name Celia Jones ID 2849 Order 156 Number 7.6 Title Connected - Area of Change Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why We object to the one-way systems proposed for Amersham and Gerrard’s Cross. For bus passengers at these important destinations, creating a one-way system will be confusing as the return stop cannot be opposite the arrival stop. The walk distance either to or from the destination is likely to be longer and is therefore a disadvantage for bus passengers. Policy DM DP11 requires that new streets should be designed according to Manual for Streets – which states: 4.2.8 To create a permeable network, it is generally recommended that streets with one-way operation are avoided. They require

107 additional signing and result in longer vehicular journeys. There is not a compelling reason for departing from the MfS guidance, therefore we consider it should be followed in these cases and the existing two-way layout should be maintained. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

Person ID 1213063 Full Name Mrs Merrin Molesworth ID 5741 Order 156 Number 7.6 Title Connected - Area of Change Organisation Details Planning Field Officer Chiltern Society Consultee Type - Please select the type of consultee: Local Interest Group/Amenity Society Date Received - Date Received: 2016-03-14 Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? No Agent on behalf of - Consultee is an agent on behalf of: Chiltern Society Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A

108 of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why Any development of Green Belt will generate increased traffic, and only insufficient and unfunded highways improvements are suggested in the Plan. In Chesham the evidence shows that most of the road junctions and infrastructure is already operating above capacity. However Chesham cannot accommodate any significant highways improvements due to the already constrained verges and lack of space beside the highway. The topography of the town in the valley cannot take any more traffic congestion. Chesham already suffers from poor air quality along Berkhampstead Road (A416) where the designated Air Quality Management Area is recording air quality below EU safe levels. Adding more homes up a steep hill outside the town on the Green Belt will generate more traffic and make the air quality in the valley even worse. Policy DM CP6 Connected-Areas of Change. I welcome Chesham Town Centre Transport Interchange and the creation of a public, cycle and pedestrian transit interchange at Chesham Station with improved facilities and connectivity to the High Street. However how is this compatible with the proposal to build shops over the car parks? In the HEELA specific sites – they want to change designation of parking in Star Yard and Station/Waitrose car parks to retail. Ashridge Road is still classed as employment even though permission has been granted for some 42 houses there. We want people in the town centre, not more shops, many of the current shops are empty. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

Person ID 1223031 Full Name Curson Rochford LLP ID 5788 Order 156 Number 7.6 Title Connected - Area of Change Organisation Details Consultee Type - Please select the type of consultee: Other

109 Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Curson Rochford LLP Person ID 1223018 Full Name Lois Partridge (Sworders) Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why Connected Places Paragraph 7.6.2, supporting text to Policy DM C6, states that: ‘During the Plan period, it is anticipated that proposed major developments will occur which may impact on a future update to this Plan. The new strategic plan for the whole of Buckinghamshire, to be prepared by the new unitary authority, is the appropriate mechanism in which to consider the following: • Heathrow Airport Runway 3 • Western Rail Link - Heathrow • Oxford - Cambridge Arc’ These schemes are well advanced and are likely to be implemented early in the Plan period. A development consent order application for the western rail link is due to be submitted to the Planning Inspectorate in 2019. The rail link, when approved, will provide services which link the main western line with the airport, stopping at Slough and Iver. This will lead to pressure for new homes and new jobs in Slough Borough and South Bucks district. Similarly, there will be significant development pressure associated with the expansion of Heathrow Airport. Plans for Heathrow Airport Runway 3 were approved by Parliament in 2018 and a consultation is currently underway on the plans, prior to the

110 planned submission of a development consent order application to the Planning Inspectorate. These are plans which have progressed significantly in recent years and which are well understood. To defer consideration of their impact on South Bucks District to a future plan seems at best naïve. The Plan should be proactively planning to meet future needs for housing and economic development, and the sensible location for this development is in the part of South Bucks where greatest development pressure is likely to be felt, adjacent to Slough. This approach is not sound. It is not effective because strategic cross boundary matters have again been deferred rather than dealt with. In order to be sound, paragraph 7.6.2 should be amended to add text to reflect the fact that this Plan acknowledges the proposed major developments, and plans proactively for them. ‘During the Plan period, it is anticipated that proposed major developments will occur which may impact on this Plan. This Plan recognises that these projects are well underway, and plans proactively for them, allocating land for development to meet the needs generated by the projects, and to afford new residents access to the new infrastructure. • Heathrow Airport Runway 3 • Western Rail Link - Heathrow • Oxford - Cambridge Arc’ PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

Person ID 1222961 Full Name Dr James Conboy ID 4473 Order 156 Number 7.6 Title Connected - Area of Change Organisation Details The Chesham Society Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant.

111 Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why 7 Connected Places Traffic congestion appears to be considered only in the context of air quality. While this is a serious concern, there is also the obvious impact on new and existing residents, who waste their time in traffic jams, and are unable to plan their journeys. This is a particular concern for Chesham, where the A416 has been designated a Priority Congestion Management Corridor (between Moor Road and The Vale). Addressing existing traffic congestion is listed as a strategic objective (3.5.5). Policy DM DP9 aims to "accommodate walking and cycling as a primary means of transport to serve the development.", and DM CP6 supports "Creation of a public, cycle and pedestrian transit interchange at Chesham Station with improved facilities and connectivity to the High Street." Large new developments are required to produce a travel plan (Policy DM CP1 & Appx CP2), which includes an assessment of air quality (9.10.4). These policies relate to new developments, and so are unlikely to address the problem of existing traffic congestion. The Strategic Assessment lists air quality as a residual negative impact (SA table N4, pxxxiii): Local Air quality The Local Plan is anticipated to lead to a reduction in local air quality with implications for human health. Development proposed in the Local Plan would place a large number of new residents in locations within 200m of busy or major roads and increase traffic volumes, contributing to decrease in air quality. Any policy which contributes to a decline in air quality is likely to be inconsistent with national policy, and the resulting plan will be unsound.

112 The impact of increased traffic volumes on the already existing congestion has been ignored, raising doubts as to whether the plan is deliverable. 7.6.1/DM CP6 The proposal for a Chesham Town Centre Transport Interchange is incompatible with the removal of the station car park proposed in 6.2.11, unless there is a serious belief that there will be a significant switch to cycling and walking. The hilly terrain makes this rather unlikely. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

Person ID 1223091 Full Name Colin Blundel ID 4623 Order 156 Number 7.6 Title Connected - Area of Change Organisation Details Consultee Type - Please select the type of consultee: Local Authority Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Chiltern Society Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence

113 Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. The Plan is not effective in that it does not make provision for the Misbourne Greenway. The ‘Misbourne Greenway’ is a proposed path for walkers and cyclists, between Wendover and the Chalfonts, one section of a route between Birmingham and London within the HS2 corridor. The Chiltern Society involvement began in June 2017 when members of the Society HS2 group attended a Workshop event at Misbourne Abbey, where outlines of a dozen or so ‘Additional Projects’ were presented - designed “to further integrate the scheme [HS2] into the AONB landscape - over and above the mitigation identified in the Environmental Statement / pursuant to the Hybrid Act.” The Chilterns AONB review group had been assured a sum of £3m to take some of these projects forward. In order that the project progresses during the Plan period, the Society would like to see a reference to the Councils supporting the proposals and safeguarding the route from development. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to Misbourne Greenway improve its alignment to this test of soundness. Creation of a new cycleway linking Wendover to Uxbridge. Safeguarding of the route from development and providing associated leisure facilities. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

Person ID 1224167 Full Name Mr Rob Smith ID 5924 Order 156 Number 7.6 Title Connected - Area of Change Organisation Details Director Growth, Strategy and Highways Buckinghamshire County Council Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID

114 Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why Policy DM CP6 “Creation of a one-way traffic gyratory system utilising Hill Avenue and Sycamore Road, incorporating traffic calming measures with pedestrian and cyclist priority. Increased opportunities for on-street parking, landscaping and overall improved public realm.” “Creation of a public transport interchange at Chesham Station (Underground) incorporating improved facilities for pedestrians, cyclist and public transport services and users. Improved connectivity to the High Street.” PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

Person ID 1224552 Full Name David Wilson Homes Southern ID 6434

115 Order 156 Number 7.6 Title Connected - Area of Change Organisation Details Consultee Type - Please select the type of consultee: Other Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: David Wilson Homes Southern Person ID 1210930 Full Name Katherine Jones Organisation Details Planning Administrator Savills Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why Policy DM CP 6 – Areas of change DWHS supports the reference to the delivery of an Iver relief road under point 4 (‘Iver Village Environmental Improvements’) and the recognition that a solution must be found to address the ongoing problem in Iver. As per our comments on DM CP4, the LPPV’s acknowledgement of the impact of HGVs and commercial traffic on Iver village, particularly given the AQMA designation for the High Street, is welcomed. However, the policy states that proposals which enhance movement and accessibility in the Ivers “are not fundamental to the delivery of the Plan” but will be supported. Therefore, unless proposals for Iver Village Environmental Improvements are brought forward, there is no commitment or obligation that they will be delivered. There must be a firmer commitment to the delivery of a relief road in the Local Plan rather than passing reference to assisting delivery. There is no definition

116 to what assisting means, or obligation for the developers of the site to physically deliver a relief road. This is addressed further to our comments under Policy SP BP11 which is the only site allocation in the LPPV which the Councils’ have identified as possibly being able to facilitate delivery. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

Person ID 1224167 Full Name Mr Rob Smith ID 6774 Order 156 Number 7.6 Title Connected - Area of Change Organisation Details Director Growth, Strategy and Highways Buckinghamshire County Council Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID Full Name Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A

117 of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why Para 7.6.2 Additional modelling may be needed to anticipate impact of growth anticipated from major infrastructure projects and what impact they will have on highways and how that can be catered for. PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

Person ID 1224612 Full Name Chiltern Conservation Board ID 6482 Order 156 Number 7.6 Title Connected - Area of Change Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID 1224611 Full Name Lucy Murfett Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant. Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness?

118 Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy The local plan should include proposals for the Framework Feb 2019 please explain why Misbourne Greenway. This is a proposed major new strategic cycleway to improve the national cycle network, involving Sustrans and the Chiltern Society. It will benefit the local community and the many leisure cyclists who enjoy the Chilterns AONB. It will run for 20 miles along the Misbourne Valley linking Wendover and Uxbridge and the villages in between. Policy 3a - Please specify as precisely and succinctly as possible how you would modify this Add a new connected areas proposal for the policy to improve its alignment to this test of soundness. Misbourne Greenway: 5. Misbourne Greenway Creation of a new cycleway linking Wendover to Uxbridge. Safeguarding of the route from development and providing associated leisure facilities. Add to mapping and key diagram. Policy-level file upload - Please attach any supporting evidence

Person ID 1224612 Full Name Chiltern Conservation Board ID 6226 Order 156 Number 7.6 Title Connected - Area of Change Organisation Details Consultee Type - Please select the type of consultee: Date Received - Date Received: Duty to Cooperate Body - Is this organisation a Duty to Cooperate Body? Agent on behalf of - Consultee is an agent on behalf of: Person ID 1224611 Full Name Lucy Murfett Organisation Details Plan-Level: Legally Compliant - Do you consider the Local Plan to be legally compliant/non-compliant.

119 Legally compliant a - Please give details of why you consider the Local Plan is/is not legally compliant, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Legally compliant b - Are you proposing a modification to make the Local Plan legally compliant and/or to strengthen its compliance? Legally compliant c - Please set out your suggested modification(s) below:You will need to say why this modification(s) will make the Local Plan legally compliant/strengthen its legal compliance. Please be as precise and succinct as possible. Plan-Level: Soundness - Do you believe this plan meets the tests of Soundness? Soundness mods - Please give details of why you consider this Local Plan is/is not sound, including references to relevant legislation, policies and/or regulations. Please be as precise and succinct as possible. Soundness mods - Are you proposing any modifications to strengthen the Plan's ability meet the test of soundness? Policy 1a - Please specify how you would modify this policy to improve its alignment to this test of soundness. Please be as precise and succinct as possible. Plan-level upload - Please upload any supporting evidence Plan-Level: Duty to Co-operate - Do you consider the Local Plan to have met the requirements of the Duty to Co-operate in accordance with section 110 of Localism Act 2011 and section 33A of the Planning and Compulsory Purchase Act 2004? Please note that any non-compliance with the Duty to Co-operate is incapable of modification at examination Duty to Co-operate a - Please give details of why you consider the Local Plan has met/not met the requirements of the Duty to Co-operate.Please be as precise and succinct as possible. Attendance at the EiP - If your representation is proposing a modification(s), do you consider is necessary to participate at the examination in public? Attend EiPb - If you wish to participate at the examination in public, please outline why you consider this to be necessary (please be as precise and succinct as possible Policy Level - PP - If you do not believe this policy to be positively prepared please explain why PP Mods - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 1 - If you do not believe this policy to be justified please explain why Policy 2a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy 2 - If you do not believe this policy to be effective please explain why. The local plan should include proposals for the Misbourne Greenway. This is a proposed major new strategic cycleway to improve the national cycle network, involving Sustrans and the Chiltern Society. It will benefit the local community and the many leisure cyclists who enjoy the Chilterns AONB. It will run for 20 miles along the Misbourne Valley linking Wendover and Uxbridge and the villages in between. PAa - Please specify as precisely and succinctly as possible how you would modify this policy to Add a new connected areas proposal for the improve its alignment to this test of soundness. Misbourne Greenway: 5. Misbourne Greenway Creation of a new cycleway linking Wendover to Uxbridge. Safeguarding of the route from development and providing associated leisure facilities. Add to mapping and key diagram. Policy 3 - If you do not believe this policy in consistent with the National Planning Policy Framework Feb 2019 please explain why Policy 3a - Please specify as precisely and succinctly as possible how you would modify this policy to improve its alignment to this test of soundness. Policy-level file upload - Please attach any supporting evidence

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