Transport  Economy  Environment County Council County Hall, Walton Street Stephen Walford , Buckinghamshire HP20 1UA Director Growth & Strategy

Aylesbury Vale District Council Miss Emily Hodgson Forward Plans 01296 383142 The Gateway [email protected] Gatehouse Road Aylesbury Telephone 0845 3708090 HP19 8FF www.buckscc.gov.uk

Submitted by email: 16th June 2015 [email protected]

Dear Louise Anderson

Re: Pre Submission Neighbourhood Development Plan

Thank you for inviting Buckinghamshire County Council to comment on the Neighbourhood Development Plan for Cheddington. Our observations around Education, Sustainability, Green Infrastructure and Ecology are detailed below. We would like to again draw your attention to our now adopted Memorandum of Understanding for Neighbourhood Planning, which details the role and expectations of the County Council with regards to the Neighbourhood Development Plan process1.

With regards to Education we would like to draw your attention to comments submitted previously around paragraph 2.25. This states “The primary school planning area for Cheddington includes Wing and , there are ten primary schools in the area, with a capacity for 1561 pupils. There is generally a surplus capacity for primary school places according to the Fact Pack 2011.” We feel that this statement is misleading and wish for it to be replaced with the more appropriate wording of:

“Cheddington School is a popular and successful school and is generally full in all year groups. The school does admit a few children from outside its catchment – so any growth from new development would displace any out of area children over the long term (e.g. from /Ivinghoe) although this is likely to increase the pressure on places at neighbouring schools. Based on current trends, the school would be able to accommodate the relatively small scale growth allocated in the neighbourhood plan (i.e. 100 homes) although this would provide little flexibility to allow for peaks in demand. Typically in rural areas as well as on new developments the population can be volatile and fluctuates significantly year on year – so there may be some years where the school is oversubscribed and transport may need to be provided to the next nearest school with places (e.g. Overstone School). It is for this reason the admissions code does not allow Local Authorities to guarantee places to parents in a

1 The agreed Memorandum of Understanding can be viewed here: https://democracy.buckscc.gov.uk/documents/s55061/Appendix%201%20- %20Memorandum%20of%20Understanding.pdf

local catchment area (i.e. in case the pattern of preferences expressed or fluctuations in the population do not allow this guarantee to be met). Across the wider area, the County Council will need to keep the population and pupil trends under review and if necessary provide additional places. Should the need for additional places arise, BCC would seek to use of the Community Infrastructure Levy to contribute towards any necessary school improvements.”

With regard to Sustainability, we would like to reiterate our previous comments. The encouragement of safe walking, cycling and horse riding is a welcome objective of the pre-submission Plan. The objective could be developed further to detail the specific improvements that are aspired to for the area, particularly in relation to sustainable access routes to key destinations (such as the rail station). Providing a visual interpretation of the aspirations for cycling, walking and horse riding in the main Plan document would be useful and could be supported by a more detailed aspirational plan of improvements as an appendix. This information could help to garner support from wider organisations and identify potential opportunities to attract external funding and is an approach used successfully by a Beaconsfield local community group to establish an aspirational cycle network for the town2.

With regards to the use of diagrams throughout the Plan, we would encourage the inclusion of the , the Outer Aylesbury Ring promoted walking route and the Circular Walk promoted walking route to properly illustrate the environmental and village assets in the local area. It would be also helpful to identify the nearby but outlying settlements that surround Cheddington to visually highlight the links that could be strengthened to enable greater access to services across the local area. An example could be an aspiration to improve cycling links to the Aylesbury Arm of the Grand Union Canal.

More specifically, we would welcome the inclusion of the term “bridleways and cycleways” (as well as footpaths) under Policy 6 of the Plan to support the provision of new access links and improvements to the existing rights of way network to facilitate greater access to green spaces for residents with limited mobility.

The County Council acknowledges reference to district wide green infrastructure strategy in Policy 6, however it noticed that there is no reference to the Buckinghamshire Green Infrastructure Strategy (2009) or the Green Infrastructure Delivery Plan (2013). These set out the priorities and aspirations for the protection, improvement and creation of Green Infrastructure across Buckinghamshire and should be reflected in Local Policy and supported in development proposals. Commitment to these priorities and aspirations will enhance the strategic Green Infrastructure network across the County, boosting sustainable route connectivity throughout Buckinghamshire and into neighbouring areas and increase opportunities for recreational activity and environmental protection across this highly valued resource.

Lastly with regards to Ecology the NERC Act (2006) states that with regard to Section 40 ‘Every public authority must, in exercising its functions, have regard, so far as is consistent with the proper exercise of those functions, to the purpose of conserving biodiversity. Conserving biodiversity includes restoring and enhancing species populations and habitats as well as protecting them.’ This responsibility extends to town and parish councils.

2 www.beaconsfield-cycle-paths.org.uk

Buckinghamshire County Council wishes to make the following recommendations:

1. Firstly it is suggested that Biodiversity should have its own policy, even though green infrastructure is linked in with the conservation of biodiversity. Biodiversity is all around us and should be taken account of at all levels of planning. It is important to protect biodiversity in its own right. However, biodiversity is also important as an asset for the local community and as a key element of local wellbeing. 2. The National Planning Policy Framework (NPPF, 2012)3 paragraph 109 states that the planning system should contribute to and enhance the natural and local environment by: ‘…minimising impacts on biodiversity and providing net gains in biodiversity where possible, contributing to the Government’s commitment to halt the overall decline in biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures…’ Though some suggestions are given below how this may be achieved, I recommend reviewing the Bucks Biodiversity and Planning document produced in collaboration between a number of nature conservation organisations and NGO’s across Buckinghamshire. This can be viewed here: http://www.buckinghamshirepartnership.co.uk/biodiversity/biodiversity-and-planning/

3. We particularly welcome the recommendation for using the Biodiversity Impact Assessment approach which, where appropriate can assist in the assessment of achieving biodiversity net gain.

4. Local Wildlife Sites (LWS) are afforded protection through the local planning system and recognise that significant conservation value can be found outside of statutory sites. They are often designated as they are known to contain habitats and species that are priorities under the UK Biodiversity Action Plan (S41 NERC Act). Biological Notification Sites are those with the potential to qualify for Local Wildlife Site status subject to confirmation. Until such a time as they are confirmed they should be given equal weight in the planning process. Within the parish of Cheddington there is the Church Hill Farm Orchard Local Wildlife Site which is recognised in the neighbourhood plan. However two Biological Notification Sites also run into this parish and these should also be taken into account. For further information on the most up to date information regarding statutory and non-statutory sites and species please approach the Buckinghamshire and Milton Keynes Environmental Records Centre (BMERC) here: http://www.buckinghamshirepartnership.co.uk/environmental-records/

5. The importance of traditional orchard habitats are highlighted in this plan but other Biodiversity Action Plan habitats have been omitted including an area of mixed woodland and unimproved grassland. Please also refer to BMERC as above for further information. 6. Again, it should be highlighted that the provision of green infrastructure within development applications is expected and must be consistent with the principles of the Local Planning Authority’s Green Infrastructure Strategy or subsequent equivalent policy or strategy such as the AVDC Green Infrastructure Strategy, 2011 and the Buckinghamshire Green Infrastructure Delivery Plan http://www.buckscc.gov.uk/media/1521901/5326-Bucks-GI-Delivery-Plan-FINAL- ISSUE_2013_08_07_low_res.pdf

3 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf