North Bucks Planning Consortium

Secretary: Geoff Culverhouse [email protected]

Response to a consultation on the Draft Vale of Local Plan September 5th 2016

Beachampton, with Broughton, , , , , , , Hardwick, Leckhampstead, , , Nash, , , , Steeple , , , Thornborough, Twyford, Watermead, Whaddon, Wing, Winslow.

FOREWORD

North Bucks Parishes Planning Consortium was founded in the year 2000 by a small group of councils in the north of . Its initial brief was to guard against the western expansion of and address planning matters of common interest. It now has 25 Town and Councils as members each paying an annual membership fee. These member councils represent almost 40,000 residents amounting to 22% of the total population of Aylesbury Vale. Each member council is entitled to send up to two representatives to consortium meetings and the minutes of these meetings are sent to all. The committee meets at least quarterly and additionally as required. Officers are elected at the Annual General Meeting each year

Since its formation NBPPC has concentrated on discussing and commenting only on planning related matters which have a strategic rather than just a local impact. The issues we have been involved in include;

 Being active stakeholders in the Roger Tym study of Milton Keynes and South Midlands (MKSM) Sub-Region 2000-2002, participating in the MKSM Sub-Regional Spatial Strategy (MKSM SRS) examination in Public, April 2004, being recognised by MK Partnership Committee as consultees on the MK2031 Plan and responding to all subsequent matters relating to the future development of Milton Keynes and in particular its south west expansion.  Responding to the Aylesbury Vale Local Development Framework (Core Strategy) Consultation, and the Vale of Aylesbury Plan (VAP) Consultation. Maintaining a close scrutiny of the progress of the emerging Vale of Aylesbury Local Plan (VALP) and responding to the consultation stages.  Meeting with Officers and Members of Bucks CC and AVDC to discuss a wide range of issues as and when possible.  Being fully accredited stakeholders in the Public Examination of the South East Regional Spatial Strategy (SE Plan).  Responding to proposed major developments such as ‘Winslow Green’, ‘’ and ‘Salden Chase’.  Monitoring proposals for, and commenting where appropriate on, HS2, East West Rail, Luton Airport expansion, Calvert EFW site, Wind Power, Gypsy and Traveller sites and Neighbourhood Plans.  Commenting on changes to AVDC Officers delegated powers and changes to the way in which AVDC planning communicates with parishes.

NBPPC is the only group within Aylesbury Vale dealing solely with planning related matters. The membership level, and consistency of renewal, suggests that member parishes appreciate having a forum in which planning matters can be debated and acted upon. We believe that there is a real benefit in AVDC receiving well considered, detailed, responses to strategic planning issues from a group with such wide membership.

This response has been compiled from the comments of member councils which were reviewed at a meeting of consortium representatives on 17th August 2016. Individual member councils will make their own responses where they consider it appropriate. For convenience the comments in this response follow the same order as the consultation draft of the Vale of Aylesbury Local Plan.

G. Culverhouse. Secretary, North Bucks Parishes Planning Consortium

1. BACKGROUND

1.1 Having been actively involved in planning matters within Aylesbury Vale and Milton Keynes for sixteen years the Consortium has a good understanding of the background to the development of the Vale of Aylesbury Local Plan. From our experience of AVDC’s previous attempts to deliver a sound Local Plan we recognise that meeting the duty to cooperate and delivering an acceptable level of housing are issues which have been very much at the forefront of their deliberations. However, we are concerned that the previous failures are leading to an over-reaction to the duty to cooperate. The figure of 12000 (Para 1.13) in respect of ‘unmet need’ appears to be entirely arbitrary. There does not appear to be any evidence of a detailed analysis of the unmet need figures promoted by neighbouring authorities. These figures need to be vigorously challenged.

2. VISION AND STRATEGIC OBJECTIVES

2.1 We note that growth will be accompanied by delivery of infrastructure, services and facilities in the right place at the right time. (Para2.4 d) Given the ongoing delays to delivery of East West Rail (EWR) and the fact that the Cambridge Expressway (OCX) is , at this stage no more than a consultation on potential need we consider it foolhardy in the extreme to plan development on the assumption that either or both will be completed within the plan period. Much clearer evidence of firm delivery dates for each of these major infrastructure projects is needed.

2.2 We note that a ‘new settlement’ (NS) will be under development (p23 6.i). This does not suggest that the NS will only be developed if there is a proven need. Much will depend on levels of unmet need to be catered for in the final version of the plan. It is clear that the figures promoted as unmet need by neighbouring authorities to the south are entirely arbitrary and that they themselves have not done sufficient to meet their own needs particularly when considering proposed density levels. If the unmet need proves to be considerably less than the 12,000 figures quoted then there will be no requirement for a new settlement.

2.3 Para 2.6 item 4 recognises the importance of ‘phasing’ of development. Policies related to phasing will need to be tightly drawn to ensure that housing delivery matches need and is in line with the delivery of infrastructure and services.

3. STRATEGIC POLICY ISSUES Policy S1- Sustainable development 3.1 We support the general principles promoted in this policy and in particular note that in assessing the most sustainable locations priority will be given to (inter alia) ; b – Mix of uses, especially employment. c – Delivering strategic infrastructure e – Minimising impact on local communities

Policy S2 –Spatial strategy 3.2 We do not agree with the spatial strategy. The proposed distribution between Aylesbury and the rural areas is fundamentally flawed. Aylesbury and its environs will be taking only 46% of the proposed growth. Previous draft Local Plans for Aylesbury Vale have indicated that Aylesbury and its environs should take at least 60% of the growth.

3.3 Too much emphasis is placed on housing delivery in the rural North East of the Vale. The proposed percentage growth in rural north-east corner of Vale will be almost three times that proposed for Aylesbury. Up to 12,000* new homes, equal to 135% growth vs 46% (not 50% as per policy) at Aylesbury (*If new settlement included) Potentially up to 41% of the total proposed growth is suggested for an area within three miles of the village of Little Horwood. By the end of the plan period the population of this area, including existing settlements, would be up to 40,000. This is wholly unsustainable. It is important to note that Buckingham is not included in the above figures.

3.4 The area in question is 11 miles distant from Aylesbury and 10 miles from . There is no provision for employment, retail, education or leisure facilities to service this massive growth. The combined proposed developments at Whaddon and Newton Longville would be equal to the proposed New Settlement. It is worth noting that this area did not even figure in the initial list of ten possible sites examined by GL Hearn in the New Settlement Study.

3.5 The much delayed delivery of East West Rail would have little positive impact on local travel. Furthermore, even if the Oxford Cambridge Expressway is routed via the A412 and eventually constructed (of which there is no certainty) this would be of no benefit to local traffic at all. Development of this area on the scale proposed would result in traffic gridlock on local roads.

3.6 Growth of 50% in the Strategic Settlements appears entirely arbitrary. No rationale is given for the growth level. Aylesbury is the principle employment, retail and leisure centre of Aylesbury Vale yet Winslow, with very limited retail, employment or leisure facilities is expected to grow at the same rate. The scale of growth adjacent to MK is unsustainable as described above. AVDC will take the council tax revenue but MK will reap the economic benefit as it provides a vastly superior range of retail facilities albeit at a similar distance to Aylesbury.

Policy S3 Settlement hierarchy and cohesive development 3.7 We note that the settlement hierarchy is explained in Policy S2 so suggest that this needs to be referenced by a link in policy S3.

3.8 The differences in percentage growth levels between settlements is entirely arbitrary. There are large settlements with almost the same population as two of the strategic settlements and small settlements restricted to 5% growth which could accommodate more as they are strategically located. (e.g. Whaddon is in 5% category but growth will actually be 375% whereas Great Brickhill which is equally close to MK will only be 5%) More work needs to be done to explain and rationalise the settlement hierarchy which appears to be a ‘blunt tool’. Whilst we have severe reservation about elements of the draft Wycombe Local Plan we do believe that it has a good methodology for its comparisons between settlements.

Policy S4 Green Belt 3.9 We agree with the proposal to release Green Belt land at / Halton. We do not understand the logic for the proposal to add land adjacent to to the Green Belt. This has been a much contested application site and appears worthy of inclusion in the proposed development areas.

3.10 Currently there is no formal protection for land around the borders of Milton Keynes. We propose that an area of Green Belt is established to the west of Milton Keynes which would prevent coalescence with the exiting communities such as Whaddon, Newton Longville, Drayton Parslow and Mursley. In particular Whaddon Chase needs to be protected. NBPPC would welcome the opportunity to be involved in a study to identify boundaries for a new area of Green Belt on the western fringes of Milton Keynes.

Policy S5 Infrastructure 3.11 We agree that ‘the provision of Infrastructure should be linked directly to the phasing of development’. In respect of the introduction of Community Infrastructure Levy (CIL) clarity is required in respect of the distribution of the 25% of CIL contributions which will be due to Neighbourhood Plan communities.

Policy S6 Protected transport schemes 3.12 HS2 We suggest that protection should be provided for additional land adjacent to the HS2 route to provide a dual carriageway as the southern section of a ring road for Aylesbury should finance become available. This to link with the Aylesbury eastern link road which is to be delivered by developments to east of Aylesbury. See also our further comments regarding the Oxford Cambridge Expressway which are related.

3.13 East West Rail EWR Brings only limited benefits in terms of supporting sustainable development and is already at least five years behind delivery schedule. The latest projection for services is 2022 - 24 not 2020 as shown in the draft VALP. EWT will provide very little benefit in terms of travel to Milton Keynes as rail station not close to either employment centres or the retail hub. EWR will improve journey times to Oxford for a limited number of people. Links to Cambridge and further east are a very long way off and of little relevance to Aylesbury Vale residents. The proposed journey time to (74 mins from Winslow) is no incentive for relocation to this area. For those considering relocating to, or within, the Vale in order to commute into London there are several better options operating already. (Bicester 46 mins / Leighton Buzzard 30 mins / Haddenham 40 mins / Aylesbury 60 mins.)

Oxford Cambridge Expressway (OCX) 3.14 The copy in para 3.63 of the draft VALP is misleading. There is no evidence yet of the route to be proposed as it is understood that at least three are under consideration each of which has been considered by NBPPC members. a) Dualling the A421. This route could provide improved employment opportunities for Buckingham but has severe delivery issues. The preferred option is that the OCX would have minimal intersections in order to speed traffic but the current section through Milton Keynes is all at grade with traffic roundabouts. This would therefore require several flyovers to be built. The westward section from the ‘Bottle Dump’, where the current dualling ends presents many challenges and ultimately would take traffic into Oxford via the already highly congested A34. b) The New Settlement Study illustrates a route which diverts the A421 at the Bottle Dump to join the route of EWR as far as the west of Winslow. There is no indication of the onward route but this would require more than twenty miles of entirely new road in order to reach the A34. This route would have the same problems though MK as mentioned above and could not be built as shown. The route illustrated would demolish houses, run through the proposed Winslow station and its car park, demolish the western end of the new school, cut across the Burial Ground and across a high pressure gas main. Clearly not possible. A diversion around Winslow would only add to the significant amount of entirely new road which would be required. The basic premise of the proposed OCX is that it would use, and where necessary upgrade, existing roads. This route would also approach Oxford by the heavily congested A34. c) Strategically the best route for Aylesbury Vale would be via A4146/A418. This would link Aylesbury into the Oxford - Cambridge ‘knowledge arc’ and support the housing growth at Aylesbury. The protection of a route alongside HS2 to the south of Aylesbury would help to facilitate this. However, this route would involve the dualling of the A418 from Wing to Bierton to which there was strong opposition in the past. One benefit of this route is that it would approach Oxford via the A40 which is much less congested that the A34.

3.15 Clearly all of the three routes considered present challenges and in any event at this stage there is no evidence of need. The government sponsored study into the feasibility of OCX is not due to report until December by which time AVDC will need to have completed the submission version of VALP. Even if the result of the study were known at this time there can be no certainly that the preferred route would prove deliverable or that it would be delivered at all. Against this background NBPPC considers it impossible to recommend any particular route and we believe that it would be wholly unsustainable for VALP to propose housing delivery which would be reliant on the delivery of OCX.

Policy S7 Gypsy, Traveller and travelling showpeople provision. 3.16 We support the provision of sites in appropriate locations and at appropriate levels. Site location should take into account traditional movement and resting locations of the traveling community.

Policy S8 Previously developed land 3.17 We support this policy and have no further comment.

Policy S9 Securing development through Neighbourhood Plans 3.18 We support this however the timescale for implementation of new or revised NP’s after adoption of VALP is unrealistic. NP communities will need to await the adoption of VALP before they know exactly what their housing requirement will be. A new NP could take at least 18 months to get to submission stage and, depending on challenges by hostile developers could be even longer. We suggest that the time limit is altered to 18 months and that this is approached in a spirit of cooperation with the NP community.

Proposed additional policy on Coalescence 3.19 We note that the issue of coalescence is referred to in Policy S3 but consider that this is wholly insufficient in policy terms. We would prefer to see a separate policy which makes it clear that developments which result in coalescence with existing communities will not be permitted. A clear description of what will be deemed to be coalescence is required.

4. STRATEGIC DELIVERY ISSUES

Policy D1 Delivering Aylesbury Garden Town 4.1 We support the principle but the calculation is incorrect. There is disharmony between the share of total growth being proposed for Aylesbury and the aspiration for it to develop as a Garden Town. The plan does not indicate that Aylesbury will take the majority of the Districts’ Growth. In fact it is less than half as currently proposed. In order to maximise the Garden Town opportunity the percentage of total growth should increase significantly to 60% of the total requirement. Additional growth levels to the west of the town where there is a new and under-utilised rail connection should be included. Expansion to the immediate north of Aylesbury should also be re-considered.

Policy D2 Delivering a new settlement 4.2 There is no policy provided in the draft VALP for us to comment on. However, we would draw your attention to submissions from Great Horwood Parish Council and Winslow Town Council in respect of the New Settlement Scoping Study prepared by GL Hearn. Both of these councils are members of NBPPC.

Policy D3 Delivering sites adjacent to Milton Keynes 4.3 For all purposes the two proposed sites are an extension to Milton Keynes and in fact the Salden Chase site is even described by the promoters as such. We fail to understand why AVDC are promoting development which supports the western expansion of Milton Keynes when that authority has vast areas of undeveloped land to the east.

4.4 The relative scale of these two sites in relation to the existing communities phenomenal. Whaddon parish would grow by 375% and Newton Longville by 138%. As stated in our comment on Policy S2 the scale of the combined developments would be equal to the proposed New Settlement. It is worth noting that this area did not even figure in the initial list of ten possible sites examined by GL Hearn in the New Settlement Study.

4.5 Policy D3 refers to the need for a Master Plan and delivery SPD and highlights most of the issues we have raised ourselves. We do not believe that these sites should be included in the submission VALP without the Master Plan and SPD being included as appendices.

We would refer you to our comments at paragraphs 3.3 to 3.5 of this document and to the separate submissions of Whaddon Parish Council and Newton Longville Parish Council which are both members of NBPPC.

Policy D4 Housing developments at strategic settlements (excl. Aylesbury) 4.6 The suggested growth of 50% at strategic settlements (SS’s) is entirely arbitrary. No explanation of the rationale for this is given. Opportunities for growth clearly vary in each of the SS’s. We would draw your attention to the separate submissions of Winslow and Buckingham Town Councils, both of which are members of NBPPC.

Policies D5-D8 Housing development at larger villages, medium villages, smaller villages and at other settlements. 4.7 We would refer you to our comments in respect of PolicyS2 which for convenience we repeat here. The differences in percentage growth levels between settlements is entirely arbitrary. There are large settlements with almost the same population as two of the strategic settlements and small settlements restricted to 5% growth which could accommodate more as they are strategically located. (e.g. Whaddon is in 5% category but growth will actually be 375% whereas Great Brickhill which is equally close to MK will only be 5%) More work needs to be done to explain and rationalise the settlement hierarchy which appears to be a ‘blunt tool’. Whilst we have severe reservation about elements of the draft Wycombe Local Plan we do believe that it has a good methodology for its comparisons between settlements.

Policy D9 Provision of employment land 4.8 The proposed reduction in already consented or reserved employment land presents both opportunities and problems. It is vital that employment opportunities are created in all areas where significant growth is proposed. This is particularly so at strategic settlements. Reserved sites must be protected and there should be specific requirements for employment land within major new development sites. Policies should make it clear that applications for conversion of employment land to housing will not be considered within the first ten years of the plan. VALP must ensure that a sound geographic spread of employment and sites across the vale is maintained. We are concerned that the provision of employment is under-valued in VALP. It is an important parameter for development.

Policy D10 Town village and local centres to support new and existing communities 4.9 This policy makes provision for new and expanded facilities in town centres but does nothing to protect existing facilities. Para 4.106 indicates that the strategy is to resist the on- going loss of local facilities but this needs to be given full policy status by inclusion in D10 or via a specific policy. The provision and / or retention of offices for voluntary services providers (e.g. Citizens Advice) and local authority services (e.g. Libraries and Parish Council offices) should be added to local shops, and post offices which are mentioned in P4.106.

4.10 It should be noted that in some development locations the slavish adherence to providing new facilities at so-called ‘district centres’ can result in an adverse affect on existing service facilities nearby which would adequately serve the new developments. Change of use from retail / service uses to residential should be strongly resisted. Residential use ‘above the shop’ should be supported.

Policy D11 Site for new Town Centre Development. 4.11 No comment

Policy D12 Aylesbury Town Centre 4.12 For a majority of NBPPC members Aylesbury Town Centre is not as relevant as Milton Keynes Centre where there is a more significant provision of retail and leisure options.

Policy D13 Housing in Aylesbury Town Centre 4.13 No comment

Policy D14 Gypsy / Traveller and Travelling Showpeople Sites 4.14 See comment at Policy S7.

5. HOUSING

Policy H1 Affordable housing 5.1 Affordable housing should be provided a minimum rate of 35% of all relevant developments. The strongest possible action should be taken to ensure that this requirement is met in all cases. Within AVDC’s area there are numerous communities which are defined as ‘rural areas’ by Statutory Instrument 1997 No. 625 (referred to at para 5.15 of VALP). The recent change to PPG relating to affordable housing not being required on sites of 10 or less would therefore not apply on sites within these ’rural areas’. Policy H1 needs to be amended to reflect this.

5.2 We believe it is important that when establishing the affordable housing requirement Neighbourhood Plans and Housing Need Surveys should be referred to at an early stage. This requirement should be incorporated into policy.

5.3 Affordable housing ‘clusters’ should reflect the scale of the overall development and not be set at a specific number. Where developments are completed in phases no affordable housing cluster should be permitted adjacent to a cluster on an earlier phase of the development. These matters should be incorporated into the policy and not left to be reliant on the supporting text.

Policy H2 Rural Exception sites 5.3 We suggest that ‘may be permitted’ in the first line of this policy should be replaced with ‘will be encouraged’.

Policy H3 Rural workers dwellings 5.4 This policy is supported

Policy H4 Replacement dwelling in the countryside 5.5 Add to this policy. Replacement dwellings should occupy no more than twice the footprint of the existing dwelling.

Policy H5 Self/custom build housing 5.6 This is already being explored in respect of a site at Winslow. Meetings with the developers, interested self-builders, AVDC planners and Winslow Town Council (WTC) representatives have established that there is much work to be done on this as yet. There is clearly strong evidence of the need and therefore the development of a clear SPD will be important. WTC would be happy to contribute to discussions on the development of a suitable SPD.

Policy H6 Housing Mix 5.7 Generally this is supported. Additionally, Neighbourhood Plans and Housing Need Surveys, where available, must be referred to when establishing housing mix on developments.

Policy H7 Dwelling sizes 5.8 This policy is noted.

6 ECONOMY

Policy E1 Protection of key employment sites 6.1 The list of key employment sites should be extended to include any employment sites specifically referenced in Neighbourhood Plans. It is important to recognise that in some locations even a small employment site could be classed as ‘key’ to development in that area. Furthermore it is vital that employment opportunities are created in all areas where significant growth is proposed. This is particularly so at strategic settlements. Reserved sites must be protected and there should be specific requirements for employment land within major new development sites. Policies should make it clear that applications for conversion of employment land to housing will not be considered within the first ten years of the plan. VALP must ensure that a sound geographic spread of employment sites is maintained across the vale. We are concerned that the provision of employment is under-valued in VALP. It is an important parameter for development.

Policy E2 Other employment sites 6.2 We consider that this policy, as worded, will make it much too easy for employment land to be converted to housing. This will be particularly important in strategic settlements such as Winslow where there is already a serious shortfall in local employment opportunities. Alternative uses to employment on reserved sites should not be permitted within the first ten years of the plan.

Policy E3 Provision of complementary facilities for employees 6.3 Replace ‘appropriate’ with ‘encouraged’ at beginning of second line of policy.

Policy E4 Working at home 6.4 This policy is supported

Policy E5 Development outside town centres 6.5 Replace ‘have been considered’ with ‘are met’ in the third line of the second paragraph. Without this change, or something similar, the policy will be utterly meaningless.

Policy E6 Shop and business frontages 6.6 We support this policy and can only hope that it is enforced effectively.

Policy E7 Tourism development 6.7 The wording of the second sentence in the opening paragraph appears to restrict rather than promote development of tourism in countryside locations. In particular this could have an adverse impact on much needed expansion of hotel facilities at Silverstone which is in a countryside area. AVDC should be encouraging tourism related businesses and working with BCC highways to improve access to key locations such as Silverstone, Stowe and .

Policy line ‘e’ appears to restrict fair competition and would therefore fall foul of existing legislation. It is not for VALP to interfere with issues of commercial viability.

Policy E8 Tourist accommodation 6.8 Similarly to the above item ‘b’ is commercially restrictive. Many tourists would prefer to stay at accommodation in smaller communities. There are already many successful B&B operations in smaller communities. This could also prevent the conversion, and thereby preservation, of large country properties to hotels.

Policy E9 Agricultural development 6.9 After ‘where’ at the end of the introductory sentence delete colon and add. ‘evidence is produced which clearly illustrates that:’

Additional comments 6.10 We consider that there are serious omissions in this policy area. There is no mention of policies to support economic development and in particular it seems that there should be in respect of the three ‘Enterprise Zones’ which AVDC were granted by the government.

6.11 Jobs and houses need to be linked to maximise sustainability. Of the three Enterprise Zones which are at Silverstone, Westcott and Woodlands (Arla), (see, http://enterprisezones.communities.gov.uk/enterprise-zone-finder/aylesbury-vale/ only the latter is nominated for housing growth and even that is suspect, due to flood zone problems. That does not represent a sustainable, well integrated approach to economic development in our view.

7 TRANSPORT

Policy T1 Vehicle Parking 7.1 We support this policy. In particular we note item T1c which recognises that garages are rarely used for parking cars! However, there needs to be specific recognition that car ownership levels and therefore parking requirements, in rural areas with poor public transport provision are greater that in urban areas. We would encourage the introduction of a zoning system for parking standards as promoted in BCC’s parking standards. This would ensure that higher levels of off street parking are delivered in areas where there is limited public transport.

T2 Footpaths and cycle routes 7.2 This is supported

T3 Electric vehicle infrastructure 7.3 This policy is supported. It would further evidence AVDC’s commitment to supporting sustainable modes of transport if the policy were extended to call for the provision of charging points at all new dwellings. Where dwellings are delivered as blocks of flats one charging point for every five units should be provided at an easily accessible location adjacent to the block.

8 BUILT ENVIRONMENT

Policy BE1 Heritage assets 8.1 In the list which follows the opening two sentences item ‘g’ should be separated and become an independent sentence as the content does not relate to the list above. We feel that support for heritage assets in AVDC’s area has been in decline in recent times. How successful this policy will be in protecting heritage assets will depend entirely on the interpretation of it in planning decisions.

Policy BE2 Design of new development 8.2 We have some concern that this policy restricts opportunities for modern design where appropriate and will merely encourage developments which are a pastiche of historic local development, often with mixed period styles of dwellings.

Policy BE2a External space standards 8.3 We have shown this item as policy BE2a as it would appear that it is a separate policy but has not been given a reference number. This should be clarified which may need renumbering in this section.

Policy BE3 Protection of the amenity of residents 8.4 No further comment.

9 NATURAL ENVIRONMENT

Policy NE1 Protected sites 9.1 This policy is supported.

Policy NE2 Biodiversity 9.2 This policy is supported

Policy NE3 Landscape character and locally important landscape 9.3 Proposals for development in all greenfield locations need to address the issues referred to for AAL’s and LLA’s. Just because a greenfield site does not benefit from a landscape designation does not make it any less attractive to people living in that area or indeed any receptor.

Policy NE4 The Chilterns and AONB setting 9.4 No comment

NE5 Pollution, air quality and contaminated land 9.5 This policy is supported.

Policy NE6 Local green space 9.6 At item ‘a’, in line one, after ‘outdoor sport and’ replace ‘recreational’ with ‘community recreation and/or leisure facilities’. As written the policy could prevent the use of Local Green Spaces as locations for buildings to support or contain sport and leisure facilities.

Policy NE7 Best and most versatile agricultural land 9.7 This policy is supported.

Policy NE8 Trees hedgerows and woodlands 9.8 This policy is supported.

10 COUNTRYSIDE

Policy C1 Conversion of rural buildings 10.1 This policy is supported. In the first line of the section headed ‘Proposed uses’ we assume it should read ‘economic development or community uses’ not of.

Policy C2 Equestrian development 10.2 In respect of Riding Areas this policy needs a reference to the use of arena lighting being restricted in order to avoid light pollution in rural areas.

Policy C3 Renewable energy 10.3 This policy is supported but there should be a specific section, or separate policy, relating to guidance for the development of Wind Turbines and Solar Farms.

Policy C4 Protection of public rights of way 10.4 This policy is supported

11 DETAILED INFRASTRUCTURE

Policy I1 Green Infrastructure 11.1 This policy is supported

Policy I2 Sports and recreation 11.2 In line five insert ‘net’ between ‘the’ and ’loss’. This would help to ensure that at least equivalent alternative facilities need to be provided where development on existing sports and recreation areas is permitted.

Policy I3 Community facilities 11.3. We believe that this policy does not adequately cover situations where new development may result in the loss of community buildings and/or sports facilities. The policy should make it clear that such proposals will require replacement facilities of at least equal level or a financial contribution to the provision of such facilities.

Policy I4 Flooding 11.4 This policy is supported. We would also refer you to the comments on this matter in the submission of Buckingham Town Council which is a member of NBPPC.

Policy I5 Telecommunications 11.5 This policy is supported

END OF COMMENTS

NORTH BUCKS PARISHES PLANNING CONSORTIUM