Policy SP BP2 - Chesham Person ID 1214824 Full Name Mr John Munns ID 5371 Order 236 Number 11.3 Title Policy SP BP2 - Chesham 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 8741 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 8742 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 I consider the Local Plan to be NOT legally compliant because in reading through the contents, I see that believe this policy in on many counts, the proposals are at odds with the National Planning Policy Framework (NPPF) and consistent with the National government directives, with regard to Green Belt Policy, and to areas protected by Green Belt status. I set Planning Policy Framework out my reasons as follows; Feb 2019 please explain why 1/ The proposals indicate with much emphasis, the intention of removing Green Belt designation from thirteen areas, and also the intention of removing or modifying Green Belt status of villages and hamlets in Chiltern District and South Bucks. Firstly, I question the confliction of interests concerning carbon emissions. The Local Plan forecasts a 21% increase in emissions; yet recently the government confirmed its aim to achieve zero emissions by 2050. It should be clear to all that increased vehicle use and higher volumes of traffic are major perpetrators of emissions growth. With this in mind, it should also be recognised with responsible concern, that a direct consequence of building housing developments on Green Belt land and in rural villages, by the nature of their location (generally out of town/rural), will be a wholesale increase in traffic volume, with the reliance on residents' vehicles travelling into (and returning from) surrounding towns for their needs. Awareness of these facts should add weight to the necessity when planning, for home-building to be where possible, within the proximity of town centres to minimise use of vehicles / traffic congestion. This ultimately reduces growth of emissions and poor air quality. However, there is little evidence in the local plan that suggests much consideration is given to options such as higher-density development of existing brown field sites, and for centralising developments within (or close to) town centres where possible. Chesham Renaissance CIC ( a community-led, non-profit) organisation has produced such a plan; `The Chesham Master plan' for mainly affordable homes to be built within the town centre, which also aims to regenerate the town in the process. 2/ With reference to the revision of Green Belt boundaries; 8743 The NPPF and government directives specify that local authorities must be able to demonstrate `exceptional circumstances' and fully explain why they are justified in any proposal to remove Green Belt designation of an area, or modify a Green Belt boundary. Any such proposal should only be put forward after ALL other possible options have been considered and exhausted. In addition, the NPPF (Paragraph 11B) require Plan Makers to provide for objectively assessed needs for housing and other uses, unless the application of Framework policies (including Green Belt) provide a strong reason for restricting the overall scale, type or distribution of development in the plan area.. Therefore, it must be recognised that both Chiltern District and South Bucks are responsible for areas which are covered predominantly by areas of AONB and Green Belt protection¼which together, impose a necessary restriction on development. With this situation, the Local Plan is at odds with the NPPF/Government directives, which renders it not legally compliant in its proposals. 3/ It is acknowledged that The Community Infrastructure Levy (CIL) associated with the Local Plan, has an infrastructure funding gap of between £179 m and £231 m. Provision of effective infrastructure would be crucial for the scale of developments proposed in the Local Plan before any plans could even be considered as sustainable. Therefore, this shortfall of available funding is another reason that renders the Local Plan as not legally compliant and unsound in its concept. I refer to Spatial Policy SP SP1 and Policy SP BP2 (Lye Green, Chesham). In particular, I draw attention to proposals which aim to remove Green Belt designation from areas within the Local Plan.. REF: POLICY SP SP1: 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. In relation to the 3 part strategy, I explain why I consider the Local Plan is unsound; (1) I question whether the council have paid due attention to identifying / exploring the potential of brown field sites/areas; particularly those close to, or within town centres. (2) I question whether the council are only in liaison with Aylesbury authority, and not with other authorities across a wider area, to possibly deliver a more dispersed spread for the delivery of housing. (3) Developments of such magnitude as those proposed in the Local Plan would no doubt create detrimental results if provided in Green Belt sites. In particular, the locations are generally away from town centres and on the periphery ± which will generate increased traffic congestion from more vehicle use, and ultimately an increase in emissions and poor air quality. Such developments would necessitate provision of new highway infrastructure to accommodate them; However, this may be prohibitive in both practical and financial terms. Furthermore, some essential purposes that Green Belt designation serves, will be either lost or undermined in the process of development if plans were to proceed in these areas. These are; · To check the unrestricted sprawl of large built up areas · To assist in safeguarding the countryside from encroachment · To preserve the setting and special character of historic towns. With specific regard to Chesham; its local environment and topography, with its limited road infrastructure, does not lend itself to large development plans, due to the nature of its location, being surrounded largely by AONB, steep hills and narrow, winding roads which will not accommodate any necessary highways alterations to support the big increase in traffic that such large developments would create. As Chesham is in effect, a `basin', it is sensitive and susceptible to vehicle emissions being trapped in locations, such as the A416 Berkhamsted Road. This stretch already falls short of EU safe air levels, and thus, is a designated air quality management area, as a result. This is the main route through Chesham and it already bears the brunt of traffic regularly exceeding capacity level.