9-Aug-2019

Chiltern and South Bucks
Local Plan consultation

Why is it such a mess ?

Numbers

The plan aims to accomodate an additional 11,000 homes in the plan area (after 5,750 have been passed on to Aylesbury Vale under the duty to cooperate). This number is provided by the "national standard methodology for calculating local housing need" (5.1.5 p51), but the methodology, and the data used to arrive at this number, are not disclosed. Consequently it is not clear whether the number of houses required, or their distribution, will change following the establishment of the new Bucks Unitary Authority next year.

Page 2 fig .. helpfully indicates that 88% of the plan area is currently Green Belt, leaving just under 42 sq km of non Green Belt land to accomodate the new housing. Clearly there will be problems

Duty to cooperate

The duty to cooperate was introduced by the Localism Act 2011, and is set out in section 33A of the Planning and Compulsory Purchase Act 2004. It places a legal duty on local planning authorities and county councils in England, and prescribed public bodies to engage constructively, actively and on an ongoing basis to maximise the effectiveness of local plan ... in the context of strategic cross boundary matters.

While there is evidence of cooperation with AVDC, there is no reference in the plan to any discussions with other neighbouring authorities regarding cross border cooperation.

Resources

Water

Clearly one of the most urgent problems confronting the Chilterns AONB is a shortage of water, as described in the report "Chalk Streams in Crisis". This is speedily delt with in section 9.6 - "Natural - River Character and the Water Environment" which notes (9.6.2) "The Misbourne, Chess and Colne provide internationally-rare and important chalk stream habitats that are identified as priority habitats in the Buckinghamshire Biodiversity Action Plan." and (9.6.4) "Reducing per capita demand is key to improving flows in the catchment’s chalk streams to ensure their survival for future generations." This is to be achieved by policy DM DP20 -

Design – Residential Water Standards
Planning permission will be granted for new homes provided that they meet the higher water efficiency standard set out in Approved Document Part G of the Building Regulations or any subsequent replacement.

This seeks to limit water consumption to 110l/person/day, by specifying the maximum permitted consumption of the various fittings consuming water. While it remains legal to instal a shower pump, or replace a dishwasher, this does not appear to be a robust solution to the problem.The use of alternative water sources - harvested rainwater, reclaimed greywater - may also be used to reduce consumption of 'Wholesome Water', but is not mandatory.

The Strategic Assessment SA13.1.2 states (the obvious) "The Plan area is identified as being under serious
water stress, new developments within the Plan area will increase demand of an already stressed resource.
"

Box 13.3 (SA p124) advises
"Neither the DM nor SP policies refer explicitly to increased stress of the water resource. Para 20b of the NPPF states that “policies should make sufficient provision for infrastructure for…water supply. Para 22 further states that policies should look ahead over a minimum 15-year period…to anticipate and respond to long term requirements and opportunities”.
Recommendation: New residential developments will meet the higher water efficiency standard (110 litres per person per day)"

However, while the developments may meet the higher water efficiency standards, the occupants may not. The only possible solution would be to limit the sale of new dwellings to people with low standards of personal hygine, which might prove a difficult policy to implement.

Sewage

There are two references to sewage in the plan -

which suggests that the planners are in denial regarding the capacity issues at the Chesham treatment works.

SA N49 (page xviii) expresses concern regarding pressure on the Maple Lodge STW, but otherwise disregards the issue entirely.

 

Road Space

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 exisiting 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, p-xxxiii):
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.

Again, the impact of increased traffic volumes on the already existing congestion has been ignored.