28-Aug-2019

Local Plan Consultation,
Aug 2019

How to respond (below)

The new local plan may be found here, together with the (not particularly rigourous) Sustainability Appraisal. The purpose of the consultation is to determine whether the Draft Plan is Legal and Sound - as described here.

A Sound plan must be Positively Prepared, Justified, Effective and Consistent with National Policy, and it can be argued that the worst aspects of the draft plan fail one or more of these tests - see the sample responses, below. A Legal plan is one which complies with various statutes. This is a technical issue, best decided by lawyers, and we recommend that you ignore the legality of the plan - unless of course you are a lawyer who specialises in planning. It is hard to see why this question has been included in the consultation, unless it is to dissuade lay people from responding.

How to respond

The SBDC website lists four methods of responding to the plan - via their portal, an online form, a printed form or a letter. Brown not Green have discussed the different methods (here), and recommend downloading their version of the (11 page) form, which can be completed using an editor, e.g. MS Word. (A completed example is also available.) As this version does address the legal questions, it is still rather long and complex.

We suggest that you submit our even simpler (word) document, outlining the main reasons for finding the plan unsound, while avoiding the legal technicalities. This indicates that you support those local organisations who have made detailed submissions on various aspects of the plan, which should increase the weight given to them. You may wish to add other reasons to our short list of defects, or expand on the justifications given.

Hints

Alternatively, you may send an Email to planning, or a written response to

Planning Policy Team
King George V House
Amersham
Buckinghamshire HP6 5AW

Responses

The Chesham Society response relies on, and seeks to promote the responses of the organisations we have been working with. It may be found here.

Other responses -

Chesham Society Meeting, 15-Aug

This was a well attended meeting with presentations by the Chesham Society, and Brown not Green. Speakers included representatives of Chesham Renaissance, and Chesham Town Council.

Why to respond ?

Where to start ? The draft plan appears poorly constructed, ignores previous consultations, and the outcome for Chesham appears particularly dire.

Policies affecting Chesham

Listed below are the policies and proposals most directly linked to Chesham. (This does not imply that the remainder of the plan is entirely unobjectionable )

SP LP1 (p54), SP BP2 (p156, below)
Homes - Site Allocations (for 5200 additional homes)
SP EP1 (p72)
Enterprising - retail. The council 'will aim to retain and enhance main town centre uses'
6.2 Enterprising - Retail Need (p74)
The studies identify a number of possible locations for new retail-led development within town centres. (6.2.10,11), also SP EP3 p 77-
3) Star Yard / Darvell's Bakery
4) Coal Yard and Station Car Park, Chesham

the only potential development sites that would be physically capable of accommodating a food store of between 2,000 and 4,000 square metres gross are (6.2.12):
2) 31 Red Lion Street, Chesham (Watermeadows Surgery & Job Centre)
SP EP2 (p76) - Retailing Allocations
These proposals would increase the retail capacity in the Chesham - Prestwood area from 1294 to 1812 sq. m., providing lots of space for new charity shops.
DM CP6 (p102) 'Connected - Areas of Change'
Chesham Town Centre Transport Interchange -
Creation of a public, cycle and pedestrian transit interchange at Chesham Station with improved facilities
and connectivity to the High Street.
DM NP7 (p140) - Chesham Flood Alleviation
Planning permission will be granted for development within Chesham provided that it improves the management of surface water and reduces the risk of localised flooding
9.10 Natural - Air Quality (p145)
There are three Air Quality Management Areas (AQMAs) in the Plan area:
Chesham, encompassing buildings along parts of Broad Street and Berkhamsted Road;
Given the scale of development planned for over the Plan period, it is likely that there will be an increase
in the amount of car emissions and other airborne pollutants being produced... The Council will require applicants to submit an assessment of air quality as part of applications requiring a Travel Plan or Transport Assessment
. (9.10.4)
10 (Un)Protected Places (p149)
National policy allows for Green Belt boundaries to be altered through the preparation of a Local Plan,
where exceptional circumstances exist. The Council ... has concluded that the locally identified needs cannot be met without some Green Belt release.
(10.1.4)
... villages ‘washed over’ by the Green Belt were assessed to consider whether they met the criteria in national policy for continued inclusion in the Green Belt. This assessment concluded that twelve villages should be removed from the Green Belt (10.1.6)
SP PP1 (p150)
To help meet identified housing and employment needs 7.83 sq.km of land has been removed from the
Metropolitan Green Belt.
... the following villages [that] have been removed from the Green Belt
:
Botley, Denham, Dorney Reach, Higher Denham, Hyde Heath, Jordans, Ley Hill, Little Kingshill, South Heath, Tatling End, Wexham Street, Winchmore Hill
DM PP1 (p151) Infilling within Villages
Planning permission will be granted for infilling within the listed villages washed over by the Green Belt :-
Ashley Green, Ballinger Common, Bellingdon, Buckland Common, Chartridge, Chenies, Cholesbury, Coleshill, Dorney, Fulmer, Hawridge, Hedgerley, Hedgerley Hill, Little Missenden, Penn, Penn Street, Taplow, The Lee – Lee Common, The Lee, Whelpley Hill
SP BP2 (Lye Green Development) p156
Land to the north-east of Chesham, as shown on the Policies Map, is allocated for approximately 500 homes,
other facilities and 15 pitches for Gypsies and Travellers. See also 11.3 p155

Response - Hints

In addition to our own observarions, this section relies on comments from Brown not Green and Chesham Renaisance, and minutes of the Chesham Town Concil planning committee.

See this example of a completed response form. Any response may wish to address some of these points -

You may well find other aspects of the plan on which to comment. These should be made with regard to the Measures of Compliance - Legality and Soundness. While illegality may be difficult to demonstrate, tests for Soundness include -

Is it Justified ?
"An appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;"
It could be argued that the alternative proposals advanced by Chesham Renaissance have not been taken into account, and nor has the evidence supplied by Brown not Green regarding Green Belt status
Is it Effective ?
"Deliverable over the plan period". Deliverability is called into question by the failure to address existing infrastructure problems, and upgrade facilities to cope with increased demand.

If this plan is adopted in its present form, it will control planning decisions for the next 20 years, potentially inflicting great damage on Chesham and the surrounding areas. Now is the time to resist these proposals, and send the planners back to produce a plan which helps solve local problems, rather than making them worse.