Buckinghamshire Council has invited all residents and stakeholders to contribute comments to a consultation on its draft Local Plan. The consultation CLOSES on Wednesday 29th October.
Below PCA explains why having an up-to-date Local Plan is so important, and gives its initial observations on the current draft.
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What is a Local Plan, how does it fit into the planning process?
Why should we care?
The current context – Buckinghamshire
PCA’s initial observations
Link to main Local Plan page on Buckinghamshire Council website. Includes links to:
Part A: The Local Plan vision, key planning issues facing Buckinghamshire and associated objectives, and spatial strategies for housing, travelling communities and employment.
Part B: Development Management Policies
Here’s where you can add your voice: Link to Local Plan consultation page
If you would like to discuss this with PCA, ask any questions or make suggestions, please e-mail us. PCA is also looking for a volunteer with planning expertise to join our Committee and lead our work on planning issues.
Please e-mail us on info@prestwoodcommunity.uk.
What is a Local Plan, how does it fit into the planning process?
Planning policy in England is set at several different levels. At the top is the ‘National Planning Policy Framework’ (NPPF), the latest revision being in December 2024. The NPPF provides a framework within which locally prepared plans can provide for housing and other development in a sustainable manner.
‘Development plans’ include local plans and neighbourhood plans, and spatial development strategies. The development plan usually consists of a local plan, setting out agreed planning policies for the local area. It includes a mix of policies relating to vision, strategic aims and objectives, and policies to achieve these, whilst also delivering appropriate balance. Development plans cannot ignore national policy – they must be drawn up taking into account the NPPF, and be examined and approved by the Planning Inspectorate. Planning law requires that applications for planning permission should then generally be determined in accordance with the development plan. This is what Buckinghamshire Council’s present consultation is all about.
Why should we care?
Let’s consider what happens if a Local Authority doesn’t have an up-to-date Local Plan in place.
Paragraph 11 of the NPPF states that where there are no relevant development plan policies, or they are out of date, then permission should be granted, subject to any judgements relating to policies within the NPPF.
We in Prestwood have seen this in the case of the recent planning application on Greenlands Lane. The applicants’ King’s Counsel insisted that ‘limited weight’ should be given to the Development Plan – “It will be the examination of any proposal against the replacement NPPF that will be of much greater relevance and weight”. Without an up-to-date development plan, applicants take the opportunity to argue that local planning policy should be accorded little weight, and effectively set aside.
Partly due to the creation of a unitary Council in 2020, Buckinghamshire does not have an up-to-date Local Plan. Planning officers in different ‘heritage’ authority areas have to operate with a variety of plans, some quite aged. In our locality, the Chiltern Local Plan was adopted as far back as 1997, with alterations in 2001, and ‘consolidated’ in September 2007 and November 2011.
The new, revised NPPF was published in December 2024. This caused particular concern in rural communities through its setting of conditions under which Green Belt land can be opened up for development. It spelt out a requirement to look at Green Belt sites if development needs cannot be met on non-Green Belt land. It introduced the concept of ‘Grey Belt’, previously developed or low-quality land within the Green Belt that does not strongly contribute to the Green Belt’s purposes. This is especially relevant to Prestwood which sits within the Chiltern National Landscape (formerly known as AONB) and with significant areas of Green Belt.
To put it plainly, without an up-to-date local Development Plan, and with the new guidance of the NPPF, Prestwood is vulnerable.
178 letters of objection to the Greenlands Lane application says that our community DOES care. But however strong the community’s response, sheer number of objections from the public is simply not a consideration in planning decisions. However, you CAN input your views proactively by contributing to the consultation.
The current context – Buckinghamshire
In Buckinghamshire Council’s words, the “new local plan will set out how we plan to manage future growth across Buckinghamshire. It will show where development can happen and protect places where it needs to be carefully controlled.
It will set out what new development must do, such as:
- building the right number and size of homes
- allocating land for new jobs
- creating good places to live – including shops and public open spaces
- contributing to the infrastructure people need – such as roads, schools and health facilities
- helping to address climate change, protecting and preserving our most valued landscapes and habitats.”
Housing targets
Buckinghamshire Council also has to respond to Government dictate as to overall building targets. The revised NPPF sets down a calculation for assessing housing need. For Buckinghamshire, the requirement is 4,332 dwellings per annum, or around 95,000 over the plan period to 2045. With just over 22,000 homes committed for development from existing local plans, neighbourhood plans and planning permissions, Buckinghamshire Council says it is looking for a further 69,000 new homes.
The draft plan identifies seven strategic approaches for development, and potential for new homes. Of these seven, ‘Limited Expansion of Villages’ is expected to provide 13,000 to 15,000 new homes, between a fifth and a quarter of the total. This approach is said to focus on development in more sustainable rural villages both within and outside the Green Belt. This is obviously the strategy of most relevance to our community.
Expanding Villages – pros and cons
The draft plan presents a list of ‘pros’ and ‘cons’ to expanding villages. Significantly, the ‘cons’ are much more numerous than the ‘pros’.
Pros:
- Helps sustain existing facilities and infrastructure in the village.
- Helps to meet local housing needs for the village community.
- Provides good access to high-quality natural areas.
- May provide small scale new and upgraded sport, recreation, health and community facilities.
- Has scope for limited small-scale employment development e.g. small-scale offices or other ‘neighbourly’ employment uses.
- This approach could avoid overloading one settlement or part of the road network.
- Could assist with rural diversification and rural employment.
Cons:
- Would require the allocation of greenfield sites.
- Cannot meet our housing needs in full.
- Could adversely impact on high quality landscape.
- May have adverse recreation impacts on our protected environmental areas and will therefore require mitigation which may be harder to deliver through small scale sites.
- Services and facilities may be limited in the established settlement, development is unlikely to provide significant improvements.
- Unlikely to have access to existing frequent public transport, development will be of a scale which is unlikely to provide significant public transport improvements.
- Small sites are unlikely to significantly contribute to infrastructure improvements.
- Unlikely to benefit Buckinghamshire’s key growth sectors.
- This approach can be viewed as ‘pepper potting’ and not strategic.
- Likely to encourage continued car use and increase commuting by car and travel to access services and facilities, particularly if the village is away from main transport corridors.
- Potential impact on village character needs to be carefully managed.
PCA’s initial observations
PCA will be making a submission to the consultation. This will concentrate on issues relating to Prestwood and similar communities, in particular housing, transport and environmental protection.
PCA recognises that Prestwood will need to accept its share of additional development over coming years. PCA welcomes the very comprehensive nature of the draft Local Plan, and the framework by which planners and developers can seek to achieve a balance between development and protection of Buckinghamshire’s natural assets.
PCA welcomes also the objective on affordable, accessible and specialist housing, and provision under rural exception sites. (Local Plan Objective 3)
Especially for younger families and the children of residents, affordability of housing is a serious issue. Ultimately lack of sufficiently varied housing will impact adversely on Prestwood as a community.
Sustainability is a key consideration in planning decisions. PCA is very anxious to stress that development in a rural village should be appropriate to its circumstances.
In presenting its strategic approaches for development, the draft Local Plan recognises this issue through its list of pros and cons in relation to ‘Limited Expansion of Villages’.
Leaving aside the obvious threat to landscape within National Landscape and Green Belt, major new development within or on the edge of villages MUST be accompanied by investment in appropriate services, facilities and local transport. Transport is particularly important. Local Plan Objective 8 states, “Aim: To improve connectivity across and between Buckinghamshire towns and villages… by securing new sustainable transport infrastructure, upgrading existing infrastructure and improving digital connectivity”. Considering its size (7,600 residents), Prestwood is already something of a desert in terms of effective public transport.
The final ‘con’, ‘Potential impact on village character needs to be carefully managed’, is very true!
The Chilterns National Landscape covers 27% of Buckinghamshire. Approximately 32% of Buckinghamshire is designated as Green Belt. The updated NPPF contains considerable protections for National Landscape (ie Chilterns). National Landscapes also enjoy protections under other legislation.
Para 189 of the updated NPPF states that “Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, the Broads and National Landscapes which have the highest status of protection in relation to these issues.”
Para 190 states “When considering applications for development within National Parks, the Broads and National Landscapes, permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.”
And despite concerns about the NPPF’s more permissive stance on development within Green Belt, introducing the concept of ‘Grey Belt’, its ‘Golden Rules’ place restrictions and hurdles on how this can be argued by applicants. One of these restrictions is a need for 50% affordable housing on new developments on Green Belt land. PCA notes that the UK Government has recently watered down affordable housing quotas in London in an attempt to stimulate developer activity; it is to be hoped that the NPPF will not dilute further protections on Green Belt.
PCA welcomes the draft Local Plan’s provisions on Biodiversity Net Gain, which in any case is now a legal requirement. Whilst the NPPF does permit compensation for habitat loss through Section 106 contributions or purchases through an off-setting provider, we welcome the statement that this should be a very last resort.
Based on examples and experience within our community, we would urge Buckinghamshire Council to be more robust in ensuring achievement of net gains. It should be aware of and take account of developers stripping a site before application, to reduce the baseline for biodiversity calculation. Where permissions are granted, it should be robust in enforcing conditions relating to biodiversity net gain. We also urge attention to detail in setting conditions, in particular ensuring that landscaping conditions are not open ended and therefore unenforceable.
Finally, PCA notes that the 2021 UK Census stated that Buckinghamshire contains nearly 10,000 ‘long term empty’ dwellings. Could these be part of the long-term arithmetic? 15% of these homes would be roughly equivalent to the target for homes on brownfield land.