[HTS-members] Local Plan report

Fri Jul 12 22:14:15 BST 2019

Dear residents,

THE DRAFT LOCAL PLAN

Taplow Parish Council set up a working party to develop a Neighbourhood Plan
for Taplow. It contains representatives from the Parish Council, the Hitcham
and Taplow Society and the Ellington and District Residents Association.

The working party has been assessing the Draft Local Plan (DLP) for South
Bucks and Chiltern that is in consultation until July 19th

We thought it might be helpful to circulate a list of items in the Plan that
we are minded to object to, having taken some professional advice on the
points.

Objections have to be very clearly based on certain criteria:

LEGAL COMPLIANCE
SOUNDNESS
DUTY TO COOPERATE

To have a useful effect, an objection also has to provide a proposed remedy
for the complaint.

Listed below are headlines of these objections. More detailed reference to
the Plan content is in attachments.

Links to important documents and how to object are listed below, followed by
more detail on our objections.

(We are sending this to various Taplow circulation lists so you may receive
it more than once.)

Objection Topics (detail covered at bottom of this document)

*       Housing Figures for Taplow neighbourhood Plan are wrong

*       Sports facilities are not named in the section 7 Connected Places

*       Requirements for Transport Assessments are too high and too flexible

*       Travel Plans should be tested before any approval

*       Cycle parking not fully covered

*       Car parking standards are poor

*       Proposed land use at Taplow Station for office use is incompatible
with policies to limit traffic growth.

LINKS
https://www.southbucks.gov.uk/planning/localplan
The Plan, an independent assessment "The Sustainability Appraisal" and a
summary of changes from old plans "Policy Changes Mapping". Also covers how
to object (You can just send an email but you should use the headings
advised).
https://www.southbucks.gov.uk/EiPform 
A pro-forma submission form 

Re; Housing figures objection;-
https://www.southbucks.gov.uk/planning/other-housing
Carries the Settlement Capacity Study which defines housing allocations by
parish. Used for our Housing figures objection.

https://www.southbucks.gov.uk/planning/helaa
The HELAA tables carry all the information on identified sites

Re; Non-residential Car Parking Standards objection;-

https://www.southbucks.gov.uk/media/3556/Local-Plan-Consolidated-Feb-2011-/p
df/Local_Plan_(Consolidated_Feb_2011)_.pdf?m=635264199679000000

Appendix 6 quoted is on page 183 -  re 1.1 and 1.4 

Re; Taplow Station land objection;-
https://www.southbucks.gov.uk/Infrastructure
Carries the Infrastructure Delivery Schedule which supports the Plan with
road works etc. Used for our Taplow Station land objection.

Good luck!

The Taplow Neighbourhood Plan Team

Objection Topics details

.            DLP 5.12 Appendix LP1 - Housing Figures for Taplow
Neighbourhood Plan area

This entry is obviously a clerical error. The actual figure is 431 taken
from the Settlement Capacity Study, (pages 5&107). A query to SBDC changed
this (unpublished) to 427. We object that the whole data needed to calculate
the number is in Council files not pointed to in the Evidence Base, making
checking impossible. 

.           There is also an invalid entry of 24 houses which we contend
must be removed.

Also the "windfall" allocation is wrongly calculated. The allocated 43
houses is across the whole Plan period whereas the full housing requirement
(LP page 53) shows that only 5 years windfall allowance is needed which
should be 12 houses.

.            DLP Appendix CP1, CP2, CP3 and 7.9.12    - Transport
Assessment, Travel Plans, Parking Standards

Sports facilities are not named in section 7 Connected Places (e.g.
categories listed in Appendix CP1, CP2, CP3 and 7.9.12 "Land Use - New
Developments") and requires to be as in the current Plan otherwise this is
not justified. 

.            DLP 7.1 Appendix CP1 & CP2         - Transport Assessment,
Travel Plans

Thresholds based on size of development proposals before Transport
Assessments and Travel Plans require to be undertaken are much too high and
are unsound so should remain without thresholds being required as is
currently the case.

.            DLP 7.7.1              - Transport Assessment

The Transport Assessment can be reduced by the Council dependent on
circumstances and at the Councils discretion which should not be allowed as
guidelines are meaningless if they are not required to be adhered to and
those affected by the development are rendered unable to contest it. This is
therefore unsound.

.             DLP 7.8.10           - Travel Plan

A minimum period of 6 months should be operated for a Travel Plan measure to
determine whether a Travel Plan measure is feasible before its approved /
planning permission granted - as the permission will have already been
granted and the development built once a Travel Plan is established its
unfeasible so too late then to do anything about it making this unsound.

.           DLP Appendix CP3              - Cycle Parking  

Sports is not named in CP3, however Public Sports Facilities was in the
draft and so why now omitted? - and thus it requires to be reinstated;- in
the draft it had 1 space per 5 staff (or other people) 1 space per 100 sq
mts. If not reinstated its omission cannot be justified.

.           DLP 7.9.12   - Non-residential Car Parking Standards

A parking standard basis should be on Gross Floor Area (GFA) as default and
the "staff/consultation room where indicated" to be removed as the GFA
requirement for parking needs shouldn't be allowed to be undermined which
would therefore make it unsound. The GFA should stipulate includes floors on
all levels as it is in the current Local Plan (1.4) Appendix 6 - Parking
Standards.

.           DLP Table 7.9.12         - Non-residential Car Parking Standards

The DLP does not contain what the alternative to the 'optimum' requirements
is and whilst local circumstances could justify a deviation, the deviation
should be capped at a 10% reduction in the optimum parking standards in
Table 7.9.12. in order to make it sound as that would align with the current
Saved Local Policy Appendix 6 (of +10% of the operational minimum standard).

.           DLP SP BP14 - Land Adjacent to Taplow Station

The original approval for removal from the Green belt did not contain a
traffic assessment. The full Plan now shows that the A4 must be widened to
accommodate the development. (Infrastructure Delivery Schedule p24,25). This
is contrary to the Strategic Policy of modal shift away from private car use
and also produces unacceptable further load to the grossly congested A4.
Modification to the site zoning is suggested

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