Joining the Bucks Local Plan Dots

The draft Buckinghamshire Local Plan has now been published for consultation with a deadline for responses on 29 October. This is an important step on the road to the Council adopting its first Local Plan covering the whole county and replacing the existing Local Plans.

But, and this is a big but, you have to join some dots to obtain a clear view on what it all means for your town or parish. And as the Council has decided it will head straight to the final pre-submission stage next year this is the main opportunity to make your positions known.

Why? Because by that stage the Council will have tied its colours to the mast in terms of proposing the final spatial strategy and site allocations which will then be subject to examination. Most planning authorities consult on a full draft plan with those allocation proposals in it, but they are not obliged to. Here, the Council had no choice given it has to submit by December 2026 and left too little time to reach this point. Not a great advert for genuine community engagement in Local Plan making.

For towns and villages we see three related problems with all this. Firstly, the spatial strategy (and resultant site allocations) seems to be a fait accompli given the distribution of Housing & Economic Land Availability Assessment (HELAA) sites and housing supply position set out in the table on p38 of Part A.

It suggests that the Council will propose to allocate almost all of the HELAA sites – strategic and non-strategic – as they correlate closely to those seven distinct spatial approaches. The Council has been subtlety signalling this for some time, perhaps more as a threat than a promise, as it railed against the new Standard Method requiring the plan to provide for at least 95,000 homes over the next 18 years.

The spatial approaches are conventional in distributing new development inside and on the edge of existing settlements and to new locations beyond that. Unusually here, they are not effectively proposed as options to choose from but rather as the answer, perhaps with some nuance to increase supply in some places and lower it in others. But if the HELAA shows all available greenfield and brownfield land, there is not much room for manoeuvre.

Which raises the second problem. In counties like this one, which have half their land area in designated Green Belt, there is normally a spatial option that shows the effects of releasing land for development. It also shows the effects on the rest of the area of not releasing land in the Green Belt. The Bucks plan does not do this, indicating that only those sites which make a strong contribution to all three of the five purposes of the Green Belt (A, B and D) may not be considered for release. This could explain the variance in the p38 Table, as the Green Belt Study has not been completed, but again there seems so little flexibility in the strategy (and we’ve not even mentioned the ‘New Towns’ approach).

And thirdly, neither the draft plan nor the Council’s Cabinet report on 9 September acknowledge a role for neighbourhood planning in helping them get this right, from the bottom up as well as the top down. Although the Council has said it will carry out a ‘focused consultation’ with town and parish councils at some point next year, this seems an astonishing omission for a county with one of the highest levels of made, remade and emerging neighbourhood plans in the country (and our research suggests with a far higher number making site allocations than the national average).

It seems inconceivable that a county whose neighbourhood plans in the non-Green Belt areas have done most of the heavy lifting of site allocations over more than a decade would completely ignore this legacy. Instead, it would appear that, contrary to explicit Government guidance (see Planning Practice Guidance §41-043), the Council intends to make every allocation in the final version of the plan. On a purely pragmatic level, we can’t see how the assessment (including Sustainability Appraisal) can process 200+ sites in a year.

We therefore recommend that every town and parish council with a made, remade or emerging neighbourhood plan objects to this oversight and reminds the Council of its duties to support neighbourhood planning and of the relevant national guidance with which it is failing to comply.

Beyond that we think every town and parish council should look carefully at the latest HELAA map on the Council’s website. If you are concerned at the location and potential cumulative effects of many or all of those sites being allocated next year then we strongly advise you make representations.

Finally, a swathe of evidence documents has been published alongside the core documents. It comes to some significant conclusions and/or signals future intention on a number of matters including the settlement hierarchy, highways, infrastructure etc. Town and parish councils should also review the evidence base to ensure that it does not miss an opportunity to fact-check its contents.

For those with legacy or emerging neighbourhood plans, bringing forward a new plan to propose non-strategic allocations and their supporting local infrastructure improvements is as likely to prove as valuable as it did in Aylesbury Vale more than a decade ago.

If well thought through and evidenced those plans should provide an effective way of making representations on next year’s Local Plan and its examination in 2027. For those in the county’s Green Belt the value of having a neighbourhood plan has risen dramatically since February’s ‘grey belt’ planning practice guidance, especially for well-connected village settlements.

In the meantime, given the dire housing land supply position across the county those plans should help maintain the currency of the plan-led system. Securing the benefit of NPPF §14 in retilting the ‘tilted balance’ may never have been so important.

This note is intended as a helpful guide to Buckinghamshire town and parish councils needing a starting point for responding to the consultation. If you require any further assistance then please do not hesitate to contact us for help.