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Representations on VALP Proposed Submission - I5 Water resources

Representation ID: 2609

OBJECT Natural England (Ms Kirsty Macpherson)


the only mention of green
infrastructure in the section covering
employment land. There is no
mention of biodiversity.
One of the central aims of this
section is to increase patronage of
the town centre by creating a space
that people want to visit for
socialising as well as shopping.
Providing green infrastructure as
part of this strategy will create a
space that people want to visit,
provide the wellbeing benefits of
access to nature for central town
residents, possibly provide SUDS
and provide shelter for urban

More details about Rep ID: 2609

Representation ID: 2428

OBJECT The Environment Agency (Michelle Kidd)


The Water Cycle Study evidence is unsound as we are not certain from the
evidence in the water cycle study whether the proposed growth for Aylesbury
Vale District will not cause a deterioration in the ecological status of the receiving
watercourses within the lifetime of the Aylesbury Vale local plan.This is a potential concern as without the assessment of the permit limit required to cap deterioration to 3%, we cannot determine if the proposed growth is feasible and compliant with the water framework directive (WFD).

More details about Rep ID: 2428

Representation ID: 2412

OBJECT The Environment Agency (Michelle Kidd)


For consistency, Policy I5 should reference Policy C3 which also lists water
consumption standards and requirements for new builds.

More details about Rep ID: 2412

Representation ID: 2366

OBJECT The Environment Agency (Michelle Kidd)


Site Allocations
We are pleased to see the points J and K in the site criteria for site allocation BUC043.
However we strongly recommend that these points are included in the criteria for all
sites proposed in constrained sewer catchments and STWs. These sites are highlighted
in the Water Cycle Study.

More details about Rep ID: 2366

Representation ID: 2363

OBJECT The Environment Agency (Michelle Kidd)


This policy would benefit from an inclusion of a requirement for developers to provide a foul and surface water drainage strategy (especially important for the strategic settlements and those sites identified as having infrastructure capacity issues). The proposed treatment/destination of the effluent is an important piece of information if potential water quality impacts are to be understood. This can be provided by a drainage strategy.

More details about Rep ID: 2363

Representation ID: 2346

OBJECT The Environment Agency (Michelle Kidd)


Water Cycle Study
Paragraph - Recommendations

A key recommendation for major developments within the local plan is for developers to provide foul and surface water drainage strategies. This is a key piece of evidence that would be expected at the planning application phase at the latest. This should be included within this list of recommendations.

More details about Rep ID: 2346

Representation ID: 2345

OBJECT The Environment Agency (Michelle Kidd)


It is suggested in the Water Cycle Study para that a WFD deterioration in Water Quality at Winslow cannot currently be avoided based on current available technology. It is not clear if this is the permit required to limit the phosphate deterioration to 3% within bad status. If a within 3% deterioration cannot be prevented it may be a limitation to the proposed growth which needs to occur within environmental capacity. The Water Cycle study has not identified what permit limit would be required to prevent these 'within bad' deteriorations.

More details about Rep ID: 2345

Representation ID: 2344

SUPPORT The Environment Agency (Michelle Kidd)


We are pleased to see that the local plan (in Policy I5) embeds a requirement for
developers to provide evidence that they have communicated with the sewer undertaker to ensure there is available capacity in the network and at the treatment works. This ensures timely infrastructure planning and helps to avoid capacity issues such as sewer flooding and more frequent combined sewer overflow (CSO) spills.

More details about Rep ID: 2344

Representation ID: 2343

OBJECT The Environment Agency (Michelle Kidd)


Water Cycle Study evidence suggests that it is not possible to prevent a phosphate deterioration at Buckingham STW. However in Appendix B section A.8.1 it suggests that there will not be a 10% or a WFD status deterioration from the present day to the future growth scenario. This is contradictory and needs to be clarified as the executive summary suggests growth at this works will result in a failure to meet the objectives of the water framework directive (WFD). This could suggest that the growth planned for this works cannot occur without non-compliance with the WFD which would be unacceptable.

More details about Rep ID: 2343

Representation ID: 1822

OBJECT Wates Developments Ltd. represented by Boyer Planning Ltd (Jonathan Liberman)


The capacity of wastewater treatment works is the responsibility of the utility provider and as such we would recommend that criterion (c) is deleted as it is misleading.

More details about Rep ID: 1822

Representation ID: 1508

OBJECT Anglian Water Services Limited (Planning Liaison Manager


Reference is made to planning applications taking account of the capacity available at wastewater treatment works but is unclear what is being required of applicants and how this would be assessed as part of the planning process. It is considered that it could be the requirement for applicants should be clarified to make the policy effective.

any application to vary a permit would be made by the relevant sewerage undertaker to the Environment Agency. As such it unclear whether it is necessary to include a requirement for a flood risk assessment as this does not relate to planning application process.

More details about Rep ID: 1508

Representation ID: 1443

SUPPORT Thames Water (Sir/ Madam )


Support Policy I5 on Water Resources and all the supporting text from paragraphs 11.32-11.36

More details about Rep ID: 1443

Representation ID: 1228

SUPPORT Berkshire, Buckinghamshire & Oxfordshire Wildlife Trust (Mr Neil Rowntree)


We support these policies which are necessary in order to comply with NPPF requirements regarding biodiversity and the natural environment, and the NERC Act (2006) duty with regard to biodiversity. If proposals are made to modify them we would welcome the opportunity to discuss if that affects their soundness in our opinion.

Note that we are aware that the Natural Environment Partnership (the NEP, which is the equivalent of a Local Nature Partnership in Buckinghamshire) is asking for a modification with respect to the supporting text of Policy I1 Green Infrastructure.

More details about Rep ID: 1228

Representation ID: 891

OBJECT Buckingham Town Council (Mr Christopher Wayman)


There is failure to consider essential evidence brought forward in the Water Cycle Study. If Buckingham is to remain a strategic settlement, a clearer policy as to how to upgrade WwTw needs to be provided if deliverability and viability issues are to be met, and to justify the additional allocation within the deliverability timescale set out. Otherwise Buckingham will lose out on other essential infrastructure from developer contributions/viability concerns.

More details about Rep ID: 891

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