Representations must be submitted by 11:59pm on Sunday 6 September 2026.
This is the publication (Regulation 19) stage — the final opportunity to make formal representations before the Plan is submitted to the Planning Inspectorate for independent examination. Late representations will not be accepted.
Requesting to participate in the examination hearings.
If your council submits a representation, we strongly recommend you also indicate that you wish to participate in the hearing sessions. If that request is not recorded now, there is no later opportunity to seek participation once the Plan has been submitted.
The Plan’s proposals also carry implications for infrastructure and communities in Milton Keynes, and colleagues there may wish to consider a response.
Buckinghamshire Council’s consultation is hosted on the Opus portal. Councils have reported practical difficulties with online consultation systems of this type — sessions timing out, representations having to be split across multiple separate forms, limited scope for attaching supporting evidence, and no reliable copy of what was submitted.
We would suggest that councils consider submitting by email instead, and requesting written acknowledgement of receipt. This gives the council a dated record of exactly what was submitted, allows evidence to be attached properly, and keeps a multi-policy representation together as a single document.
If submitting by email, include everything the online form would have captured:
Use this email address for email responses:planningpolicyteam.bc@buckinghamshire.gov.uk
At Regulation 19 the question is no longer whether a council likes or dislikes what is proposed. Representations should address whether the Plan is legally compliant and whether it is sound. A Plan is sound if it is:
Positively prepared — Does it provide a strategy that meets objectively assessed development and infrastructure needs? Concerns typically arise where infrastructure requirements are not identified, or where growth is proposed without corresponding provision for services.
Justified — Is it an appropriate strategy, taking into account reasonable alternatives, based on proportionate evidence? Concerns typically arise where alternatives have not been properly assessed, or where the supporting evidence is incomplete or out of date.
Effective — Is it deliverable over the plan period? Concerns typically arise around highway constraints, utility capacity, land assembly, or the absence of any clear mechanism for delivering the infrastructure a site depends upon.
Consistent with national policy — Does it enable sustainable development in accordance with the NPPF? Concerns typically arise in relation to heritage, biodiversity and climate policy.
A representation carries weight where it identifies a specific policy or allocation, states which test is engaged, sets out the evidence relied upon, and proposes a precise modification. General objection without evidence carries little.
A recording of the session is available at https://youtu.be/PxWURTYyAVw, and the summary slide is attached.
1. Frame everything around soundness. Responses should be evidence-led and tied to one or more of the tests above.
2. Register your interest in the hearings now. Submit a formal response, request participation, and indicate the matters on which you intend to make submissions. Do this even if your evidence is still being assembled.
3. Neighbourhood planning. ONH’s view is that the draft Plan could give clearer recognition to neighbourhood planning — how made neighbourhood plans will sit alongside the new Local Plan, and how the protections available under the NPPF (currently paragraph 14) will operate in practice. Councils with a made plan may wish to seek strengthened policy wording on this point.
4. The settlement hierarchy. The Plan places settlements into six tiers. The tier a settlement occupies influences where growth is directed, how future applications are determined, and how appeals are decided. Councils should consider whether their settlement is correctly categorised, whether the categorisation reflects its actual role and services, and whether the level of growth proposed is matched by infrastructure capacity.
5. The spatial strategy. The Plan concentrates growth in the north of the county, proposes no Green Belt release in the south, and relies substantially on a small number of large strategic allocations. This is the defining choice in the Plan and merits close attention.
6. Delivery assumptions. ONH’s assessment is that the strategy depends heavily on those strategic sites coming forward broadly as anticipated, with limited contingency in the early years of the plan period. Councils may wish to examine the trajectory, the five-year supply position, and the evidence underpinning the delivery assumptions.
7. Green Belt areas. Although no Green Belt release is proposed, communities in the south should not treat the position as settled. If strategic delivery in the north falls short, and given the operation of Grey Belt policy, villages may still face development pressure. Proactive local planning remains worthwhile.
8. Windfall policy (Policy H10). ONH raised concerns about the clarity of this policy, particularly the treatment of development adjacent to settlement boundaries, the meaning of “exceptional cases”, and what constitutes “community benefit”. Councils may wish to seek clearer wording.
9. Check allocations affecting your area. Review site boundaries, indicative housing numbers, density assumptions and infrastructure requirements against your own local knowledge, and identify any factual errors or omissions for correction.
10. Use the evidence you already hold. Councils with a made or reviewed neighbourhood plan, a settlement spatial plan, housing needs work or other local studies are in the strongest position. Where the Local Plan’s conclusions conflict with that evidence, say so and cite it.
Councils with an up-to-date or recently reviewed neighbourhood plan, or a settlement spatial plan already hold evidence that can be set directly against the Local Plan’s conclusions.
Northern settlements without a neighbourhood plan are the most exposed, given the concentration of proposed growth. Consideration should be given to commencing neighbourhood planning or a settlement spatial plan, and to building local evidence now.
Green Belt councils should continue planning proactively — reviewing existing neighbourhood plans, considering defined settlement boundaries, and assessing how Grey Belt policy may affect future pressure.
For the parish as a whole, and for each allocated site within or adjacent to it:
The Plan as published is not fixed. Councils that engage with the evidence, frame their representations around soundness, and are prepared to appear at examination are the ones most likely to influence the outcome.