VALP Proposed Submission
Representation ID: 1987
Respondent: Edward Ware Homes
Agent: Pegasus Group
Legally compliant? Yes
Duty to co-operate? Yes
Criterion i) states that growth in villages will be according to 'capacity and needs'.
We note that the focus of the NPPF is upon delivering sustainable development, including in rural areas. The NPPF takes a positive approach toward development and calls upon LPA's to find solutions to development and not barriers. Section 7 of the NPPF talks about planning positively for healthy communities and paragraph 55 seeks enhancement of rural communities. The emphasis is to provide the infrastructure to support development, rather than restrict development.
VALP consultation- land at Broadway, Grendon Underwood
Please find the attached representations to the VALP consultation on behalf of Edward Ware Homes. (includes a layout plan for one of the sites and a site boundary plan for the other)
Full text if there is more than the summary:
Paragraph 4.154 seeks to prevent development at medium villages (where it is not allocated) and allow it 'only in exceptional circumstances where it can be demonstrated that sites allocated are not coming forward at the rate anticipated'.
This is not justified and is too restrictive. The NPPF is clear that the emphasis is to boost housing supply. The wording of the policy incorrectly and inappropriately plans for the Council to fail to provide sufficient housing before allowing development to occur at villages. Such an approach is at odds with the NPPF and the approach to achieving sustainable development.
Land east of Broadway, Grendon Underwood
Edward Ware Homes is promoting a circa 3.5ha site located to the south of the village, located behind development off Main Street (see enclosed plan) for residential development.
The site was the subject of an outline planning application (ref 16/03170/AOP) and a dismissed appeal (ref 3169545) for 82 dwellings.
The appeal Inspector concluded that thatproposed development would result in a significant harmful impact on the character and appearance of the landscape and setting of Grendon Underwood.
However, in Common Ground, the Council accepted that:
* *The site is in a sustainable location for housing development in principle,
* *Grendon Underwood has a range of services and facilities that make it a sustainable location for housing,
* *The provision of 82 dwellings at the village was acceptable in principle,
* *There are no technical reasons (e.g. agricultural land, highway, ecology, flooding or drainage) that would prevent the development
The appeal Inspector did not reach a different conclusion on the above points. Thus, the acceptability of the site in principle to provide housing,is firmly established.
Given our comments regarding the need to increase the housing requirement andthe futureneed to increase housing numbers in response to the standardised methodology, we suggest thatadditional sites need to be allocated in the VALP and the site should be identified for residential development.
In response to concerns raised by the Inspector we have enlarged the site areafrom that of the application and appeal to include additional land to the southso that:
* *Residential developmentparcelsretainand respondto the Public Right of Way
* *Views from the PROW of the church retained
* *Additional public open space and landscaping is provided, to create a stronger landscape screento the site and village edge
* *Public open space adjoining the existing playing fields and playground
As such, the landscape harm that the Inspector identified can be reduced, and the site canhelp meet the housing shortfall.
A framework plan showing the enlarged site area and a suggestion of how development could be provided on the site is submitted.
We consider that medium villages should deliver more housing development than the Plan currently proposes and that this site presents an ideal opportunity to help meet housing need. The site is deliverable and can come forward very quickly.
Land to the south of Darley's Close, Grendon Underwood
Edward Ware Homes also has an interest in land south of Darley's Close. All, or part of this site could be allocated for residential development.
The site adjoins the existing settlement boundary and is in close proximity to local services.
Policy D2 is too restrictive and seeks to limit development on sites not allocated by the Development Plan to 'small scale areas' within built up areas. There is no definition of 'small scale' and we would suggest that in any case, trying to establish a definition would be fruitless as one would expect different definitions depending upon whether a site is in a village or one of the strategic settlements.
The supporting text at paragraph 4.122 says that unallocated sites will not normally be permitted on the basis that the level of growth is being met by proposed allocations. But the housing requirement should be expressed as a minimum figure and the NPPF is very clear that a fundamental objective of the planning system is to boost housing supply.
The policy is therefore unclear, inappropriate and unjustified and is likely to restrict development that constitutes sustainable development.
The policy does allow flexibility for sites to come forward where delivery of housing is failing, but we consider that it is not appropriate for the VALP policies to plan to fail. The NPPF is very clear that the emphasis should be to meet the full objectively assessed needs.
In addition, the policy states that additional development will 'only' be permitted where housing delivery is not being maintained. This does not allow for the proper balancing exercise to be undertaken whereby positive material considerations should be balanced against any conflict with the Development Plan.
Criterion e) requires that development should not 'adversely affect its character and appearance '. However, all development is likely to result in some harm, however limited that harm is.
Similarly, in respect to criteria f)and g), it will not always possible to retain all natural features on a site or have no adverse impact on environmental assets. Therefore, the policy should be worded flexibly to take account of this.
Policy H6 proposes that all new residential development should meet Category 2 of Approved Document M, that 10% of market housing should meet Category 3 and 15% of affordable housing should meet Category 3.
NPPG (56-002) requires that these optional standards can only be justified where the Local Planning Authority has gathered evidence to demonstrate the need.
Whilst the HEDNA suggests that these needs are likely to increase, there is no justification currently for requiring 10% of market housing to meet Category 3 in response to the need for 2.3%; or for requiring that 15% of affordable housing should meet Category 3 in response to the need for 7.1%.
Furthermore, the provision of extra care units has not been tested in the Viability Assessment and as such the effects of this policy are unknown.
The opportunity for such extra care accommodation could be provided at the new settlement/s once these are identified in the early review.
The policy encourages specialist types of housing at 'all residential schemes'. This appears to leave sufficient flexibility but we are concerned that the policy approach is 'subject to taking account of viability'. This suggests that even very small schemes may have to disprove that it cannot include specialist housing.
Such provision should be supported within policy but there is currently no justification for the levels of provision identified in Policy H6
Policy S2 makes provision for a total of 27,400 homes. The VALP should make provision for at least 33,350 homes to address the rounded OAN (of 24,000), the rounded unmet need (of 8,950) and the unmet need of Luton (of 400).
These figures will almost certainly increase significantly, once the standardised methodology becomes part of national policy and so additional provision should be supported or planned for (including through early review). The standardised methodology identifies an annual local housing need of 1,499 in Aylesbury Vale and 3,039 across Buckinghamshire. This compares to the proposed annual housing requirement of 970 in Aylesbury Vale and 2,310 across Buckinghamshire.
Therefore additional mechanisms will need to be identified now to address the resultant shortfall. This will need to include the identification of new sites in the Plan and through the proposed early review.
The wording of the policy will also need to be reviewed, as it states that provision will be made for 27,400 homes when paragraph 3.17 identifies that 29,016 homes have already been identified. This means that the policy as drafted will be ineffective and that it will be instantly obsolete.
The policy identifies only 1,095 dwellings to be delivered at the 19 medium villages. The medium villages are therefore accommodating quite limited growth and we consider that this figure, referred to by criterion 'h)', should be expressed as a minimum figure.
Presenting the figure as a minimum is important because, as stated above, the housing requirement is likely to increase and additional housing sites will need to be found.
Relatively limited growth is being proposed at the medium village and we consider that additional sites exist at these villages to support their sustainable growth and also help deliver the required housing. Sites at medium villages can make an important contribution to early housing delivery as they provide a different product to larger urban extensions and can often be quicker to deliver.
Paragraph 3.16 states that the future growth of medium villages reflects the capacity of these settlements to accommodate development. We question what this capacity is based on. For example, the Settlement Hierarchy (September 2017) evidence paper confirms Grendon Underwood to have a population of 1,111 and to meet 7 of the sustainability criteria.
In comparison, Maids Moreton has a population of 847 and meets 6 criteria, yet 170 dwellings are to be allocated at the settlement.
We are concerned that the viability of providing electric charging points has not been assessed.
Furthermore, whilst we support the move toward electric vehicles, our experience is that trying to require this via planning policy is problematic. For example, there is no single 'charging point' design and different vehicles use different charging plug types. Future land ownership issues on sites when the properties are sold can cause problems for the routing/laying out of charging cables, and requiring communal charging creates problems with electricity billing and management of parking spaces for EV vehicles.
In addition, EV technology is also moving very quickly and any local plan policy that is too specific is likely to become outdated very quickly. Wireless charging is being developed for example, destination charging is increasingly important and it is also predicted that people will own and drive cars differently in the future.
Consumers are also buying EV's in ever greater numbers, and it is not considered necessary, or appropriate, for planning policy to be over prescriptive in this regard.