VALP Main Modifications
Representation ID: 3086
Respondent: Village Foundations
Legally compliant? Yes
In summary we object to the revised wording of policy H1 and the addition of new text that would allow neighbourhood plans made before the adopted VALP to set a different affordable housing requirement.
Removal of text "except where a different requirement already applies in a neighbourhood plan which has been made before the adoption of the VALP".
We object to the revised wording of policy H1 that allows neighbourhood plans made before the adopted VALP to set a different affordable housing requirements.
From attending the hearing sessions and looking at the evidence base for the local plan it is clear that a district wide affordable housing target of 25% is reasonable. This is considered a realistic and achievable target in order to deliver affordable homes as part of market housing led developments.
The percentage of affordable housing has already been questioned by the Inspector as part of examination of the VALP(Q79) and it is not clear why this modification is considered necessary in order to make the plan sound.
The Inspector questioned whether the requirement for affordable housing should be varied across different parts of the district. Aylesbury Vale District Council full response is contained in examination document ED108A, in summary they stated, "there is no evidential basis for varying the requirement for affordable housing between different parts of the district. It is was considered that affordability is broadly comparable across the district meaning that a variation on an area basis is not justified. The Buckinghamshire Housing And Economic Development Needs Assessment (CD/HOU/004) contained no suggestion that the affordable housing should be varied across different parts of the district".
Some of the existing Neighbourhood Plans across Aylesbury Vale have been adopted with levels of affordable housing of around 35%. These neighbourhood plans were prepared using a different evidence base to calculate affordable housing and as a result could justify a higher level of affordable housing. AVDC has since acknowledged in responding to the Inspectors Q79 that the evidence base used to prepare those neighbourhood plans which contain a requirement for 35% affordable housing is now out of date. AVDC acknowledge that the newer evidence must inform the new local plan when using the prescribed method for assessment on affordable housing. Further details on this matter are contained in examination document ED110.
The Council has robustly defended the 25% target throughout the hearings and the matter did not feature in earlier versions of the Inspectors findings of 29 August 2018.
In conclusion we object to the new wording to policy H1 that "except where a different requirement already applied in a neighbourhood plan which has been made before the adoption of the VALP". Aylesbury Vale have acknowledged that there is a lack of evidence base to vary the levels of affordable housing across different parts of district. Instead, if a neighbourhood plan wishes to go beyond the District wide VALP policy, then it should be justified based on evidence that is more up to date than that which the VALP is based. This would need to be undertaken as part of a review of the neighbourhood plan.