Aylesbury Vale Area

Object

VALP Main Modifications

Representation ID: 3096

Received: 17/12/2019

Respondent: Clifton Kirstie (Bovis Homes Limited)

Agent: Define Planning & Design

Legally compliant? Yes

Sound? No

Representation Summary:

The recent refusal of full planning permission by Milton Keynes Council (MKC) for the roundabout infrastructure to support the implementation of the development at Salden Chase (site allocation D-NLV001) on the grounds of insufficient evidence to mitigate the harm of this development, clearly puts into question the ability of this site to deliver dwellings over the plan period. It is evident that delivery would be delayed significantly compared to the purported VALP housing trajectory and further flexibility is required through the allocation of more sites or increased capacity of existing allocations that have been assessed as suitable for development.

Change suggested by respondent:

Amend delivery assumptions for D-NLV001 to appropriately reflect current planning status.

Full text:

It is acknowledged that a resolution to approve the outline planning application for Salden Chase (site allocation D-NLV001) was given in April 2019 subject to a S106 Agreement that is currently being negotiated (Application Ref. 15/00314/AOP). However, the recent refusal of full planning permission by Milton Keynes Council (MKC) for the roundabout infrastructure to support the implementation of the development (Application Ref. 15/00619/FUL refused 15th November 2019 on the grounds of insufficient evidence to mitigate the harm of this development), clearly puts into question the ability of this site to deliver 150 dwellings in the period 2018-2023 and a further 1,705 dwellings between 2024-2033 (as summarised in the attached VALP Housing Trajectory Overview - Figure 1).

Evidently, the refusal of full planning permission relating to highways and access specifically will have considerable repercussions for the deliverability of Salden Chase, as proposed to be allocated through MM074. Quite simply, if an access arrangement is unable to be negotiated, then the site is not deliverable. In this event, there is a chance that the site may not come forward whatsoever, and thus 1,855 dwellings may be lost from the projected housing supply for the District (as illustrated in the attached VALP Housing Trajectory Overview - Figure 2). In this event, AVDC's supply of housing in the plan period would fall to 28,378; falling below the VALP's housing requirement of 28,600 dwellings. In this light, the refusal of permission also puts into question the soundness of the VALP, particularly in relation to deliverability of housing to meet the area's significant housing requirement.

Even if development were to come forth at Salden Chase, the housing trajectory set out by AVDC in MM074 is entirely unreasonable in light of the anticipated delays relating to this recent refusal. Indeed, the presence of clauses within the draft S106 Agreement that make reference to highway arrangement plans that have been submitted and subsequently refused by MKC suggest that the two applications are interdependent. That is, the S106 Agreement relating to the residential-based outline planning application cannot realistically be signed until full planning permission is granted by MKC in relation to the development's highways arrangements.

As it currently stands, it is unclear how long this may take; the applicant must reconsider the highway and access arrangements in light of the recent refusal, seek consultation from the Highway Authority, submit a new full planning application and be given full approval. Only then could a S106 Agreement with AVDC be signed. Even after this, the client must discharge conditions, prepare and submit Reserve Matters, await their determination, discharge pre-commencement conditions, undertake site remediation and preparation, as well as deliver supporting infrastructure (including highways infrastructure), before the first dwellings are delivered on site.

Thus, it is evident that delivery of Salden Chase would be delayed significantly compared to the purported VALP housing trajectory. The application of the assumptions put forth by the findings from Lichfields' Planning Matters: Driving housing delivery from large sites: What factors affect the build out rates of large scale housing sites? ("Planning Matters") can provide a reasonable assumption of the delivery of the site in light of this refusal. That is, the report suggests that the average Total Development time (to the first on-site delivery) is 7.5 years for sites between 1,000 and 1,999 dwellings. Given that highways arrangements require re-negotiation and that the residential application may require amending in this light, this assumption appears reasonable. That would suggest that the site would begin delivering in 2027/28; six years later than the VALP's contention. Furthermore, Planning Matters indicates an average build out rate of 50 dwellings per developer. Given that four housebuilders were involved with the outline application, this would limit the peak build out rate to 200dpa.

Applying these reasonable assumptions would remove 905 dwellings from AVDC's housing supply between 2018 and 2033; of which 150 dwellings would be lost 2018-2023 and 755 dwellings would be lost 2023-2033 (as illustrated in the attached VALP Housing Trajectory Overview - Figure 3). This would reduce AVDC's supply of housing in the plan period from 30,233 dwellings to 29,328 dwellings. On this basis, the supply would afford just a 2.5% buffer above the housing requirement of 28,600 dwellings.

Evidently, therefore, delivery from the site as allocated through MM074 is uncertain, with no assurances regarding when first delivery of housing may be and no clarity of the site's overall capacity in light of transport issues, or indeed whether the site will be delivered at all. Therefore, further flexibility will be required through the allocation of more sites or, indeed, the increased capacity of existing allocations that have been assessed as suitable for the accommodation of further dwellings. This is discussed further in response to MM094.