Aylesbury Vale Area

T5 Vehicle Parking

Showing comments and forms 1 to 13 of 13

Object

VALP Proposed Submission

Representation ID: 443

Received: 12/12/2017

Respondent: AOTRA

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Parking provision limitations within the Inner Relief Road according to Policy AY21 of the 2004 Local Plan are needed

Full text:

This policy should be amended to incorporate the gist of the first paragraph of Policy AY21 of the 2004 Local Plan (i.e. that within Aylesbury Inner Relief Road on-site parking provision for all new development proposals will be restricted to that required for the operational needs of the business or land use) and make it clear that the provision of public parking (both on and off-street) should give priority to the disabled, residents of homes within the Inner Relief Road and the customers of town centre uses. Employees of town centre uses should generally be encouraged to walk, cycle or use public transport for journeys to and from work whenever possible.

Support

VALP Proposed Submission

Representation ID: 512

Received: 10/12/2017

Respondent: Mrs Nicky Gregory

Representation Summary:

Wendover currently has a critical parking problem which needs to be resolved now. Any future development must make parking an essential part of any infrastructure plan.

Full text:

Wendover currently has a critical parking problem which needs to be resolved now. Any future development must make parking an essential part of any infrastructure plan.

Support

VALP Proposed Submission

Representation ID: 518

Received: 10/12/2017

Respondent: Mrs Roz Green

Representation Summary:

Wendover has been trying to resolve a long standing parking problem for many years. The current difficulties need to be resolved before any future development is undertaken.

It is imperative that any future development in the area makes parking a priority.

Full text:

Wendover has been trying to resolve a long standing parking problem for many years. The current difficulties need to be resolved before any future development is undertaken.

It is imperative that any future development in the area makes parking a priority.

Support

VALP Proposed Submission

Representation ID: 626

Received: 12/12/2017

Respondent: Mr David Child

Representation Summary:

the availability of public transport should not included temporarily subsidized transport that is usually supported by S106 funding

Full text:

the availability of public transport should not included temporarily subsidized transport that is usually supported by S106 funding

Object

VALP Proposed Submission

Representation ID: 635

Received: 14/12/2017

Respondent: J & J Design

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

The NPPF (paragraph 174) advises that local planning authorities should set out their policy on local standards in the Local Plan.

Full text:

Representation on behalf of Brackley Fox Lane Gospel Hall Trust.

The NPPF advises that any additional development plan documents should only be used where clearly justified. Supplementary planning documents should be used where they can help applicants make successful applications or aid infrastructure delivery, and should not be used to add unnecessarily to the financial burdens on development. SPD is not subject to independent examination. The NPPF (paragraph 174) also advises that local planning authorities should set out their policy on local standards in the Local Plan. At the recent Canterbury Local Plan Examination the Inspector drew attention to the Written Ministerial Statement (WMS) of March 2015 (copy attached) which indicates that local planning authorities should only impose local parking standards for residential and non-residential development where there is clear and compelling justification that it is necessary to manage their local road network. The Canterbury Local Plan was modified with a new appendix containing the appropriate advisory standards. The Inspector concluded that Canterbury City Council had not shown that there was a case to impose standards across the District that met the WMS tests.

We submit that the WMS advice has been reinforced by the recent case of William Davis Ltd v Charnwood Borough Council [2017] EWHC 3006 (admin), where the Council sought to promote a Housing SPD, which the court found to be a significant departure from the policies of the NPPF. We attach a copy of the caselaw report.

Object

VALP Proposed Submission

Representation ID: 1439

Received: 14/12/2017

Respondent: Hertfordshire County Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

The proposed policy T5 suggests a generous provision for car parking for new residential development. Much of the proposed development is urban extension, some distance from public transport interchanges and proposed to be served by new road networks that would connect to main routes e.g. A41 and A418. Even with improved provision for walking, cycling and public transport, high levels of car use and demand are still likely. This does not seem to be consistent with other stated policies e.g. S1 and T1 and the objectives of the Local Plan.

Full text:

Vale of Aylesbury Local Plan (VALP) - Proposed Submission Consultation (Regulation 19)

Thank you for the opportunity to comment on the above. The following is focused on comments from the Highways service within the Environment Department of the County Council. There were no substantive comments from our other services within the Department.


Context

Aylesbury, Aylesbury Vale District's main town, is located very close to the border with Hertfordshire. The A41 is the main road link between Aylesbury and the Hertfordshire network, connecting to Hemel Hempstead and Watford, and being a main route from Aylesbury to the wider strategic road network including the M25 and M1 towards London. The B440 (recently reclassified) is another link between Hemel Hempstead and the east of Aylesbury Vale district. The 500 bus service operates between Aylesbury and Watford via Tring, Berkhamsted and Hemel Hempstead. Other bus routes connect towns and villages on the Aylesbury Vale / Dacorum border area such as Pitstone, Tring, Wendover and Aylesbury. Aylesbury is on the Chilterns Line to London Marylebone, so provides a link to the Chorleywood and Rickmansworth. However the Hertfordshire towns of Tring, Berkhamsted, Hemel Hempstead, Kings Langley and Watford are on the West Coast Mainline, which connects them to London Euston, Milton Keynes and the West Midlands / Birmingham. There is no direct train link to Aylesbury.



Proposed growth in Aylesbury Vale

The VALP proposes a total 27,400 dwellings 2013-2033 in the district, the majority focused in Aylesbury, Buckingham, Winslow, Wendover and Haddenham and adjacent to Milton Keynes. Aylesbury Vale is also accommodating some unmet housing need from Wycombe and Chiltern & South Bucks. The Local Plan puts forward a vision for 'Aylesbury Garden Town', which would effectively provide most of the district's housing growth along with employment development and the enterprise zone. Around 16,400 homes are in the plan to 2033 in and around the edges of Aylesbury.

We appreciate that following this settlement hierarchy and concentrating growth in the largest town is intended for reasons of sustainability and being able to provide needed infrastructure and access to jobs for the growing population. However, the location of Aylesbury close to the boundaries of Hertfordshire, the direct road links, and the close cross-boundary connections and commuter flows between Aylesbury, south west Hertfordshire and Luton / Dunstable for instance, means that there needs to be an understanding of the likely cross boundary, cumulative impacts on the highway and transport networks of planned growth in all of these areas. Joint working with neighbouring LPAs and LHAs to understand and address these challenges may be needed in some areas in particular.


Cumulative and Cross-boundary Impacts

We note the Cumulative Impact Assessment that has been undertaken and considers all of the development sites around Aylesbury. However, we are concerned that it does not appear to consider impacts that may result outside of the border of the Vale of Aylesbury Local Plan. We also note the Aylesbury Transport Strategy commissioned by Bucks County Council and that transport modelling work has been undertaken - again, we have some concerns about how cross boundary impacts and cumulative growth is factored in.

There would be concern that the level of growth at Aylesbury, particularly on the eastern and southern edge, will worsen traffic conditions on parts of the Hertfordshire network. HCC has a countywide transport model which is being used to help support Hertfordshire's LPAs with their Local Plan development. A new run of the model is planned, which will include AVDC's planned growth at Aylesbury to 2036 alongside expected growth in south west Herts. Bucks County Council's modelling identifies traffic congestion issues on the A41 around Aylesbury in the peaks. HCC's existing Countywide 'COMET' modelling to 2031 identifies M25 J20 and the A41 as an issue, and this will worsen with the increased levels of growth planned (e.g. Hemel Hempstead, Aylesbury, Tring, Watford). Access onto the A41 at Tring and Berkhamsted is also identified as an issue.

The developments around Aylesbury will add journeys travelling between the new developments and areas to the east and south east in the Boroughs of Dacorum and Watford, and more journeys heading to the M25. Is the impact on networks outside of Buckinghamshire accurately picked up in the VALP's transport evidence base? Are cumulative impacts outside of Aylesbury Vale considered?

It should be noted that Dacorum Borough Council, Watford Borough Council, Three Rivers District Council and Hertsmere Borough Council are all undertaking reviews of their Local Plans. The Strategic Housing Market Assessment undertaken jointly for these authorities indicates a very substantial increase in the objectively assessed housing need for these LPAs relative to the housing targets in their adopted Local Plans.



Aylesbury Transport Strategy proposals

The Aylesbury Transport Strategy puts forward transport improvements and mitigations to support the planned growth, including series of link roads that would connect in to the proposed new developments around Aylesbury. The plans infer that these are intended to spread traffic and reduce traffic through the town centre including on the congested A41. We would have concerns about whether these link roads would increase demand and through traffic that would adversely affect the Hertfordshire network.

We strongly agree that all the new link roads should be built to provide for cycling, walking and public transport from the outset to aid connectivity and promote active and sustainable journeys.

The proposed policy T5 suggests a generous provision for car parking for new residential development. Much of the proposed development is urban extension, some distance from public transport interchanges and proposed to be served by new road networks that would connect to main routes e.g. A41 and A418. Even with improved provision for walking, cycling and public transport, high levels of car use and demand are still likely. This does not seem to be consistent with other stated policies e.g. S1 and T1 and the objectives of the Local Plan.

There is concern that the transport policies and proposals in the VALP and supporting ATS will perpetuate high levels of car use and add to existing traffic and congestion issues on the Hertfordshire network.

The VALP and ATS propose a 'Primary Public Transport Corridor' on the A41 approaching central Aylesbury, providing for buses, pedestrians and cyclists, but states this would be pursued only after the alternative road links are in place. We would welcome introduction of bus priority measures on this route and elsewhere in the town that would make bus journeys more attractive, including between Aylesbury and towns and villages in Hertfordshire. However, careful thought must be put into when these measures will be delivered, firstly so that the opportunity to do so is not lost, but also to try to avoid car dependent habits becoming established for the new communities.

Aylesbury, Aylesbury Parkway and Stoke Mandeville stations are on a different rail line to Tring, Berkhamsted, Hemel Hempstead and Watford. This means there is no direct train option for people between Aylesbury and these towns. Tring station may present an attractive option for people commuting to London from the east and south east of Aylesbury Garden Town, offering better journey times. Access to all of the rail stations in the surrounding area (not just the stations in Aylesbury Vale) by non-car modes therefore needs thinking about as part of the mitigation plans. Due to the lack of a direct train link, there is also likely to be a high reliance on car journeys generally between Aylesbury and the A41 / Grand Union Canal corridor towns, adding to existing traffic congestion at peak times.

The Aylesbury Transport Strategy is proposing a possible P&R site off the A41 as well as bus priority measures on A41 Aston Clinton Road. Although this would be envisaged to help traffic in central Aylesbury and is positive for supporting more sustainable travel options, traffic will be travelling to and from the P&R site via the A41 and other parts of the Hertfordshire network, so contributing towards traffic and congestion issues. We would welcome more insight into BCC's proposals so it can be considered and factored in to HCC's transport planning in a complementary way.

The Cumulative Impact Assessment and ATS mentions new cycle links to Tring from new developments to the east and south-east. The Wendover Arm of the Grand Union Canal offers a good active travel link between Aylesbury and Tring. The main canal connects to Leighton Buzzard and Milton Keynes. Improvements to this route and to improve connections to a wider network would be welcome. However, as a general point, the limitations of towpaths and similar routes for utility journeys particularly in winter and outside of daylight hours should be recognised and consideration given to alternatives for key links / routes. We would be interested to better understand what improvements are in mind for cycling routes in this part of the district. Aylesbury Vale needs to work with HCC and Dacorum Borough Council to ensure any planned cycle routes and the wider network fit together.


Next steps

HCC would welcome closer engagement with AVDC / BCC to better understand transport and highway implications of growth and planned development, infrastructure needs and transport proposals in our respective authority areas.








Yours sincerely,



Lewis Claridge
Environment Department
Hertfordshire County Council

Object

VALP Proposed Submission

Representation ID: 1688

Received: 14/12/2017

Respondent: Buckinghamshire Fire & Rescue Service

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

We are supportive of the policy in general and, in particular, design requirements that discourage anti-social parking on streets as we have many examples of inadequate parking facilities on new estates leading to parked vehicles obstructing access to premises and hydrants when responding to emergency calls. We recommend that the policy at T5a, on levels of parking provision, also require that this be sufficient to facilitate unobstructed access to all parts of residential developments by fire appliances and other emergency services vehicles and to firefighting infrastructure such as fire hydrants.

Full text:

Please find attached a letter containing our representations in relation to Vale of Aylesbury Local Plan.

Object

VALP Proposed Submission

Representation ID: 1841

Received: 14/12/2017

Respondent: Rectory Homes Limited

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

The policy seeks to provide guidance on parking provision within new developments, although it defers detail of parking standards to a yet to be produced design SPD. This detail should be contained within the policy as without it, it is not possible to judge the effectiveness of the policy. Furthermore, the policy also states that garages, integral garages and car ports will not be included within the allocation of parking spaces unless they meet a minimum internal size as set out in the design SPD. the minimum should be specified in the policy

Full text:

Please find attached representations submitted by Rectory Homes in response to the consultation on the Vale of Aylesbury Local Plan Proposed Submission, together with an appended report which forms part of the supporting evidence to these representations.

Object

VALP Proposed Submission

Representation ID: 1921

Received: 14/12/2017

Respondent: Home Builders Federation Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

we do not consider it appropriate to set out in SPD elements of a policy (namely the number of charging points, the minimum internal size of a garage and the level of parking) that will have a direct role in the determination of planning application. As such they must be set out in policy and open for debate at the Examination in Public. Without these details it is impossible to consider the impact of these policies on viability, whether they are justified and ultimately whether they will be effective.

Full text:

Response by the House Builders Federation to the Regulation 19 consultation on
the Vale of Aylesbury Local Plan
Thank you for consulting the Home Builders Federation (HBF) on Vale of Aylesbury
Local Plan (VALP). The HBF is the principal representative body of the housebuilding
industry in England and Wales and our representations reflect the views of discussions
with our membership of national and multinational corporations through to regional
developers and small local housebuilders. Our members account for over 80% of all
new housing built in England and Wales in any one year.
We would like to submit the following representations on the Local Plan and we
would welcome, in due course, participating in hearings of the Examination in
Public.
Duty to Co-operate
We do not consider the Council's approach to the duty to co-operate is consistent with
national policy.
It would appear from the evidence that Aylesbury Vale District Council (AVDC) have
met the legal requirements of the Duty to Co-operate in relation to meeting housing
needs for the Housing Market Area (HMA). There is a clear agreement between the
Council's in the HMA to meet needs in full with the unmet needs from the other
authorities in the HMA be provided for by Aylesbury Vale District Council (AVDC). This
is set out in policy S2 and we welcome the broad approach that has been taken by the
Councils in seeking to meet the needs of the HMA.
However, we are concerned that this co-operation is based on a housing needs
assessment that seeks to significantly reduce the overall level of housing need for the
HMA compared to official projections. In particular the latest assessment of housing
need has reduced the demographic starting point for AVDC, and subsequently its
objective assessed housing need (OAN). This has in turn provided greater scope for the
needs of the other authorities in the HMA to be met by AVDC. We consider the
approach to assessing housing needs is flawed and that there is significantly less
capacity in AVDC than is being suggested. In fact if the standard methodology were to
be applied across the HMA, and current distributions maintained, there would be even
less scope to meet the full needs of the Housing Market Area.
2
If the full needs of the HMA cannot be met, which would appear to be the case at
present then the policy requirements of the duty to co-operate as set out in 178 to 181
of the NPPF will not have been addressed. To ensure the plan is compliant with the
policy requirements of the duty to c-operate further consideration as to how the needs
of the HMA will be met in full will be necessary.
Our key concerns regarding the assessment of needs is set out below.
Housing needs
In our earlier comments on housing needs to the AVDC we raised concerns regarding
the January 2016 Housing Economic Development Needs Assessment (HEDNA) and
the reduction in housing needs compared the 2015 HEDNA. However, since the
regulation 18 consultation the HEDNA has been updated again to take into account the
latest 2014 based population projections published in the summer of 2016 which has
resulted in a significant reduction on the assessment of housing needs. We would
support the Council in undertaking such an update which is in line with Planning
Practice Guidance, however, we are surprised as to the outcomes of the update.
Having examined the 2014 based Household Projections for the HMA we note that
between 2013 and 2033 total households were 1,925 higher than those in the 2012
based projections. The updated HEDNA though sets out a distinctly different projection
of household growth. Between 2013 and 2033 the updated HEDNA expects the
demographic starting point for assessing housing needs to be 2,826 less than the
previous HEDNA using the 2012 based household projections. It seems surprising that
the updated HEDNA would see the opposite trend to the official projections. Despite
this significant discrepancy we cannot find any explanation as to why the upward trend
in the official projections leads to a reduction in households using the Council's
methodology.
Of particular concern is the fact that the latest HEDNA anticipates that AVDC are
expected to see household growth that is significantly lower than that set out in the
original HEDNA. The reason why this concern is so important is that AVDC are
expecting to meet the unmet needs arising from the other authorities in the HMA. The
updated HEDNA shows a reduction in the total number of households expected to form
during the plan period in AVDC from 18,144 households using the 2012 based
projections to 16,933 using the 2014 based data. However, the 2014 based household
projections expected there to be 2,623 more households in 2033 than was expected in
the 2012 based projections. So, despite the 2014 based household projections showing
an increase when compared to the 2012 projections the updated HEDNA projects a
reduction in household growth for AVDC. As mentioned above, there is no explanation
as to why this has occurred and given that it has enabled the HMA to meet its needs we
would have expected this to be addressed in the evidence supporting the plan. In fact,
the most recent HEDNA continues to claim in paragraph 9 that the growth identified for
AVDC is "marginally lower" than the CLG starting point. We would suggest that a
reduction of 4,095 households is more than "marginally lower".
3
It is essential that the Council's in the HMA provide a clear justification as to the reason
for this significant reduction in the demographic starting point. There are inconsistencies
with both previous projections provided by the Council and those provided by the
Government and ONS. The approach taken by the Councils is not clear and is one of
the reasons why the Government have been looking to apply a standard methodology
for assessing housing needs. However, even before the latest consultation Planning
Practice Guidance (PPG) sets out that Government considers the official household
projections to be robust stating in paragraph 2a-017:
"The household projections produced by the Department for Communities and Local
Government are statistically robust and are based on nationally consistent
assumptions."
The latest consultation 'Planning for the Right Homes in the Right Planes' reiterates this
position with the standard methodology being based on the household projections.
Paragraph 16 of the consultation document states:
"The Office for National Statistics' projections for numbers of households in each local
authority are the most robust estimates of future growth."
We recognise that the PPG allows for some sensitivity testing but it also requires these
to be based on robust evidence. So whilst our initial response was positive, despite our
usual concerns regarding the use of the 10 year trend, there is insufficient justification
as to why the latest projections for the HMA have substantially reduced household
growth for AVDC from the original HEDNA and, most importantly, why they have moved
in the opposite direction to the DCLG household projections.
The latest consultation also sets out that across the HMA the Government would expect
the new methodology, if implemented, to require a more significant level of housing
delivery. Based on the Standard Methodology the HMA would need to deliver 3,039
dwellings per annum (dpa) compared to the 2,269 dpa that is the Councils' assessment
of housing need. With regard to the duty to co-operate and meeting needs across the
HMA there must be a concern that AVDC's needs assessment is 534 dpa lower than
the standard methodology. Given the constraints expressed by the other authorities
there will clearly be a need for AVDC to consider a further increase in its housing
requirement in order to address an ever increasing level of unmet need in the HMA.
There have also been wider concerns regarding the tendency of local authorities within
this area to underestimate the levels of housing needs. The recent National
Infrastructure Commission (NIC) report1 on the Cambridge-Milton Keynes-Oxford Arc
identified the tendency for local planning authorities in this area to run assessments that
produce lower level so f housing need than official projections. On page 26 of this report
the NIC states:
1 Partnering for Prosperity: A new deal for the Cambridge-Milton-Keynes Oxford Arc (National
Infrastructure Commission 2017)
4
"... there is good reason to believe that the methodology used in undertaking
assessments of local housing need can be conservative and mask high levels of unmet
need."
It would appear that the tendency to underestimate housing need is prevalent across
this region. If the long term economic growth and infrastructure plans that are required
for this area are to be realised then the assessments of housing need must not seek to
supress official demographic projections.
In conclusion we do not consider that the level of housing needs, as set out in the
updated HEDNA, to have been sufficiently justified. In particular we do not consider the
substantial reduction in household growth using the government's 2014 based data to
have been adequately explained. These reduce the overall level of need for the HMA
and thus enabling the HMA to meet its needs. If the lower level of need set out in the
latest HEDNA cannot be justified then this will have significant implications for the
progression of the other Local Plans in the HMA due to the significantly reduced
additional development capacity in AVDC.
In addition there is potential for the level of unmet need from the other authorities to be
higher than initially considered. Whilst only limited weight can be given to the
consultation as a whole it does give the clearest positon yet as to the degree to which
market signals should be taken into account. This would suggest that housing needs
across the other authorities in the HMA could also have been underestimated leaving a
more significant degree of unmet needs than has been considered by AVDC and its
partners.
So, whilst the co-operation would appear to be effective it is potentially based on
erroneous evidence. If there is insufficient justification for the reduction in housing
needs resulting from the updated HEDNA then there will be a need for the authorities in
the HMA to revisit their collective approach to meeting housing needs.
We would also like to mention that it would have been beneficial for all parties had the
authorities in the HMA taken a more strategic approach in preparing their Plans to allow
housing needs to be considered by a single inspector. This enables the approach to
assessing and meeting housing needs for an HMA to be considered just once and
would avoid repetition of debates. We have seen across the Country that a decision on
OAN for an HMA at one EIP can make it difficult for any inspector at subsequent EIPs
using the same evidence to potentially disagree with a colleague. As such we welcome
approaches to strategic planning such as those taken in the North Essex HMA where a
strategic plan for the whole area has been prepared and allows housing needs across
the three LPAs concerned to be considered at the same time.
S2 Spatial strategy for growth
The policy is unsound as the delivery expectations to support the other authorities in the
HMA are unjustified
5
As set out above we have concerns as to the approach taken by the Council in
assessing the housing needs for the HMA and in particular the OAN for AVDC. We do
not consider that there is sufficient justification to reduce the demographic starting point
for AVDC and that the DCLG household projections remain robust and should be used
as the baseline for assessing needs. If the household projections were used as the
starting point for considering needs and a 10% uplift were applied, as recommended in
the HEDNA, then AVDC's OAN for the plan period would be 23,129 (1,156 dpa). As
such the Council would continue to be able to meet its own needs but there would be
less capacity to support the other authorities in the HMA. However, given the
Government's latest consultation we would suggest that a 10% uplift for AVDC is too
low and we would suggest it be reconsidered prior to submission.
So whilst we welcome the approach taken by AVDC to set a housing requirement of
27,400 new homes we do not consider the level of growth to be sufficient to support the
other authorities in the HMA to the degree stated. This will require the Council and its
partner authorities to reconsider its approach to meeting the needs of the HMA. If
current distributions of need are continued then AVDC will need to include additional
allocations to offset the limited delivery elsewhere in the HMA. Alternatively the other
authorities could seek to increase their own housing requirements to make up for the
shortfall. We recognise that not all the LPAs in the HMA are at the same stage of plan
preparation and if further allocations cannot be made in this plan the policy must set out
the need for an early review based on the final requirements of the other LPAs in the
HMA.
The policy should also establish that the housing requirement as the minimum number
of homes that will be delivered. This is important in order to ensure that growth beyond
the requirement is supported by the Council. This would also be consistent with the
positive approach to planning required by paragraph 14 of the NPPF and the Council's
own position in table 1 of the VALP, which sets out the expectation that 28,850 new
homes will be delivered.
Housing trajectory
The HBF does not comment on the merits or otherwise of individual sites therefore our
representations are submitted without prejudice to any comments made by other parties
on the deliverability of specific sites included in the overall housing land supply, the fiveyear
housing land supply and housing trajectories. However, we want to stress the
importance of having realistic delivery expectations within any allocations to ensure the
deliverability of the plan across its lifetime. This is particularly important where there is a
reliance on strategic sites to deliver the majority of new homes within the plan period.
Delays to the delivery of strategic sites for any number of reasons could lead to the LPA
not being able to meet its housing requirement. A more cautious assessment of delivery
on strategic sites offset with the allocation of smaller sites will offer a more flexible and
sound housing trajectory.
H1 - Affordable housing
The policy is not sound as it is unjustified and inconsistent with national policy
6
Whilst we appreciate that the Council were looking to test scenarios prior to setting
policies, it would appear that full consideration has not been given to the cumulative
financial impact of those policies as required by paragraph 173 of the NPPF. For
example, the policies on electric vehicle charging and accessible homes have been
considered separately and only with regard to a 50-unit mixed scheme. In addition, the
requirements in policy H4 concerning the optional accessibility standards have not been
tested. The nearest assumption is for 70% M4(2) and 5% M4(3). Significantly lower
than the requirements of policy H4. Until further testing is carried out on the cumulative
impact of the policies as set out in the Local Plan it is not possible for the Council to
state that the Local Plan will not threaten the viability of development in the area.
We consider that the wording of the policy is not consistent with the core planning
principles set out in the NPPF and the requirement established in paragraph 17 for
Local Plans to:
"... provide a practical framework within which decisions can be made with a high
degree of predictability and efficiency".
The policy states that the Council will require "a minimum of 25%" of all homes provided
on appropriate sites to be affordable. This suggests that in some circumstances the
Council will seek a high proportion of affordable housing provision and increases the
uncertainty for the decision maker and applicant as to what the appropriate amount of
affordable housing provision should be. This is of increasing concern to our members
who, where affordable housing policies are set as minimums, are being asked to
provide evidence to justify meeting the minimums. There is a real danger that such
policies will generate additional and unnecessary justification for policy compliant
schemes.
In order to make this policy consistent with national policy we would suggest that the
word "minimum" is removed. This will provide the necessary certainty required of such a
policy for both decision maker and applicant.
H5 - Self/Custom Build Housing
The policy is unsound as it is not consistent with national policy and is ineffective.
Whilst we support the encouragement of self-build housing through the local plan we
consider the requirement for sites of over 100 to provide an unstated number of selfbuild
plots is not justified and inconsistent with national policy. Whilst we recognise that
Local Planning Authorities now have a duty to promote self-build housing we do not
consider the Council to have looked at sufficient options with regard to how it can
provide plots to support self-builders. Paragraph 57-024 of the PPG sets out a variety of
approaches that need to be considered - including the use of their own land. This is
reiterated in para 57-14 of the PPG which sets out the need for Council's to consider
how they can support the delivery of self-build plots through their housing strategy, land
disposal and regeneration functions. We cannot find any evidence as to the Council's
consideration of other reasonable approaches to delivery as suggested in PPG. Without
7
such consideration it would appear that the Council is seeking to place the burden for
delivery of self-build plots on house-builders without looking sufficiently at other delivery
mechanisms as set out in national guidance.
We also consider the policy to be inconsistent with the third bullet point of paragraph
57-025 of PPG. This outlines that the Council should engage with landowners and
encourage them to consider self-build and custom housebuilding. The approach taken
by the Council moves beyond encouragement and requires land owners to bring
forward plots. We would therefore suggest that the policy be deleted and replaced with
a policy that seeks to encourage the provision of self-build plots on developments of
over 100 units.
Where plots are not sold it is important that the Council's policy is clear as to when
these revert to the developer. At present this policy makes no such provision, as such it
is ineffective. We would suggest that the policy state that if a plot remains unsold after 6
months of it being offered on the open market then it should revert back to the
developer to be delivered as part of the overall scheme. We would also recommend
that if development of a purchased plot has not commenced within three years of
purchase that the buyer be refunded and the plot reverts to the developer. It is
important that plots should not be left empty to detriment of its neighbours or the
development as a whole.
H6 - Housing mix
Parts of the policy are unsound as they are not justified
We do not consider the Council to have justified the requirement for all homes to be
built to part M4(2) and for 10% of market homes and 15% of affordable homes to be
built to part M4(3). With regard to Part M4(2), the evidence in the HEDNA suggests that
as the population is ageing then all new homes should be made accessible to ensure
those older people who do move are able to acquire an accessible home. However, the
HEDNA itself outlines that many of the existing older people are unlikely to move from
their current homes and as such there is likely to be significantly less need for new
homes to be built to part M4(2). It is also likely that many of those who do move will
move to accommodation specifically built to meet the needs of older people and not to
general market housing. As such we do not think it is justified for all new homes to be
built to part M4(2) solely on the basis that there is an ageing population.
The proposal to require 10% of market homes as being M4(3) is contrary to national
policy. PPG sets out in paragraph 56-009 that the standard for wheelchair accessible
homes only to properties where the local authority is responsible for allocating or
nominating a person to live in that dwelling. This means that M4(3) can only be applied
to affordable homes and the policy should be amended to reflect this position.
We accept that there may be some need to ensure a proportion of new affordable
homes are wheelchair accessible. However, we do not consider there to be sufficient
evidence to support a policy requiring 15% of all affordable homes as being built to Part
M4(3). Firstly, the Local Plan sets out that nationally 7.1% of households living in
8
affordable accommodation which suggests that provision at 15% is much higher than
the number of wheelchair users requiring such homes. Secondly, no consideration has
been given, as required in PPG, to the existing stock of affordable homes that are
already accessible to wheelchair users. Without this evidence the Council cannot be
certain as to whether there will currently a surplus of such homes within the Borough.
It is also the case that the Council's viability assessment has not tested the viability of
providing the level of accessible housing set out in this policy. As set out above in our
representation ton policy H1 the proportion of homes to be provided as either M4(2) or
M4(3) has not been tested. In addition, it has only been tested with regard to one
scenario - a 50-unit mixed development. As the full cumulative impacts of the policies
set out in the plan have not been tested we do not consider there to be sufficient
justification to support the proportion of homes required by the policy to conform to the
optional accessibility standards.
H7 Dwelling sizes
This policy is unsound as it is not consistent with national policy and is unjustified
The policy is not consistent with the approach to setting internal space standards in
PPG. Paragraph 56-018 to 56-023 set out that if a Local Planning Authority has
sufficient evidence to support the introduction of minimum space standards they should
only do so by reference to the national described space standards. Any other approach
taken to setting space standards must, therefore, be considered unsound. However, in
addition to this fundamental principal the Council state in paragraph 5.68 there is no
evidence to suggest that homes are coming forward below the nationally described
space standards. If this is the case then seeking to apply an alternative standard is
unjustified and unhelpful as the wording of this policy provides no clear guidance as to
what should be considered "sufficient internal space".
Such a subjective assessment could lead to confusion amongst both the decision
maker and the applicant. This policy is therefore inconsistent with one of the core
planning principles set out in paragraph 17 of the NPPF which states that local plans
should provide a:
"practical framework within which decisions on planning applications can be made with
a high degree of predictability and efficiency"
We would also suggest that is inconsistent with paragraph 154 which states:
"Only policies that provide a clear indication as to how a decision maker should react to
a development proposal should be included in the plan"
Given these clear inconsistencies with national policy and guidance policy H7 should be
deleted from the Local Plan.
T5 Vehicle Parking and T7 Electric Vehicle Infrastructure
9
These policies are unsound as they are ineffective
Within both these policies the Council will look to set out elements of both these policies
as in Supplementary Planning Documents (SPD). However, we do not consider it
appropriate to set out in SPD elements of a policy (namely the number of charging
points, the minimum internal size of a garage and the level of parking) that will have a
direct role in the determination of planning application. As such they must be set out in
policy and open for debate at the Examination in Public. Without these details it is
impossible to consider the impact of these policies on viability, whether they are justified
and ultimately whether they will be effective.
Conclusion
At present we do not consider the plan to be sound. Whilst we are pleased with the
significant progress the Council has made in meeting its own needs and those of the
HMA we do not consider the Council has met the tests of soundness on the following
areas:
 Policy S2 sets out the degree to which AVDC is meeting the needs of other
authorities in the HMA but these are based on an unjustifiably low OAN. This
potentially impacts on the soundness of this policy and whether the HMA is
meeting its needs in full as required by the NPPF.
 The policy on affordable housing has not been adequately justified and does not
provide sufficient flexibility
 Policy H5 on self-build housing is inconsistent with national policy and is
ineffective as it as it does not consider how unsold sites will be treated.
 Requirements relating to accessible homes have not been sufficiently justified
either on the basis of needs or viability.
 Policy H7 on dwelling size departs completely from the approach set out in PPG
and as such is inconsistent with national policy, unjustified and ineffective.
 Policy T5 and T7 on parking and Electric Vehicle Infrastructure set out that the
level of provision required will be set out in SPD. These elements of the policy
will inform decision makers and should be considered as policy. As such they
should be included in the Local Plan.
We hope these representations are of assistance in taking the plan forward to the next stage of plan preparation and examination. I would also like to express my interest in attending any relevant hearing sessions at the Examination in Public. Should you
require any further clarification on the issues raised in this representation please
contact me.

Object

VALP Proposed Submission

Representation ID: 1962

Received: 14/12/2017

Respondent: Careys New Homes

Agent: Bidwells

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Representation Summary:

We consider that the reference to the requirements set out under the policies is too prescriptive. It is not
appropriate to set out SPD elements of the policies that will have a direct role in the determination of
planning applications. This includes matters relating to the minimum internal size of a garage and the level
of parking (Policy T5) and the number of electric charging points required (Policy T7). We have concern
that it is impossible to consider the impact of Policies T5 and T7 on viability without details.

Full text:

On behalf of my client, Careys New Homes, I am pleased to submit the attached (4 no. PDFs) response to the VALP Proposed Submission consultation in respect of land at Wingrave.

Object

VALP Proposed Submission

Representation ID: 1979

Received: 14/12/2017

Respondent: Persimmon Homes Midlands

Agent: Bidwells

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

We consider that the reference to the requirements set out under the policies is too prescriptive. It is not
appropriate to set out SPD elements of the policies that will have a direct role in the determination of
planning applications. This includes matters relating to the minimum internal size of a garage and the level
of parking (Policy T5) and the number of electric charging points required (Policy T7). We have concern
that it is impossible to consider the impact of Policies T5 and T7 on viability without these details.

Full text:

As it stands, the VALP is not sound and hence there are a number of changes required to the plan including a number of strategic and development management policies as identified in the submitted representation letter. In summary, we consider that the following policies are unsound and for reasons stated above, do not meet the test of soundness: Policy S2 'Spatial Strategy for Growth'; Policy S3 'Settlement Hierarchy and Cohesive Development'; Policy H1 'Affordable Housing'; Policy H5 'Self/Custom Build Housing'; Policy H6 'Housing Mix'; Policy H7 'Dwelling Sizes'; Policy T5 'Vehicle Parking'; and Policy T7 'Electric Vehicle Infrastructure'. My client's site at Calvert Green represents an achievable, suitable and deliverable allocation that is part brownfield to support the necessary housing growth for Aylesbury Vale.

Object

VALP Proposed Submission

Representation ID: 2407

Received: 14/12/2017

Respondent: Wendover Neighbourhood Plan Steering Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Transport issues have been raised in many responses. Parking is considered
a vital local issue for the Town centre businesses and we do not feel that this
has been adequately addressed; in terms of the existing network, the impact
of the new proposed homes will impose too great a strain, without a range of
highway improvements and safety measures, as well as provision for
enhanced public transport (range and availability of bus services) and trains
(capacity).

Full text:

Response to Proposed Submission Vale of Aylesbury Local Plan (VALP) - see attachment for detailed responses on specific parts of the plan.

Overview and Summary

1) The following comments are being made by the Wendover Neighbourhood Plan (WNP) Steering Group (SG) on the proposed submission Vale of
Aylesbury Local Plan (VALP). Please note that extracts from the Plan, or a summary of their contents, are in italics, and our response is in ordinary type.

2) The current position is that the SG is completing the work in researching the
factual data for the WNP and completing its engagement events to ensure all issues are covered. During the first part of 2018 a detailed Questionnaire will be sent to residents and the timetable for the project to produce the WNP has been drawn up with the aim of producing the WNP in late 2019. The SG is an independent group of residents who operate under the auspices of the Parish Council but may take different views on the VALP. The aim of this response is to reflect the views of the SG but also the opinions and priorities of the residents who have given feedback to date, on the issues that concern them. We have sought to include all the main items of feedback to date in our comments, but ongoing research, and our Questionnaire, will undoubtedly throw up other ideas to implement, and concerns to be addressed.

3) The key points we would wish to make are:-

* We welcome the recognition of Wendover's distinctive identity as a settlement in the south of Aylesbury Vale.
* We welcome the adjustment to the draft Green Belt proposals and the limitation of development within the Town which accords with the great majority of views expressed by the public.
* We understand the decision to allocate 1000 or so homes to the brownfield site at RAF Halton: however there is insufficient detail on either the numbers of homes (and the lack of definition is an issue), or their types and tenure and size. The public support a variety of types of affordable homes to meet local needs but have still to be consulted on the mix of provision.
* The public have made it clear that, whilst they support affordable housing of all types, in appropriate locations within the Town, and if necessary at RAF Halton, they have asked that appropriate and sufficient infrastructure is provided at RAF Halton to include new, or expanded, health, and schools provision, the maintenance and expansion of sports and leisure facilities, the appropriate retention and development of heritage assets, and the provision of a range of jobs closely connected to the new housing provision and appropriate to the labour market needs. The SG must reflect this in its development of the WNP.
* The proposed development at RAF Halton will have a close and intimate impact on Wendover and we have concerns about the policies which have yet to be developed for the provision of employment land, and the maintenance and enhancement of the shopping centre in Wendover
* Transport issues have been raised in many responses. Parking is considered a vital local issue for the Town centre businesses and we do not feel that this has been adequately addressed; in terms of the existing network, the impact of the new proposed homes will impose too great a strain, without a range of highway improvements and safety measures, as well as provision for enhanced public transport (range and availability of bus services) and trains (capacity).
* Details of the Garden Town and proposed expansion of Aylesbury has repercussions for the surrounding area but is insufficiently addressed - we had understood there would be a consultation on this issue in the Autumn of 2017 but this is awaited.
* The impacts of HS2 will be significant yet there are few details known at this stage of the mitigation impacts. Given its effects on residents business and workers in the Town we are anxious to know more given the longer term impact on the whole community.
* We welcome the principle of sustainability underlying the whole plan and feel all measures to meet the challenge of climate change should be taken.

4) The community of Wendover is faced with unique difficulties in addressing the VALP response. The impact of development proposed at RAF Halton will affect it significantly, yet no details of the proposed settlement plan (described as a Masterplan in some documents) are yet available. RAF Halton is not within the Parish of Wendover, nor does it appear to be covered in the Halton Neighbourhood Plan. We think it desirable that there are specific proposals in any VALP to ensure there is proper and meaningful debate on the future of the RAF Halton site, and surrounding heritage and green infrastructure, in Halton and Wendover Parishes, so that the public can work together with landowners and the Government to ensure that the ultimate development of the site is for the benefit of the whole community and reflects the contribution of those living and working in the areas.

5) In addition we think that there will be a need for revisions to the VALP as well as a joint Neighbourhood Plan (involving Wendover, Halton, and the MOD) at a later stage of the VALP process to ensure that proper planning principles are adhered to and the full consultation promised is in fact provided.

6) We now comment on specific provisions of the VALP by reference to page and paragraph numbers. We have made some separate comments on the documents included as supporting evidence.

Object

VALP Proposed Submission

Representation ID: 2441

Received: 14/12/2017

Respondent: Wendover Neighbourhood Plan Steering Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

The SG is aware, through public comment, of the concern that adequate car parking
provision is provided at all developments and will be looking to contribute to the
refining of this policy.

Full text:

Response to Proposed Submission Vale of Aylesbury Local Plan (VALP) - see attachment for detailed responses on specific parts of the plan.

Overview and Summary

1) The following comments are being made by the Wendover Neighbourhood Plan (WNP) Steering Group (SG) on the proposed submission Vale of
Aylesbury Local Plan (VALP). Please note that extracts from the Plan, or a summary of their contents, are in italics, and our response is in ordinary type.

2) The current position is that the SG is completing the work in researching the
factual data for the WNP and completing its engagement events to ensure all issues are covered. During the first part of 2018 a detailed Questionnaire will be sent to residents and the timetable for the project to produce the WNP has been drawn up with the aim of producing the WNP in late 2019. The SG is an independent group of residents who operate under the auspices of the Parish Council but may take different views on the VALP. The aim of this response is to reflect the views of the SG but also the opinions and priorities of the residents who have given feedback to date, on the issues that concern them. We have sought to include all the main items of feedback to date in our comments, but ongoing research, and our Questionnaire, will undoubtedly throw up other ideas to implement, and concerns to be addressed.

3) The key points we would wish to make are:-

* We welcome the recognition of Wendover's distinctive identity as a settlement in the south of Aylesbury Vale.
* We welcome the adjustment to the draft Green Belt proposals and the limitation of development within the Town which accords with the great majority of views expressed by the public.
* We understand the decision to allocate 1000 or so homes to the brownfield site at RAF Halton: however there is insufficient detail on either the numbers of homes (and the lack of definition is an issue), or their types and tenure and size. The public support a variety of types of affordable homes to meet local needs but have still to be consulted on the mix of provision.
* The public have made it clear that, whilst they support affordable housing of all types, in appropriate locations within the Town, and if necessary at RAF Halton, they have asked that appropriate and sufficient infrastructure is provided at RAF Halton to include new, or expanded, health, and schools provision, the maintenance and expansion of sports and leisure facilities, the appropriate retention and development of heritage assets, and the provision of a range of jobs closely connected to the new housing provision and appropriate to the labour market needs. The SG must reflect this in its development of the WNP.
* The proposed development at RAF Halton will have a close and intimate impact on Wendover and we have concerns about the policies which have yet to be developed for the provision of employment land, and the maintenance and enhancement of the shopping centre in Wendover
* Transport issues have been raised in many responses. Parking is considered a vital local issue for the Town centre businesses and we do not feel that this has been adequately addressed; in terms of the existing network, the impact of the new proposed homes will impose too great a strain, without a range of highway improvements and safety measures, as well as provision for enhanced public transport (range and availability of bus services) and trains (capacity).
* Details of the Garden Town and proposed expansion of Aylesbury has repercussions for the surrounding area but is insufficiently addressed - we had understood there would be a consultation on this issue in the Autumn of 2017 but this is awaited.
* The impacts of HS2 will be significant yet there are few details known at this stage of the mitigation impacts. Given its effects on residents business and workers in the Town we are anxious to know more given the longer term impact on the whole community.
* We welcome the principle of sustainability underlying the whole plan and feel all measures to meet the challenge of climate change should be taken.

4) The community of Wendover is faced with unique difficulties in addressing the VALP response. The impact of development proposed at RAF Halton will affect it significantly, yet no details of the proposed settlement plan (described as a Masterplan in some documents) are yet available. RAF Halton is not within the Parish of Wendover, nor does it appear to be covered in the Halton Neighbourhood Plan. We think it desirable that there are specific proposals in any VALP to ensure there is proper and meaningful debate on the future of the RAF Halton site, and surrounding heritage and green infrastructure, in Halton and Wendover Parishes, so that the public can work together with landowners and the Government to ensure that the ultimate development of the site is for the benefit of the whole community and reflects the contribution of those living and working in the areas.

5) In addition we think that there will be a need for revisions to the VALP as well as a joint Neighbourhood Plan (involving Wendover, Halton, and the MOD) at a later stage of the VALP process to ensure that proper planning principles are adhered to and the full consultation promised is in fact provided.

6) We now comment on specific provisions of the VALP by reference to page and paragraph numbers. We have made some separate comments on the documents included as supporting evidence.