VALP Proposed Submission
Representation ID: 573
Respondent: Marrons Planning
Legally compliant? Yes
Duty to co-operate? Yes
The evidence in the HEDNA was formulated prior to the Government's commitment to build 300,000 dpa.
The proposed provision of 19,400 dwellings between 2013 - 2033 and the 8,000 dwellings to meet the unmet need of neighbouring authorities is less than the previous assessments.
At a time when there is considerable public and political pressure for an uplift in the provision of new homes, it is counter intuitive to be providing for a lower number of dwellings.
The Government's proposed methodology should be applied; an increase of the number of dwellings per year of over 50%.
The Government has committed to the building of 300,000 dwellings per year (dpa); a significant increase on previous policy objectives (250,000 dpa) and current output of approximately 170,000 dpa. It is only by securing this scale of uplift that it will be possible for the severe housing crisis in this country to be addressed and it is therefore essential for all those involved in the residential development process to facilitate this provision.
It is in this context that the provision now being proposed by the Council needs to be assessed. It may be that the latest evidence contained in the Housing and Economic Development Needs Assessment (HEDNA, December 2016 and its Update Addendum dated September 2017), and prepared on the basis of current formulae, correctly identifies an objectively assessed need (OAN) for Aylesbury Vale of 19,400 dwellings between 2013 - 2033 as well as the unmet need from neighbouring authorities (8,000 dwellings). However this was formulated prior to the Government's aforementioned commitment to build 300,000 dpa. It is also pertinent to note that it is 1,900 fewer homes than in the previous assessment and before any account is taken of the reduction in the neighbouring authorities' OAN. Consequently at a time when there is considerable public and political pressure for an uplift in the provision of new homes, it is counter intuitive to be providing for a lower number of dwellings.
Further, evidence of the pressure for the number of dwellings in this area to be increased is contained in the Government's consultation paper on 'Planning for the right homes in the right places' which sets out a standard approach to assessing local housing need. Accompanying tables set out an indicative assessment of housing need based on the proposed formula. For Aylesbury Vale, the application of this methodology results in an increase of the number of dwellings per year of over 50% from 970 dpa to 1,499 dpa. Rey Construction is aware that the Government's announcement on the methodology to be adopted when undertaking the standard approach for housing need assessments is still awaited; even so there is a clear direction of travel which should be reflected in those Local Plans which are currently being prepared, not least because it is only in so doing that it will be possible to "boost significantly the supply of housing" as required by paragraph 47 of the Framework
It is also relevant to the consideration of this issue to note that the National Infrastructure Commission published its report 'Partnering for Prosperity: a new deal for the Cambridge-Milton Keynes-Oxford Arc' in November 2017. This considers how to maximise the potential of the Cambridge - Milton Keynes - Oxford corridor as a single, knowledge-intensive cluster. In so doing, it argues that, if East West Rail and the Expressway were developed, analysis of land constraints suggests that key opportunities for growth over the next 30 years could include the re-establishment of Milton Keynes as a development location of national significance expanding the town to at least 500,000 (from a current population of approximately 267,000). This will clearly have implications for Aylesbury Vale as well as Milton Keynes and in view of the importance of the Arc to the national economy, it is essential that development in this area is not unnecessarily constrained.
In the circumstances it is imperative that the Plan provides for more dwellings than currently proposed if the needs of the country are to be met in the most sustainable locations.
VALP Proposed Submission
Representation ID: 1044
Respondent: Chiltern and South Bucks District Council
Draft VALP acknowledges the three southern districts are subject to constraints such as Green Belt and AONB, and that a comprehensive capacity assessment has been carried out which shows that Chiltern, South Bucks, and Wycombe Districts cannot accommodate all of their housing need within their own districts. Policy S2 (Spatial Strategy for Growth), therefore commits to providing for 5,750 additional dwellings arising from unmet needs in Chiltern and South Bucks Districts. This reflects the agreed outcomes of Duty to Co-operate discussions and provides for housing need to be met within the HMA. Our Councils are therefore supportive of this policy.
Please find attached representations regarding the Draft Vale of Aylesbury Local Plan, made on behalf of both Chiltern District Council and South Bucks District Council.
Please note that this representation is provided on the basis of the agreed Memorandum of Understanding between our Councils, currently awaiting signing by our respective portfolio holders.
VALP Proposed Submission
Representation ID: 1536
Respondent: Halsbury Homes Ltd
Agent: RPS Planning and Development
Legally compliant? No
Duty to co-operate? No
Given that the DCLG figure of 30,000 dwellings representing local OAN in AVDC, is actually higher
than the current draft figure of 27,400 dwellings contained in the Local Plan, the question must be
asked as to whether:-
1) AVDC is content to accept a minimum of 8,000 additional dwellings in addition to the 30,000
local need - giving an adjusted total of 35,400 dwellings in 2 years time; or
2) Whether it will have to review the MOU to see if it considers the current allocations should
provide for its own local need rather than the needs of adjoining authorities.
Please find attached representation made of behalf of Halsbury Homes Ltd in regard to the Proposed Submission Vale of Aylesbury Local Plan.
VALP Proposed Submission
Representation ID: 1811
Respondent: Mrs Alina Neagoe
Legally compliant? Yes
Duty to co-operate? No
In the Local Plan for AVD, the experts talk about 27,400 homes that will be accommodated by Aylesbury Vale District for the period 2013 and 2033 - without mentioning that this is a provisional figure.
Why a provisional figure? Because the un-met need for Wycombe District (2,250 dwellings) and Chiltern/South
Bucks Districts (5,750 dwellings) may change as a result of representations sent (by the community/land owners/developers) to the independent Planning Inspectors in charge of validating these Local Plans.
see attachment for full rep
* The Local Plan for Aylesbury Vale District fails to comply with the Duty to Cooperate Memorandum of
Understanding signed in July 2017. Paragraph 2.1 (d) of this document sets out the conditions under which
the resultant unmet housing need of different Districts would be met elsewhere within the 'best fit': 'The
Councils agreed that that the housing need within the HMA would first fall to be met within each plan area
based on the needs of each individual plan area, but if that was proven to be impossible then the resultant
need would be met elsewhere within the 'best fit' HMA where it was reasonable to do so and was consistent
with achieving sustainable development.'
As you will see below, the Wycombe District has the potential for a greater number of new homes to be built
within the District (as Aylesbury Vale District Council also stated in the representation sent in August 2016),
but for various reasons they decided not to use these sites (and instead to using as an argument for the unmet
need the lack of land within the District due to Green Belt and AONB - which is not true).
By including the 2,250 dwellings (derived from the un-met target for Wycombe District) into the Aylesbury
Vale Local Plan, although these AVDC experts know that WDC has more potential for development beyond the
Green Belt and AONB at Princes Risborough - both Council's become accomplices in non-compliance with the
MoU rules set up in July 2017.
* The Local Plan for Aylesbury Vale District does not mention that the 27,400 dwellings represent just a
provisional figure - and the final number will only be set when the other local plans from Buckinghamshire
(showing un-met need) will be approved (Chiltern District Council, South Bucks District Council, Wycombe
In this Local Plan, AVDC started from the idea that the un-met need declared by the other Councils is real, but
this is not true in the Wycombe District. We are many land owners/developers from the Wycombe District
that sent a representation to the independent Planning Inspector in charge of validating this Local Plan
providing - asking our land to be used for development for the period 2013 - 2033 (and showing that our sites
are eligible for development).
Enter your full representation here:
Paragraph/Policy/Other: Duty to Co-operate
In July 2017 Aylesbury Vale District Council, Chiltern District Council, South Bucks District Council, Wycombe District Council, and the Bucks Thames Valley Local Enterprise Partnership (BTVLEP) signed the Buckinghamshire Duty to Cooperate Memorandum of Understanding.
The process set out at paragraph 2.1 (d) of the Buckinghamshire Duty to Cooperate Memorandum of Understanding (MoU) in relation to unmet housing needs was that:
'The Councils agreed that that the housing need within the HMA would first fall to be met within each plan area based on the needs of each individual plan area, but if that was proven to be impossible then the resultant need would be met elsewhere within the 'best fit' HMA where it was reasonable to do so and was consistent with achieving sustainable development.'
It should be noted at paragraph 4.1 that:
'This is not a legally binding document but is an agreement and working understanding through which authorities are agreeing approaches for working together on shared planning principles and approaches to issues joint evidence and the content of respective local plans where relevant. The content will be kept under review and may be modified by agreement to take account of any relevant changes in circumstances. The following authorities agree to the above.'
It is noted in the MoU that Wycombe District has a significant level of Green Belt and Area of Outstanding Natural Beauty (AONB) which paragraph 3.16 of the Wycombe District Local Plan states is approximately 50% and 70% respectively.
However, there are areas within the Wycombe District which do not fall into Green Belt or AONB which can accommodate sustainable development over and above that which has already been allocated. It is my representation that further land is available in Wycombe District that can be sustainably allocated to the north/north east of Princes Risborough. Even the Aylesbury Valley District Council experts had doubts about the lack of land in the Wycombe District to accommodate the full 15,000/13,200 homes. To demonstrate this, in 2016 a report was commissioned by AVDC relating to the number of houses Wycombe District Council has the capacity to provide. This independent Why we are in this situation? Because the WDC experts used a wrong approach (from the beginning) at creation of the Local Plan for this District: instead of identifying additional sites suitable for development inside the Wycombe District (to fully achieve the target set up by the Government) they checked what un-met need can be accommodated by Aylesbury Vale District and then speculated at maximum this opportunity (using as an excuse the lack of land inside the District due to Green Belt and AONB - which is not true - and we truly hope that this mistake will be corrected by the Planning Inspector). Aylesbury Vale District Council signaled since August 2016 that ''the draft Wycombe District Local Plan seems to only have considered the provision of 10,000 homes and appears to have made only a limited attempt to accommodate the full 15,000 homes''. My representation supports this conclusion (but AVDC had to be stronger and more determined in demonstrating these irregularities before accepting the 2,250 dwellings un-met need to be transferred from Wycombe District. This may have happened if the AVDC sent a representation in November 2017, but these documents are not public at this time and a Freedom of Information request would take me a month until I get an answer - so I could not verify this in a timely manner). I am one of the people directly affected by this decision by WDC to transfer the un-met need to Aylesbury Vale District due to lack of land inside the District (because WDC not only does not use our land to build the house, but adds new restrictions - turning it without justification into the Green Buffer). To better understand our situation I have attached to this representation a copy of the representation for Wycombe District Local Plan submitted by the Planning expert (Mr. Paul Smith) on our behalf - in December 2017.
VALP Proposed Submission
Representation ID: 2525
Respondent: Aylesbury Society
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
The location of the 'oversupply' of employment land reflects the lack of connectivity of some sites to the transport network.
The Aylesbury Society
1. The Society's response is only concerned with those aspects of the plan which we believe imping on Aylesbury itself.
2. Our response will only deal with areas within which we have some knowledge and experience.
3. Arising from Point 2 above we are of the view that the sheer range of the plan (313 pages) together with the considerable number of supporting documents (64 No.) means that a meaningful consultation is not possible. The studies on Housing and Economic Development Needs, Sustainability, Cumulative Growth Impact, Housing Land Supply, New Settlement, Green belt, Land Availability, Sequential test Landscape, Open Space and Recreation, Retail, Viability Assessment, Aylesbury Transport Strategy, Countrywide Traffic Modelling, Housing Delivery and Infrastructure Delivery are generally comprehensive documents with major 'chapter' devoted to Aylesbury and its surrounds. There are no bodies with the range of skills to deal holistically with the various aspects.
4. In several cases, particularly transportation, the studies are incomplete, leaving doubts as to the conclusions in the proposed plan or effect on the existing area.
5. A major and significant omission is the lack of consideration of air quality and to what degree it will deteriorate as a result of development.
6. Failure to comment on some aspects of the plan does not imply approval or agreement to those aspects.
7. There is a need for a policy on community assets.
Before considering the principles and policies we wish to comment on the VALP definition of the town centre. It is defined as including Aylesbury College, Morrison's, the Vale Park. We would define it more narrowly as the area bound by the Chiltern Line railways, Exchange Street, New Street and Oxford Road including Friars Square, Market Square, Hale Leys and the High Street.
The remaining areas in the Town Centre Plan we consider as edge of centre with the exceptions of the Aqua Vale Centre which is accessed from the Park Road and well over 800 meters from the main retail area and therefore detached.
This smaller area is where the signs of decline and the need for regeneration are most obvious. Including area further out has the effect of glossing over the extent to which the town centre as defined more narrowly has been undermined by the way that retail parks and big supermarkets have been allowed in other parts of the town - a past failure a adopt what the Town Centre Plan calls a 'connected whole town approach.
Section 3 - Strategic
Para 3.3 - Should include reference to social facilities such as community centres, church halls, public houses, cafes etc.
Para 3.6 - We do not consider that the VALP has taken sufficient account of water and transport constraints nor that sustainability of residential location has been fully taken into account (see later).
Para. 3.13 - The location of the 'oversupply' of employment land reflects the lack of connectivity of some sites to the transport network.
Para 3.41 - Reflects a wish rather than a policy. It is by no means certain that necessary infrastructure will be4 delivered 'in timely manner' or even at all (see letter).
Para. 4.13 - If Aylesbury town centre is to be a sub-regional centre then it requires exhibition halls and areas set aside for use for open air festivals. None of these are present nor are they proposed in Policy D7. The polices and proposals in the Town Centre Plan do not appear to have been brought forward in Policies D7 and D8. Nor do any proposals for 'greening' the town centre as a whole appear in the document.
Para 4.16 - The three transport studies in the supporting evidence demonstrate that the following three objective will not be achieved; minimising the impact of future growth on traffic levels, congestion and air quality, improving journey time reliability and improving access and movement in the town centre.
Para 4.18 - makes no reference to community centres and village halls.
Para 4.28 (1) How will traffic growth be managed?
(2) No road improvements are proposed in the existing built up area
(3) Where will festivals be staged?
(4) There are no proposals to slow or stop the drift of employees away from the centre (e.g to Gatehouse) which is one of the root causes of the decline of the town centre.
(5) How will the growth of Aylesbury narrow the gap between the affluent and less well off...... Explain.
Policy D1 (b) According to the infrastructure Delivery Plan infrastructure will NOT be provided at the right time.
Policy D1 (h) A sub-policy is required to prevent residential encroachment by fencing hedging or construction onto local green infrastructure.
Policy D6 requires a clause setting limits to non retails uses in the town centre retail areas.
Para 4.196 Where will open space be provided, what will it be used for? A more positive statement and location and required.
Para 4.220 Makes no mention of narrow footways in Buckingham St., and Cambridge St., the unnecessary intrusion of vehicles into Kingsbury and Market Square and the new to extend the long standing pedestrianisation of Upper High Street.
Para 4.227 Parking policy and shop types need to take into account the sharp rise in 'click and pick-up' e.g. Argos and Waitrose/John Lewis which may well be the future of shopping in town centre. It may be that short term 'drive through' parking will arise
Section 5 - Housing
As policy is driven by government pressure we have no comment to make on number. However, we believe that no all reasonable alternatives sites have been considered. Given the road and rail improvements proposed across the congestion on Tring Road and Bedgrove without mitigation measures and lesser effects with full mitigation. In the summary table 5A Aylesbury it is stated that neither mitigation scenario fully negates the local plan impact.
The Aylesbury Transport Strategy has three objectives: to improve transport connectivity and accessibility, to improve accessibility to other urban centres and to contribute to improving air by minimising the growth in traffic levels and congestion. This last is clearly a contradiction, further objectives are: improving journey time reliability, reducing accidents and making it easier to travel by bus, cycle and foot.
The base year AM analysis shows congestion in the AM Peak on Tring Road, Wendover Road, all a road approaches to the Walton Triangle and Oxford Road. The congestion plot for the AM peak is 2033 without mitigation shows extensive serious congestion on Tring Road, Wendover Road, Lower Road and on all approaches to the Walton Triangle. The model shows, with full mitigation, serious congestion arises on Oxford Road, Lower Road, Bedgrove, Tring Road, Broughton Lane Buckingham Road and Bicester Road (Fig. 6.5 and 6.6).
AVDC produced a Transport Topic Paper with the draft submission. The paper sets out the purpose of the above papers and lists the previous public comments and AVDC's response.
It is our view that the comparisons of changes in traffic conditions do not properly take into account the several residential developments approved in the recent past. These pre-empted the VALP and their impact is not considered. It is our view that the transport infrastructure to be provided is inadequate for the ultimate level of development including those recently approached development.
No consideration has been given to the potential effects of enlarging both Winslow and Haddenham instead of just one.
Despite occasional references within the explanatory paragraphs there is no policy on park and ride.
There is no policy on priority for public transport nor a comprehensive approach to bus priority except as an indication on one plan.
8. Air Quality NE 6
From traffic studies it can be seen that congestion is likely to increase significantly on Lowe Road, Stoke Road, Tring Road and Wendover Road at least until such time as the link road network is complete. Congestion will decrease air quality particularly on Tring Road.
It is suggested that the following sub clauses be added to 'Air Quality'
g. Any development proposed which is shown to lower air quality on Tring Road, Wendover Road, Lower Road and Stoke Road will not be permitted.
Sub clause (e) needs to indicate that if air quality standards elsewhere are likely to be breached elsewhere development will not be permitted.
Infrastructure Delivery Plan
As a society we do not have the expertise and experience to comprehensively comment on the full range of infrastructure needs. Our comments are this limited to transport.
Although most of the link roads are marked 'critical' in the IDP for completion by 2023 (medium term) several are 'developer contribution' funded with no indication as to whether this is in whole or in part. Several have vague indicative costs.
The Western Link is described as critical but 'funding could be an issue'. The North East Link is described as 'necessary' in contrast to all the other links. There is no explanation for this anomaly. Funding is also vague.
Park and ride (in association with the PPTCs) is described as desirable. It is the society's view that it is essential and critical particularly in interim period when the links are piecemeal.
Overall we are of the opinion that there should be policy of no further development until at least two park and ride sites, linked by bus priority measures, are available and the system of link is substantially complete.
A policy of monitoring the transport infrastructure should be included which includes levels of congestion, air quality, accident rates and reliability of travel time by all modes of transport.