Aylesbury Vale Area

3.17

Showing comments and forms 1 to 5 of 5

Object

VALP Proposed Submission

Representation ID: 1080

Received: 14/12/2017

Respondent: Mr. Terry Annable

Agent: Framptons Town Planning

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

The Housing Land Supply of 28,830 represents a buffer of only 5.2%. In Medium Villages identified in Table 2, provision is made in Policy S2(h) for 1,095 dwellings of which 274 are allocations and the remainder are completions/commitments. Given uncertainties about delivery in the Medium Villages, it would be reasonable to expect a higher level of non-implementation than 5.2%. There is justification for additional allocations at Medium Villages provided they meet the requirements of Policy S2(h) i.e. "at a scale in keeping with the local character and setting." Land south of Gawcott is proposed as an allocation for 24 dwellings.

Full text:

Please find attached representations to the Proposed Submission November 2017 Vale of Aylesbury Local Plan 2013-2033 submitted on behalf of Mr Terry Annable

Object

VALP Proposed Submission

Representation ID: 1813

Received: 14/12/2017

Respondent: Mrs Alina Neagoe

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation:

how will the AVDC plan change if the 2250 homes from the un-met need for WDC will no longer be transferred to Aylesbury Vale District (because Wycombe District must fully respect the Buckinghamshire Duty to Cooperate Memorandum of Understanding)? What if also some of the 5,750 dwellings will no longer be transferred from Chiltern/South Bucks? Will this Local Plan for Aylesbury Vale continue to reflect the reality after serious modifications regarding the un-met need (being jeopardized)? Does the Aylesbury Vale have a back-up Local Plan to contain only the number of homes originally set up for this District (19,400 dwellings)?

Full text:

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
District Council).
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.

Object

VALP Proposed Submission

Representation ID: 1892

Received: 13/12/2017

Respondent: Amarillo Ltd & Scandale Ltd

Agent: Planning Prospects

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation:

Regarding the inclusion of a new settlement we consider that the VALP current position is likely to give rise to significant objection from residents of numerous settlements which will hamper the delivery of the required homes in Aylesbury Vale. The New Settlement should be allocated now and not part of an early review due to the length of time to deliver a new settlement.
Land to the North of Winslow (WIN001 - Greenway project) has been previously promoted is the most sustainable option for a new settlement in the district and is located adjacent to key infrastructure priorities.

Full text:

See attachments

Policy S2 sets out the Spatial Strategy for growth in Aylesbury Vale over the emerging Plan Period (2013 to 2033) and says that the VALP will provide for 27,400 new homes during that period. Policy S2 is followed by Table 1 which sets out that the Allocations put forward in teh draft VALP amount to 12,997, which when added to commitments in the Sitrict will result in provision of 28,830 new homes during the plan period. This represents a buffer of 5.2% over the total housing requirements put forward in the VALP.

Not with standing our concerns over the level of housing growth put forward in the VALP (subject to a separate response form) we do not consider that a 5.2% buffer gives sufficient flexibility should the sites identified by the Council not deliver at the rate or density anticipated in the Plan or even should they fail to deliver at all. This is particularly concerning where the VALP includes a number of large strategic allocations which are subject to significant delivery constraints such as major infrastructure requirements (including being linked to delivery of HS2).

Paragraph 3.79 of the draft VALP sets out that in the four years of the Plan period that have occurred to date (i.e 2013 to 2017) delivery in those years has cumulatively fallen short of the annual delivery target. this means that there is already a pent-up shortfall in delivery in Aylesbury Vale in the Plan period and the %.2% buffer has already been eaten into during its early years, thereby reducing the flexibility further going forward.

Paragraph 3.80 acknowledge that achieving the level of housing delivery set out in the VALP is ambitious and will be a significant increase on past rates. With this in mind, we consider it necessary to identify additional allocations to provide a greater buffer and provide sufficient flexibility to ensure that the homes required in Aylesbury Vale are delivered in the Plan period.

Our concerns are exacerbated if (as we consider it should be) a higher OAN is considered and the level of housing growth is increased as a result.

With the above in mind, we do not consider that the Plan as currently drafted is positively prepared, justified, effective or consistent with National Policy as it will not deliver the homes required in Winslow or the District or indeed the winder HMA.

Object

VALP Proposed Submission

Representation ID: 2385

Received: 07/12/2017

Respondent: Nash Parish Council

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation:

Another major problem with the VALP springs up every time any of the figures for housing is looked
at in detail, it is very difficult to establish a set point. Almost all the figures given are variations, 650
more houses, 15 more traveller pitches, but nowhere are the base or starting figures nor the target
figures for 2033. This makes assessment of the plan difficult as also any future monitoring.
Minor points which appear include in paragraph 3.17 the suggestion, with little backing, that a 5.9%
contingency should be added to the housing figure which becomes 5.2% in table 1.

Full text:

Please see attachment for full representation.

Object

VALP Proposed Submission

Representation ID: 2718

Received: 14/12/2017

Respondent: Ainscough Strategic Land

Agent: Turley Associates

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation:

We would question whether the approach of over-allocating by 5.2% provides sufficient headroom to ensure the delivery of a significant uplift in the housing requirement, especially when the Council has had a track record of under delivery in previous year. To provide the context ASL would highlight that since 2011 the Council have only achieved the delivery of 1,370 new homes (the proposed annual requirement) in 2014/15.

Full text:

Please find attached representations to the Pre Submission Vale of Aylesbury Local Plan Consultation prepared on behalf of Ainscough Strategic Land in relation to 'Land at the Former Marsworth Airfield, Marsworth, Buckinghamshire', which is being promoted through the emerging Local Plan for a residential led mixed use development.