Aylesbury Vale Area

S2 Spatial Strategy for Growth

Showing comments and forms 1 to 30 of 152

Object

VALP Proposed Submission

Representation ID: 190

Received: 17/11/2017

Respondent: Mr Tim Jones

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation:

The document appears to assume as a given, that we have to adopt the additional homes that are not to be built in South Bucks, this is unreasonable. Where does this passing of responsibility end? Can we expect to absorb the shortcoming of Northants, Beds and Milton Keynes as well?

Once this 'process' is established there will be boundary or control that can be fairly reasoned for or against. We must address the needs of North Bucks and North Bucks only. The environmental impact of this diktat will be enormous.

Full text:

The document appears to assume as a given, that we have to adopt the additional homes that are not to be built in South Bucks, this is unreasonable. Where does this passing of responsibility end? Can we expect to absorb the shortcoming of Northants, Beds and Milton Keynes as well?

Once this 'process' is established there will be boundary or control that can be fairly reasoned for or against. We must address the needs of North Bucks and North Bucks only. The environmental impact of this diktat will be enormous.

Object

VALP Proposed Submission

Representation ID: 206

Received: 13/12/2017

Respondent: Crevichon Properties Ltd

Agent: Delta Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

It is considered that the development strategy and proposed level of housing provision set out in Policy S2 will not provide for sufficient levels of sustainable development to meet the OAN of the District and HMAs and therefore does not meet the test of soundness as it fails to accord with NPPF.

Full text:

Objection is raised to the level of housing numbers identified in this version of the Plan on the basis that it is not positively prepared. The previous iteration of the Plan in 2016, identified a total of 33,000 houses would be provided in the plan period, whilst this Submission version has reduced this figure to 27,400. Of this new total it states that 19,400 are provided to meet the needs of Aylesbury Vale District, 2,250 to meet the needs of Wycombe District and 5,750 to meet the needs of Chiltern/South Bucks. The basis of these figures comes from the Buckinghamshire HEDNA. The HEDNA has undergone a number of revisions and has been subject to significant criticism for the way it has been undertaken and is yet to be fully tested through examination. Furthermore, the HEDNA does not take into account Government Initiatives to increase growth along the Cambridge to Oxford growth corridor nor does it use the proposed new standard methodology which is likely to increase the housing requirements of the housing market area. The Council is suggesting that the new methodology can be addressed through a future update to the Plan but this would not accord with the emerging timetable of implementation for the new methodology which will require all plans to accord with it from April 2018. Since examination of this Plan will be after this date it should clearly be prepared with this change incorporated.

A central requirement of NPPF is the provision of sufficient housing to meet the needs of present and future generations and in doing so widen the choice of housing. To achieve this, it requires Local Planning Authorities to positively seek opportunities to meet the development needs of their areas and that 'Local Plans should meet objectively assessed needs , with sufficient flexibility to adapt to rapid change' and 'set out a clear strategy for allocating sufficient land'. Delivery is underpinned in NPPF by paragraph 47, which seeks to significantly boost the supply of housing requiring local planning authorities to 'use their evidence base to ensure that their Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area'.
It is considered that the development strategy and proposed level of housing provision set out in Policy S2 will not provide for sufficient levels of sustainable development to meet the OAN of the District and HMAs and therefore does not meet the test of soundness as it fails to accord with NPPF.

Furthermore, this level of housing provision could seriously impact on the future prospects of the District and have negative impacts on the provision of affordable housing for local people making the District less attractive as a location for people to live and work.

Objection is also made to the level of growth identified at Winslow. This is a strategic settlement and it is considered that given its sustainability credentials, including a new free school and rail station, it has the ability to deliver more homes that the 1,166 currently identified.

Object

VALP Proposed Submission

Representation ID: 207

Received: 13/12/2017

Respondent: The University of Buckingham

Agent: Delta Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

Objection is raised to the level of housing numbers identified in this version of the Plan on the basis that it is not positively prepared.

Full text:

Objection is raised to the level of housing numbers identified in this version of the Plan on the basis that it is not positively prepared. The previous iteration of the Plan in 2016, identified a total of 33,000 houses would be provided in the plan period, whilst this Submission version has reduced this figure to 27,400 without ,we believe, sufficient justification. Of this new total it states that 19,400 are provided to meet the needs of Aylesbury Vale District, 2,250 to meet the needs of Wycombe District and 5,750 to meet the needs of Chiltern/South Bucks. The basis of these figures comes from the Buckinghamshire HEDNA (December 2016) but this does not take into account proposed new standard methodology which is likely to increase the housing requirements of the housing market area. The Council is suggesting that the new methodology can be addressed through a future update to the Plan but this would not accord with the emerging timetable of implementation for the new methodology which will require all plans to accord with it from April 2018. Since examination of this Plan will be after this date it should clearly be prepared with this change incorporated.

A central requirement of NPPF is the provision of sufficient housing to meet the needs of present and future generations and in doing so widen the choice of housing. To achieve this, it requires Local Planning Authorities to positively seek opportunities to meet the development needs of their areas and that 'Local Plans should meet objectively assessed needs , with sufficient flexibility to adapt to rapid change' and 'set out a clear strategy for allocating sufficient land'. Delivery is underpinned in NPPF by paragraph 47, which seeks to significantly boost the supply of housing requiring local planning authorities to 'use their evidence base to ensure that their Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area'.
It is considered that the development strategy and proposed level of housing provision set out in Policy S2 will not provide for sufficient levels of sustainable development to meet the OAN of the District and HMAs and therefore does not meet the test of soundness as it fails to accord with NPPF.

Furthermore, this level of housing provision could seriously impact on the future prospects of the District and have negative impacts on the provision of affordable housing for local people making the District less attractive as a location for people to live and work.

Objection is also raised to the proposed level of housing development at medium villages. It is considered that more development should be directed towards these locations on sustainable sites to ensure that these villages remain viable.

Support

VALP Proposed Submission

Representation ID: 275

Received: 02/11/2017

Respondent: Paradigm Housing

Representation:

The only query I have as I do agree you have followed the correct procedure for Duty to Cooperate in the Housing market area is the fact Lutons unmet need locations is still undetermined. It looks like they were looking to AVDC to see whether they would accept an allocation. As far as I am concerned as AVDC have already taken 8,000 unmet need from three other LAs it would be unreasonable to expect AVDC to accept a higher figure.

Please be aware it would be wise to consider Chiltern/ South Bucks unmet need number could well rise as they will be submitting their local plan after March 2018 when the new methodology will kick in. As they feel they have exhausted all suitable sites for development it may be AVDC will have to accept a higher figure. (Slough will also have a large unmet need as this has not been determined either)

Full text:

Hello

The only query I have as I do agree you have followed the correct procedure for Duty to Cooperate in the Housing market area is the fact Lutons unmet need locations is still undetermined. It looks like they were looking to AVDC to see whether they would accept an allocation. As far as I am concerned as AVDC have already taken 8,000 unmet need from three other LAs it would be unreasonable to expect AVDC to accept a higher figure.

Please be aware it would be wise to consider Chiltern/ South Bucks unmet need number could well rise as they will be submitting their local plan after March 2018 when the new methodology will kick in. As they feel they have exhausted all suitable sites for development it may be AVDC will have to accept a higher figure. (Slough will also have a large unmet need as this has not been determined either)

Steve Brown | Housing Officer
Paradigm Housing Group

Object

VALP Proposed Submission

Representation ID: 362

Received: 22/11/2017

Respondent: Joyce Graham

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

You do not provide schools, doctor's surgeries, sufficient roads to cope with all the countryside you will ruin, all the wildlife you will kill putting up housing to turn Aylesbury into a borough of London.

Aylesbury is loosing it's character each time you agree to plans that turn our road system into one long traffic jam. If you believe that builders care about Aylesbury other than to make money and run straight to the bank, you are fooling yourselves. They will not be living with the results of the crowding and lack of facilities. I would like to think that those of the council that are pushing these plans will be around to be accountable for the mess they are making.

Full text:

Dear Sir/Madam.

I am appalled and disappointed by your report and proposals/plans in the VALP. You do not provide schools, doctor's surgeries, sufficient roads to cope with all the countryside you will ruin, all the wildlife you will kill putting up housing to turn Aylesbury into a borough of London.

Aylesbury is loosing it's character each time you agree to plans that turn our road system into one long traffic jam. If you believe that builders care about Aylesbury other than to make money and run straight to the bank, you are fooling yourselves. They will not be living with the results of the crowding and lack of facilities. I would like to think that those of the council that are pushing these plans will be around to be accountable for the mess they are making. I believe the decision makers will be retired, on very good pensions, living elsewhere than Aylesbury well before 2033 when the full stupidity of this action is realised. As with most public bodies, no one is ever responsible for the failures, they are usually long gone!

If this email has not been sent to the correct department, I would be grateful if you would forward this to the correct place. Thanks.

From a saddened member of the public.

Joyce Graham

Support

VALP Proposed Submission

Representation ID: 368

Received: 05/12/2017

Respondent: Milton Keynes Council

Representation:

Policy S2 (Spatial strategy for growth) of the Proposed Submission Local Plan provides for about 1,855 new homes adjacent to Milton Keynes. We have no objections in principle to the inclusion of Salden Chase (SWMK), provided that the infrastructure requirements for Salden Chase outlined in the VALP are retained in the final plan and are delivered in the manner set out in the attached Memorandum of Understanding.

Full text:

Vale of Aylesbury Local Plan - Proposed Submission Plan Consultation

Thank you for the opportunity to consider and comment on your draft Local Plan.

Milton Keynes Council has no objections in principle with the content of the proposed submission Vale of Aylesbury Local Plan and no concerns regarding the Duty to Co-operate.

Policy S2 (Spatial strategy for growth) of the Proposed Submission Local Plan provides for about 1,855 new homes adjacent to Milton Keynes. We have no objections in principle to the inclusion of Salden Chase (SWMK), provided that the infrastructure requirements for Salden Chase outlined in the VALP are retained in the final plan and are delivered in the manner set out in the attached Memorandum of Understanding.

In particular, we welcome the commitment from AVDC to work with MKC to address the infrastructure and services needed to mitigate the impact of the development on Milton Keynes, including highway improvements, public transport provision, public rights of way improvements, green infrastructure, community facility, education facilities, health facilities, local centre and employment area as included in VALP.

We would, however, request that one minor modification is made to the Salden Chase policy (pages 110-114) in the proposed submission VALP:
* To insert in the Salden Chase policy a requirement for a green buffer to be included on the eastern edge of the site to protect the adjacent community of West Bletchley.

Yours sincerely

John Cheston, Development Plans Team Leader

Object

VALP Proposed Submission

Representation ID: 426

Received: 12/12/2017

Respondent: Hampden Fields Action Group

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation:

The allocation of housing is too great for the areato the South of Aylesbury. The plan will lead to more local traffic in the peak times as people commute out of the town. The placement of large housing developments which do not have sufficient public transport links will result in very high car usage and exacerbate the problem. The expected jobs are no more than allocations on map. AVDC has a particularly bad track record of delivering jobs. Aylesbury is no more than a dormitory town for London, Milton Keynes and Oxford commuters.

Full text:

The allocation of housing is too great for the areato the South of Aylesbury. The plan will lead to more local traffic in the peak times as people commute out of the town. The placement of large housing developments which do not have sufficient public transport links will result in very high car usage and exacerbate the problem. The expected jobs are no more than allocations on map. AVDC has a particularly bad track record of delivering jobs. Aylesbury is no more than a dormitory town for London, Milton Keynes and Oxford commuters.

Object

VALP Proposed Submission

Representation ID: 468

Received: 08/12/2017

Respondent: Arnold White Estates

Agent: Gardner Planning Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

ORS District number is flawed at 970 homes p.a., well below other sources - ONS (1,092), GL Hearn 2015 (1,326), DCLG (1,499). CMKOx figures will be even higher. Household figures rose in the 2014 based projections (from 18,404 to 21,028), but ORS figures fell (from 21,289 to 19,385). ORS uses 10-year migration but ONS is 5-year. ORS have raised this point many times but ONS has not agreed. ORS numbers are so different complete re-assessment is required.
5YHLS is wrongly calculated and cannot be demonstrated - inadequate provision is made for 'persistent under-performance'.

Full text:

I attach the response to the consultation on the Proposed Submission VALP on behalf of Arnold White Estates. This is in the format of a full written Response because it deals with matters that cannot be adequately set out in a simple form.
However, a completed facsimile of you form is attached as an appendix with contact details and a summary of the representations (by policy number on separate sheets).
Please acknowledge receipt, note that I wish to participate in the Examination and keep me advised of progress.

Full summary given where it was more than 100 words (more detail in the main report):

S2

1. In order for the Plan to be 'sound' it must be based on robust evidence. The ORS
HEDNA, and thus the basis for the housing numbers in Policy S2 of the PSVALP, is long
and detailed, but essentially flawed. Its robustness is challenged by comparison with
three other sources in which ORS arrives at an annual OAN (970 homes p.a. for the
District) which is well below these: the ONS household projections (1,092), the GL
Hearn 2015 HEDNA (1,326) and the DCLG new methodology (1,499). Even the early
versions of the VALP/HEDNA had a higher OAN based on ONS 2012 projections. Yet
when these figures rose in the 2014 based projections (from 18,404 to 21,028) the
ORS figures fell (from 21,289 to 19,385). Also, the adjustment for migration trends
and other adjustments seem to fluctuate wildly (compare fig 109 in October 2015
with fig 122 in September 2017).
2. The HEDNA's low number is based on an early assumption that the use of a 10-year
migration trend is superior to that which continues to be used by ONS, even though
ORS have raised this point many times in recent years and are likely to be in close
touch with ONS. The ORS methodology reduces the ONS 'demographic starting
point' by over 4,000 households or 19%. There are then many further 'adjustments'
which are very detailed but almost incomprehensible. Even without the higher
numbers of the DCLG new methodology, it fails the test of "simpler, quicker, and
more transparent". A principle of the new methodology is to add a margin well
above household projections. Whilst the DCLG 2017 consultation states that Plans
submitted before 31.3.17 "will continue with the current plan preparation", the ORS
HEDNA numbers are so different to those derived from other sources that a complete
re-assessment is required and the PSVALP should then be based on the new, simpler
and transparent methodology.
3. The GL Hearn 2015 HEDNA arrived at an OAN (without allowance for accommodating
unmet housing needs of adjoining Authorities) of 1,326 home p.a. mainly because it
added housing needs of greater economic growth. The Cambs-MK-Oxford Growth Corridor vision and proposals of 2017, supported in the Autumn Budget, reinforce
and extend that growth potential and the consequent need for more housing.
4. The provision for unmet housing needs of adjoining Authorities may be inadequate
when the new DCLG methodology is applied to their numbers which are significantly
higher than currently anticipated.
5. The 5-year housing land supply figures are wrongly calculated in PSVALP paras 3.78 -
3.80 and Table 7 because inadequate provision is made for 'persistent underperformance'
and the correct figures show that a 5-year supply cannot be provided.
This is contrary to NPPF para 47.
6. PSVALP Policy S2, in terms of housing numbers, is therefore unsound because it is
not:
* Positively prepared - the objectively assessed housing needs are not based on
clear and robust evidence, and unmet requirements from adjoining Authorities
may be higher than anticipated.
* Justified - this is not the most appropriate strategy based on the evidence.
* Consistent with national policy - no account is taken of the Housing White
Paper and the growth proposals for the Cambs-MK-Oxford Corridor; and
provision for the 5-year housing land supply is inadequate.

D1 & S2

1. Whilst the term "Garden Town" is unobjectionable, the reality is that all the
Aylesbury sites are just urban extensions, two of which (AGT5 Berryfields and AGT6
Kingsbrook) already have planning permission and two (AGT3 Aston Clinton and AGT4
Hampden Fields) are the subject of applications submitted in early 2016.
2. In reality, therefore, the majority of "Garden Town" already (or almost) has planning
permission. Only two sites AGT1 (South Aylesbury) and AGT2 (South-West Aylesbury)
effectively seem open to discussion.
3. In relation to PSVALP Policies CP2 and D1, this Response raises objections to the
proposed allocation of both sites:
* AGT1 (South Aylesbury, 1,000 homes) is a collection of 6 small sites in different
ownerships without highway access, such that delivery must be in doubt.
* AGT2 (South-West Aylesbury, 1,550 homes) is severely constrained by HS2 of
which the centre line forms the south-west boundary of the site such that for at
least 100m into the site there can be no housing, and even beyond that living
conditions would be uncomfortable. The conclusion of the Core Strategy
Inspector's report in June 2010 on this site was "This would have a major
impact on the deliverability and potentially, the viability of the SGA, through
significant land take in the SW site".
The Plan is therefore unsound because
Positively prepared - two major sites have been allocated not based on clear and
robust evidence.
Justified - this is not the most appropriate strategy based on the evidence. Two
other sites proposed by GPL/AWEL are more sustainable, provide significant
benefits, are deliverable and are not adversely affected by HS2.
Berryfields East
1. The AWEL Berryfields East site (Appendix 3 in Full Response) to the NW of Aylesbury
should be considered as part of the growth of Aylesbury as a 'garden town'. The site
was submitted in response to the 'call for sites' in April 2014. It has a gross area of
some 20ha and a net developable area of some 11ha, with a capacity for some 350
homes.
2. The HELAA response was to raise concerns about landscape, impact on the setting of
the Scheduled Ancient Monument and biodiversity. These were broadly the reasons
for rejecting an appeal on the site in 2012. However, the scheme has been radically
revised since then to take account of the reasons for dismissal and has been
considerably reduced in terms of site area and numbers of dwellings. The appeal
decision related to some 1,380 dwellings on the larger site of some 33ha net.
Appendix 3 shows the revised illustrative masterplan, which has regard to the
Inspector's findings, and, for comparison, the rejected masterplan.
3. As well as a substantial reduction in site area and numbers of dwellings, the revised
scheme demonstrates significant changes since the last scheme was dismissed 5
years ago:
* The Western Link Road is now constructed and the Berryfields development has
advanced which changes the character and appearance of the local countryside
and the setting of the SAM.
* A substantial gap is provided between the eastern boundary of the
development area and Weedon Hill Urban Extension further to the east.
* Extensive open countryside in the new scheme would enhance the countryside
setting.
* The need for housing growth around Aylesbury is much greater than in
2010/12, and this Response has demonstrated that the PSVALP will have a
shortfall in requirements of thousands of homes.
* The site is unaffected by HS2.
* The landscape objection falls away because of the LUC study which designates
the nearest landscape designation being the Quainton-Wing Hills, some 2.76
km from the site to the nearest point just south of Weedon.
4. The HELAA seems to be assessing the 2010 scheme which is now superseded. The
new proposals are achievable, suitable and deliverable (the site is in single
ownership), and all within 5 years.
5. The proposal for the 'Aylesbury Linear Park' is supported. The plan on p66 is
somewhat difficult to read in the vicinity of Berryfields East but shows this Park as the
open land south of the Western Relief Road partly on land in the same ownership as
Berryfields East. Development on Berryfields East would therefore facilitate this
section of the Linear Park/green infrastructure network. Such integration of
development and green infrastructure is encouraged in Policy I1:
The Council will work with partners to ensure that existing and new green
infrastructure is identified, planned, delivered, enhanced and managed in a
strategic way as an integral part of supporting sustainable communities and
sustainable growth. The Council will implement the most up-to-date green
infrastructure strategies. Green infrastructure networks whether existing or
potential are expected to be a key part of site masterplanning as required in the
VALP.
6. Berryfields East, capacity 350 dwellings, should therefore be added to the list of
sites for Aylesbury in Policies S2 and D1.
Waddesdon
1. Waddesdon has been 'under-scored' in the settlement hierarchy by one factor -
distance to a main settlement - based on inaccurate measurement (see paras 2.28 -
2.30 above). In fact, Waddesdon is a 'large' large village with extensive facilities
(including a school, retailing, employment, good public transport, police and fire
stations, hotel and stately home), but is fundamentally harmed by the passage of
heavy traffic on the A41, which bisects the settlement.
2. However, Waddesdon is classed as a 'large village' in the hierarchy, which means
(emphasis in bold):
* As stated in the introduction to this report, the settlement hierarchy purpose is
not only to identify the current role of settlements through the facilities and
services they provide, but also to help define a sustainable settlement hierarchy
to facilitate decisions through the Vale of Aylesbury Local Plan on which
settlements are best placed to accommodate future development.
* Larger, more sustainable villages that have at least a reasonable access to
facilities and services and public transport, making them sustainable locations
for development.
3. Despite this encouragement, there are no housing allocations in the PSVALP for
Waddesdon.
4. In several places PSVALP mentions that the impact of HS2 will have to be mitigated.
This is particularly important to the opportunities for development at Waddesdon.
Here, HS2 passes close to the north of Waddesdon and the proposed AWEL
development (Appendix 4) includes mitigation measures that will shield the village.
5. The Inspector's Report on the NP included the following extracts:
In my assessment, the promotion of this major development to the north of the
village, together with a projected A41 Relief Road, is a matter of strategic districtwide
importance which falls properly to be considered as part of the preparation of
the VALP.
6. In several places PSVALP mentions that the impact of HS2 will have to be mitigated.
This is particularly important to the opportunities for development at Waddesdon.
Here, HS2 passes close to the north of Waddesdon and the proposed AWEL
development (Appendix 4) includes mitigation measures that will shield the village.
7. The proposed development at Waddesdon (Appendix 4 in full Response) includes the
advantages as fully set out in the full Response, e.g.
* provision of some 600 homes, either in the context of the housing shortfall
detailed or as an opportunity site
* the creation of a Garden Village development
* facilitation of a relief road and improvements to the central area of the village
* provision of a village green
* improvement to the appearance of the site by removal of poor and redundant
agricultural buildings
8. These are interesting times when much of planning orthodoxy is being overturned in
order to meet society's real needs (especially housing). It is turning away from
negative stances of protectionism against development towards positive action which
benefits all parts of the community which it serves. The first policy (S1) in the DP
begins:
The council will work proactively with applicants to find solutions so that proposals
can be approved wherever possible, and to secure development that improves the
economic, social and environmental conditions in the area.
9. AVDC has the opportunity to put this into practice at Waddesdon and include the
AWEL development proposal as a strategic site in the Local Plan in Policies S2 and
D1.

Object

VALP Proposed Submission

Representation ID: 471

Received: 07/12/2017

Respondent: Mr and Mrs J L Wickson and S G Raven

Agent: JMI Planning Ltd

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

We believe this strategy to be ineffective, significant concerns are raised with the
deliverability of the larger allocations. We are therefore of the view that the Proposed Submission Local Plan places too
much reliance on the new settlement, and also on development on unspecified sites
around Milton Keynes and within strategic settlements.

The failure of the Proposed Submission Local Plan to allocate organic and sustainable
growth to smaller villages including Nash is inconsistent with National Planning

Full text:

1 Introduction
1.1 JMI Planning is a Midlands based town planning consultancy. Its directors are chartered town planners with over 30 years' combined experience in both the public and private sector.
1.2 The author of this appraisal, Jim Malkin, has worked as a principal planning officer in local government, and more recently as a planning consultant in the private sector. He has extensive knowledge of the planning system and is a member of the Royal Town Planning Institute.
1.3 This document sets out representations to the Proposed Submission Vale of Aylesbury Local Plan made on behalf of Mr J L Wickson and Mrs S G Raven, the owners of a piece of land in the village of Nash.
2 Site Details
2.1 The area of land over which Mr J L Wickson and Mrs S G Raven have an interest comprises approximately 0.45 hectares of agricultural grassland to the rear of Church Farm in Nash. This is a suitable, sustainable and in our view entirely logical site for development, is immediately available and achievable and has the opportunity to provide significant benefits to the village of Nash. Our representations are submitted against this background.
2.2 The site measures 0.45ha in size and is directly linked connected to the existing built form of the village. The site is bordered on 3 sides by existing residential development, the majority of which constitutes post war expansion of the village, and can be accessed through the recently completed All Saints Close development. The site cannot therefore be considered to be an intrusion into the countryside.
Proposed Submission Local Plan Representations - Aylesbury Vale District Council
4
2.3 There is easy access from the site to all current available amenities within Nash and access to sustainable transport options in the village. The scale of the site is commensurate with scale of the village and will not provide for a disproportionate level of development but will support and enhance facilities available in Nash and adjoining settlements for the benefit of all residents.
3 Representations on the Proposed Submission Local Plan
3.1 Nash is defined as a smaller village within the Proposed Submission Local Plan. It is proposed that the amount of new housing that will come forward within smaller villages will be defined 'through neighbourhood plans or through the development management process considered against relevant policies in the Plan'.
3.2 The key test related to the Submission Local Plan is one of soundness and the plan should be positively prepared, justified, effective and consistent with National Planning Policy. We have significant concerns as to whether the plan can be considered sound, especially with regards to the provision of new development within smaller villages.
3.3 The plan fails to provide positively for the sustainable growth of smaller villages and is likely to result in these villages stagnating. Not all of the villages / parishes will prepare Neighbourhood Plans, and general development management policies seek to restrict new residential development outside development boundaries, and will not promote the sustainable expansion of smaller villages in Aylesbury Vale.
3.4 The plan seeks to provide for 27,400 new homes which is a significant reduction on the number of new homes suggested within the initial draft Vale of Aylesbury Local Plan, Policy S2 initially stated that provision should be made for 33,300 new homes. The plan advises of the spatial distribution of new development and advises the following:
Proposed Submission Local Plan Representations - Aylesbury Vale District Council
5
* 16,398 will be provided in Aylesbury Garden Town
* 2,359 in Buckingham
* 1,051 in Haddenham
* 1,166 in Winslow
* 1,128 in Wendover
* 2,212 on Land Adjacent to Milton Keynes
* 1,963 in Larger Villages
* 1,095 in Medium Village
3.5 We believe this strategy to be ineffective, significant concerns are raised with the deliverability of the larger allocations. There is significant reliance placed on the completion of the Aylesbury Garden Town. The delivery of over 16,000 new homes and necessary infrastructure by the end of the plan period is at best highly unlikely. These types of allocations in other areas have historically been known to require significant lead times due to market conditions or through infrastructure constraints, whilst issues inevitably arise where multiple landowners are involved.
3.6 We are therefore of the view that the Proposed Submission Local Plan places too much reliance on the new settlement, and also on development on unspecified sites around Milton Keynes and within strategic settlements.
3.7 Considering this we feel that the Council's decision to remove a specific allocation from smaller villages cannot be justified. It would be entirely appropriate for smaller villages to provide a level of organic growth to take the pressure off the delivery of larger sites. If 5% of housing growth (as was the case in the draft plan) was focused on smaller villages this would equate to 1,370 houses and this would take significant pressure off the other allocations.
3.8 The failure of the Proposed Submission Local Plan to allocate organic and sustainable growth to smaller villages including Nash is inconsistent with National Planning
Proposed Submission Local Plan Representations - Aylesbury Vale District Council
6
Policy which seeks to promote development rural areas. Paragraph 55 of the National Planning Policy Framework seeks 'to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities'. National Planning Policy also advises that where there are smaller groups of settlements 'development in one village may support services in a village nearby'.
3.9 In paragraph 17 the National Planning Policy Framework requires plan makers to take 'into account of the different roles and character of areas' and this should underpin plan-making. In removing / reducing the role of smaller villages in delivering development the proposed Submission Local Plan fails to respect the different roles associated with smaller villages as opposed to main urban areas.
3.10 It is therefore clear that the thrust of national planning policy is to promote the growth of villages, and the Proposed Submission Local Plan is entirely inconsistent with this requirement.
3.11 With focus on Nash the village is in close proximity to other designated 'smaller villages' including Whaddon, Thornborough and Beachampton, therefore growth of Nash will have residual benefits to adjoining settlements and promote sustainable expansion as advocated in paragraph 55 of the NPPF.
3.12 The Proposed Submission Local Plan in advising that there is no housing requirement in smaller villages such as Nash, fails to promote the growth of such communities and it would lead to stagnation. The site that is being promoted by Mr J L Wickson and Mrs S G Raven comprises of a small area of land to the rear of Church Farm which could provide for 9 units; this would be a proportionate expansion of the village (equating to a 5.3% increase in the number of dwellings, which is broadly the same as the level of growth over the previous 20 years), and will support the existing community and facilities in both Nash and adjoining villages.
Proposed Submission Local Plan Representations - Aylesbury Vale District Council
7
3.13 Nash is located in close proximity to facilities in larger, key settlements in Aylesbury Vale. Aylesbury Vale District Council's Settlement Hierarchy Assessment considers Nash only in relation to accessing services in Milton Keynes 7 miles away. The village is also approximately 7 miles from Buckingham which has a large number of facilities including primary and secondary schools, higher education facilities. Approximately 4 miles from Nash is Winslow which has a GP's surgery, secondary school, and is on the proposed East West Rail link. 2 miles from Nash and within easy cycling distance is the larger village of Great Horwood which too provides several key services including a primary school. The proposed route of the Oxford to Cambridge expressway following the A421 close to Nash is also considered important and adds to sustainability credentials of the village.
3.14 The proposed site in Nash is identified, alongside another six in the Housing and Economic Land Availability Assessment (HELAA). The HELAA identifies circa 20 sites within designated smaller villages that are capable of coming forward, and these could provide for up-to 200 homes across the plan period.
3.15 The HELAA identifies the site as the deliverable with the site assessment stating the site is 'suitable for housing - providing suitable access is provided via new housing development on Stratford Road and suitable amenity space is allocated within the site. Restricted visibility at High Street/Whaddon Road junction. Subject to adequate access arrangements'. It has been proven through the previous application that the site can be provided with suitable amenity space, and also with safe access. On this basis it is clear that the proposal is deliverable and will make a small, but valuable contribution to meeting the housing requirements over the plan period.
3.16 The Sustainability Appraisal also provides consideration of the site and it scores highly with regards to the designated criteria. Out of the 31 criteria 21 of these are green, with 5 amber which include proximity to the Conservation Area, Listed Buildings, Attractive Landscape Area (Whaddon Nash Valley to east of village), and
Proposed Submission Local Plan Representations - Aylesbury Vale District Council
8
the area of Grade 3 agricultural land. These are development management issues and should not preclude the site being allocated in any submission Local Plan. The 5 criteria that at stated to be Red are due to site being more than a certain distance from services, this situation will however never change however if development is precluded in smaller villages. As advised above sustainable development in Nash will support services not just in Nash itself but it in nearby smaller villages, and this is a fundamental aim of the NPPF as set out in paragraph 55.
3.17 The Parish and those involved in preparing Nash's neighbourhood plan have made it very clear in their objections to our recent application that they do not wish to support the organic and sustainable growth of the village. Their representations presented a conflicting view as to the suitability of our site as opposed to those set out in the HELAA. On this basis we feel that it is highly unlikely that the site will be considered as an appropriate development opportunity in any forthcoming neighbourhood plan, and therefore the restrictive nature of the Proposed Submission Aylesbury Vale Local Plan will stifle appropriate development in Nash and other smaller villages.
4 Conclusions
4.1 We are concerned that the Proposed Submission Local Plan fails to support the sustainable and organic growth of the smaller villages in the district. The plan therefore fails to meet the basic test of being consistent with National Planning Policy.
4.2 Paragraph 55 of the NPPF supports small scale residential development in rural areas to support facilities not just in the village in question, but in nearby small rural communities. Nash is close to three similar settlements and small, proportionate development in these settlements should be supported by district wide policies not those within a neighbourhood plan.
Proposed Submission Local Plan Representations - Aylesbury Vale District Council
9
4.3 Our site has the benefit of being controlled by a single landowner and therefore the can be considered as being immediately available for development, and is one of the few sites supported in smaller villages supported by the HELAA. We therefore feel that our site should form part of an allocation of small sites within smaller villages as set out in the Local Plan.
4.4 In conclusion, we feel that the Proposed Submission Local Plan is unsound and is entirely inconsistent with the requirements of the National Planning Policy Framework.

Support

VALP Proposed Submission

Representation ID: 503

Received: 10/12/2017

Respondent: Mrs Nicky Gregory

Representation:

e. I am pleased to note there will be no further building development in Wendover as the Halton Camp development will provide 1000 homes, the remaining 128 are already covered by completions and commitments. Especially as I have a concerns about coalescence between Wendover and Halton.

Full text:

e. I am pleased to note there will be no further building development in Wendover as the Halton Camp development will provide 1000 homes, the remaining 128 are already covered by completions and commitments. Especially as I have a concerns about coalescence between Wendover and Halton.

Support

VALP Proposed Submission

Representation ID: 514

Received: 10/12/2017

Respondent: Mrs Roz Green

Representation:

I am pleased there will not be any further building in Wendover as the Halton Camp development of 1000 houses plus the 128 houses already built or planned will cover the required 1280 required in the Plan. I am, however, concerned about future development which would effect the coalescence between Wendover and Halton.

Full text:

I am pleased there will not be any further building in Wendover as the Halton Camp development of 1000 houses plus the 128 houses already built or planned will cover the required 1280 required in the Plan. I am, however, concerned about future development which would effect the coalescence between Wendover and Halton.

Object

VALP Proposed Submission

Representation ID: 557

Received: 08/12/2017

Respondent: Mrs Claudia Belardo

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

The number of houses that AVDC is proposing directly contradicts that being required in the Housing Need Consultation Data (Published 14th September 2017) (attached)

Higher number: "based on proposed formula, 2016 to 2026 " = 1,499 per annum = maximum of 14,990 houses in this time period.

Actual Number "Current local assessment of housing need, based on most recent publicly available document" = 965 per annum = maximum of 9,650 houses in this time period.

However, these latest proposals would see nearer 23,000 new homes being built which far outstrips what has been ruled as Sustainable for the area.

Full text:

Dear Sirs,

As a resident of Stoke Mandeville village I would like to raise grave concerns for the outline plan put forward by AVDC. The inconsistencies contained therein are so alarmingly confusing and worrying as they directly counter all objectives that the purportedly aim to address for the better and will result in the complete obliteration of Aylesbury's southern villages.


Case and point:


3.3 and Policy S1 Sustainable development

Number of houses proposed goes against Central Government guidance

The number of houses that AVDC is proposing directly contradicts the number stated as being required in the Housing Need Consultation Data (Published 14th September 2017) (attached)

ONS code: E07000004 - Aylesbury Vale.

Higher number: "Indicative assessment of housing need based on proposed formula, 2016 to 2026 (dwellings per annum)" = 1,499 per annum = this is maximum of 14,990 houses in this time period for this area.

Actual Number "Current local assessment of housing need, based on most recent publicly available document (dwellings per annum)" = 965 per annum = this is maximum of 9,650 houses in this time period for this area.

However, these latest proposals would see nearer 23,000 new homes being built which far outstrips what has been ruled as Sustainable for the area.


4.16 Aylesbury Transport Strategy ATS and 4.17 Interventions including outer link roads
The proposed transport strategy has not been finalised and even confirmed as viable. Consequently, and by the Council's own admission that want to raise funds to build any new roads by building houses first which is, in itself, a self-defeating objective.

Specifically thinking about Stoke Mandeville - the latest new road proposal for this village effectively moves the bulk of traffic from one road to another and with the increase in housing in the vicinity there has been nothing good in place to alleviate the current problem nor the exasperation which will inevitably occur as a result of yet more houses. This can currently be seen in the Berryfields and Buckingham Park estates.

Policy Dl: Delivering Aylesbury Garden Town
This proposal is a direct contradiction of these terms. With this proposal, the Council is successfully stripping Aylesbury and any surrounding areas of green space and it is not being replaced. Engulfing surrounding villages and making Aylesbury into a City.

3.22 Preserving character and identities of neighbouring settlements and resisting development compromising open countryside between settlements
D-AGTl South Aylesbury

Plans earlier this year specifically detailed that "The following settlements do not require any allocations in this plan as either their housing requirement has already been met, or due to their proximity to major development areas around Aylesbury, no allocations are required:

Aston Clinton
Stoke Mandeville"

The latest plans not only overrule that but have stripped all remaining green space in Stoke Mandeville village.

Including land that AVDC had previously deemed as being "unsuitable for housing or economic development" as detailed on the red areas outlined in the following plan published by the Aylesbury Vale Draft Housing and Economic Land Development Assessment 2015

http://www.stokemandevilleparishcouncil.org.uk/wp-content/uploads/2016/07/Capture.png


I specifically refer to SM006, SM00, SM008 and SM010. This land floods. The nature of this land has not changed and the stream that is created from all the excess water that these fields harbour will currently run through the residents' back gardens along Dorchester Close due wet periods and already flood - and that is with no housing on this land. To give some indication as to the amount of water these fields hold. If they are no longer able to retain some of this water and it all spills into these seasonal streams, then this will create a massive flooding problem which is why they are deemed unsuitable for development.

Even the Garden Town Concept Plans, that AVDC published indicated this as a green zone: http://stokemandevilleneighbourhoodplan.org.uk/wp-content/uploads/2016/04/Garden_Town_Concept_Plan.pdf


(area circled in yellow)

Yet in AVDC's most latest plans: http://stokemandevilleneighbourhoodplan.org.uk/wp-content/uploads/2017/11/Stoke-Mandeville-VALP-Allocations.pdf


The same area has been allocated as AGT1. The unsuitable land now allocated for housing and Stoke Mandeville village has disappeared being renumbered as AGT1 (Aylesbury Garden Town 1).

Not only building on land that should not be built on but indicating a coalescence between Aylesbury, Stoke Mandeville and Hampden Hall. Which is a wholly unjustified strategy which obliterates the character and identity of Stoke Mandeville whilst at the same time eradicating the open countryside between settlements.

In summary, AVDC's most recent proposal not only goes contrary to that which Central Government has advised but also seeks to slowly engulf and absorb all surrounding villages and settlements that add character to this rural part of Buckinghamshire.

The infrastructure cannot sustain any move to become a city, which in essence this latest proposal creates and I have grave concerns about the transparency of what AVDC is actually suggesting in this proposal since it is clearly not in any way an Aylesbury a 'Garden Town'.

I urge you to look carefully at these inconsistencies and appeal to your wider knowledge to consider the impact that allowing these ill-considered plans through.

Support

VALP Proposed Submission

Representation ID: 561

Received: 14/12/2017

Respondent: Wokingham Borough Council

Representation:

The plan outlines that Aylesbury Vale is able to meet their own housing need as well as the unmet need of Wycombe District as well as Chiltern/South Bucks Districts.

Wokingham Borough Council is therefore satisfied that on the basis of available information that AVDC are planning to meet the need for the District within the Buckinghamshire HMA, but would welcome further understanding of pressure regarding the meeting of the housing need as an HMA as well as impact on the East Berkshire HMA.

Full text:

Aylesbury Vale District Council (AVDC) is proposing to meet all of their housing need within the District, as well as 18% of the residual capacity which Wycombe, Chiltern and South Bucks District Councils currently assess as not being capable of accommodation within their own areas. As part of the ongoing cooperation between the Buckinghamshire authorities, Aylesbury Vale have entered into a number of memoranda of understanding to agree how unmet need in the wider Central Buckinghamshire HMA will be met.

The July 2017 Buckinghamshire duty to cooperate memorandum of understanding, states the agreement from AVDC to accommodate the unmet need of 8,000 homes for Wycombe, Chiltern and South Bucks District Councils. This is lower than the expected 12,000 homes at the draft plan stage mainly due to other districts finding more capacity through greater Green Belt release, and partly through a revised need assessment.

As part of the Berkshire (including South Bucks) Strategic Housing Market Assessment (SHMA), South Bucks has been identified as being within the East Berkshire HMA with Slough and the Royal Borough of Windsor and Maidenhead (RBWM). As South Bucks have now decided to undertake a joint plan with Chiltern, they are working under the assumption that as a joint area they fall under the Central Buckinghamshire HMA. The Buckinghamshire authorities memorandum of understanding addendum February 2016, states that South Bucks is included within the HMA as a 'best fit'.

It is understood that ongoing discussions are taking place between Slough and the Buckinghamshire authorities. It is important for Wokingham Borough Council to understand further how the Central Buckinghamshire HMA is working collaboratively with the Eastern Berkshire HMA; as it may have implications for Wokingham Borough and the Western Berkshire HMA within which Wokingham Borough sits.

It should be noted that the Government is currently consulting on a suggested standardised methodology for housing need. Under this methodology, the new objectively assessed need for Aylesbury Vale would increase, as well as other LPAs in the Central Buckinghamshire HMA. The proposed transitional arrangements would allow plans submitted before 31 March 2018 to proceed against current housing evidence, with the confirmed standard methodology becoming relevant to future revisions.

The AVDC Local Plan seeks to allocate sites across the locations of Aylesbury Garden Town, Buckingham, Haddenham, Winslow, Wendover and spread across the district at different sized settlements. None of these sites are adjoining the Wokingham Borough boundary or are considered to have particular impact at this stage. This includes taking land out of the Green Belt in the District and allocating this for development.

Wokingham Borough Council is therefore satisfied that on the basis of available information that AVDC are planning to meet the need for the District and others within the Buckinghamshire HMA, but would welcome further understanding of pressure regarding the meeting of the housing need as an HMA as well as impact on the East Berkshire HMA.

Object

VALP Proposed Submission

Representation ID: 564

Received: 11/12/2017

Respondent: Mr Stephen Richards

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

Object to new homes being built because of the issues with traffic and congestion and the impact this will have on the AONB. Homes should be built in the north instead.

Full text:

You people drive around the Aylesbury area at peak times, even Saturdays. Massive congestion, snail-like average speeds, so...pollution, noise, frustration, quality of life dropping like a stone. It seems to me that your proposals are likely to make things even worse. There is no way that you can convince me that your plans for new roads will make a significant difference. Just look at models for the M25. Add another lane. 6 lanes of standstill traffic! More cars equals more congestion. Simple. All of the new housing to the S and E of Aylesbury is going to make it a nightmare. When I drive home to Wendover in the evenings the traffic is backed up all the way to the Wendover by-pass. And a a1000 houses on RAF Halton? That'll be about 2000 more vehicles, most heading off down Halton Lane or out through the once pleasant Halton Village. More people heading into Wendover in their cars to pick up bread/ milk etc.... It's busy already. Again, try it at 17:30 weekdays, oh wise planners.
Let's face it, large numbers of the people in these new houses will work in London and they will either drive or somebody will drive them to the station, or they will park and walk to the station. More car journeys, more congestion, more pollution.
And, of course, all bringing pressure on the soon to be misnamed AONB of the Chiltern, sullied by HS2 and over-population.
When I take my son to University in the N of England there are 1000s of hectares of space. Get your Tory government to invest up there. [Inappropriate content removed]
S. Richards

Object

VALP Proposed Submission

Representation ID: 571

Received: 11/12/2017

Respondent: Valerie Jones

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

Object, S2:
4.16 Aylesbury Transport Strategy - ATS, 4.17 Interventions including Outer Link Roads, D-AGT1 South Aylesbury, 3.3 and Policy S1 Sustainable Development, New Settlement, 3.22 Preserving character and identities of neighbouring settlements and resisting development compromising open countryside between settlements, Aylesbury Town Centre, D-AGT4 Aylesbury south of A41 Hampden Fields, RAF Halton, Policy H1 : Affordable Housing, East-West Rail, Oxford-Cambridge Expressway, Air Quality Requirement on Developers

Full text:

Dear AVDC
I wish to comment on some aspects of the draft Vale of Aylesbury Local Plan which I think need to be looked at again.
1 - 4.16 Aylesbury Transport Strategy - ATS
The ATS has not been planned properly even Bucks CC are not happy with it. Having parts of an orbital road network as "aspirational" does not inspire any confidence at all. It cannot be correct to literally come up with a half-baked scheme with the increased traffic flows from the new housing developments gradually making the town grind to a halt. At the moment increased traffic movements are causing snarl-ups during peak times so what will it be like over the next 5 years and beyond. The Plan is not Positively Prepared nor Effective.
2 - 4.17 Interventions including Outer Link Roads
The extra 16,000 houses are going to have a severe impact on the transport system. The orbital roads will not take the traffic away from the town centre but in all probability spread the traffic chaos over a wider area. The evidence produced has not the rigour to make any sort of sound assessment.
3- D-AGTI South Aylesbury
This will create a coalescence between Aylesbury, Stoke Mandeville and Hampden Hall. The building of 1,000+ houses, schools etc. along the South Eastern Link road will cause chaos on the gyratory system. The gyratory system at present functions well for most time of the day but at peak times traffic sometimes backs up as far as the Worlds End roundabout with its junction with the Wendover by-pass. The draft Plan is not effective in terms of infrastructure planning.

4- 3.3 and Policy S1 Sustainable Development
There are too many houses in too small an area which will leads to considerable traffic problems and make Aylesbury grind to a halt economically. The problems have been brought about by there not being an effective Plan in place which has enabled developers to, effectively, do as they like. The proposed Plan is not a Justified or an Effective strategy.
5 - New Settlement
AVDC should have thought about this years ago and considered planning a new town to the north of the town taking advantage of the possible Oxford-Cambridge Expressway rather than making the existing town less and less viable with each extra house each with possibly 2 cars. The current plan is not Justified as the most appropriate strategy.
6 - 3.22 Preserving character and identities of neighbouring settlements and resisting development compromising open countryside between settlements
The words "will seek to preserve" needs to be stronger. At the moment the planned developments at Hampden Fields and Stoke Mandeville have meant that they will be subsumed into Aylesbury. It seems at the moment that all villages to the south of Aylesbury will become one entity unless there is a willingness from the Council to prevent these joined-up developments so that villages lose their character and identities. This is not an Effective Approach.
7 - Aylesbury Town Centre
In order to make the Town Centre more attractive, AVDC needs to think about the impact traffic from the new housing developments. The town has recently sold of half of the main car park for a development of flats. The car park was always full before with access to the cinema, dedicated market stall holders parking, theatre and shops. Available parking has been considerably reduced and the parking cost has increased. Anyone considering buying one of the new homes would be well advised to look at easy access to local amentities and, maybe based on what they see, go somewhere else. This element of the Plan is not Justified nor Effective.
8 - D-AGT4 Aylesbury south of A41 Hampden Fields)
The impact on the road system on A41, A413 and the gyratory system will be severe. Not Effective. The development would also join Aylesbury, and Stoke Mandeville into one homogenous area. So much for "Preserving Character etc." 3.22.
9 - RAF Halton
The announcement of the closure of RAF Halton probably came too late for serious consideration to be given to it in relation to the Draft Plan. The potential of another 1,000 in an area with lots of other new developments need to be considered especially with regard to traffic. Closer investigation is required for this significant element.
10 - Policy H1 : Affordable Housing
The national policy is, I believe, that all large developments should offer 35% affordable housing. The Council's Woodland Development provides only 20%. How is this so? Are developers here permitted to ignor National Guidelines? This is a serious and important aspect which is not Justified under the Plan and should be looked at again as a matter of great concern.
11 - East-West Rail
Such an important element has not been acknowledged as significant. Such a rail link would change the whole environment to the north of Aylesbury with maybe have the potential for affordable science parks and local housing available. This should be considered in detail and planned for accordingly. The draft plan needs to reflect this in detail as a Justified Plan.
12 - Oxford-Cambridge Expressway
The Government supports this scheme but AVDC, as with the Rail link, are not actively planning to capitalising on the huge potential that this could bring to the area. This is not 'Consistent with National Policy.
13 - Air Quality Requirement on Developers
Air quality is considered to be quite poor in some highly trafficked road even now - Tring Road for instance. The increase in the number of houses and consequently the number of cars, often static or slow moving, will obviously be a cause for concern in respect of air quality. The Council should commit in this Plan to positive policies and actions to improve air quality. Without that this aspect of the plan is not Positively Prepared or Justified.

I hope you will consider my comments and hope that you will ensure that Aylesbury Vale will remain a nice place to live in. At present I am not sure that it will be.

Yours faithfully
Valerie Jones

Object

VALP Proposed Submission

Representation ID: 574

Received: 13/12/2017

Respondent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

It is inappropriate to specify "2,212" homes and to attempt to inject this degree of precision into a strategic planning policy. In any event, there is greater scope for further development to the south west of Milton Keynes which would enable the provision of a greater number of dwellings.

Flexibility will be essential to ensure that changing circumstances and requirements can be accommodated during the application process.

The final sentence is too dogmatic in its approach to development proposals which will contravene the presumption in favour of sustainable development as set out in Policy S1.


Full text:

Rey Construction has no objections in principle to Policy S2 and the spatial strategy for growth contained therein. In particular, it welcomes the reference to sites adjacent to Milton Keynes, and within Aylesbury Vale, making provision for new homes. However when a plan needs to be "positively prepared" to be sound, it is considered unacceptable to specify a figure of "2,212" homes as it is totally inappropriate to attempt to inject this degree of precision into a strategic planning policy. In any event, it is considered that there is greater scope for further development in the area to the south west of Milton Keynes which would enable the Council to provide for a greater number of dwellings; an issue which is expanded upon in the representations to Table 1.

In this context, it is notable that paragraph 4.117, which provides some of the explanatory text to Policy D-NLV001 'Salden Chase', explains that the application which now has a favourable resolution is for up to 1,885 dwellings; a maximum figure which could presumably be significantly less which could undermine the Council's delivery strategy.

The exact capacity of any development site will only be known when detailed technical studies have been undertaken and these will then inform any application(s) for planning permission. Even then it is very rare for an outline planning application to be able to specify an exact number of dwellings. A degree of flexibility will be essential to ensure that changing circumstances and requirements can be accommodated through the consultation and negotiation stages.

Further it is considered that the final sentence of Policy S2 ("development which does not fit with the scale, distribution or requirements of this policy will not be permitted") is too dogmatic in its approach to development proposals which will contravene the presumption in favour of sustainable development as set out in Policy S1 which states that proposals should fit with the intentions and policies of the Local Plan (and Neighbourhood Plans were relevant). It is therefore imperative that the policy is amended as it is only in so doing that it will be consistent with national policy.

Object

VALP Proposed Submission

Representation ID: 578

Received: 09/12/2017

Respondent: Ms F. Mari

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

I have recently tried to consider as many documents as possible relating to the VALP but to have to read the equivalent of a number of academic texts in less than six weeks is an impossibly tall order. In addition to the VALP itself, in its assorted incarnations, the other significant document in this matter has been Buckingham Town Council's response to the VALP. (As summarised in the document at (09/12/2017) https://www.buckingham-tc.gov.uk/wp-content/uploads/2017/02/171211-ExFC-Appendix-A-1.pdf ) I here endorse all the objections made in that document, noting that these objections predominantly focus on a general unsoundness in the VALP.

Full text:

REF: MMO006


VALP Methodology
I moved to Maids Moreton at the end of January 2017. I had been seeking peace and quiet and improved air quality, in order to recuperate from a long illness. Partly because of this illness, 7 years elapsed before I was able to move, during which time I consulted a great many planning documents, SHLAAs, minutes from meetings, etc. at all levels of administration. So, while I am a newcomer to this area, I am more familiar than most with the labyrinthine nature of strategic planning in the SE of England.
I have recently tried to consider as many documents as possible relating to the VALP but to have to read the equivalent of a number of academic texts in less than six weeks is an impossibly tall order. In addition to the VALP itself, in its assorted incarnations, the other significant document in this matter has been Buckingham Town Council's response to the VALP. (As summarised in the document at (09/12/2017) https://www.buckingham-tc.gov.uk/wp-content/uploads/2017/02/171211-ExFC-Appendix-A-1.pdf ) I here endorse all the objections made in that document, noting that these objections predominantly focus on a general unsoundness in the VALP.
In addition, I wish to express objections more specifically, under three headings: Community, Services and Facilities, and Environment and well-being.


Community
Neighbouring places need some neighbourliness between neighbours in lived reality. Not only are the VALP housing allocations for Buckingham and Maids Moreton distinctly UNneighbourly in their excessiveness (in relation to other, similarly sized, communities), but these plans are already fostering divisions between both individual neighbours and between communities. It is also unneighbourly to skew housing matters in favour of landowners and developers rather than, more properly, in favour of local tax-paying residents. Therefore, I also strongly object to the VALP on the grounds of unneighbourliness.
Related to this is the matter of planned affordable housing. It should be a matter of some urgency to receive assurances from AVDC that developers will not use "viability assessments" to reduce agreed allocations. No resident can truly benefit from such practices, and increased social divisions and inequalities are likely to appear in consequence, as families fracture and connections are severed. Therefore, I also object to the VALP on the grounds of inadequate safeguarding of adequate provision for affordable and social housing.
Services and facilities
Contrary to the statement at the VALP para 4.151, Maids Moreton is far from "moderately well served with services and facilities". None of the three community buildings - church, hall and pub, can currently accommodate all the local residents. We will all have to go into Buckingham to discuss any problems arising in Maids Moreton. There are no other local services other than veterinarian. Every local resident must go to Buckingham, or further, to meet their every domestic need. Local public services are already overstretched: a 60% increase in demand by Maids Moreton residents for medical, social, and educational services will increase the strain, perhaps to breaking point. All Buckingham residents will be affected. Local public transport is already inadequate, most particularly for residents of Maids Moreton. A local bus every 2 hours is a token service at best. The most likely future scenario is a significant increase in personal car use, on an already inadequate local road system. All Buckingham residents will be affected.
Local health services are also greatly stretched, one indicator being the current waiting time for urgent blood testing. Again, inadequate health care provision will affect all Buckingham residents.
Therefore, I strongly object to the VALP on the grounds of its inadequate plans for supportive infrastructures.


Environment and Well-being
Any development, whatever its size, will result in increased noise, air, and light pollutions, both during construction and during subsequent occupation. I take little comfort from the VALP paragraphs 8.46 & 47 that residents should not be "unreasonably" harmed, and would like to have explained exactly what level (and quality) of harm to residents is considered "reasonable".
Noise and light pollutions infringe on personal privacy, increase stress, interfere with sleep, and therefore negatively impact on both mental health and physical well being, and so seriously compromise an individual's, or indeed a community's, quality of life. Again, the VALP offers no assurances: on the one hand much new road building is mentioned through the document, and yet the writers also, at paras 9.38 and 39, for instance, mention a "less than significant" impact on air quality, without satisfactorily demonstrating how this will be achieved, nor indeed defining "significance" in this context.
Therefore, I strongly object to the VALP on the grounds it is highly likely to prove physically and mentally injurious as well as environmentally deleterious.

Concluding remarks.
In conclusion, I must note that the VALP is but one of many such documents across the SE, all hastily contrived, many riddled with sophistry and obvious opportunism, and all constantly prone to constant abridgement, as with the South East plan, or multiple revisions, as indeed has been this VALP. This seems to be true at every level of 'strategic' planning, from the government's own piecemeal and toothless legislation, down to the (always unfinished) work of the (unpaid and put upon) volunteers who constitute our parish councils. I have no confidence whatever that my needs, or those of my neighbours, will ever be met by such a shambolic and byzantine system, so open to venality and so lacking in real knowledge of and sympathy with real tax-payers.

Object

VALP Proposed Submission

Representation ID: 593

Received: 10/12/2017

Respondent: Mr Peter Hoare

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

3.3, 4.16, 4.17, D-AGTI, D-AGT3, and Policy H1 do not provide effective solutions or are totally inadequate for the development proposals.

Full text:

Dear Sirs, I write to express my deeply felt concerns regarding the
various proposals forming the Vale of Aylesbury Local Plan. With
the current developments in and around the County Town, traffic and
movement is pretty bad, pollution can only rise and form additional
hotspots to those which exist already. I feel that a number of
Sections have a linkage-- more houses, more vehicles on our already
overcrowded roads. Side roads in residential areas are already a
nightmare during evenings and weekends. How long will it be before
the" Vale" is covered entirely with houses and inadequate
roads? I fear the worst possible outcome and although at 81
years of age I'm way past my sell by date, my concerns cover future
generations as well as the difficulties that exist at the moment.
Of the various sections in the plan 3.3, 4.16, 4.17, D-AGTI, D-AGT3, and
Policy H1 are of particular concern which I feel do not provide
effective solutions or are totally inadequate for the development proposals.

Yours Faithfully,
Mr P.J.Hoare

Object

VALP Proposed Submission

Representation ID: 661

Received: 12/12/2017

Respondent: Claydon Estate

Agent: Strutt and Parker

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

VALP will be out of date soon after it is adopted due to it being blind to progress in bringing forward significant strategic infrastructure, the new method for calculating
housing need, progress in relation to cross boundary planning and the potential of the O2C Corridor.

Full text:

The VALP makes large scale housing allocations to be delivered late in the Plan period, without clarity in relation to strategic infrastructure, particularly transport (HS2, East-West Rail and the Expressway). This infrastructure will or should be delivered within that Plan period and will impact upon and help support these and other housing allocations. There is no detailed consideration in the VALP, or the supporting evidence, of the fact that development allocations will need to align with
strategic infrastructure delivery and development will need to support and contribute to both strategic as well as local infrastructure provision. Consequently, the Infrastructure Delivery Plan provides little more than an account of progress on the critical strategic schemes. This is not an effective and therefore sound basis for delivery across the whole of the plan period.

It is however necessary to recognise that circumstances in Aylesbury demand pragmatism. The need for Aylesbury Vale District to adopt a Plan as quickly as possible to deal with immediate housing need arising with the indigenous population, and from neighboring and more heavily constrained Districts, is without question. The decision to progress, despite the inability to properly plan for delivery beyond
the early years of the plan period, is supported. The intention, clearly stated in the VALP, to undertake an early review is therefore vital, as is the acknowledgment of the need to address a step change in growth through that review, including consideration of a new settlement as part of the growth strategy. It is this commitment that will allow the Plan to be determined as sound.

For the Plan to be effective and to ensure that it does not, in due course, delay or frustrate the delivery of strategic infrastructure which is fully aligned with and enabled by development, there should be a clear, firm commitment to review within a specified timeframe or, preferably linked to a meaningful trigger for a review and for a corresponding change in the development strategy for the
District.
For the Plan to be effective this commitment should be stated in Policy.

Support

VALP Proposed Submission

Representation ID: 677

Received: 13/12/2017

Respondent: Whaddon Parish Council

Representation:

Whilst supporting this policy, WPC reiterates that whilst 'The strategy also allocates growth at a site adjacent to Milton Keynes which reflects its status as a strategic settlement immediately adjacent to Aylesbury Vale District' , these 2212 houses, of which 1855 are on two main proposed sites do nothing, or very little, to help the economy or well being of the Vale of Aylesbury, - which should surely be the focus of this plan.
Had the two sites adjoining Milton Keynes not been granted planning consent already, then WPC would have been objecting to this element of the S2 policy.

Full text:

Whilst supporting this policy, WPC reiterates that whilst 'The strategy also allocates growth at a site adjacent to Milton Keynes which reflects its status as a strategic settlement immediately adjacent to Aylesbury Vale District' , these 2212 houses, of which 1855 are on two main proposed sites do nothing, or very little, to help the economy or well being of the Vale of Aylesbury, - which should surely be the focus of this plan.
Had the two sites adjoining Milton Keynes not been granted planning consent already, then WPC would have been objecting to this element of the S2 policy.

Support

VALP Proposed Submission

Representation ID: 711

Received: 12/12/2017

Respondent: Rockspring Hanover Property Unit Trust

Agent: Castle Planning

Representation:

The sites identified in the HELA, which may form the growth at Westcott Village are not the most appropriate locations and all sites should be subject of more rigorous testing.

Full text:

Paragraph 3.16 of the Submission Draft Plan recognises the need for growth in villages, as part of the wider growth strategy for Aylesbury Vale.
In this context, Westcott is identified as small village, where development will come forward 'through planning applications assessed against planning policy' as opposed to allocations.
The level of growth which can be accommodated in these villages is informed by the identification of potential sites which might be capable of delivering the level of growth which is anticipated and/or acceptable in these locations. These sites are set out in the HELLA, which forms one of the background documents to the Plan and which reviews all sites put forward to the Plan. This document identifies 3 sites for Westcott village, the largest of which is 4.53ha, identified as having the potential to deliver 10 homes, on the basis that the assessment concludes that only the front side of the site is likely to be appropriate for development as an extension to the village (site reference WSC003).
The assessment notes that development of any more than the front section of the site would result in impact on listed buildings and the settlement pattern. It is considered that this site has not been subject of a robust assessment against specific criteria, which should be required of all potential future development sites. This should be not least in terms of their acceptability and deliverability, but also in the context of other technical considerations, such as archaeology. In this context, it may be that there are other sites in and around Westcott village, which can more suitably meet local needs, with a lesser or more acceptable level of impact.
The other two sites put forward in Westcott Village (reference WSC001 and WSC004) are 0.5ha is size each and which the HELLA concludes are not appropriate for development. We support this conclusion, although accept that all sites should be subject to detailed testing as set out above.

Support

VALP Proposed Submission

Representation ID: 724

Received: 13/12/2017

Respondent: Mr Andrew Docherty

Representation:

The proposed hierarchy and general approach is considered the appropriate way to deliver the required housing

Full text:

The proposed hierarchy and general approach is considered the appropriate way to deliver the required housing

Object

VALP Proposed Submission

Representation ID: 728

Received: 12/12/2017

Respondent: Aldbury Parish Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

Aldbury Parish Council wishes to draw attention therefore to the serious omission of consideration of the impact on the infrastructure of a Parish in the neighbouring
county of Hertfordshire (and indeed the other Town and Parish Councils of West Dacorum).

Full text:

CONSULTATION ON THE VALE OF AYLESBURY LOCAL PLAN (VALP)
PROPOSED SUBMISSION

COMMENTS BY ALDBURY PARISH COUNCIL,
HERTFORDSHIRE


Introduction & Comments

Aldbury is a Parish in the Dacorum Borough Council area of Hertfordshire, located to the east of the town of Tring, on the Hertfordshire - Buckinghamshire border and adjoining Pitstone Parish which is in Aylesbury Vale. The West Ward of Aldbury Parish comprises the hamlet of Tring Station, which includes Tring railway station. The train service is well used by residents from both sides of the county border, as our near neighbours in Aylesbury Vale are within easy travelling distance by road to Tring station. The railway station is on the West Coast Main Line and train services go southwards towards London Euston and northwards towards Leighton Buzzard, Milton Keynes and Birmingham. It is well used by commuters going to work and by other passengers travelling for shopping or leisure purposes. There is no direct bus service from Buckinghamshire, which would be able to offer a sustainable means of access.

There can confidently be expected to be major traffic increases from housing developments from neighbouring areas in Aylesbury Vale e.g. Aylesbury Garden Town, RAF Halton and smaller developments in the likes of Pitstone, Aston Clinton, Weston Turville and Wendover. Some of these proposed developments have already been approved and others are contained in the Vale of Aylesbury Local Plan (VALP) Proposed Submission, currently out for consultation. It is inevitable that some of the new residents of these locations will want to use Tring railway station, rather than the stations in Aylesbury. The Tring railway station car park is full to capacity before the end of peak travel time on weekdays.

Aldbury Parish Council is concerned and disappointed that there is no mention of the need for sustainable transport provision in the VALP Proposed Submission. At present, those in the catchment area on both sides of the county line, proposing to travel by train mostly use cars to travel to Tring Station, or failing that drive to other stations, e.g. Berkhamsted, Leighton Buzzard or Milton Keynes or make their entire journey by car. This cannot be good for the environment. The alternative stations will not have spare parking capacity for long, even if they have some currently. On street parking at Tring Station is very limited, often results in dangerous or obstructive parking and parking restrictions are bound to be tightened up as time goes by.

Aldbury Parish Council wishes to draw attention therefore to the serious omission of consideration of the impact on the infrastructure of a Parish in the neighbouring county of Hertfordshire (and indeed the other Town and Parish Councils of West Dacorum). It asks, therefore, that suitable recognition of these issues be contained in the version of the VALP which is to be submitted for examination. Aldbury Parish Council assumes that discussions have taken place, or will take place, with Dacorum Borough Council, the appropriate Local Planning Authority.


Approved by
Aldbury Parish Council
4 December 2017

Object

VALP Proposed Submission

Representation ID: 734

Received: 13/12/2017

Respondent: Sue Barber

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation:

Halton is a separate parish and NOT part of Wendover. Why has the housing allocation for Wendover now been moved to Halton? There is no evidence provided to demonstrate that Halton can accommodate 1,000 houses. Wendover is stated as a sustainable settlement suitable for development. Wendover is not Halton. Halton is a rural settlement with agriculture at its core and not a sustainable settlement. There is insufficient evidence about how Halton will become a sustainable community.

Full text:

Halton is a separate parish and NOT part of Wendover. Why has the housing allocation for Wendover now been moved to Halton? There is no evidence provided to demonstrate that Halton can accommodate 1,000 houses. Wendover is stated as a sustainable settlement suitable for development. Wendover is not Halton. Halton is a rural settlement with agriculture at its core and not a sustainable settlement. There is insufficient evidence about how Halton will become a sustainable community.

Support

VALP Proposed Submission

Representation ID: 755

Received: 13/12/2017

Respondent: Peter Brett Associates LLP

Representation:

BA supports Policies S1 and S2 in respect of sustainable development and the spatial strategy for growth, especially now the earlier draft VALP's reference in S2 to no more than 27ha of new employment land being required has been tempered with "and additional provision of employment land to contribute to the employment needs of the wider economic market area". This is particularly relevant to the employment provision envisaged within the Woodlands development.

Full text:

BA supports Policies S1 and S2 in respect of sustainable development and the spatial strategy for growth, especially now the earlier draft VALP's reference in S2 to no more than 27ha of new employment land being required has been tempered with "and additional provision of employment land to contribute to the employment needs of the wider economic market area". This is particularly relevant to the employment provision envisaged within the Woodlands development.

Object

VALP Proposed Submission

Representation ID: 786

Received: 13/12/2017

Respondent: Define (on behalf of Bovis Homes)

Agent: Define (on behalf of Bovis Homes)

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

Considered unsound as it is:
-not positively prepared as it is not based on a strategy that will ensure that the OAN will be met within the plan period;
-not justified in that it is not the most appropriate strategy and has not properly considered reasonable alternative strategies;
-not effective in that some allocation sites will not deliver the scale of development the Submission Plan currently assumes, and the identified needs will not be met;&
-inconsistent with national policy in that it doesn't fully reflect the Government's priorities/policies in terms of enabling sustainable development and boosting the supply of housing.

Full text:

Whilst the underlying principles of the spatial strategy set out in Policy S2 are supported, the policy as currently framed will not enable sufficient sustainable development to come forward to meet the objectively assessed development requirements of the District and Housing Market Areas (HMAs). It therefore, fails to accord with the provisions of the NPPF and is fundamentally unsound in that regard.

Policy Context
A central tenet of the NPPF is the provision of sufficient housing to meet the needs of present and future generations and, in doing so, to widen the choice of housing (paragraphs 7 and 9). To achieve that it requires (paragraph 14) "local planning authorities should positively seek opportunities to meet the development needs of their area", that "Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to rapid change", and set out a "clear strategy for allocating sufficient land" (paragraph 17). Delivery is underpinned by paragraph 47, which seeks to significantly boost the supply of housing requiring local planning authorities to "use their evidence base to ensure that their Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area".

In terms of the required evidence base, the NPPF requires (para. 159) local planning authorities to prepare a Strategic Market Housing Assessment (SHMA) to assess their full housing needs, and that the SHMA should identify the scale and mix of housing and the range of tenure that the local population is likely to need over the plan period. That should meet household and population projections, address the needs for all types of housing and cater for housing demand in the area.

Assessment of Need
The housing requirement as set out in Policy S2 is derived from the Buckinghamshire Housing and Economic Development Needs Assessment Update (HEDNA) published in December 2016 and its Update Addendum Report in September 2017. They conclude that the Objectively Assessed Need (OAN) for the District for the period 2013-2033 is 19,400 dwellings. However, whilst the HEDNA appears to largely follow best practice to assess the housing needs arising in the area, there are some critical matters which do not appear to have been addressed in the translation to a housing requirement in the Local Plan:

* The selected HMA has substantial migration and commuting flows beyond its borders, notably with Milton Keynes. The HEDNA does not examine the impact of the Milton Keynes HMA on the District, or therefore, identify the quantum of housing required to meet Milton Keynes' housing need in the District (see below).

* Nor has it considered the employment needs of Milton Keynes, when there is a clear overlap of the Functional Economic Market Area (FEMA).

* The approach to affordable housing is flawed. It seemingly continues to rely on private rented sector provision (through housing benefits) to meet some of the affordable housing needs and does not consider whether "an increase in the total housing figures included in the Local Plan should be considered where it could help deliver the required number of affordable homes" as required by the PPG (2a-029-20140306).

* The housing figure in Policy S2 must be expressed as a minimum requirement rather than a target to ensure that the acute housing needs are actually met.

These matters must be addressed if the Local Plan is to accord with the NPPF's policy imperatives as set out above.
Duty to Cooperate
The Duty to Cooperate (DTC), introduced by the Localism Act 2011, requires the Council to engage "constructively, actively and on an on-going basis to maximise the effectiveness of Local and Marine Plan preparation in the context of strategic cross boundary matters" (NPPG). The NPPF requires (para 181) that authorities "demonstrate evidence of having effectively cooperated to plan for issues with cross-boundary impacts". The demonstration of effective cooperation in reality means a positive outcome to these strategic planning discussions, even if agreement is not secured on all issues. Compliance with the duty to cooperate is central to ensure that a Council delivers sustainable development (NPPF paras 150-151) and meets its full objectively assessed needs for market and affordable housing in the HMA (NPPF para 47), including the unmet needs of neighbouring authorities where it is reasonable to do so and consistent with sustainable development (NPPF para 182).

A Memorandum of Understanding was agreed in July 2017 between Aylesbury Vale, Chiltern, South Bucks and Wycombe District Councils and Buckinghamshire Thames Valley Local Enterprise Partnership. That sets out the commitment for those authorities to work together under the Duty to Co-operate (DtC). Consequently Policy S2 states that the Local Plan will make provision for the delivery of a total of 33,000 dwellings in the period to 2033, comprising of 19,400 to meet its own needs and estimated 8,000 dwellings to accommodate the anticipated unmet needs arising from Wycombe, Chiltern and South Bucks.

However, there is very little reference to Milton Keynes in the Local Plan and there is no documentation of any constructive engagement between the two Councils in the Plan's evidence base. That is despite the close proximity of the City to the District, the strong physical and functional connections that arise from that, and the consequent extension of the Milton Keynes HMA and FEMA into the District.

The Proposed Submission Plan:MK consultation document highlights that Milton Keynes will need to deliver at least 1,767 dpa until 2031 (based on the 2017 SHMA), and the recent Milton Keynes Future 2050 Commission Report states that level of need will persist until 2050. Given the geography of the area, it is inevitable that some or all of that will need to be accommodated in Aylesbury Vale District. The District Council should, therefore, commit to working together with Milton Keynes Council in order to identify a positive outcome that meets the development needs of the area. To entirely ignore the key issue of the relationship with Milton Keynes at this stage is entirely unacceptable, either in terms of the City's housing needs arising in the District or the inevitable unmet need from within the City.

Spatial Strategy: Land Supply
The Local Plan's strategy to focus future housing growth on the Strategic Settlements in the District is accepted. However, there is an over reliance on a small number of development locations to provide the vast majority of the required housing. In order to meet the identified housing needs, all of those sites must come forward in accordance with the ambitious timescales set out in the Housing Trajectory as set out in the VALP Housing Land Supply Soundness Document (2017).

The concern is particularly acute in relation to Aylesbury, where a total of 16,398 dwellings is proposed in the plan period (57% of the District's total development). Clearly that will be a significant challenge given the need to co-ordinate the provision of the highway, public transport, drainage and community infrastructure required to support all of those planned developments coming forward at the same time in the same town. There is therefore, an significant inherent risk that the identified housing need will not be met in the plan period if any of those sites fail to come forward as anticipated.

Indeed, whilst predicting the timing, phasing and delivery rates of developments of the scale and complexity proposed is inherently difficult, the current housing trajectory is underpinned by entirely unrealistic assumptions in terms of both the timing and rate of delivery at Aylesbury and land adjacent to Milton Keynes. The trajectory indicates that the Council anticipate that the strategic allocations will begin to deliver housing in less than 3 years from the date of this consultation at Aylesbury South East, within 4 years at Salden Chase, Haddenham and Buckingham, and within 5 years at the other strategic sites at Aylesbury.

In order to achieve that, this Local Plan will first need to be submitted, examined and, if found sound, adopted to allocate the sites for development. The District Council currently anticipate that the Plan will be adopted by the end of 2018, but that programme is extremely ambitious given the progress made thus far, and the complexities of the key development proposals on which the Local Plan relies in order to meet identified development needs. Adoption during 2019 does, however, appear feasible subject to the issues highlighted in these representations being appropriately resolved.

Outline planning applications will then need to be prepared, submitted and approved. The very detailed allocation policies in the Local Plan clearly highlight the scale and complexity of that process for each of the strategic sites. Notably, Policy D1 requires the prior preparation of detailed design guidance and site specific Supplementary Planning Documents. That is perfectly understandable, but will take time to do given the range of issues that need to be addressed. Furthermore, given the scale and nature of the sites, the planning applications submissions will need to be accompanied by robust Environmental Statements and Transport Assessments. The SPD and outline application preparation process should, therefore, be expected to take 1 to 2 years. The determination of those applications, including the signing of the associated Section 106 Agreements to secure the infrastructure required to support the development, should also be excepted to take 1 to 2 years.

Following the grant of outline planning permission, the sale (if promoted by the landowner) / purchase (if promoted by the developer) of the land needs to be finalised in light of a detailed cost & revenue planning exercise (which is further complicated if multiple landowners are involved). Reserved Matters submissions will then need to be prepared, submitted and approved, conditions discharged and other (highway and drainage) consents secured to deliver the site. That process will take at least 2 years.

The developers resources (labour, equipment and materials) will then need to be mobilised before the development can begin. That commonly takes around 6 months. Site preparation and enabling works (e.g. infrastructure provision) then takes place prior to the construction of the actual homes and their delivery to the market. The first completions are usually provided 6 months following the start on site.

This realistic view of the likely timescales for delivery of the strategic development areas is supported by the various nationwide studies of the delivery of housing on strategic sites that have been published in recent years. Indeed, the Housing Delivery Study for Buckinghamshire (2017) also refers to these very issues, and states (para 14) "the real challenge is getting the sites to the point at which homes start to get built". It does not, however, provide any clear guidance to support the Trajectory that underpins the Submission Plan.

Therefore, unless there is clear site specific evidence to the contrary (and nothing has been presented thus far), the conservative analysis of the required timescales to deliver the strategic development areas as set out above highlights that the Local Plan should assume the first delivery of housing completions on (uncommitted) strategic sites will not occur until at least 6 years post the likely adoption of the Local Plan in 2019; i.e. in the 2025/26 period. Even then there is a significant risk that the resolution of the site specific environmental constraints, infrastructure provision and landownership issues will further delay delivery.

Moreover, thereafter a robust view on the rate of delivery needs to be taken. The Housing Trajectory currently assumes that the annual completions will increase significantly to, for example, 280dpa at Aylesbury South East, and 250dpa at Salden Chase. Those figures greatly exceed the national average for sites over 2,000 dwellings of circa 161 dpa (ref: "Start to Finish: How Quickly Do Large Scale Housing Sites Deliver? 2016; NLP).

Indeed, the Housing Trajectory indicates that the cumulative delivery at Aylesbury is expected to exceed 750 dpa over a 7 year period towards the end of the plan period. That assumption is extremely ambitious, and no evidence has been presented to demonstrate that it is actually achievable in this location. Indeed the Housing Delivery Study for Buckinghamshire (2017) specifically refers to the "possible limits on market absorption of new homes in Aylesbury town" (para 10), but does not seek to quantify what that limit might be. It concludes (para 11) "to deliver the emerging Plan numbers will be challenging." There are also practical issues in terms of labour and materials availability and coordinated infrastructure provision to consider. Clearly there is ultimately a finite amount of housing that can be sustained in Aylesbury, and the housing trajectory must take that into account.

The only outcome of not taking a realistic view in the housing trajectory both in terms of when development will start to deliver new homes, and then the number of homes that will be delivered each year, is that the identified housing needs in the District will not be met.

Consequences
Bovis Homes are, therefore, concerned that the District Council are not seeking to meet the full OAN across the HMAs in the District or allocating sufficient land to meet the identified housing need in the plan. This must be remedied as the consequence of not planning to meet the identified housing need in the area is simply to exacerbate the nation's housing crisis.

The Housing Strategy for England "Laying the Foundations" states in paragraph 1 that a "thriving, active but stable housing market that offers choice, flexibility and affordable housing is critical to our economic and social wellbeing." It continues to highlight (para 5) that "we have not built enough homes for more than a generation", and (para 8) that "without urgent action to build new homes, children will grow up without the same opportunities to live near their families, young people will struggle to get a place to call their own and older people will not have the choice and support they need." Furthermore, paragraph 9 states: "Housing is crucial for our social mobility, health and wellbeing - with quality and choice having an impact on social mobility and wellbeing from an early age, and our homes accounting for about half of all household wealth. Social housing should provide support for those who need it, when they need it, and should help vulnerable people to live independently. And opportunities for wealth must be open to all, with housing choices helping rather than hindering people's ability to build assets and find employment."

More recently the Housing White Paper presents startling facts and figures that highlight the acute socio-economic effects of a continued undersupply of housing in the country. Average house prices have rocketed compared to earnings, home ownership in the under 35s has significantly decreased and rental costs are continuing to escalate. The under supply of housing is also having a severe negative impact on the economy in terms of labour mobility, the construction industry, economic spend and increasing housing benefit costs. It concludes:
"You don't have to be an expert in housing or construction to know that our property market is broken. You just have to be one of the millions of hardworking people who can't afford to buy or even rent the kind of safe, secure, affordable home that previous generations have taken for granted. It's all down to the fact that not enough houses are being built."

Remedial Action
To accord with the NPPF's policy requirements (notably paras 14 & 47), the Local Plan must facilitate a continual supply of both market and affordable housing from a "portfolio" of deliverable development sites based on a robust spatial development strategy, with sufficient flexibility to make sure that the identified full OAN for the District and the unmet need arising elsewhere in the HMAs are met even if key developments do not proceed as currently anticipated. That will ensure a rolling 5 year housing land supply is maintained, that the overall housing requirements are met within the plan period and that everyone actually has the opportunity of a decent home.

As set out above it is inevitable that there will be a delay to at least some of the identified development sites in the Local Plan coming forward and/or the rate of their delivery will not be high as currently anticipated. That inevitability should be addressed at the outset rather than monitored and managed, which does not reflect the positive plan led approach to delivering sustainable development to meet the HMA's housing needs as required the NPPF (para 150-151) and will only result in a further delay in the acute housing needs being met. Therefore, the true objectively assessed need should be identified, the deliverability of individual sites carefully examined, and a robust housing trajectory prepared with the sufficient (additional) allocations to ensure that the housing needs are actually met.

The Local Plan should also include contingency plans to address any shortfall in housing delivery arising from a delay in the strategic allocation sites coming forward in the short and medium term. The Submission Plan refers to the incorporation of a buffer in the planned housing supply against the housing requirement, but Table 1 highlights that amounts to only 5.2% which is clearly insufficient and is in any comprised of the anticipated windfall delivery, which by definition does not provide the certainty required to ensure that the acute housing needs are met. A buffer of 10-20% of specific deliverable sites is required to reflects the positive plan led approach to ensuring the delivery of sustainable development to actually meet the HMA's housing needs as required the NPPF.

It is apparent, therefore, that there is a need to identify and allocate a number and variety of additional sustainable development sites over and above those already identified in the Local Plan. The allocation of additional development sites in other sustainable locations at the Large and Medium Villages such as Stone and Tingewick (see below in relation to Policy S3) is required, and they should be brought forward at the earliest opportunity to address the shortfall in provision in the early part of the plan period and thereon to accelerate the supply of housing and meet identified needs.

Soundness:
For the reasons set out above, Bovis Homes object to Policy S2, which is considered unsound on the basis that it:
- has not been positively prepared as it is not based on a strategy that will ensure that the objectively assessed housing needs, including unmet development requirements arising elsewhere in the HMAs, will be met within the plan period;
- is not justified in that it is not the most appropriate strategy and has not properly considered reasonable alternative strategies;
- is not effective in that some allocation sites will not deliver the scale of development the Submission Plan currently assumes, and the identified needs will not therefore, be met; and
- is inconsistent with national policy in that it does not fully reflect the Government's priorities and policies in terms of enabling sustainable development and boosting the supply of housing to meet identified needs.

Object

VALP Proposed Submission

Representation ID: 843

Received: 14/12/2017

Respondent: Slough Borough Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

The Council objects to the submission version of the Vale of Aylesbury Local Plan on the grounds that it is not reasonable or sustainable to plan to import housing into Aylesbury from the part of South Bucks District that is not within the same functional Housing Market Area.

Full text:

Slough representations to the Vale of Aylesbury Proposed Submission Local Plan (VALP) were approved at Planning Committee on 6th December 2017.

The Committee resolved that:

* That an objection should be made to the submission version of the Vale of Aylesbury Local Plan on the grounds that it is not reasonable or sustainable to plan to import housing into Aylesbury from the part of South Bucks District that is not within the same functional Housing Market Area

The full planning committee report is attached.

Meeting Un Met Housing Needs from Outside of the Functional Housing Market Area

The VALP housing target is made up from the amount of housing required to meet Aylesbury's needs plus additional housing to meet unmet needs from elsewhere in Buckinghamshire:

The Spatial Vision states in paragraph 2.4 (b) that Provision will be made for the housing and employment needs of the new and existing population, including unmet needs from elsewhere if reasonable and sustainable......

Policy S2 (Spatial Strategy for Growth) makes provision for the delivery of 27,400 dwellings between 2013 and 2033 including the unmet need of 2,250 dwellings from Wycombe and 5,750 from Chiltern and /South Bucks Districts.

Paragraph 182 of the NPPF which sets out the tests of soundness for examining Local Plans states that they should seek to meet unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development.

Whilst it is appropriate to seek to meet un met needs which cannot be accommodated elsewhere in the same functional Housing Market Area, Slough Council does not considered it is reasonable or sustainable to import housing from outside of this. More than half of South Bucks District is outside of the same "functional" Housing Market Area as Aylesbury Vale and so the Council objects unmet needs from here being met in the VALP.

Policy S2 (Spatial Strategy for Growth) which seeks to meet all of South Buck's unmet housing needs is not justified by the available evidence as to what the appropriate Housing Market is.

The Plan states that it has been prepared on the basis of a joint report by ORS which identified a best fit Housing Market Area which consists of Aylesbury Vale, Wycombe, Chiltern and South Bucks.

What it does not explain is that this has been produced by using Plan making areas as the basis for determining the best fit.

If judged upon a best fit to Local Authority boundaries basis the whole of South Bucks is in a different Housing Market Area. This was the recommendation of the 2015 HMA and FEMA report (ORS and Atkins) commissioned by the Buckinghamshire Councils.

This only changed in June 2016, following the decision by South Bucks and Chiltern to prepare a joint Local Plan. It was on this basis that the report by ORS Atkins entitled "HMAs and FEMAs in Buckinghamshire: Updating the evidence" recommended the use of the plan making areas for determining the best fit HMA.

This study concluded:

we would continue to recommend to the Buckinghamshire councils that the most pragmatically appropriate best fit for the Central Buckinghamshire housing market area based on Local Plan areas comprises Aylesbury Vale district, Wycombe district and the combined area of Chiltern and South Bucks districts [...] these best fit groupings do not change the actual geography of the functional housing market areas that have been identified - they simply provide a pragmatic arrangement for the purposes of establishing the evidence required ... (para 36-37, p10).

It goes on to note:

Whilst we believe that this proposed grouping for Central Buckinghamshire HMA provides the overall best fit for joint working (based on a Joint Plan being developed for Chiltern and South Bucks), it is not the only arrangement possible given the complexities of the functional housing market areas in the region. Regardless of the final groupings, the more important issue will be the need for all of the Buckinghamshire districts to maintain dialogue with each other and also with their neighbouring authorities, as well as with the Mayor of London through the Greater London Authority (para 38, p10).



These pragmatic reasons mainly relate to evidence gathering and policy making. They do not apply to consideration as to where unmet housing needs should be met. The recent decision by the Inspector for the Luton Local Plan makes it clear that the functional Housing Market should be used for determining where the unmet housing needs from Luton should be accommodated.

As a result it is considered that the technical basis for the Vale of Aylesbury Plan is unsound in so far that it does not recognise the importance of using the functional Housing Market Area as the basis for deciding the extent to which it should accommodate unmet housing need outside of this area.

It is considered that housing needs should be met as close as they can to where they arise. Failure to do so can result in unstainable forms of development and an increase in housing stress in the area where development does not take place.

The Plan has not sufficiently considered what the social and economic impact of importing housing from outside its functional Housing Market Area

The proposal in the Aylesbury Plan to import housing from southern Buckinghamshire to Aylesbury has not taken account of the adverse effects that this will have upon the local housing market which is deprived of new housing. South Bucks District is already one of the least affordable areas in the country. Failure to build the required houses in this area will make affordability even worse. It will also restrict the supply of affordable housing in the area and result in people having to move long distances, in some cases outside of the functional Housing Market Area, in order to find suitable housing. This could result in unsustainable commuting patterns as in practise the major employment in the area is London, Slough, and Heathrow.

The AVLP should not propose to take some of South Bucks housing allocation unless it is deliverable. If this housing is for some reason not delivered there will be an under supply of housing which could have been addressed in other Local plans. As a result it is not considered that planning for provision of all of South Bucks' unmet housing need is an effective strategy

It is not, however, suggested that the overall housing target in S2 should be reduced even though it is very ambitious. This is because Slough Council does not want to restrict new housing coming forward if it is deliverable. It is also it is possible that all of the houses proposed in the VALP will actually be required to meet Aylesbury's needs

Object

VALP Proposed Submission

Representation ID: 844

Received: 14/12/2017

Respondent: AB Planning & Development Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

Increase District housing numbers by 5,000-6,000.
Reduce an over-concentration of development planned at Aylesbury and increase commensurately the development totals planned elsewhere to help facilitate deliverability.
Provide a full outer ring road for Aylesbury, if the scale of development currently planned at Aylesbury is maintained.
More development allocations and/or targets ought to be set for the named larger and medium-sized villages.

Full text:

The overall quantum of 27,400 new houses appears too low, based on past evidence and it would be more sustainable to increase the 19,400 homes requirement for Aylesbury Vale District to a figure closer to 25,000 in order to fully accommodate the District's growth needs.
Given consistent failure in the past to deliver the scale of growth planned at Aylesbury in a timely fashion, to now propose virtually 16,400 of the planned 27,400 new homes (i.e. about 60%) seems destined to almost inevitable failure, which would risk compromising the Plan's strategy and risk further years of the District not having a deliverable 5-year housing land supply.
The scale of development envisaged around Aylesbury does not appear, from the transport strategy background papers available, to be adequately served by sufficient new highway capacity to enable the town to continue functioning without massive congestion at peak-period (which appear will grow considerably in their length). Severe capacity limitations at key highway junctions, especially at the Gyratory and the Oxford and Bicester Road junctions with the inner ring road, have not been addressed. Only providing short sections of outer link roads without a full ring of roads will only serve to move congestion black-spots rather than providing any real solutions.
The Plan's strategy requires new housing numbers to be accommodated at named larger and medium-sized villages and yet very few new allocations are proposed. Delivery of the strategy is heavily reliant on past appeal decisions and on new Neighbourhood Plans and yet where evidence of new emerging draft Neighbourhood Plans is available, it appears that many Parish Council's appear to be attempting to use the process to avoid further development, particularly amongst the villages surrounding Aylesbury.

Object

VALP Proposed Submission

Representation ID: 846

Received: 12/12/2017

Respondent: Mrs Claire Woodward

Agent: WYG

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

Object to S2, the housing need has reduced since the draft plan, this is not sound in the context of the housing crisis and the NPPF requirement to significantly boost housing supply. VALP fails to have regard to DCLG's proposed new methodology, which identifies 1,499dpa need. It fails to adequately consider the role of Aylesbury Vale District in the development of the East-West Rail link, and its position within the Cambridge-Milton Keynes-Oxford Corridor, particularly with its proximity to the growth hub of Milton Keynes.

Full text:

Dear Sirs,
VALE OF AYLESBURY LOCAL PLAN (VALP) PROPOSED SUBMISSION CONSULTATION, NOVEMBER 2017
WYG are instructed by Ms Woodward and Mr Connolly in respect of their land interests adjacent to Raven Crescent and Linnet Drive at Westcott in Aylesbury Vale. Our client's site is identified on the accompanying Site Location Plan. This 0.78ha site is adjacent to the southern village boundary where a modest residential development would assist in "rounding off" the existing settlement.
Our Client's land has previously been promoted for residential development to the Aylesbury Vale Housing and Economic Land Availability Assessment (Site Reference WSC004) and the Draft Vale of Aylesbury Local Plan consultation in May 2017. The Local Plan as drafted does not propose to allocate our client's land for future development.
The purpose of these representations is to provide commentary on the current consultation documentation, particularly in terms of the soundness of the development strategy of Proposed Submission Vale of Aylesbury Local Plan, having regard to Paragraph 182 of the National Planning Policy Framework (NPPF).
Representations
Policy S2 (Spatial Strategy for Growth)
We consider that Policy S2 is not sound on the grounds that the Policy has not been positively prepared, justified and is not consistent with national policy.
These representations seek to ensure that the full objectively assessed housing need is identified and met by the new Vale of Aylesbury Local Plan, particularly in light of the work of the National Infrastructure Commission on the Cambridge-Milton Keynes-Oxford Corridor and the proposed East-West Rail link which will run through the District.
Policy S2 made provision for the delivery of 33,300 homes over the Plan period, subject to a decision on unmet needs from neighbouring authorities. The Proposed Submission Plan Policy S2 has reduced this requirement to 27,400, which includes 8,000 to accommodate unmet need from Chiltern, South Bucks and Wycombe Districts. A reduction in the housing requirements is not considered to be sound in the context of the current national housing crisis and the Framework's requirement to significantly boost housing supply.
This approach fails to have regard to the DCLG's proposed new methodology, which if adopted would likely result in a further increase in the numbers of dwellings required per annum in Aylesbury Vale. The indicative figures published as part of the Government's 'Planning for the Rights Homes in the Right Places' consultation (September
2017) shows a significant increase on the currently identified level of need in Aylesbury Vale from 970 dwellings per annum to 1,499 dwellings per annum. This would equate to a total of 10,580 dwellings more over the plan period.
The Proposed Submission Plan has failed to adequately consider the role of Aylesbury Vale District in the development of the East-West Rail link, and its position within the Cambridge-Milton Keynes-Oxford Corridor, particularly with its proximity to the growth hub of Milton Keynes. The National Infrastructure Commissions Interim Report published in November 2017 emphasised that the success of the Cambridge-Milton Keynes-Oxford corridor has fuelled exceptionally strong demand for housing across the corridor and in its key cities, which has not been matched by supply. Lack of housing supply is leading to high house prices and low levels of affordability, for both home ownership and private rental. Aylesbury Vale is ideally positioned to accommodate additional growth within the Corridor.
It is clear that the undersupply of housing in the corridor is putting the future economic development of the area at significant risk. It would appear that there is currently some serious disparity between aspirations for the Corridor emphasized by the National Infrastructure Commission and the East-West Rail Consortium, and the development strategy adopted for future delivery within Aylesbury Vale District.
The Policy should also be amended so that the housing figure is expressed as a minimum. This would ensure the Policy and Local Plan also better reflects the Framework's requirement to significantly boost housing supply. This amendment should be incorporated into other policies that establish housing limits for individual settlements.
Policy S3 (Settlement Hierarchy and Cohesive Development)
Our Client supports Policy S3, insofar as it allows for future development at the village of Westcott.
Policy S3 identifies Westcott as a 'Smaller Village' and as a suitable location for "small scale development". Our Client is in favour of future development at Westcott as a means of meeting the development needs of Aylesbury District and supporting the sustainability of the settlement.
The Policy further states that, in considering new buildings in the countryside the Council will have regard to maintaining the individual identity of villages and avoiding extensions to built-up areas that might lead to coalescence between settlements. Our Client agrees that new development should be directed to edge of settlement locations where new buildings can be assimilated into an existing settlement structure, maintaining the character of the countryside and avoiding coalescence between existing settlements.
Policy D3 (Housing Development at Smaller Villages)
Our Client supports aspects of Policy D3 with regards to allowing for new housing development at Smaller Villages. However, the Policy is not sound as a whole, as parts are not consistent with national policy.
The previously drafted Policy D7 covered housing development within the smaller villages, and proposed a percentage approach to apportioning development to settlements. Our Client expressed concerns that the Policy did not properly reflect the Government's objective to boost significantly the supply of housing, and therefore supports the removal of the percentage apportionment approach.
Policy D3 states that new housing development at Smaller Villages will be supported where it contributes towards the sustainability of that village and accords with all applicable polices in the Local Plan, subject to certain criteria being met. This includes a requirement that development be located within or adjacent to the existing developed footprint of the village; would not result in coalescence; is of a small scale and in a location that is in keeping with the existing form of the settlement.
The newly drafted wording of Policy D3 imposes a threshold of five dwellings or fewer within the definition of small scale development at criteria c. It is considered that the policy should be amended to allow more
flexibility to recognise the unique characteristics, sustainability and capacity of individual villages and development sites to accommodate developments of more than 5 dwellings but also remain in accordance with the other criteria within Policy D3.
Our Client's land has capacity for development of up to 10 dwellings, whilst remaining consistent with the principles for new development set out in the Policy. The site is present in an urban setting and a detailed analysis of the landscape impact demonstrates that development can be accommodated on the site and would in effect better "round off" this part of the village.
In the case of Westcott, the Council's Draft Settlement Hierarchy acknowledges that settlement, along with the village of Worminghall, "have exceptionally high levels of employment compared to other small villages". The Westcott Venture Park is located some 0.7km from our Client's site, and comprises a 263ha employment site with over 70 individual business and 400 staff employed. The Local Plan proposes to retain this area as protected employment land - indeed it has been included within one of the three Enterprise Zones proposed in Aylesbury District. This indicates a strong commitment to its retention and development at this location as a key source of employment in the District.
The key planning principles towards sustainable development, as set out in Paragraph 17 of the NPPF, include the need to actively manage patterns of growth to make the fullest use of public transport, walking and cycling. Paragraph 37 of the Framework is also clear that planning policies should aim for a balance of land uses within their area, so that people can be encouraged to minimise journey lengths for, amongst other things, employment.
Our Client considers that Policy D3 should contain more flexibility in respect of levels of "small scale development" which should be permitted in Smaller Villages. Restricting this to 5 dwellings or less does not allow consideration of the suitability and sustainability of the village of Westcott to accommodate additional housing development given that the Westcott Venture Park employment site in very close proximity. They suggest that Policy D3 should be amended accordingly to allow an increase in the proportion of housing development here. Providing additional housing development close to a major employment site will help to deliver a sustainable pattern of development by reducing the need to travel.
Yours faithfully
Keith Fenwick
Director
For and on behalf of WYG

Object

VALP Proposed Submission

Representation ID: 847

Received: 12/12/2017

Respondent: Mr Connolly

Agent: WYG

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

Object to S2, the housing need has reduced since the draft plan, this is not sound in the context of the housing crisis and the NPPF requirement to significantly boost housing supply. VALP fails to have regard to DCLG's proposed new methodology, which identifies 1,499dpa need. It fails to adequately consider the role of Aylesbury Vale District in the development of the East-West Rail link, and its position within the Cambridge-Milton Keynes-Oxford Corridor, particularly with its proximity to the growth hub of Milton Keynes.

Full text:

Dear Sirs,
VALE OF AYLESBURY LOCAL PLAN (VALP) PROPOSED SUBMISSION CONSULTATION, NOVEMBER 2017
WYG are instructed by Ms Woodward and Mr Connolly in respect of their land interests adjacent to Raven Crescent and Linnet Drive at Westcott in Aylesbury Vale. Our client's site is identified on the accompanying Site Location Plan. This 0.78ha site is adjacent to the southern village boundary where a modest residential development would assist in "rounding off" the existing settlement.
Our Client's land has previously been promoted for residential development to the Aylesbury Vale Housing and Economic Land Availability Assessment (Site Reference WSC004) and the Draft Vale of Aylesbury Local Plan consultation in May 2017. The Local Plan as drafted does not propose to allocate our client's land for future development.
The purpose of these representations is to provide commentary on the current consultation documentation, particularly in terms of the soundness of the development strategy of Proposed Submission Vale of Aylesbury Local Plan, having regard to Paragraph 182 of the National Planning Policy Framework (NPPF).
Representations
Policy S2 (Spatial Strategy for Growth)
We consider that Policy S2 is not sound on the grounds that the Policy has not been positively prepared, justified and is not consistent with national policy.
These representations seek to ensure that the full objectively assessed housing need is identified and met by the new Vale of Aylesbury Local Plan, particularly in light of the work of the National Infrastructure Commission on the Cambridge-Milton Keynes-Oxford Corridor and the proposed East-West Rail link which will run through the District.
Policy S2 made provision for the delivery of 33,300 homes over the Plan period, subject to a decision on unmet needs from neighbouring authorities. The Proposed Submission Plan Policy S2 has reduced this requirement to 27,400, which includes 8,000 to accommodate unmet need from Chiltern, South Bucks and Wycombe Districts. A reduction in the housing requirements is not considered to be sound in the context of the current national housing crisis and the Framework's requirement to significantly boost housing supply.
This approach fails to have regard to the DCLG's proposed new methodology, which if adopted would likely result in a further increase in the numbers of dwellings required per annum in Aylesbury Vale. The indicative figures published as part of the Government's 'Planning for the Rights Homes in the Right Places' consultation (September
2017) shows a significant increase on the currently identified level of need in Aylesbury Vale from 970 dwellings per annum to 1,499 dwellings per annum. This would equate to a total of 10,580 dwellings more over the plan period.
The Proposed Submission Plan has failed to adequately consider the role of Aylesbury Vale District in the development of the East-West Rail link, and its position within the Cambridge-Milton Keynes-Oxford Corridor, particularly with its proximity to the growth hub of Milton Keynes. The National Infrastructure Commissions Interim Report published in November 2017 emphasised that the success of the Cambridge-Milton Keynes-Oxford corridor has fuelled exceptionally strong demand for housing across the corridor and in its key cities, which has not been matched by supply. Lack of housing supply is leading to high house prices and low levels of affordability, for both home ownership and private rental. Aylesbury Vale is ideally positioned to accommodate additional growth within the Corridor.
It is clear that the undersupply of housing in the corridor is putting the future economic development of the area at significant risk. It would appear that there is currently some serious disparity between aspirations for the Corridor emphasized by the National Infrastructure Commission and the East-West Rail Consortium, and the development strategy adopted for future delivery within Aylesbury Vale District.
The Policy should also be amended so that the housing figure is expressed as a minimum. This would ensure the Policy and Local Plan also better reflects the Framework's requirement to significantly boost housing supply. This amendment should be incorporated into other policies that establish housing limits for individual settlements.
Policy S3 (Settlement Hierarchy and Cohesive Development)
Our Client supports Policy S3, insofar as it allows for future development at the village of Westcott.
Policy S3 identifies Westcott as a 'Smaller Village' and as a suitable location for "small scale development". Our Client is in favour of future development at Westcott as a means of meeting the development needs of Aylesbury District and supporting the sustainability of the settlement.
The Policy further states that, in considering new buildings in the countryside the Council will have regard to maintaining the individual identity of villages and avoiding extensions to built-up areas that might lead to coalescence between settlements. Our Client agrees that new development should be directed to edge of settlement locations where new buildings can be assimilated into an existing settlement structure, maintaining the character of the countryside and avoiding coalescence between existing settlements.
Policy D3 (Housing Development at Smaller Villages)
Our Client supports aspects of Policy D3 with regards to allowing for new housing development at Smaller Villages. However, the Policy is not sound as a whole, as parts are not consistent with national policy.
The previously drafted Policy D7 covered housing development within the smaller villages, and proposed a percentage approach to apportioning development to settlements. Our Client expressed concerns that the Policy did not properly reflect the Government's objective to boost significantly the supply of housing, and therefore supports the removal of the percentage apportionment approach.
Policy D3 states that new housing development at Smaller Villages will be supported where it contributes towards the sustainability of that village and accords with all applicable polices in the Local Plan, subject to certain criteria being met. This includes a requirement that development be located within or adjacent to the existing developed footprint of the village; would not result in coalescence; is of a small scale and in a location that is in keeping with the existing form of the settlement.
The newly drafted wording of Policy D3 imposes a threshold of five dwellings or fewer within the definition of small scale development at criteria c. It is considered that the policy should be amended to allow more
flexibility to recognise the unique characteristics, sustainability and capacity of individual villages and development sites to accommodate developments of more than 5 dwellings but also remain in accordance with the other criteria within Policy D3.
Our Client's land has capacity for development of up to 10 dwellings, whilst remaining consistent with the principles for new development set out in the Policy. The site is present in an urban setting and a detailed analysis of the landscape impact demonstrates that development can be accommodated on the site and would in effect better "round off" this part of the village.
In the case of Westcott, the Council's Draft Settlement Hierarchy acknowledges that settlement, along with the village of Worminghall, "have exceptionally high levels of employment compared to other small villages". The Westcott Venture Park is located some 0.7km from our Client's site, and comprises a 263ha employment site with over 70 individual business and 400 staff employed. The Local Plan proposes to retain this area as protected employment land - indeed it has been included within one of the three Enterprise Zones proposed in Aylesbury District. This indicates a strong commitment to its retention and development at this location as a key source of employment in the District.
The key planning principles towards sustainable development, as set out in Paragraph 17 of the NPPF, include the need to actively manage patterns of growth to make the fullest use of public transport, walking and cycling. Paragraph 37 of the Framework is also clear that planning policies should aim for a balance of land uses within their area, so that people can be encouraged to minimise journey lengths for, amongst other things, employment.
Our Client considers that Policy D3 should contain more flexibility in respect of levels of "small scale development" which should be permitted in Smaller Villages. Restricting this to 5 dwellings or less does not allow consideration of the suitability and sustainability of the village of Westcott to accommodate additional housing development given that the Westcott Venture Park employment site in very close proximity. They suggest that Policy D3 should be amended accordingly to allow an increase in the proportion of housing development here. Providing additional housing development close to a major employment site will help to deliver a sustainable pattern of development by reducing the need to travel.
Yours faithfully
Keith Fenwick
Director
For and on behalf of WYG