Aylesbury Vale Area

Table 1 Spatial strategy for growth in Aylesbury Vale

Showing comments and forms 1 to 13 of 13

Support

VALP Proposed Submission

Representation ID: 158

Received: 11/11/2017

Respondent: Mrs Sheila Bulpett

Representation:

I welcome the consideration of Wendover and Halton RAF camp together as the 1128 houses in the local area will impact greatly on the infrastructure of Wendover both in services and traffic.
I have concerns over the coalescence of Halton Village and Wendover however, as a result of this development and who will gain S106 funds as both parishes will be impacted.

Full text:

I welcome the consideration of Wendover and Halton RAF camp together as the 1128 houses in the local area will impact greatly on the infrastructure of Wendover both in services and traffic.
I have concerns over the coalescence of Halton Village and Wendover however, as a result of this development and who will gain S106 funds as both parishes will be impacted.

Object

VALP Proposed Submission

Representation ID: 308

Received: 01/12/2017

Respondent: Cllr Warren Whyte

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

The note to Table 1 says: This represents a 5.2% buffer on top of the total housing requirement made up of Aylesbury Vale's objectively assessed need and the unmet need from other authorities (27,400). There is no evidence as to why this should be 5.2% and should be amended to 5% (which could then reduce the pressure on the over-scaled allocations in Maids Moreton)

Full text:

The note to Table 1 says: This represents a 5.2% buffer on top of the total housing requirement made up of Aylesbury Vale's objectively assessed need and the unmet need from other authorities (27,400). There is no evidence as to why this should be 5.2% and should be amended to 5% (which could then reduce the pressure on the over-scaled allocations in Maids Moreton)

Object

VALP Proposed Submission

Representation ID: 575

Received: 13/12/2017

Respondent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

Provision needs to be made for additional dwellings in Table 1. A significant proportion of these dwellings could and should be provided in the most sustainable location for development within the District, namely adjacent and within the vicinity of Milton Keynes; an area which Milton Keynes Council in its Plan:MK Strategic Development Directions consultation described as "an arc of urban extensions" which includes the land to the 'south and west around Newton Longville'.

This area has the scope and capacity for more development than AVDC is currently envisaging.

Full text:

In the representations to Policy S2, the case has been made for an uplift in the housing requirement as it is only in so doing that the Plan will be consistent with existing and emerging national policy. It therefore follows that provision needs to be made for additional dwellings in Table 1.

A significant proportion of these dwellings could and should be provided in the most sustainable location for development within the District, namely adjacent and within the vicinity of Milton Keynes; an area which Milton Keynes Council in its Plan:MK Strategic Development Directions consultation described, within 'Direction of Growth 1', as "an arc of urban extensions" which includes the land to the 'south and west around Newton Longville'. In so doing, it has clearly been acknowledged that the area has the scope and capacity for more development than AVDC is currently envisaging.

Support

VALP Proposed Submission

Representation ID: 671

Received: 12/12/2017

Respondent: Wendover Parish Council

Representation:

The WPC welcomes the consideration of Wendover and Halton RAF camp together as the 1128 houses in the local area will impact greatly on the infrastructure of Wendover both in services and traffic.

Full text:

INTRODUCTION
The Wendover Parish Council (WPC) represents the 8000 residents of Wendover. An historic market town that is known as the Gateway to the Chilterns.

S2 Table 1 Spatial Growth for Growth
The WPC welcomes the consideration of Wendover and Halton RAF camp together as the 1128 houses in the local area will impact greatly on the infrastructure of Wendover both in services and traffic.

The WPC have concerns over the coalescence of Halton Village and Wendover however, as a result of this development and who will gain S106 funds as both Parishes will be impacted.

Employment
1.14
The provision of local jobs is supported by the WPC. The RAF Halton site, with its history of technological excellence, offers an opportunity to attract employers that offer quality jobs and above average pay rates.

Town Centres
1.15
The WPC calculates that a retail provision of 50 sq.m. is more realistic than the 29 sq.m. currently proposed. The WPC and our retailing colleagues in our Chamber of Trade would be able to give accurate information on the local retail scene.

Housing and Economic Needs
3.14
Infrastructure should be provided where development takes place. It is likely that Wendover will serve as a major hub for the development. Hence infrastructure benefit i.e. cash/new housing bonus allocation should be spent in Wendover.

The proposal for 1000 new homes to be built at the RAF Halton site is a late addition to the plan and will undoubtedly result in challenges for Wendover's infrastructure, commerce and community.

This figure is likely to rise substantially over time and it's to be hoped that improvements to Wendover's transport and other resources will be in line with this growth.

An allocation of low cost housing for people who have to live or work in Wendover to buy would be welcome.

The WPC greatly values the greens spaces and mature trees on the RAF Halton Estate.

3.15
We expect a new settlement to form part of that Local Plan review. Halton could be the new settlement that is referred to - separate from Wendover with its own infrastructure provision.




Proposed Settlement
3.22/3/4
The WPC would request there is no development between the 2 Parishes of Wendover and Halton, and that Babbington Road remains the Border.

Green Belt
3.32
The WPC fully endorses the removal of the site for 800 dwellings from the Plan as it involved using Green Belt land.

The WPC welcomes the decision to leave the Green Belt status of Land around Wendover unchanged. Access to unspoiled and undeveloped countryside draws visitors to the Wendover area and enhances the quality of life for our residents.

Infrastructure
3.41
School and GP provision must be instigated at the start of a development as existing services in the Wendover area are already over capacity. Infant pupils in the catchment are unable to obtain places in the local school at present. GP appointments are currently a 14 day wait unless urgent.

Medical Services
The WPC has serious concerns regarding health care provision. Currently the healthcare provider Westongrove appears to have difficulty recruiting doctors and nurses, and in delivering a satisfactory level of service. It is important to Wendover that care provision of all kinds scales up in a proportional way as development goes forward and giving due consideration to key worker housing.

Schools and Early Years Provision
The WPC supports the provision of a new primary school to serve the new development. Concerns regarding availability of education provision for additional younger and older children from the proposed housing will need to be addressed.

Recently the expansion of school capacity in Wendover proved to be a contentious issue. The reason was to do with the highway infrastructure and parking availability that surrounds the school being totally inadequate for the existing traffic demands.

S5
In planning terms for a new development, regard should be given to existing deficiencies in services and infrastructure, hence new car parking facilities (or extension of existing parking facilities) and extra health facilities should be provided.

Water Issues
3.46
Water and the disposal of waste are essential to new development. Priority needs to be focussed on sustainability and the health of rivers and the water table.






Neighbourhood Plan
3.68-3.74
It is to be hoped that when the WPC Neighbourhood Plan has been approved, AVDC will take it into account when approving planning applications etc.

RAF Halton Near Wendover
4.131-4.135
The policy recognises that the RAF base is in Halton Parish and proposes 1000 houses.

The 1st phase proposes redevelopment and refurbishment of existing buildings. The implication is that the 2nd phase could be in the green belt.

A concern in the previous Princess Mary Gate development was that refurbished RAF houses in Halton Wood Road were not taken into account when the final housing numbers were quantified. Therefore, hardly any account was taken of a transitory population replacement with a permanent one and the resultant extra pressures put upon Wendover infrastructure.

At present, in Wendover, there are approx. 180 RAF houses in Tedder Road, 50-60 in Haddington Close (Halton/Wendover Parish) and at least another 200-300 officer housing in Halton Parish.

4.138
The WPC agree with most of this statement but not the "link with Halton and Wendover" as this will be coalescence of 2 distinct villages. Both Villages have a long history of a strong individual identity, which neither would wish to see removed.
Transport Strategy
4.17
Wendover continues to suffer from excessive traffic congestion at key periods during the day - attributable to "rush hour" and "school run" volumes. The village would benefit from completion of the existing by-pass into a full ring-road.

Trains need more carriages and cheaper parking at the stations.

Cycle routes should avoid the current criss-crossing of the main roads as this is a dangerous aspect of cycling.

Delivering Allocated Sites Halton/Wendover
4.125
The WPC supports the development of 1000 dwellings at Halton RAF camp. The roads/parking etc will not cope with increased volume of traffic. It was hoped that the sporting facilities on site would be an excellent facility for the local area. The current map indicates these in the main housing development which seems a complete waste of the high quality astroturf and centre.





Aylesbury - An Area of Leisure and Entertainment
4.229
The leisure facilities identified are good but inadequate with more needed in the central area. For example, an ice rink, bowling alley and gym where badminton, squash etc would encourage people into Aylesbury.
Events like the Roald Dahl Procession and Summer In The Park are very popular and help to retain community identity. Attention should be given to facilities focussed on younger children like soft
play that would allow one parent to shop whilst the other parent can entertain their child/children in a safe environment.
Transport and Parking
7.27
The WPC strongly supports vehicle parking being designed into new developments to include on-plot parking and adequate on-street parking. People need vehicles to travel to places of work not accessible by public transport and to be able to park them securely and safely. The WPC has major concerns regarding transport links and road network shortcomings.

The pressure on Wendover's already busy roads will only be made worse by the Halton development. To mitigate some of this negative effect will require a traffic management plan that is agreed with local Parishes.

Congestion and parking issues can only become a larger problem as the Halton developments proceed.

Traffic
The WPC finds that the presentation of traffic data is confusing and unhelpful. Wendover is expecting the significant negative effects of HS2 construction traffic on the B4009 and the A413 this will be long term and is likely to be at its peak during the Halton development. We acknowledge that this is not a permanent effect, but it is going to be a long-term feature of motoring in the Vale of Aylesbury for a significant proportion of the VALP.

Car parking
The WPC believes that any traffic modelling needs to take parking into account. Wendover has too few parking spaces, both on road and off road, to meet today's demands. Parking pressures are generated by....

Commuters : Parking all day in our residential streets.
Visitors : Using our shops, health services, cafes and accessing the countryside.
Residents : Using our shops, health services, schools, cafes and other facilities.
Workers : People who need to be in Wendover to run our business' or to build or repair things.

Any infrastructure planning associated with this plan needs to remedy Wendover's existing parking problems as well as develop for future need.






Protected Sites
NE1
All protected sites need an area around them to function without impact from development and it is to be hoped that this will be upheld in future planning approvals. Connectivity between sites is also necessary to maintain healthy populations of fauna and flora.

Wendover Woods is a geological site which should be protected. The derelict Thames Water site on Aylesbury Road is a non-statutory designated site, it should be protected.

Trees and Hedgerows
9.59
Trees and hedgerows are essential and AVDC must ensure that developers respect them, during construction by careful monitoring.

Green Infrastructure
11.12
The current RAF Halton with its excellent sports facilities could be a real asset to the area and should be developed sympathetically.
Protection of Key Employment Sites
E1 & E2
The WPC supports this strategy and would encourage further development within our area of sites suitable for expansion of the creative/high tech industries.

Conclusion
Change is on the way and the value of a proper plan for the Vale is beyond dispute. The structure and content of the VALP as presented seems sound in general but lacks detail as to a number of specific issues. It is to be hoped that this consultation will influence the VALP to provide solutions to these local issues.

Object

VALP Proposed Submission

Representation ID: 781

Received: 13/12/2017

Respondent: Amarillo Ltd & Scandale Ltd

Agent: Planning Prospects

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation:

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

Full text:

See attachments

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

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

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

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

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

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

Object

VALP Proposed Submission

Representation ID: 812

Received: 13/12/2017

Respondent: Mr & Mrs Keith Ware

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation:

The development of 1000+ houses on the Halton Camp site will add additional strain on Wendover and the local community in terms of transport, road congestion, local services, schools, hospitals and emergency services. A development of this scale is out of proportion with the ability of existing services to facilitate it.

Full text:

The development of 1000+ houses on the Halton Camp site will add additional strain on Wendover and the local community in terms of transport, road congestion, local services, schools, hospitals and emergency services. A development of this scale is out of proportion with the ability of existing services to facilitate it.

Object

VALP Proposed Submission

Representation ID: 950

Received: 14/12/2017

Respondent: Thame Town Council

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation:

Some 1,205 dwellings have been identified within the Proposed Submission Plan. The occupants will use Thame's services yet no conversation has been sought by AVDC with Thame Town Council about the impact on local services, including schools and health facilities. No evidence exists of similar conversations with South Oxfordshire District Council, either.

officer Note: reassigned to Table 1 for relevance

Full text:

Thame is identified as a service centre within the VALP Settlement Assessment Hierarchy (Table 1). The assessment identifies Thame as being the primary service centre for 10 settlements within the Vale (Appendix A [1]). It is not itself, however, assessed within the Settlement Assessment.
Thame, with its shops, community hospital, secondary school, etc. acts as the main service centre for Haddenham, and all the villages identified as having Haddenham as a service centre, too. The following committed or allocated dwellings therefore have their service centre identified as Thame:
Haddenham - 1,051 dwellings; villages serviced by Haddenham - 25 dwellings; villages serviced by Thame - 129 dwellings (source: VALP Settlement Hierarchy, September 2017).
This means that 1,205 dwellings identified within the Proposed Submission Plan will rely on Thame for their services. Yet there has been no conversation sought by the Vale Council with the Town Council, who, with its neighbourhood plan remit, have the greater local responsibility in providing infrastructure and supporting service facilities. This includes new GP/Health Hub facilities, a community centre, the movement of a primary school and the provision of further secondary school facilities; new sports facilities, parking, employment and public transport infrastructure.
No evidence exists either that AVDC have been in conversation with South Oxfordshire District Council regarding cross-border impact on Thame, or its services and facilities.

Object

VALP Proposed Submission

Representation ID: 1090

Received: 14/12/2017

Respondent: Gleeson Strategic Land

Agent: Nexus Planning Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

That Table 1 should be amended to express housing numbers as a minimum.

Full text:

1. Table 1 of the Local Plan outlines proposed housing delivery across the Plan period by settlement, taking account of commitments, completions and allocations in the Plan. The total number of new dwellings for Aylesbury is specified as 16,398.

2. Consistent with our more detailed representations to Policy S2, Table 1 should be amended to make it clear that the total number of new homes proposed at each identified settlement should be seen as minimum and not a ceiling, in accordance with the presumption in favour of sustainable development at paragraph 14 of the NPPF, and Policy S1 of the Local Plan.

Changes Sought

3. Amend Table 1 to ensure that all housing numbers are expressed as minima.

Support

VALP Proposed Submission

Representation ID: 1714

Received: 14/12/2017

Respondent: Wendover Neighbourhood Plan Steering Group

Representation:

We welcome the recognition of Wendover's distinctive identity as a settlement
in the south of Aylesbury ValeWe welcome the recognition of Wendover's distinctive identity as a settlement
in the south of Aylesbury Vale

Full text:

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

Overview and Summary

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

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

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

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

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

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

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

Object

VALP Proposed Submission

Representation ID: 1828

Received: 14/12/2017

Respondent: Rectory Homes Limited

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation:

as drafted is too reliant on delivery of small large strategic urban extension sites. strategy offers insufficient opportunities to small/medium sized House builders. a re-balanced spatial strategy is required which increases the proportion of housing delivery at sustainable rural settlements such as Haddenham. offering chance to enhance local services, reduce risk of delays with housing delivery and potential future housing land supply shortfall.

Full text:

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

Object

VALP Proposed Submission

Representation ID: 1865

Received: 11/12/2017

Respondent: Halton Parish Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Yes

Representation:

In both Tables 1 and 2 of S2 Spatial strategy for growth, the single line entry combining Wendover with Halton (Halton Camp) should be separated into distinct rows and Halton should have a distinct entry in the tables with the correct demarcation (a "smaller village") and its housing allocation (1,000 houses). In Table 2 the entry for Halton needs to have a description in column 2 highlighting why it has been selected for the 1,000 houses and how that fits within the settlement hierarchy.

Full text:

Halton Parish Council (HPC) supports AVDC's desire to provide housing on the current RAF
base sited within Halton within the existing building footprint on the site. This is providing that
sufficient employment, leisure, retail and infrastructure are included as part of any housing
development. Whilst HPC acknowledges that the Defense Infrastructure Organisation (DIO)
wants to sell the land for the highest price, HPC is keen to ensure that protected land, including
land with green belt status, is preserved for future generations during the opportunity to build on
to-be-vacated Ministry of Defense (MoD) land. Whilst the HPC has not been engaged in the
development of the VALP, we welcome the opportunity to add local knowledge to ensure that
development of the MoD land is of sufficient quality commensurate with the local area.
Issues
 Some of the VALP wording suggests that the 1,000 houses will be sited in Wendover,
not Halton.
 Halton will need to lose its classification as a "smaller village".
 Halton is not part of a strategic settlement.
 The VALP is unclear that the dwellings proposed for the RAF Halton site are within
Halton.
 HPC looks forward to early involvement in producing the Masterplan / SPD specific to
land in the parish of Halton.
 Information and Infrastructure
 Green Belt and Other Protected Land.
 Mixed Use
 VALP Policy map.
 Infrastructure
 Transport.
 Remove Uncertainty.

Object

VALP Proposed Submission

Representation ID: 2016

Received: 14/12/2017

Respondent: Crest Strategic Projects

Agent: Savills Southampton

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

This strategy devalues Milton Keynes, which is unjustified, and threatens the prompt delivery of appropriate levels of planned growth, which is ineffective.

Full text:

On behalf of Crest Strategic Projects (CSP), I enclose a suite of documents as formal representations on the above plan.

The lead representations statement (Savills) provides a detailed account of CSP's stance on the VALP as a whole. A range of inter-related objections are set out, relating to the amount and distribution of housing, site-specific allocations, and the consideration of alternatives within the Sustainability Appraisal. Particular objections are raised in respect of Shenley Park (site WHA001), which was included in the previous draft of the VALP, but is now omitted; and proposed allocation sites at RAF Halton, Buckingham and Winslow, which CSP objects to. The document should be read in conjunction with the following appendices:

* Appendix 1a - Shenley Park Vision Statement (Savills Urban Design Studio). This demonstrates and explains how the proposed development of Shenley Park can be delivered, not simply as a means to meet growth requirements for Aylesbury Vale in an optimal location and in a timely way, but to create a sustainable and integrated community with access to new facilities and nearby employment.
Please note that due to file size, the above is contained in my separate email ('email 2').

* Appendix 1b - Landscape and Green Infrastructure statement (The Landscape Partnership). This demonstrates that there are no landscape reasons why Shenley Park /WHA001 should not be included within the VALP. Concerns about the sensitive gap between Whaddon and Milton Keynes can be overcome by design and site planning. The north-west of the Site should include a permanent defensible buffer between built development on the Site and Whaddon comprising woodland planting and accessible semi-natural green space.
Please note that the above is accompanied by a series of figures and photographs in a separate file. Due to file size these are sent separately (in 'email 3').

* Appendix 1c - Technical note relating to highways and transport (RPS). This provides evidence on highways and transport matters, confirming that there are no significant transport constraints that would otherwise hamper the consideration of site WHA001 as a viable option for sustainable growth and timely delivery in the VALP.

* Appendix 2 - Draft Scoping Opinion (Aylesbury Vale District Council). This confirms that a formal EIA scoping report submitted by Savills on behalf of CSP satisfactorily sets out the likely environmental effects of the proposed development and determines the scope of the future assessment for the EIA

* Appendix 3 - Review of RAF Halton (Savills). This paper demonstrates that the VALP's allocation of RAF Halton is unsound, and should be removed and replaced with a site that is properly evidenced, available, deliverable and have a realistic prospect that it will deliver an appropriate number of dwellings within the plan period.

* Appendix 4 - Sustainability Appraisal Review (Savills). This shows that the Sustainability Appraisal of the VALP contains a number of flaws and inaccuracies, and that taking the SA as it is currently prepared may render the VALP being found 'unsound'. Correcting inaccuracies and appraising another alternative option for growth would offer a sound, sustainable way forward for the VALP.

* Appendix 5 - Technical report on housing need and local market absorption (Savills). This provides an analysis underlying CSP's view that a reduction in total housing targets (from the 2016 draft VALP to the current Submission Draft), is not justified, along with consideration of market issues.

* Appendix 6 - Review of housing land supply (Savills). This sets out an analysis to show that whilst AVDC is ostensibly able, in mathematical terms, to show a 5 year housing land supply in the Submission Draft VALP, there are number of substantial shortcomings in the intended approach relating to geographical distribution and overall levels of development.

* Appendix 7 - RAF Halton technical note relating to transport (RPS). This identifies that RAF Halton would not improve the proportion of travel by sustainable modes, by being remote from neighbouring areas or facilities, would not reduce the need to travel by relying on insufficient patronage to support a range of new facilities; and would not improve the efficiency of transport networks, by relying on lower order roads, including unsuited B-class and other rural roads and lanes for its outward connectivity.

* Appendix 8 - Representation forms (Savills). These are contained in AVDC's pro-formas, and set out CSP's representations on individual elements of the plan. There is a considerable element of overlap between these and the above-listed documents, and therefore the submission should be read as a whole.

Object

VALP Proposed Submission

Representation ID: 2395

Received: 13/12/2017

Respondent: Mr David Vowles

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

agree with methodology used, except the settlement hierarchy approach is now meaningless regarding policy differentiation among larger and medium villages.

plan is also unsound with regards to housing provision. approval of plan should be subject to immediate review.

Full text:

Paras 3.19-3.21 Policies S2 & S3 Tables 1 & 2 Pages 129 & 134
1. Very much welcome the shift in the method of allocating housing growth (additional to commitments) from one based on blanket percentage increases settlement to accommodate growth.
2. Table 2 of the Plan shows that new housing allocations made in the Plan are now distributed as shown in the attached Table A.
3. The different approached means that the policy distribution between larger villages and medium villages disappeared. In fact only three new allocations, in total, are proposed in the 12 villages whilst 6 new allocations are made in the 19 medium villages. The attached table shows that these allocations range in size from 10 to 118 in the larger villages and from 9 to 170 in the medium village.
4. However, a purported policy difference between larger and medium villages remains within sub-paragraphs g) and h) of Policy S2, Table 1, table 2 and the first sentence of Policy S3. In
5. The sections of tables 1 and 2 which distinguish between larger and medium villages should also be merged into a single, larger villages section and references to Fleet Marston and Broughton should be deleted as they are discrete "other settlements". In fact Broughton will be completely surrounded by the Aylesbury Garden Town development located in part of Bierton parish. Paragraphs 3.19 and 3.20 and redundant as they provide a description of a process which has effectively been superseded. The strategic settlements (including Salden and Halton Camp) cover a wide range of new allocation growth levels that run from 7810 at Aylesbury to zero at Wendover, whilst outside the strategic settlements these paragraphs deal with the distribution of merely 524 of the 12839 new housing allocations, all to be built before 2023 (see paragraph 8 below).
6. The changes I suggest below will clarify and simplify the Plan, removing redundant references to a settlement hierarchy approach which has little relevance tot eh polices to be pursued particularly with regard to the distribution between larger and medium villages. The Plan, correctly in my view, does make significant policy distributions between larger/medium villages (covered along with strategic settlements, in Policy D2) smaller villages (covered by Policy D3) and other settlements (covered by Policy D4).
Continuation sheet for Representation/
8. It should be noted that all the committed and allocated housing sites in the villages are expected to be developed by 2023. Therefore in the last 10 years of the Plan (2023 - 2033), unless new allocations are brought forward in a review of the Plan or in response to a shortfall in delivery revealed by monitoring, development in all villages (larger, medium and smaller) will be limited to sites brought forward in new or reviewed Neighbourhood Plans, windfall sites or Policy H2 sites.
9. Using data from the Council's housing Land Supply Soundness document I have complied the attached the Table B which gives the projected annual house building for Aylesbury Buckingham, Haddenham, Wendover/Halton Camp, Winslow, Edge of Milton Keynes, the larger villages, the medium villages and the smaller villages. It shows that building is expected to peak in 2025/26 in Aylesbury, in 2022/23 in Buckingham and Haddenham, in 2024/25 in Winslow and in 2020/21 in the larger and medium villages. Building is projected to cease in Buckingham and Haddenham after 2025/26, in Winslow after 2029/30, in the larger villages after 2024/25 and in the medium villages after 2025/26. In fact there is a discrepancy between the land Supply document and the local plan in respect of larger and medium villages. The supply document shows building continues to 2024/25 in the larger and medium villages and to 2025/26 in the medium villages. However, Polices D-SCD 008, D-MMO 006 and D-QUA 001 of the plan, which cover the sites concerned, state that development of all these sites will be completed by 2023.
10. After 2025/26 building will be restricted to Aylesbury, Halton Camp (1 site), Winslow (1site) and Edge of Milton Keynes (1 site). After 2029/30 it will be restricted to just Aylesbury and Halton Camp. I suggest that this is unrealistic and does not provide any flexibility. I reality building will almost certainly continue in the District as a whole after 2033, including to accommodate further unmet demand from the south Buckinghamshire districts; and after the dates at which it is projected to cease at Buckingham
+, Haddenham, Winslow and, probably, some of the larger and medium villages. Achieving the high building rates envisaged in the projection will be challenging but, if they are achieved, it would be perverse not to maintain them, at least in the strategic settlements (other than Wendover) for a few years, depending on there being demand, rather than assume an immediate fall0off after the peaks are reached.
11. The housing trajectory shows that house building is projected to exceed the target figure for the 10 years from 2019/20 to 2028/29, reaching a peak about 600 above the target in the 3 year period 2021/24. This mirrors the national target announced in the 2017 Budget of housebuilding increasing by about 50% to 3000,000 per year by the early 2020'2
12. However, once the peak building rate is reached the intention, nationally, is presumably that it should be maintained for at last a few years but the local plan assumes a steady decline in building post 2023/24, despite Aylesbury vale being part of the Oxford/Milton Keynes/Cambridge growth corridor.
13. If it is assumed that an average annual building rate for the district for about 1960 is indeed achievable by 2021-2024 and that it should then be continued for at least 5 years (unit 2028/29) it will be necessary for site allocations additional tot hose made in the Local Plan to start making contribution from 2024/25.
14. In other words additional sites will need to be found for at least 1810 dwellings. I suggest that these sites will need to be agreed well before 2024. It may be possible to accelerate delivery of the projected post-2024 contribution from some of the sites already allocated in the plan at Aylesbury, Winslow, edge of Milton Keynes and Halton Camp; but these sites will then new to be replenished with new allocations to maintain housebuilding at an approximate level beyond 2029.
15. The plan does not provide for this and so it is unsound as far as the later years of the house building trajectory is concerned. I therefore suggest that the plan should be found to be sound on an interim basis (as regards, say, the first five years after adoption) but that an immediate review should be required, as indeed envisages in paragraph 3.77 of the plan, to deal with the shortcomings I have identified, together with the proposals for Oxford/Cambridge growth axis and the proposed national formula for establishing housing need.