VALP Proposed Submission
Representation ID: 1455
Respondent: Mr David Vowles
Legally compliant? Not specified
Duty to co-operate? Not specified
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.
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 Paragraphs 3.19 and 3.20 and redundant as they provide a description of a process which has effectively been superseded.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.