Aylesbury Vale Area

3.20

Showing comments and forms 1 to 7 of 7

Support

VALP Proposed Submission

Representation ID: 142

Received: 06/11/2017

Respondent: Ms Patience Skillings

Representation:

This seems completely logical.

Full text:

This seems completely logical.

Support

VALP Proposed Submission

Representation ID: 678

Received: 13/12/2017

Respondent: Whaddon Parish Council

Representation:

WPC believe Whaddon village can do 'it's part' in helping provide some new housing, but really want this to be homes to support the community, rather than just expensive large homes that in the main do little to support village traditional village life.

Full text:

WPC accept the 'smaller village' category description, of Whaddon village in Table 2. This recognises the village's relatively poor access to services and facilities, but despite the fact that the village stands only one mile or so from facilities within Milton Keynes, public transport is virtually non existent, and the community relies on car borne transport. Whilst welcoming the fact that 'no site allocations are made at smaller villages', it is hoped that during the plan period some small scale 'windfall' development can be achieved in or close to Whaddon village in order to help maintain the existing community, but these should ideally be social or affordable starter homes on appropriate 'exception sites' adjoining the built footprint of the village. There will be the odd infill site or redevelopment site within the village that may provide larger family homes, and these will be welcomed, if they fulfil the Local Plan requirements.

Object

VALP Proposed Submission

Representation ID: 736

Received: 13/12/2017

Respondent: Sue Barber

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation:

Halton hierarchy appears to be based on population, a percentage of which is comprised of RAF personnel and supporting staff. This has not been specified. When Halton camp closes the population will decrease considerably therefore making the hierarchy based on population incorrect.

Full text:

Halton hierarchy appears to be based on population, a percentage of which is comprised of RAF personnel and supporting staff. This has not been specified. When Halton camp closes the population will decrease considerably therefore making the hierarchy based on population incorrect.

Support

VALP Proposed Submission

Representation ID: 999

Received: 14/12/2017

Respondent: Hertfordshire County Council

Representation:

HCC would anticipate that any increase in demand arising from new housing proposed in Aylesbury Vale District is managed in the local area(s) with new school places being provided where required as part of Buckinghamshire's school planning strategy.

Full text:

Response to Aylesbury Vale Local Plan 2013-2033 - Proposed Submission Plan (Regulation 19)
Aylesbury Vale District is located to the west of Dacorum District in Hertfordshire. The potential cross boundary issues which may arise from the current consultation document are considered below.
Paragraph 3.20
The proposed settlement hierarchy is set out in Table 2 [Proposed settlement hierarchy and housing development], along with the amount of housing to be accommodated at each settlement.
STRATEGIC SETTLEMENTS -
Wendover/ Halton
The new development proposed is located in Halton, to the west of Tring and Berkhamsted within Dacorum District in Hertfordshire. 1,128 dwellings are allocated in the area of Halton. This settlement has a relationship with Hertfordshire with children resident attending schools in Tring and Berkhamsted.
A primary school is proposed as part of the development, therefore, it is considered that the potential development proposed is unlikely to have any significant impact on primary school places in the administrative boundary of Hertfordshire County Council.
Notwithstanding this, no additional secondary school provision has been mentioned in the Proposed Submission document. Ashlyns and Tring secondary schools both prioritise local pupils in their admission criteria and due to increased Hertfordshire demand it is anticipated that there could be a 'push back' of children that live in Buckinghamshire who would typically attend these schools.
HCC would anticipate that any increase in demand arising from new housing proposed in Aylesbury Vale District is managed in the local area(s) with new school places being provided where required as part of Buckinghamshire's school planning strategy.
LARGER VILLAGES -
Aston Clinton
Within the Larger villages category, Aston Clinton is scheduled to provide 627 dwellings in the next 15 years. These dwellings are from 13 different sites and have obtained planning permission from the planning authority.
The nearest town with a school in Hertfordshire closest to Aston Clinton is Tring in Dacorum. It is not clear whether new education provision will be included as part of those developments.
At primary phase there are few Aston Clinton pupils that attend Primary Schools in Dacorum District; in particular into Long Marston Voluntary Aided C of E Primary; and Grove Road Primary School which prioritises pupils for which it is the nearest school.
With regard to secondary school provisions, Ashlyns and Tring secondary schools both prioritise local pupils in their admission criteria and due to increased Hertfordshire demand it is anticipated that there could be a 'push back' of children that live in Buckinghamshire who would typically attend these schools.
HCC would recommend that Aylesbury Vale District Council ensure that sufficient school places are provided in tandem with the proposed new housing development to prevent additional pressure being placed on existing schools where there are already capacity issues.
Resources
Property
HCC would anticipate that any increase in demand arising from new housing proposed in Aylesbury Vale District is managed in the local area(s) with new school places being provided where required as part of Buckinghamshire's school planning strategy.
Ivinghoe
18 homes are proposed in Ivinghoe. This level of growth will have a minimal impact on school places in Hertfordshire.
Pitstone
It is suggested from the consultation document that approximately 199 dwellings could be proposed in Pitstone. The 199 dwellings are made up of 5 sites, these sites proposed are to the north of Tring in Dacorum District. Education provision in Tring would be one of the closest for pupils within these new developments.
HCC would recommend that Aylesbury Vale District Council ensure that sufficient school places are provided in tandem with the proposed new housing development to prevent additional pressure being placed on existing schools where there are already capacity issues.
HCC would anticipate that any increase in demand arising from new housing proposed in Aylesbury Vale District is managed in the local area(s) with new school places being provided where required as part of Buckinghamshire's school planning strategy.
MEDIUM VILLAGES -
Weston Turville
36 homes are proposed in Weston Turville. This level of growth will have a minimal impact on school places in Hertfordshire.
Policy D1 - Delivering Aylesbury Garden Town
D-AGT4: Aylesbury south of A41
One of the growth locations identified in Policy D1 is D-AGT4 - Aylesbury South of A41.
Aylesbury south of A41 is a strategic allocation for Aylesbury and contributes to the delivery of Aylesbury Garden Town.
Aylesbury Vale District Council has proposed approximately 3,111 dwellings directly adjacent to the south eastern edge of Aylesbury in their Local Plan. Education provision in Tring would be the closest for pupils within this new development outside the District.
HCC note the proposed primary schools to form part of the development, however, it is not clear whether the two new schools would provide sufficient spaces to serve the additional population.
As opposed to primary school provision, no detailed information regarding secondary schools are included in the Proposed Submission document. The latest forecast for Tring (secondary school) shows a deficit every year, varying between -0.3 FE to -1.1FE up to 2020/21. An existing inflow of
Resources
Property
approximately 2FE per year of children living in Buckinghamshire contributes towards the forecast demand.
Ashlyns and Tring secondary schools both prioritise local pupils in their admission criteria and due to increased Hertfordshire demand it is anticipated that there could be a 'push back' of children that live in Buckinghamshire who would typically attend these schools.
HCC would recommend that Aylesbury Vale District Council to ensure that sufficient school places are provided in tandem with the proposed new housing development to prevent additional pressure being placed on existing schools where there are already capacity issues.
Conclusion
Finally, HCC welcome the opportunity to continue to work with Aylesbury Vale District Council as new housing developments within the District may potentially have an impact upon the demand for school places in Hertfordshire.

Object

VALP Proposed Submission

Representation ID: 1433

Received: 12/12/2017

Respondent: Winslow Town Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

The Plan gives no account of how the Plan has robustly established "the capacity of each settlement to accommodate housing growth." The second tier in the Plan's settlement hierarchy comprises all the larger, more sustainable villages that have at least reasonable access to facilities and services and public transport, making them sustainable locations for development [WTC's emphasis added]. A Local Plan which does not demand that these second tier settlements should provide housing growth that meets their individual demographic growth as a minimum during the Plan period, would appear to be unsound.

Full text:

Winslow Town Council Objections to the Vale of Aylesbury Local Plan (VALP)
Winslow Town Council (WTC) welcomes the creation of a new Local Plan to cover Aylesbury Vale District. The approval of VALP will remove uncertainties in local planning - but it is important that the Plan is sound, and not open to further challenge. WTC also recognises that national Government proposals for the Cambridge-Milton Keynes-Oxford Arc, as reflected in statements in the Autumn 2017 Budget, suggest that it will be necessary over the coming few years to revise VALP to accommodate greater levels of development in the area than are currently envisaged. Such matters, however, are for the future. The immediate priority is to review and revise the currently drafted VALP, and to that end WTC offers the following objections to matters which it considers need to be reviewed and revised before VALP would be sound and consistent with relevant national planning policies.
0 Summary
Winslow Town Council considers that there are elements of the submission VALP which are unsound and need to be modified. These are:
1. The allocation of sites in strategic settlements with made or emerging Neighbourhood Plans, contrary to national policy.
2. Raising to 55% the increase in housing numbers for Winslow, the least sustainable of all the strategic settlements
3. Flaws in the Buckinghamshire Memorandum of Understanding
4. Insufficient affordable housing on qualifying sites
5. Under-delivery of new homes in large villages
6. Understating the growth in population during the Plan period as about 35,000 rather than 60,000
1 Site specific allocation for housing growth
1.1 In Table 2 of the Vale of Aylesbury Plan, there is an allocation of a single site for housing growth in Winslow which is contrary to:
(a) NPPF para 185 covering the key aim/promise of Neighbourhood Planning which enables communities to decide where new homes should be located;
(b) various Ministerial Statements along the same lines; and
(c) para 1.20 of the proposed Submission VALP which confirms that made Neighbourhood Plans can determine how development will take place in their area.
1.2 This aspect of the Plan is therefore unsound and not 'justified' as the most appropriate policy because it is not consistent with national planning policy. It will be for WTC, with its made Neighbourhood Plan, to bring forward an update and revision of Winslow Neighbourhood Plan (WNP) following the approval of VALP. The updated WNP, following robust consultation with the local community, will need to identify how and where any housing growth required in an agreed VALP is to be accommodated, including (if and where necessary) any extension to the WNP's settlement boundary. Both Buckingham and Haddenham are also Strategic Settlements which have a Neighbourhood Plan, and in which VALP has also identified allocated sites for housing development contrary to the same national planning policy.
1.3 This reflects previous correspondence from WTC to AVDC (dated 13th October 2017) on this very issue which refers to the inspector's conclusions for the Maidstone Local Plan, where target housing numbers were seen as an appropriate mechanism to use for an area with a made or emerging Neighbourhood Plan.
Proposed modification:
1.4 To meet WTC's objection this issue should be addressed by VALP stating the target figure of additional housing that needs to be accommodated in an updated WNP, perhaps indicating that one option for locating this might be on the identified land to the east of Great Horwood Road. An equivalent change also should be made to VALP in respect of other areas which have a made or emerging Neighbourhood Plan.
2 Scale of housing growth for Winslow
2.1 In Table 2 and the allocation of Site ref WIN001 on page 126, the level of housing growth proposed for Winslow, which WTC considers to be the least sustainable of the strategic settlements in the Vale (See WTC's initial Strategic Settlements Sustainability Assessment, below), has apparently been increased arbitrarily to 55%. In the draft VALP, the proposed growth was 50%, which the Town Council objected to as being, comparatively, unreasonable when infrastructure provision was considered in relation to the other strategic settlements.
Aylesbury Vale Strategic Settlements Sustainability Assessment for VALP (by WTC)
Aylesbury
Buckingham
Haddenham
Wendover
Winslow
Housing
Close to areas with unmet housing need
3
1
5
4
2
Transport
Train to London, Birmingham, Oxford
4
1
5
4
2
Express bus to nearby centres
5
4
3
1
3
Access to motorway network
3
4
5
3
1
Bypass for through traffic
3
4
5
4
1
Services
Extendable employment sites
5
4
3
2
1
Modern medical centre / surgery
4
3
5
2
1
Access to major retail / leisure / employment centre (Aylesbury or MK)
5
1
3
4
2
TOTAL SCORE
32
22
34
24
13
Each settlement is given a score from 1 to 5 in each row, with 5 representing the greatest level of sustainability.
2.2 The requirement for Winslow to deliver new homes, above those detailed in the WNP, has increased from 402 in the draft VALP to 585 in the submission VALP, an increase of 45%. The housing growth proposed for Buckingham, the second largest strategic settlement in the Vale, with its much stronger infrastructure compared with that of Winslow, has seen its housing growth reduced from 2,612 (50%) in the draft VALP to 2,312 (45%) in the submission VALP. These changes in the proposed growth figures are not explained, appear counter-intuitive and lack any rationale to support them. A report to AVDC's Scrutiny Committee for VALP in September 2017 said that: the Council has worked with town and parish councils to identify sites which can be allocated through revisions to their neighbourhood plans. Winslow is not alone in being able to confirm that no such consultation took place. If the process has been simply to establish a suitable site for housing growth and use its capacity as the level of housing growth to be proposed for a community, then this process would appear to be fundamentally unsound.
Proposed modification:
2.3 WTC proposes that VALP should set a more reasonable and sustainable increase in the number of additional homes within Winslow over and above the 35% increase already detailed in the made WNP. WTC suggests that an increase of about 300 homes over and above those already provided for in the made WNP would be more appropriate in the circumstances. It will be for a future revised WNP to determine, with the benefit of local public consultation, where the additional housing should be located to achieve the required strategic housing provision.
3 Memorandum of Understanding
3.1 The Buckinghamshire Memorandum of Understanding (MoU) between Aylesbury Vale DC, Wycombe DC, Chiltern DC, South Bucks DC and Bucks Thames Valley LEP (mentioned in paragraph 1.12 of VALP) is, in WTC's opinion, a flawed document. It is the MoU that seeks to justify the requirement for Aylesbury Vale to accommodate the unmet need of 8000 additional homes elsewhere in the Bucks Housing Market Area.
3.2 The Agreement in the MoU in paragraph 2.1(d) states - That the following level of unmet housing need within respective local plan periods up to 2033 will be accommodated in the Vale of Aylesbury Plan. This absolute agreement by AVDC to accommodate 5,725 homes (21% of the VALP total) as unmet housing need from Chiltern and South Bucks in VALP, when those Districts' joint draft Local Plan will not be published until the middle of 2018 and when the figure represents over 44% of the Full Objectively Assessed Need for Chiltern and South Bucks, appears to be an unsound commitment. Similarly, the accommodation of 2,275 homes (8.3% of the VALP total), as unmet need for Wycombe District, in light of the recent publication of the submission Wycombe District Local Plan (WDLP), appears equally unsound.
3.3 WTC believes that Wycombe District Council (WDC) has not recognised its duty and responsibility in these days of 'exceptional circumstances' for the effective delivery of housing, because it has not demonstrated a robust approach to maximise the delivery of new housing within the District's boundary in order to meet its own Full Objectively Assessed Need (FOAN). As a consequence, the WDLP has not followed a strategy which seeks to meet the District's FOAN for new homes during the Plan period. This leads WTC to conclude that the plan has not been positively prepared and is therefore unsound in respect of its provision for housing development. The following paragraphs explain why WTC has come to this view.
3.4 WDLP Policy DM34 specifies that new housing developments should provide (WTC's emphasis in bold):
(a) Opportunities to enhance existing and provide new green infrastructure have been maximised, including delivering long lasting measurable net gains.
(b) In all cases, development is required as a minimum to: Secure adequate buffers to valuable habitats and
(c) Achieve a future canopy cover of at least 25% of the site area on sites outside of the town centres and 0.5HA or more
3.5 These requirements, together with other luxuries and 'nice to haves', significantly limit the area of developable land for housing on allocated sites, and therefore limit the scale of housing development that can be accommodated. WTC believes that this Policy cannot, under the prevailing circumstances, be justified as it does not represent the most appropriate strategy, when considered against the reasonable alternatives and is not based on proportionate evidence. The Plan offers no justification for this highly questionable policy, which therefore leads WTC to the view that WDLP is unsound in this respect.
Evidence
3.6 Paragraph 4.38 of the WDLP states The Council has thoroughly reviewed the scope for meeting its housing needs within the District. However it does not consider the option of increasing housing densities in order to more fully meet the District's FOAN. The WDLP includes large allocated sites for housing delivering less than 10 dwellings per hectare e.g. - HW4 Abbey Barn 4 - 11.32 hectares - 100 homes at 8.8 dwellings per hectare (dph) and HW6 Gomm Valley and Ashwells - 72.8 hectares - 530 homes at 7.3 dph.
3.7 By way of comparison, WNP, where AONB and Green Belt are not a consideration, delivers its housing growth on identified sites at more than 30 dph and delivers satisfactory provision of green space for each housing development site. Even taking into account the difficulties of the terrain in parts of the High Wycombe area, WTC believes that the identified sites could be developed at appreciably higher densities than are currently proposed, and thereby absorb more, if not all, of the District's FOAN. Similarly, it is WTC's belief that the Princes Risborough expansion area is capable of delivering many more homes than are committed in the WDLP.
3.8 The WDLP only allocates 57 hectares of previously designated Green Belt land for housing, to deliver 1,100 new homes at 19.3 dph. This represents a mere 0.4% of the District's Green Belt, in a District with 48% Green Belt, amounting to over 14,000 hectares. Many LPAs in a similar position to WDC have recognised that, in order to meet the housing need identified by the FOAN, it is necessary to recognise the 'exceptional circumstances*' and to reallocate poorly performing areas of Green Belt for housing development in order to fully meet their own FOAN. A local example of such an approach is South Oxfordshire's Local Plan, where re-designated Green Belt land will deliver 5,500 new homes on 3 sites. Central Bedfordshire and Dacorum Councils are taking a similarly positive approach.
*The Housing Minister, Gavin Barwell, when speaking in relation to the Housing White Paper, said: "The green belt is 13% of the land. We can solve this crisis without having to take huge tracts out of the green belt. We are not going to weaken the protections; we have a clear manifesto promise and there is no need to take huge tracts of land out of the green belt to solve our housing crisis. They can take land out of the green belt in exceptional circumstances but they should have looked at every other alternative first." [emphasis added]
3.9 Criticisms of the WDLP, such as those of a failure to positively plan to maximise housing delivery in order to meet the FOAN and a reluctance to take a robust approach to the reallocation of poorly performing Green Belt land for housing development, will almost certainly also apply to the emerging Chiltern and South Bucks Local Plan. The MoU is a
document which appears to invite housing overspill into Aylesbury Vale and lacks checks and balances to ensure any unmet housing need has been demonstrably minimised.
Proposed modification:
3.10 The MoU (referenced in para 1.12) appears to be based on an unsound judgement of the opportunities that exist for the three southern districts of Buckinghamshire to deliver a greater proportion of their own FOAN. Following further detailed scrutiny of the figures in the MoU through the examination of the other relevant local plans, WTC believes that the unmet need housing targets for Aylesbury Vale District should be reduced, or alternatively the time scale over which those targets apply should be extended beyond the end of the plan period for VALP.
4 Affordable housing
4.1 The reduction in percentage and quantum of affordable housing to be delivered, compared with that previously shown in the draft VALP, does not appear rational when there is a recognised national shortage of such housing. The draft VALP proposed 31% of affordable homes on qualifying sites, which would have yielded about 8,800 affordable homes, whereas the submission VALP in Policy H1 only proposes 25% generating about 5,900 affordable homes. Evidence from CPRE, the National Housing Federation, Shelter, the Institute for Public Policy Research etc are all telling the same story, one of shortfalls of affordable housing delivery, more homelessness, an ever-increasing annual housing benefit bill etc. WTC understands that the Vale of Aylesbury Housing Trust (VAHT) has evidence that indicates that the provision of 6,000 affordable homes in Aylesbury Vale over the 20 year plan period will be significantly less than demand. When a neighbouring authority (WDC) demands 40% affordable homes on qualifying greenfield sites, why does VALP propose a very much lower target for the same Plan period within the same Bucks Housing Market Area?
Evidence
4.2 WTC considers the following paragraphs of the Affordable Housing section of the VALP Housing Topic Paper November 2017 in particular contain inaccuracies which have resulted in unsound conclusions regarding the percentage of affordable homes to be delivered on qualifying sites.
4.5 As set out in the HEDNA December 2016 to establish the past trends and current estimates of the need for affordable housing local authority data on homeless households and temporary accommodation, was considered alongside census data on concealed households and overcrowding together with information from the English Housing Survey, Housing Register and information from Housing benefit data on households unable to afford their housing costs. Based on this information the study concluded that there are 3,311 households currently in affordable housing need in the Buckinghamshire HMA who are unable to afford their own housing. Deducting those whose housing is not suitable and households that will release their housing back into the market leaves a net need of a 1,150 households who that are currently in affordable housing need who are unable to afford their own housing.
[VALP Housing Topic Paper November 2017]
4.3 On 8th December 2017 VAHT told WTC that:
"As of November 2017 there were nearly 3,900 applicants registered on Bucks Home Choice (BHC) within the Aylesbury Vale. Of these just over 2,300 are in bands A to D and eligible for affordable rented housing in the Vale. Around 1,600 are in band HO and may be eligible for rural exception properties or others with strict local connection criteria."
4.4 And Bedfordshire Pilgrims Housing Association (BPHA), the organisation which manages the register for shared ownership affordable homes in the Vale, told WTC that... the figures for Shared Ownership applicants for Aylesbury Vale since 2015 (based on applicant requests for 2, 3, 4, 5 bedrooms) were:
 2015 - 352
 2016 - 434
 2017 so far - 482
BPHA does not maintain a register of unmet need and these figures no longer appear to be available. When Catalyst managed the Shared Ownership Register, they recorded unmet need figures of 407 in 2010 steadily rising to 1,048 in 2014.
4.5 So in the past 3 years about 1,300 applications for shared ownership properties have been recorded. Paragraph 1.48 of VALP states that over the past 5 years an average of 1,127 dwellings were built each year. Out of this total, an average of 349 were affordable dwellings. With 25% of affordable homes allocated to shared ownership, over the past 5 years an average of just 87 shared ownership affordable properties have been delivered each year. This leaves an unmet need figure for the past 3 years alone of over 1,000 plus the backlog from 2014 and earlier.
4.6 From the above data, WTC concludes that the current unmet need for all types of affordable homes in Aylesbury Vale is over 5,000 and the evidence is of an increasing demand. Although this evidence would have been available to AVDC and its consultants it does not appear to have been considered. WTC's evidence from those 'at the coal face' indicates that the base figure for unmet need of 3,331 for all forms of affordable homes in December 2016 is incorrect. Para 1.47 of VALP states: The total number of households on the Bucks Home Choice housing register waiting for a social housing tenancy in April 2016 was over 3,000. (WTC believes this figure only relates to Aylesbury Vale, as opposed to the entire BHC area). This appears to suggest that no account was taken in the HEDNA of the need for shared ownership affordable homes.
4.8 Government requirements now prohibit the requirement for affordable housing applying to housing sites of 10 or less dwellings. As this is expected to be a significant proportion of new housing development in Aylesbury Vale the percentage of affordable housing needs to be increased to 25% to allow the total requirement of 4,200 affordable dwellings for the district to be achieved. This is of course provided that the proportion of affordable required does not generally render proposed housing developments in Aylesbury Vale unviable on the basis of paragraph 173 of the NPPF.
[VALP Housing Topic Paper November 2017]
4.7 This paragraph (4.8, above) only takes account of the FOAN for Aylesbury Vale and takes no account of the unmet need of 8,000 for the District Councils in the south of the County, where the LPAs are expecting delivery of affordable homes in accordance with their Local Plans. Wycombe's draft Local Plan requires 40% affordable homes on their own greenfield sites. If, say, 35% of the 8,000 unmet need homes included in VALP were required to be affordable, and if 85% of them were on qualifying sites, this would result in an additional requirement of about 2,400 affordable homes, resulting in a total of 6,600 affordable homes (representing about 29% of all new homes), not 5,900 as proposed by VALP. For the overall percentage delivery of affordable homes to be based solely on the Vale's requirements, when 29% of housing delivery will be for unmet need from other Districts, is a flawed approach and therefore unsound.
4.9 The council has engaged consultants Dixon Searle Partnership to advise it on viability. They have concluded that the 25% affordable housing requirement should be viable in almost all cases. They have further advised that the affordable housing requirement of 30% could be viable in some cases. The council has therefore set the 25% requirement as a minimum in the proposed affordable housing policy which will allow a higher provision where justified by viability. The viability information is however clear that a requirement higher than 30% would not be justified.
[VALP Housing Topic Paper November 2017]
4.8 WTC believes that the evidence in the submission VALP proves that a minimum figure much higher than 25% should be viable in almost all cases. As referred to above, Paragraph 1.48 of VALP advises that average annual housing delivery in the Vale for the past 5 years was 1,127, of which 349 was the average annual delivery of affordable homes. This represents a 31% delivery of new affordable homes across qualifying and non-qualifying sites.
4.9 In Paragraph 4.8 of the VALP Housing Topic Paper it says:
...the percentage of affordable housing needs to be increased ... . As 31% affordable homes has been delivered over all sites for the past 5 years this must mean that the percentage delivery figure on qualifying sites has been appreciably more than 31%. So a target higher than 31% has been shown to be viable.
4.10 Strategic communities with made Neighbourhood Plans in the Vale require at least 35% affordable housing delivery on qualifying sites. For both Winslow and Buckingham, for those sites identified in respective Neighbourhood Plans where planning applications have been approved or submitted, no issue as to the viability of the 35% figure has been raised.
4.11 Notwithstanding the above evidence that viability can be achieved at 35%, and there is more than sufficient demand at that level, the consultant's report in the Housing Topic Paper, para 4.9, only indicates - the affordable housing requirement of 30% could be viable in some cases. AVDC then erroneously concludes - The viability information is however clear that a requirement higher than 30% would not be justified. WTC considers this to be another unsound element underpinning the highly questionable 25% delivery figure for affordable housing proposed in VALP.
4.12 Finally WTC considers that setting a minimum target for affordable housing is not appropriate as developers will seek to design to such a minimum rather than deliver anything higher. It would be more prudent to set a realistic but challenging target percentage to be delivered - and accept that developers may be able to demonstrate viability problems in meeting the target in full on some specific sites.
Proposed modification:
4.13 WTC considers that, in respect of affordable homes delivery, VALP has not been positively prepared and is therefore unsound. WTC proposes that VALP be modified to set a minimum of 35% affordable housing delivery on qualifying sites. Alternatively, in recognition that the viable delivery of brownfield sites for housing can be more problematic than for greenfield sites, it could be more realistic to specify a minimum 40% for qualifying greenfield housing sites and a minimum 30% for brownfield sites.
5 Accommodating demographic growth in second-tier settlements
5.1 In VALP para 3.20 it is stated that
The settlement hierarchy is based on an assessment of population size, settlement connectivity and the availability of employment and other services and facilities. A draft settlement hierarchy has been consulted on, and a number of changes have been made to the conclusions as a result of comments received. A report has been produced setting out how the settlement hierarchy was established which is available on the Council's website. The proposed settlement hierarchy is set out in Table 2, along with the amount of housing to be accommodated at each settlement. The allocations for each settlement are based on the capacity of the settlement to accommodate housing growth, rather than a blanket percentage increase on existing housing stock as was previously proposed in the draft Plan. [WTC's emphasis added]
5.2 The emphasised section above appears to be flawed because the Plan gives no account of how the Plan has robustly established "the capacity of each settlement to accommodate housing growth." It is important to bear in mind that the district-wide housing growth in VALP is 36% without the buffer and total growth of 40% across the district including the buffer. Table 2 simply indicates the total amount of housing development per settlement as completions/commitments plus any allocations. Of the 11 larger villages (Stoke Mandeville is omitted because, we are informed, it is included in the Aylesbury figures), defined as such in the settlement hierarchy because of their superior infrastructure, only 5 have any allocations. Of those 11 larger villages, 8 are expected to deliver less than 20% housing growth. Four of them are not even expected to meet their own demographic growth to 2033. These are Stone (population over 2,600) 3.4% housing growth, Ivinghoe (population 1,000) 4.6%, Long Crendon (pop over 2,500) 9.5% and Wing (pop over 2,800) - 10.9%. Only Steeple Claydon with a 22.8% increase and Aston Clinton with a 40.3% increase in homes exceed 20% growth, whilst Waddesdon (including Fleet Marston) has 20% growth. The second tier in the Plan's settlement hierarchy comprises all the larger, more sustainable villages that have at least reasonable access to facilities and services and public transport, making them sustainable locations for development [WTC's emphasis added]. A Local Plan which does not demand that these second tier settlements should provide housing growth that meets their individual demographic growth as a minimum during the Plan period, would appear to be unsound.
Proposed modification:
5.3 WTC proposes that VALP be modified to require all 'large villages' to deliver appreciably more than the basic figure for demographic growth during the Plan period, bearing in mind that Aylesbury Vale is a growth area and that district-wide housing growth is more than 36%.
6 Population growth expectations
6.1 Para 1.35 of the submission VALP states that during the Plan period there will be a growth in population of about 35,000 (once allowance has been made for the growth which took place between 2011 and 2013). With growth of 27,300 homes in the Plan period, this figure for population growth appears to be under-stated. WTC drew attention to this at the draft VALP stage, but has received no explanation for the apparent discrepancy, nor any correction of it in the submission Plan.
Proposed modification:
6.2 The expected increase in the population of Aylesbury Vale in the plan period should be stated more accurately to be in excess of 60,000 based on the number of additional homes proposed.
7 Examination in Public
7.1 AVDC is asked to note that Winslow Town Council wishes to participate in the

Examination in Public.

Sean Carolan

Deputy Clerk

Object

VALP Proposed Submission

Representation ID: 2208

Received: 14/12/2017

Respondent: North Bucks Parishes Planning Consortium

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

flawed because the Plan gives no account of how VALP has robustly established "the capacity of each settlement to accommodate housing growth." It is important to bear in mind that the district-wide housing growth in VALP is 36% without the buffer and total growth of 40% across the district including the buffer.

Full text:

See attachment for full representation.
North Bucks Parishes Planning Consortium (Mr Geoff Culverhouse) [29662]

Object

VALP Proposed Submission

Representation ID: 2391

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.