Aylesbury Vale Area

S5 Infrastructure

Showing comments and forms 1 to 30 of 30

Support

VALP Proposed Submission

Representation ID: 297

Received: 11/12/2017

Respondent: Mr John Currell

Representation:

Strongly support - developers must not be allowed to avoid or under provide for necessary infrastructure.

Full text:

Strongly support - developers must not be allowed to avoid or under provide for necessary infrastructure.

Support

VALP Proposed Submission

Representation ID: 455

Received: 06/12/2017

Respondent: Thames Water

Representation:

Thames Water support proposed Policy S5 on Infrastructure and its supporting text.

Full text:

Dear Sir / Madam
Thank you for consulting Thames Water on the above document. Thames Water are the statutory water and sewage undertaker for the majority of the District and are hence a "specific consultation body" in accordance with the Town & Country Planning (Local Planning) Regulations 2012. We have the following comments to make on the Proposed Submission document
Policy S5 - Infrastructure - SUPPORT
Thames Water support proposed Policy S5 on Infrastructure and its supporting text.
Paragraph 3.43 states that:
'While infrastructure associated with water supply and sewers can be provided and funded by developers, upgrades to wastewater treatment works (WwTWs) can only be provided by water and wastewater utility companies.'
Whilst this is currently correct, from April 2018 the way we and all other water and wastewater companies charge for new connections will change. All information currently available is available on our website by following the link below. Further information is expected early 2018.
https://developers.thameswater.co.uk/New-connections-charging
Policy I4 - Flooding and Sustainable Urban Drainage Systems - REQUEST AMENDMENTS TO BE CONSIDERED CONSISTANT WITH NATIONAL POLICY
Thames Water Support Policy I4 on Flooding and Sustainable Urban Drainage systems and all the supporting text from paragraphs 11.20 - 11.31.
However as previously mentioned in our representations made in August 2016 we consider it could go further and that the Plan should recognise the risk from sewer flooding in addition to fluvial flooding as recognised in the Flood & Water Management Act.

As such in order for the plan to be considered sound we would recommend that reference to sewer
flooding is also included.
Policy I5 - Water Resources - SUPPORT
Thames Water Support Policy I5 on Water Resources and all the supporting text from paragraphs
11.32 - 11.36.
Site Specific Comments
The attached table provides site specific comments from a desktop assessment on sewerage and
water supply infrastructure, but more detailed modelling may be required to refine the
requirements.
These sites have been assessed on an individual base with only limited opportunity to consider
cumulative impacts. Therefore, the impact of multiple sites in the same area coming forward may
have a greater impact. The scale, location and time to deliver any required upgrades will be
determined after receiving a clearer picture of the location, type and scale of development together
with its phasing. Thames Water welcomes the opportunity to work closely with the neighbourhood
forum to identify the net increase in wastewater and water supply demand on our infrastructure.
A couple of the sites have been highlighted. This is as the sites were not included within the
consultation document issued last year, but have been assessed as part of the Water Cycle Study
work which has taken place.
We hope this is of assistance. If you have any questions please do not hesitate to contact Carmelle
Bell on the above number.
Yours sincerely,
Richard Hill
Head of Property

Object

VALP Proposed Submission

Representation ID: 592

Received: 14/12/2017

Respondent: The Buckingham Society

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

Policy S5 seeks to ensure that ALL new development must provide appropriate on and off-site infrastructure in order to avoid placing additional burden on the existing community. BUT who is to assess what is "appropriate" and who is to assess what is meant by "on site" and "off site" infrastructure. As it is bound to vary within each settlement large and small, it should be co-ordinated with the parish councils, civic societies, residents' associations and use LOCAL KNOWLEDGE to deliver the assessments.

officer note: changed from support to Object - due to criticism

Full text:

Policy S5 seeks to ensure that ALL new development must provide appropriate on and off-site infrastructure in order to avoid placing additional burden on the existing community. BUT who is to assess what is "appropriate" and who is to assess what is meant by "on site" and "off site" infrastructure. As it is bound to vary within each settlement large and small, it should be co-ordinated with the parish councils, civic societies, residents' associations and use LOCAL KNOWLEDGE to deliver the assessments.

Object

VALP Proposed Submission

Representation ID: 641

Received: 14/12/2017

Respondent: J & J Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

The policy is unsound and incompatible with NPPF paragraph 204 in that the Council are seeking to have regard to existing deficiencies in services and infrastructure provision, whereas NPPF paragraph 204 indicates that planning obligations should only be sought where they meet all of the relevant tests.

Full text:

Representation on behalf of Brackley Fox Lane Gospel Hall Trust.

The Trust supports Policy S5 in principle. However, the policy should clarify the term "All development", and in particular whether this means all new housing or includes employment and/or community provision. Furthermore, the trust welcomes the recognition that infrastructure deficiencies should be taken into account, but would respectfully question how such deficiencies can be taken into account by new development other than in the light of the tests at NPPF paragraph 204.

The policy and supporting text should recognise that:

a. Voluntary sector organisations including faith communities may be willing and able to make community infrastructure investments without developer funding;
b. Charitable organisations will be CIL exempt for development required in furtherance of charity objectives;
c. Notwithstanding funding issues, adequate land allocations will be required to meet known infrastructure needs and/or deficiencies.

Object

VALP Proposed Submission

Representation ID: 685

Received: 13/12/2017

Respondent: Whaddon Parish Council

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation:

Whaddon PC are very concerned about the provision of new infrastructure and the improvement of existing infrastructure , especially in the rural areas that are often impacted the most by major development, because little if anything has been done to upgrade existing roads etc for many years and are unable to cope with both the amount of traffic and the increase in 'short-cutting' HGV's etc.

Full text:

Policy S5 a) Whilst generally supporting the thrust of this hugely important policy, WPC suspect that it may not be fully 'sound'. Paragraph 4.16 of the IDP, under the BCC County wide transport modelling, states 'The most recent Local County wide Traffic Modelling undertaken in July 2017 indicates that even with a full suite of mitigation measures, there would be are no significant impacts to the highway network in the Vale. There are some areas where further work is needed to investigate the nature of the mitigation measures needed such as SW of Milton Keynes.' This statement is qualified and expanded in the accompanying Appendix A where it clearly states that a route upgrade is required on the A421, which lies to the SW of Milton Keynes and remains one of the main arterial roads into the city. The columns indicates that this route upgrade is 'necessary' but the anticipated delivery date is not until '2033' and that the upgrades will be will be funded by developer contribution and grant funding. Interestingly, this is the only entry in this entire section that does not have any supporting 'Additional comments or delivery notes'. WPC have always supported the long standing 'mantra' of successive Governments of 'I before E' - meaning Infrastructure before expansion, but AVDC within the VALP appear to be reneging on this laudable and justifiable requirement, by requiring within Policy S5 that 'The provision of infrastructure should be linked directly to the phasing of development to ensure that infrastructure is provided in a timely and comprehensive manner to support new development'. This sentence ignores those areas and communities close to the development area that are affected by it. WPC has long argued (with many others) that the A421 is already unsafe - especially at peak travel times - and that upgrades should be undertaken sooner rather than later, and certainly before any further major development is allowed to join it. Traffic modelling may suggest that some capacity still exists, but WPC would like an explanation of the IDP para 4.16 and in particular what 'investigate the nature of the mitigation measures needed' really means together with an assurance that works found necessary are funded by developers and grants before the development commences at Salden Chase, and not during phases, or after development may have been completed as suggested in Policy S5 or the IDP suggested 2033 time scale. The wording of policy S5 may be appropriate to the new development being constructed, but completely ignores the surrounding road network and nearby communities who are directly and immediately impacted by additional traffic generated by the development - both to support the construction of the site from day one, and those early new residents on early phases (i.e. - before 'built housing numbers' trigger any agreed infrastructure improvements).

Policy S5 b) WPC firmly believe that infrastructure costs, including and especially noting affordable/social housing should not be negotiable, even if the applicants consultants provide cost reasons for so doing. Developers should know, or find out during their land purchase appraisals ,exactly what constraints exist (often spelt out in adopted Local Plans or via normal research) and budget for these accordingly, when either buying land or entering into option agreements with land owners. It is simply not acceptable to allow for negotiation at a later stage, which inevitably impacts on existing communities by way of lost or lesser infrastructure improvements, lower social care due to unfunded overcrowding or a reduced number of affordable or other socially required homes. The developer who brings forward such proposals should look to reduce his profit level, or renegotiate their deal with the landowner, failing which, penalties should be imposed if the land is not developed within a sensible time frame, or consent withdrawn if they prevaricate unnecessarily. It is simply unacceptable for these tactics to be used to either promise faster development or maintain profit levels, as such negotiations are unprofessional and suggest insufficient planning and investigation at the developers land acquisition stage.

Policy S5 c) Whilst WPC are in favour and understand the need for CIL or LIT, this must not be introduced - even as Supplemental Planning Guidance' without full and proper consultation. It is insufficient to simply follow Government guidance when differing forms of achieving infrastructure contributions have been adopted by various authorities. In any event WPC would not wish to see such new measures introduced on existing outline or detailed planning consents, as they should be governed by the measures in place when the consents were granted, as this could lead to financial hardship, and perhaps on some individual and smaller developments,required homes not even being built.

Support

VALP Proposed Submission

Representation ID: 757

Received: 13/12/2017

Respondent: Peter Brett Associates LLP

Representation:

Policy S5 'Infrastructure': BA supports, although suggests there should be specific mention here of the outer orbital route being a key infrastructure element - this is referred to elsewhere in the VALP and for consistency should be added here.

Full text:

Policy S5 'Infrastructure': BA supports, although suggests there should be specific mention here of the outer orbital route being a key infrastructure element - this is referred to elsewhere in the VALP and for consistency should be added here.

Object

VALP Proposed Submission

Representation ID: 788

Received: 13/12/2017

Respondent: Define (on behalf of Bovis Homes)

Agent: Define (on behalf of Bovis Homes)

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation:

Bovis Homes object to Policy S5, which is considered unsound on the basis that it:
- has not been positively prepared as it is not based on a strategy that will ensure that the objectively assessed housing needs will be met within the plan period;
- is not effective in ensuring that sustainable development can be delivered in the Plan Period; and
- is inconsistent with national policy in that it does not fully reflect the Government's priorities and policies in terms of enabling sustainable development.

Full text:

The intent of Policy S5 is supported as it is critical that the future growth in the District is appropriately supported by the necessary community, highway and utilities infrastructure.

However, the critical role of other bodies in the planning, funding and delivery of infrastructure should also be explicitly referred to in the policy in order to encourage their proactive involvement. For example, the policy should reflect that it is the responsibility of the utilities company to provide the necessary water supply and wastewater infrastructure to support development. Their investment programmes are not necessarily integrated with Local Plans, and often will not address the development requirements for an area until specific proposals become committed, normally through the grant of planning permission.

Moreover, in order to achieve the "challenging" scale of housing growth required, the Housing Delivery Study for Buckinghamshire (2017) concludes that the District Council must take on the role of Housing Delivery Enabler. It highlights that the "real challenge in housing delivery is getting the sites to point at which homes start to get built" (para 14) and a key part of that is ensuring that the essential infrastructure is provided on time (para 11). Therefore, the District Council's role in facilitating the delivery process in this respect should also be set out in Policy S5.

The second paragraph of Policy S5 refers to having regard to existing deficiencies in services and infrastructure provision. The intent of the policy is unclear in this respect, the Local Plan cannot require development to remedy existing deficiencies under the terms of the Community Infrastructure Levy Regulations 2011 (Regulation 122).

Moreover, whilst the reference to viability assessments is welcomed, the District Council must demonstrate that the policy and infrastructure requirements in the Local Plan (cumulatively) are achievable and do not render sustainable development unviable (NPPF paragraphs 158, 173-174). That must be considered at this stage.

Soundness:
For the reasons set out above, Bovis Homes object to Policy S5, which is considered unsound on the basis that it:
- has not been positively prepared as it is not based on a strategy that will ensure that the objectively assessed housing needs will be met within the plan period;
- is not effective in ensuring that sustainable development can be delivered in the Plan Period; and
- is inconsistent with national policy in that it does not fully reflect the Government's priorities and policies in terms of enabling sustainable development.

Support

VALP Proposed Submission

Representation ID: 836

Received: 14/12/2017

Respondent: The Canal & River Trust

Representation:

The Canal & River Trust fully support this policy and we recognise and thank the Council for it continuing support of the give to improving the Aylesbury Arm of the Grand Union Canal as multi functional infrastructure.

Full text:

The Canal & River Trust fully support this policy and we recognise and thank the Council for it continuing support of the give to improving the Aylesbury Arm of the Grand Union Canal as multi functional infrastructure.

Support

VALP Proposed Submission

Representation ID: 845

Received: 14/12/2017

Respondent: The Canal & River Trust

Representation:

The Council and Buckinghamshire County Council are well aware of the issues surrounding developer funding for the towpath improvement work on the Aylesbury Arm. Whilst existing commitments should finish the section from College Road North into the town centre there is less certainty for funding for the remainder of the Aylesbury Arm or for the other two legs of the Grand Union Triangle. We would wish to be assured that the proposed changes to the CIL and developer contributions regime will not result in this important multi functional Green Infrastructure project not coming to fruition.

Full text:

The Council and Buckinghamshire County Council are well aware of the issues surrounding developer funding for the towpath improvement work on the Aylesbury Arm. Whilst existing commitments should finish the section from College Road North into the town centre there is less certainty for funding for the remainder of the Aylesbury Arm or for the other two legs of the Grand Union Triangle. We would wish to be assured that the proposed changes to the CIL and developer contributions regime will not result in this important multi functional Green Infrastructure project not coming to fruition.

Support

VALP Proposed Submission

Representation ID: 1046

Received: 14/12/2017

Respondent: Anglian Water Services Limited

Representation:

Reference is made to the need for developments to be phased to ensure the timely provision of infrastructure. We support this requirement as it is important that development is phased to ensure that it is aligned with water and water recycling infrastructure which is required to serve the new development.

Full text:

Please see attached representations.

Object

VALP Proposed Submission

Representation ID: 1067

Received: 14/12/2017

Respondent: Mr John Oliver

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

1. Good access needed for commerdal success. Congestion affects everyone.
2. Uncertainty about when anything will be done.
3. Traffiic model is unreliable as a basis fur highway infrastructure planning and design.
4. A41 is a particular problem. Road is too narrow for bus lane and cycle routes.
5. LEPs' policy is to use Eastern & Stocklake Unk Roads to relieve A41, not mitigation measures.
6. Importance of correct design for Woodlands roundabout for effective diversion of A41 traffic.

Full text:

see attachments

Object

VALP Proposed Submission

Representation ID: 1196

Received: 14/12/2017

Respondent: Newton Longville Parish Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

AVDC should adopt all infrastructure before expansion in planning and funding new
development. Infrastructure requirements should be embedded with appropriate level of detail within the Local Plan, so there is a clear policy expectation from the outset of what is to be delivered, when and how it is to be funded. Far more robust policy positions must be in place and not leave infrastructure requirements to a planning application. It cannot and must not be assumed that all infrastructure will be provided by developer contributions. There must be detail of how infrastructure will be funded.

Full text:

Please see attachment for full rep

Submission draft version of Vale of Aylesbury Local Plan (VALP)
Representation by Newton Longville Parish Council - 14th December 2017
Newton Longville Parish Council representation - AVDC VALP submission draft Page 1 of 42
1. Introduction
1.1. This submission endorses the submission made by North Bucks Parishes
Planning Consortium (NBPPC) which should be read in conjunction with this
submission.
1.2. Newton Longville Parish Council consider that the draft plan is capable of
being found legally compliant and sound, subject to modifications being
made to the plan to deal with the issues highlighted below. Whilst issues are
identified on compliance with the Duty to Cooperate, it is hoped that it is a
lack submission of evidence rather than a failure to comply. These issues
had been pointed out to AVDC prior to publication of the draft submission
plan.
1.3. Newton Longville Parish Council requests participation at the Examination in
Public in relation to the points raised in this representation as well as those
made and in the submission by NBPPC. The parish council wishes to take
part in discussions on the plan and on modifications that may be required.

Object

VALP Proposed Submission

Representation ID: 1349

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:

Object, S5: That development should not be expected to resolve deficiencies in existing infrastructure and that references to the impact on existing communities should refer specifically to an 'unacceptable' impact.

Full text:

Representations to Policy S5 'Infrastructure'
1. Policy S5 of the Local Plan deals with the provision of infrastructure. We support the requirement for all new development to provide appropriately for on and off-site infrastructure to mitigate any unacceptable impacts.

2. Whilst we understand what is meant by criterion a. of the policy, we object to its current wording. What we think it meant by this criterion is that developments should avoid placing additional 'unacceptable' burden on existing communities i.e. mitigating unacceptable impacts. There are, however, circumstances where developments will place an additional burden on an existing community, perhaps by increasing pupil number at an existing school or local centre. However, these may be an additional impact that is in fact positive - helping to maintain the viability and vitality of these existing services.

3. We additional object to the statement in the second paragraph of Policy S5 that development proposals must take in to account 'existing deficiencies in services and infrastructure provision'.

4. It is of course a fundamental principle of the planning system that new development should mitigate its unacceptable impacts but should not, and cannot lawfully, be required to address existing infrastructure deficiencies. Any requirement to make good existing infrastructure deficiencies would breach Regulation 122 of the CIL Regulations 2010 (as amended) which states that contributions from new development must be necessary to make a development acceptable in planning terms, directly related to the development and fairly and reasonably related in scale and kind to the development.

Changes Sought

Amend Policy S5 to:
i. delete reference to new development having regard to / addressing existing infrastructure deficiencies; and
ii. amend criteria a. to refer to an additional 'unacceptable' burden

Object

VALP Proposed Submission

Representation ID: 1579

Received: 12/12/2017

Respondent: Wendover Parish Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

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.

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: 1692

Received: 14/12/2017

Respondent: Richborough Estates

Agent: RPS Planning & Development

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

Whilst the provision of infrastructure is supported along with phasing of provision, the policy should not inhibit development coming forward in different timescales. The Council should acknowledge that on many sites, and in particular areas around Aylesbury, due to different ownerships, land will come forward in an independent manner. This is not unusual at all, but the Council needs to ensure, through either S106 or CIL and via its intended SPD, it has mechanisms in place to coordinate the funding of infrastructure and ensure that independent development sites do not prejudice delivery of wider land parcels.

Full text:

Attached report makes comments to the Proposed Submission VALP, by RPS on behalf of our client Richborough Estates, contains full comments on the policies and includes at appendix 1 a Housing Need Technical Review by Barton Willmore (November 2017).

Object

VALP Proposed Submission

Representation ID: 1718

Received: 14/12/2017

Respondent: Wates Developments Ltd.

Agent: Boyer Planning Ltd

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

The Policy should include reference to the fact that any planning obligations should only be sought where they are necessary to make the development acceptable in planning terms , directly related to the development, fairly and reasonable related in scale and kind to the development and in accordance with the Community Infrastructure Levy Regulations.

Full text:

Please find attached representations to the Vale of Aylesbury Local Plan Proposed Submission consultation, which are submitted by Boyer on behalf of Wates Developments Ltd.

Object

VALP Proposed Submission

Representation ID: 1735

Received: 14/12/2017

Respondent: Persimmon Homes Ltd., and CALA homes Ltd

Agent: Turley Associates

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation:

Proposed Policy S5 (as cross-referenced in Proposed Policy D1) indicates that
development proposals shall provide appropriate on and off-site infrastructure (in
accordance with the Infrastructure Delivery Plan). It is clear from the wording of the
policy and its supporting text, that developer contributions (in the form of Section 106,
Section 278 and Community Infrastructure Levy payments) are envisaged as playing a
major role in funding key infrastructure. Conversely, the draft policy also infers that
where infrastructure contributions render a development unviable, such contributions
may not be sought in full

Full text:

Please find attached representations submitted on behalf of Persimmon Homes Ltd., and CALA homes Ltd., in relation to the Proposed Submission Vale of Aylesbury Local Plan (2017).

Object

VALP Proposed Submission

Representation ID: 1868

Received: 11/12/2017

Respondent: Halton Parish Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Yes

Representation:

Any direct linkage between Halton and Wendover should be removed from the VALP; notwithstanding regional transport requirements, each village should be separately sustainable and each should have appropriate infrastructure.

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: 1915

Received: 14/12/2017

Respondent: Gallagher Estates Ltd

Agent: Barton Willmore

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation:

2.18 The delivery of development through
the allocation of land at Eaton Leys could
contribute towards the infrastructure
needs of the area including any obligations
required to mitigate the impact of the
development e.g. off-site improvements to
the highway network.

Full text:

On behalf of our client, Gallagher Estates Ltd., please find attached representations to the Vale of Aylesbury Local Plan Proposed Submission.

Object

VALP Proposed Submission

Representation ID: 1916

Received: 14/12/2017

Respondent: Home Builders Federation Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

Whilst we support the encouragement of self-build housing through the local plan we consider the requirement for sites of over 100 to provide an unstated number of self-build plots is not justified and inconsistent with national policy. Whilst we recognise that Local Planning Authorities now have a duty to promote self-build housing we do not consider the Council to have looked at sufficient options with regard to how it can provide plots to support self-builders.

Full text:

Response by the House Builders Federation to the Regulation 19 consultation on
the Vale of Aylesbury Local Plan
Thank you for consulting the Home Builders Federation (HBF) on Vale of Aylesbury
Local Plan (VALP). The HBF is the principal representative body of the housebuilding
industry in England and Wales and our representations reflect the views of discussions
with our membership of national and multinational corporations through to regional
developers and small local housebuilders. Our members account for over 80% of all
new housing built in England and Wales in any one year.
We would like to submit the following representations on the Local Plan and we
would welcome, in due course, participating in hearings of the Examination in
Public.
Duty to Co-operate
We do not consider the Council's approach to the duty to co-operate is consistent with
national policy.
It would appear from the evidence that Aylesbury Vale District Council (AVDC) have
met the legal requirements of the Duty to Co-operate in relation to meeting housing
needs for the Housing Market Area (HMA). There is a clear agreement between the
Council's in the HMA to meet needs in full with the unmet needs from the other
authorities in the HMA be provided for by Aylesbury Vale District Council (AVDC). This
is set out in policy S2 and we welcome the broad approach that has been taken by the
Councils in seeking to meet the needs of the HMA.
However, we are concerned that this co-operation is based on a housing needs
assessment that seeks to significantly reduce the overall level of housing need for the
HMA compared to official projections. In particular the latest assessment of housing
need has reduced the demographic starting point for AVDC, and subsequently its
objective assessed housing need (OAN). This has in turn provided greater scope for the
needs of the other authorities in the HMA to be met by AVDC. We consider the
approach to assessing housing needs is flawed and that there is significantly less
capacity in AVDC than is being suggested. In fact if the standard methodology were to
be applied across the HMA, and current distributions maintained, there would be even
less scope to meet the full needs of the Housing Market Area.
2
If the full needs of the HMA cannot be met, which would appear to be the case at
present then the policy requirements of the duty to co-operate as set out in 178 to 181
of the NPPF will not have been addressed. To ensure the plan is compliant with the
policy requirements of the duty to c-operate further consideration as to how the needs
of the HMA will be met in full will be necessary.
Our key concerns regarding the assessment of needs is set out below.
Housing needs
In our earlier comments on housing needs to the AVDC we raised concerns regarding
the January 2016 Housing Economic Development Needs Assessment (HEDNA) and
the reduction in housing needs compared the 2015 HEDNA. However, since the
regulation 18 consultation the HEDNA has been updated again to take into account the
latest 2014 based population projections published in the summer of 2016 which has
resulted in a significant reduction on the assessment of housing needs. We would
support the Council in undertaking such an update which is in line with Planning
Practice Guidance, however, we are surprised as to the outcomes of the update.
Having examined the 2014 based Household Projections for the HMA we note that
between 2013 and 2033 total households were 1,925 higher than those in the 2012
based projections. The updated HEDNA though sets out a distinctly different projection
of household growth. Between 2013 and 2033 the updated HEDNA expects the
demographic starting point for assessing housing needs to be 2,826 less than the
previous HEDNA using the 2012 based household projections. It seems surprising that
the updated HEDNA would see the opposite trend to the official projections. Despite
this significant discrepancy we cannot find any explanation as to why the upward trend
in the official projections leads to a reduction in households using the Council's
methodology.
Of particular concern is the fact that the latest HEDNA anticipates that AVDC are
expected to see household growth that is significantly lower than that set out in the
original HEDNA. The reason why this concern is so important is that AVDC are
expecting to meet the unmet needs arising from the other authorities in the HMA. The
updated HEDNA shows a reduction in the total number of households expected to form
during the plan period in AVDC from 18,144 households using the 2012 based
projections to 16,933 using the 2014 based data. However, the 2014 based household
projections expected there to be 2,623 more households in 2033 than was expected in
the 2012 based projections. So, despite the 2014 based household projections showing
an increase when compared to the 2012 projections the updated HEDNA projects a
reduction in household growth for AVDC. As mentioned above, there is no explanation
as to why this has occurred and given that it has enabled the HMA to meet its needs we
would have expected this to be addressed in the evidence supporting the plan. In fact,
the most recent HEDNA continues to claim in paragraph 9 that the growth identified for
AVDC is "marginally lower" than the CLG starting point. We would suggest that a
reduction of 4,095 households is more than "marginally lower".
3
It is essential that the Council's in the HMA provide a clear justification as to the reason
for this significant reduction in the demographic starting point. There are inconsistencies
with both previous projections provided by the Council and those provided by the
Government and ONS. The approach taken by the Councils is not clear and is one of
the reasons why the Government have been looking to apply a standard methodology
for assessing housing needs. However, even before the latest consultation Planning
Practice Guidance (PPG) sets out that Government considers the official household
projections to be robust stating in paragraph 2a-017:
"The household projections produced by the Department for Communities and Local
Government are statistically robust and are based on nationally consistent
assumptions."
The latest consultation 'Planning for the Right Homes in the Right Planes' reiterates this
position with the standard methodology being based on the household projections.
Paragraph 16 of the consultation document states:
"The Office for National Statistics' projections for numbers of households in each local
authority are the most robust estimates of future growth."
We recognise that the PPG allows for some sensitivity testing but it also requires these
to be based on robust evidence. So whilst our initial response was positive, despite our
usual concerns regarding the use of the 10 year trend, there is insufficient justification
as to why the latest projections for the HMA have substantially reduced household
growth for AVDC from the original HEDNA and, most importantly, why they have moved
in the opposite direction to the DCLG household projections.
The latest consultation also sets out that across the HMA the Government would expect
the new methodology, if implemented, to require a more significant level of housing
delivery. Based on the Standard Methodology the HMA would need to deliver 3,039
dwellings per annum (dpa) compared to the 2,269 dpa that is the Councils' assessment
of housing need. With regard to the duty to co-operate and meeting needs across the
HMA there must be a concern that AVDC's needs assessment is 534 dpa lower than
the standard methodology. Given the constraints expressed by the other authorities
there will clearly be a need for AVDC to consider a further increase in its housing
requirement in order to address an ever increasing level of unmet need in the HMA.
There have also been wider concerns regarding the tendency of local authorities within
this area to underestimate the levels of housing needs. The recent National
Infrastructure Commission (NIC) report1 on the Cambridge-Milton Keynes-Oxford Arc
identified the tendency for local planning authorities in this area to run assessments that
produce lower level so f housing need than official projections. On page 26 of this report
the NIC states:
1 Partnering for Prosperity: A new deal for the Cambridge-Milton-Keynes Oxford Arc (National
Infrastructure Commission 2017)
4
"... there is good reason to believe that the methodology used in undertaking
assessments of local housing need can be conservative and mask high levels of unmet
need."
It would appear that the tendency to underestimate housing need is prevalent across
this region. If the long term economic growth and infrastructure plans that are required
for this area are to be realised then the assessments of housing need must not seek to
supress official demographic projections.
In conclusion we do not consider that the level of housing needs, as set out in the
updated HEDNA, to have been sufficiently justified. In particular we do not consider the
substantial reduction in household growth using the government's 2014 based data to
have been adequately explained. These reduce the overall level of need for the HMA
and thus enabling the HMA to meet its needs. If the lower level of need set out in the
latest HEDNA cannot be justified then this will have significant implications for the
progression of the other Local Plans in the HMA due to the significantly reduced
additional development capacity in AVDC.
In addition there is potential for the level of unmet need from the other authorities to be
higher than initially considered. Whilst only limited weight can be given to the
consultation as a whole it does give the clearest positon yet as to the degree to which
market signals should be taken into account. This would suggest that housing needs
across the other authorities in the HMA could also have been underestimated leaving a
more significant degree of unmet needs than has been considered by AVDC and its
partners.
So, whilst the co-operation would appear to be effective it is potentially based on
erroneous evidence. If there is insufficient justification for the reduction in housing
needs resulting from the updated HEDNA then there will be a need for the authorities in
the HMA to revisit their collective approach to meeting housing needs.
We would also like to mention that it would have been beneficial for all parties had the
authorities in the HMA taken a more strategic approach in preparing their Plans to allow
housing needs to be considered by a single inspector. This enables the approach to
assessing and meeting housing needs for an HMA to be considered just once and
would avoid repetition of debates. We have seen across the Country that a decision on
OAN for an HMA at one EIP can make it difficult for any inspector at subsequent EIPs
using the same evidence to potentially disagree with a colleague. As such we welcome
approaches to strategic planning such as those taken in the North Essex HMA where a
strategic plan for the whole area has been prepared and allows housing needs across
the three LPAs concerned to be considered at the same time.
S2 Spatial strategy for growth
The policy is unsound as the delivery expectations to support the other authorities in the
HMA are unjustified
5
As set out above we have concerns as to the approach taken by the Council in
assessing the housing needs for the HMA and in particular the OAN for AVDC. We do
not consider that there is sufficient justification to reduce the demographic starting point
for AVDC and that the DCLG household projections remain robust and should be used
as the baseline for assessing needs. If the household projections were used as the
starting point for considering needs and a 10% uplift were applied, as recommended in
the HEDNA, then AVDC's OAN for the plan period would be 23,129 (1,156 dpa). As
such the Council would continue to be able to meet its own needs but there would be
less capacity to support the other authorities in the HMA. However, given the
Government's latest consultation we would suggest that a 10% uplift for AVDC is too
low and we would suggest it be reconsidered prior to submission.
So whilst we welcome the approach taken by AVDC to set a housing requirement of
27,400 new homes we do not consider the level of growth to be sufficient to support the
other authorities in the HMA to the degree stated. This will require the Council and its
partner authorities to reconsider its approach to meeting the needs of the HMA. If
current distributions of need are continued then AVDC will need to include additional
allocations to offset the limited delivery elsewhere in the HMA. Alternatively the other
authorities could seek to increase their own housing requirements to make up for the
shortfall. We recognise that not all the LPAs in the HMA are at the same stage of plan
preparation and if further allocations cannot be made in this plan the policy must set out
the need for an early review based on the final requirements of the other LPAs in the
HMA.
The policy should also establish that the housing requirement as the minimum number
of homes that will be delivered. This is important in order to ensure that growth beyond
the requirement is supported by the Council. This would also be consistent with the
positive approach to planning required by paragraph 14 of the NPPF and the Council's
own position in table 1 of the VALP, which sets out the expectation that 28,850 new
homes will be delivered.
Housing trajectory
The HBF does not comment on the merits or otherwise of individual sites therefore our
representations are submitted without prejudice to any comments made by other parties
on the deliverability of specific sites included in the overall housing land supply, the fiveyear
housing land supply and housing trajectories. However, we want to stress the
importance of having realistic delivery expectations within any allocations to ensure the
deliverability of the plan across its lifetime. This is particularly important where there is a
reliance on strategic sites to deliver the majority of new homes within the plan period.
Delays to the delivery of strategic sites for any number of reasons could lead to the LPA
not being able to meet its housing requirement. A more cautious assessment of delivery
on strategic sites offset with the allocation of smaller sites will offer a more flexible and
sound housing trajectory.
H1 - Affordable housing
The policy is not sound as it is unjustified and inconsistent with national policy
6
Whilst we appreciate that the Council were looking to test scenarios prior to setting
policies, it would appear that full consideration has not been given to the cumulative
financial impact of those policies as required by paragraph 173 of the NPPF. For
example, the policies on electric vehicle charging and accessible homes have been
considered separately and only with regard to a 50-unit mixed scheme. In addition, the
requirements in policy H4 concerning the optional accessibility standards have not been
tested. The nearest assumption is for 70% M4(2) and 5% M4(3). Significantly lower
than the requirements of policy H4. Until further testing is carried out on the cumulative
impact of the policies as set out in the Local Plan it is not possible for the Council to
state that the Local Plan will not threaten the viability of development in the area.
We consider that the wording of the policy is not consistent with the core planning
principles set out in the NPPF and the requirement established in paragraph 17 for
Local Plans to:
"... provide a practical framework within which decisions can be made with a high
degree of predictability and efficiency".
The policy states that the Council will require "a minimum of 25%" of all homes provided
on appropriate sites to be affordable. This suggests that in some circumstances the
Council will seek a high proportion of affordable housing provision and increases the
uncertainty for the decision maker and applicant as to what the appropriate amount of
affordable housing provision should be. This is of increasing concern to our members
who, where affordable housing policies are set as minimums, are being asked to
provide evidence to justify meeting the minimums. There is a real danger that such
policies will generate additional and unnecessary justification for policy compliant
schemes.
In order to make this policy consistent with national policy we would suggest that the
word "minimum" is removed. This will provide the necessary certainty required of such a
policy for both decision maker and applicant.
H5 - Self/Custom Build Housing
The policy is unsound as it is not consistent with national policy and is ineffective.
Whilst we support the encouragement of self-build housing through the local plan we
consider the requirement for sites of over 100 to provide an unstated number of selfbuild
plots is not justified and inconsistent with national policy. Whilst we recognise that
Local Planning Authorities now have a duty to promote self-build housing we do not
consider the Council to have looked at sufficient options with regard to how it can
provide plots to support self-builders. Paragraph 57-024 of the PPG sets out a variety of
approaches that need to be considered - including the use of their own land. This is
reiterated in para 57-14 of the PPG which sets out the need for Council's to consider
how they can support the delivery of self-build plots through their housing strategy, land
disposal and regeneration functions. We cannot find any evidence as to the Council's
consideration of other reasonable approaches to delivery as suggested in PPG. Without
7
such consideration it would appear that the Council is seeking to place the burden for
delivery of self-build plots on house-builders without looking sufficiently at other delivery
mechanisms as set out in national guidance.
We also consider the policy to be inconsistent with the third bullet point of paragraph
57-025 of PPG. This outlines that the Council should engage with landowners and
encourage them to consider self-build and custom housebuilding. The approach taken
by the Council moves beyond encouragement and requires land owners to bring
forward plots. We would therefore suggest that the policy be deleted and replaced with
a policy that seeks to encourage the provision of self-build plots on developments of
over 100 units.
Where plots are not sold it is important that the Council's policy is clear as to when
these revert to the developer. At present this policy makes no such provision, as such it
is ineffective. We would suggest that the policy state that if a plot remains unsold after 6
months of it being offered on the open market then it should revert back to the
developer to be delivered as part of the overall scheme. We would also recommend
that if development of a purchased plot has not commenced within three years of
purchase that the buyer be refunded and the plot reverts to the developer. It is
important that plots should not be left empty to detriment of its neighbours or the
development as a whole.
H6 - Housing mix
Parts of the policy are unsound as they are not justified
We do not consider the Council to have justified the requirement for all homes to be
built to part M4(2) and for 10% of market homes and 15% of affordable homes to be
built to part M4(3). With regard to Part M4(2), the evidence in the HEDNA suggests that
as the population is ageing then all new homes should be made accessible to ensure
those older people who do move are able to acquire an accessible home. However, the
HEDNA itself outlines that many of the existing older people are unlikely to move from
their current homes and as such there is likely to be significantly less need for new
homes to be built to part M4(2). It is also likely that many of those who do move will
move to accommodation specifically built to meet the needs of older people and not to
general market housing. As such we do not think it is justified for all new homes to be
built to part M4(2) solely on the basis that there is an ageing population.
The proposal to require 10% of market homes as being M4(3) is contrary to national
policy. PPG sets out in paragraph 56-009 that the standard for wheelchair accessible
homes only to properties where the local authority is responsible for allocating or
nominating a person to live in that dwelling. This means that M4(3) can only be applied
to affordable homes and the policy should be amended to reflect this position.
We accept that there may be some need to ensure a proportion of new affordable
homes are wheelchair accessible. However, we do not consider there to be sufficient
evidence to support a policy requiring 15% of all affordable homes as being built to Part
M4(3). Firstly, the Local Plan sets out that nationally 7.1% of households living in
8
affordable accommodation which suggests that provision at 15% is much higher than
the number of wheelchair users requiring such homes. Secondly, no consideration has
been given, as required in PPG, to the existing stock of affordable homes that are
already accessible to wheelchair users. Without this evidence the Council cannot be
certain as to whether there will currently a surplus of such homes within the Borough.
It is also the case that the Council's viability assessment has not tested the viability of
providing the level of accessible housing set out in this policy. As set out above in our
representation ton policy H1 the proportion of homes to be provided as either M4(2) or
M4(3) has not been tested. In addition, it has only been tested with regard to one
scenario - a 50-unit mixed development. As the full cumulative impacts of the policies
set out in the plan have not been tested we do not consider there to be sufficient
justification to support the proportion of homes required by the policy to conform to the
optional accessibility standards.
H7 Dwelling sizes
This policy is unsound as it is not consistent with national policy and is unjustified
The policy is not consistent with the approach to setting internal space standards in
PPG. Paragraph 56-018 to 56-023 set out that if a Local Planning Authority has
sufficient evidence to support the introduction of minimum space standards they should
only do so by reference to the national described space standards. Any other approach
taken to setting space standards must, therefore, be considered unsound. However, in
addition to this fundamental principal the Council state in paragraph 5.68 there is no
evidence to suggest that homes are coming forward below the nationally described
space standards. If this is the case then seeking to apply an alternative standard is
unjustified and unhelpful as the wording of this policy provides no clear guidance as to
what should be considered "sufficient internal space".
Such a subjective assessment could lead to confusion amongst both the decision
maker and the applicant. This policy is therefore inconsistent with one of the core
planning principles set out in paragraph 17 of the NPPF which states that local plans
should provide a:
"practical framework within which decisions on planning applications can be made with
a high degree of predictability and efficiency"
We would also suggest that is inconsistent with paragraph 154 which states:
"Only policies that provide a clear indication as to how a decision maker should react to
a development proposal should be included in the plan"
Given these clear inconsistencies with national policy and guidance policy H7 should be
deleted from the Local Plan.
T5 Vehicle Parking and T7 Electric Vehicle Infrastructure
9
These policies are unsound as they are ineffective
Within both these policies the Council will look to set out elements of both these policies
as in Supplementary Planning Documents (SPD). However, we do not consider it
appropriate to set out in SPD elements of a policy (namely the number of charging
points, the minimum internal size of a garage and the level of parking) that will have a
direct role in the determination of planning application. As such they must be set out in
policy and open for debate at the Examination in Public. Without these details it is
impossible to consider the impact of these policies on viability, whether they are justified
and ultimately whether they will be effective.
Conclusion
At present we do not consider the plan to be sound. Whilst we are pleased with the
significant progress the Council has made in meeting its own needs and those of the
HMA we do not consider the Council has met the tests of soundness on the following
areas:
 Policy S2 sets out the degree to which AVDC is meeting the needs of other
authorities in the HMA but these are based on an unjustifiably low OAN. This
potentially impacts on the soundness of this policy and whether the HMA is
meeting its needs in full as required by the NPPF.
 The policy on affordable housing has not been adequately justified and does not
provide sufficient flexibility
 Policy H5 on self-build housing is inconsistent with national policy and is
ineffective as it as it does not consider how unsold sites will be treated.
 Requirements relating to accessible homes have not been sufficiently justified
either on the basis of needs or viability.
 Policy H7 on dwelling size departs completely from the approach set out in PPG
and as such is inconsistent with national policy, unjustified and ineffective.
 Policy T5 and T7 on parking and Electric Vehicle Infrastructure set out that the
level of provision required will be set out in SPD. These elements of the policy
will inform decision makers and should be considered as policy. As such they
should be included in the Local Plan.
We hope these representations are of assistance in taking the plan forward to the next stage of plan preparation and examination. I would also like to express my interest in attending any relevant hearing sessions at the Examination in Public. Should you
require any further clarification on the issues raised in this representation please
contact me.

Object

VALP Proposed Submission

Representation ID: 2024

Received: 14/12/2017

Respondent: Crest Strategic Projects

Agent: Savills Southampton

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

CSP does not object to this policy, however, we note that several of the site-specific allocations in the plan (notably RAF Halton, and the proposed additional allocations at Buckingham, Winslow and Milton Keynes) fail to demonstrate adherence to its objectives, in terms of ensuring adequate planning for future infrastructure needs. In contrast, the infrastructure requirements of CSP's proposed site at Shenley Park are well understood and have been factored into the emerging masterplan and EIA scoping (set out later in this document and in accompanying Appendices).

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: 2205

Received: 14/12/2017

Respondent: North Bucks Parishes Planning Consortium

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

All of the strategic locations offer primary care services but with significantly varying levels of provision. Haddenham performs best with a relatively recently built facility. Motor car journey times from the north to the two major hospitals providing specialist care for Aylesbury Vale (Stoke Mandeville and Wycombe General) are double those from Haddenham.

Full text:

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

Object

VALP Proposed Submission

Representation ID: 2249

Received: 14/12/2017

Respondent: Mrs Jane Chilman

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

Please also see my comments under 3.15 New Settlement.
The VALP does not seem to recognise the significance of East-West Rail to the Vale of Aylesbury. It is a major infrastructure project which should be embraced.

Full text:

Please find attached my letter containing my responses to the VALP dated 14th December 2017 .

Object

VALP Proposed Submission

Representation ID: 2250

Received: 14/12/2017

Respondent: Mrs Jane Chilman

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

Please also see my comments under 3.15 New Settlement.
The Government supports this scheme, therefore AVDC needs to capitalise on this opportunity and plan for transport, housing etc. that this scheme will bring forward.

Full text:

Please find attached my letter containing my responses to the VALP dated 14th December 2017 .

Object

VALP Proposed Submission

Representation ID: 2330

Received: 14/12/2017

Respondent: South West Milton Keynes Consortium

Agent: Carter Jonas - Associate SWMK Consortium

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

S5 & Paras 3.36 -3.46

IDP makes reference to both East West Rail and the Oxford to Cambridge Expressway. The Consortium considers that both projects would be supported by additional development adjacent to Milton Keynes. The land at South West Milton Keynes (Site Refs. NLV001 and NLV020) is located adjacent to the route of East West Rail and would be adjacent to or provide for the preferred route of the Oxford to Cambridge Expressway, which in our opinion supports the allocation of both these sites for development to contribute towards the funding of the planned improvements along these transport corridors.

Full text:

Please find attached representations to the Proposed Submission Vale of Aylesbury Local Plan consultation, which are submitted on behalf of the South West Milton Keynes Consortium.

In summary, representations are made to the following:

* Paragraphs 1.9 to 1.12
* Paragraph 1.13
* Paragraph 1.17
* Paragraph 2.4
* Paragraph 2.6
* Policy S2 + Objection to Policy S2 Report
* Policy S4 & Paragraphs 3.25 to 3.35 + [2016] EWCA Civ 466 Judgement
* Policy S5 & Paragraphs 3.36 to 3.46
* Paragraphs 3.75 to 3.77
* Paragraphs 3.78 to 3.80
* Policy D1 & Paragraphs 4.1 to 4.29
* Policy D-NLV001 & Paragraphs 4.110 to 4.119
* Additional Allocation D-NLV020 + Environment Agency Flood Mapping Plan, Landscape & Visual Technical Note, Highways & Transport Note, Highway Improvements Plan and Concept Masterplan
* Policy D-HAL003 & Paragraph 4.131 to 4.138 + Landscape & Green Belt Statement
* Policy T1 + Highways & Transport Note
* Housing & Economic Lands Availability Assessment (January 2017) + Concept Masterplan and Landscape & Visual Appraisal
* Sustainability Appraisal (September 2017)
* Green Belt Assessment Part 2 - RAF Halton (July 2016)

Those representations which are supported by a separate technical document or plan are provided in a separate e-mail.

Can you please confirm receipt of these representations, and continue to keep us informed of progress with the Local Plan?

Object

VALP Proposed Submission

Representation ID: 2362

Received: 14/12/2017

Respondent: The Environment Agency

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

The third paragraph of Policy S5 does not recognise where it may not be feasible to provide the sewage infrastructure in time for development phases. For example where sewer upgrades are planned as part of a water companies Asset Management Plan (AMP) these will be budgeted in advance where lead in time and planned upgrades may not be in-line with the proposed timescales of development.

Full text:

Please find attached our responses to the Aylesbury Vale DC Reg 19 Local Plan.

Object

VALP Proposed Submission

Representation ID: 2418

Received: 14/12/2017

Respondent: Wendover Neighbourhood Plan Steering Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

We have concerns about the adequacy of the IDP (given the very strong concerns
over existing as well as potential infrastructure needs identified by the community),
and make the following bullet points:-

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: 2464

Received: 07/12/2017

Respondent: Mr David Locke

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

Many parts of the link roads forming the proposed orbital route are said to be 'aspirational'. This
means that they are not funded. Who is supposed to be paying for them? Will they ever be built?
Even those parts of the orbital route that are supposedly funded, will be built at different times. The
whole thing will not be opened in one go. What consideration has been given to the effect on traffic
of a partly completed road system?

Full text:


Dear Sirs,
The draft Vale of Aylesbury Local Plan ("VALP")
My comments on specific areas of the draft Plan are as follows:
3.3 and Policy S1 - Sustainable development
Placing 16,000 houses in a relatively small area with an incomplete and partly 'aspirational' road
network will only lead to congestion and stagnation. If the traffic situation is bad, people will simply
not want to live in Aylesbury, work in Aylesbury or shop in Aylesbury.
3.15 - New settlement
AVDC should be forward looking and should be working with national government to leverage the
huge opportunities presented by infrastructure provision envisaged by the National Infrastructure
Commission regarding East West Rail (EWR) and the Oxford to Cambridge Expressway.
The western end of EWR is due for delivery within the draft VALP horizon. It does not appear to
have been considered adequately in the draft VALP.
Recommendation 4 of the National Infrastructure Commission's interim report says, in relation to
the East West Rail and Oxford - Cambridge Expressway projects:
"To fully maximise the benefits of the project local authorities should recognise the transformational
benefits of East West Rail and develop and agree, working with national government, an ambitious
strategy for housing development and deliver around stations and station towns." (my emphasis)
The proposed route options for the Oxford to Cambridge Expressway should be properly considered.
Option A (the 'green route') passes just to the North of Aylesbury
Option B (the 'purple route') passes between Aylesbury and Bicester, running parallel with the East
West Rail route.
Why wouldn't you consider a new settlement next to infrastructure that is being funded by national
government? It is surely the most sensible solution to the need for extra housing. I cannot see any
attempt in the VALP to work with national government to deliver a forward looking solution. What
is presented is a piecemeal plan, driven by developers'' profit motives.
Aylesbury deserves better than this. The VALP is inward‐looking in this regard. What is being
presented is a poor piece of work. It is simply not good enough.
Interventions - Link Roads
Many parts of the link roads forming the proposed orbital route are said to be 'aspirational'. This
means that they are not funded. Who is supposed to be paying for them? Will they ever be built?
Even those parts of the orbital route that are supposedly funded, will be built at different times. The
whole thing will not be opened in one go. What consideration has been given to the effect on traffic
of a partly completed road system?
Site D‐AGT1 - South Aylesbury
In the SEALR consultation, the South East Aylesbury Link Road is shown as passing through
undeveloped fields.
In the draft VALP, the SEALR isn't shown, but the area is shown covered in more houses. The traffic
from the houses has to be catered for. How is this traffic supposed to access the SEALR? There are
no junctions shown in the SEALR plans that I can see.
This is yet another example of the left hand not knowing (or caring) what the right hand is doing. It
is incredibly poor infrastructure planning. Again, what traffic modelling has been done to assess the
effect of 2,000 houses on what is supposed to be a strategic link route?
Policy H1 - Affordable housing
All large developments must provide at least 30% affordable housing, or serviced self‐build plots on
which younger people can build for themselves.
Even the council's own development at Woodlands ignores this basic requirement and only requires
20%. If the council ignores this need, the developers will take the council's lead and ignore it as
well.
It is simply not satisfactory for developers to say that 'up to' X% of affordable housing will be
provided. 'Up to' can mean 0% percent.
It really worries me that ignoring the needs of those who want to get onto the housing ladder, will
deny Aylesbury the opportunity to be home for the younger people that every town needs.

Object

VALP Proposed Submission

Representation ID: 2470

Received: 14/12/2017

Respondent: Jackson Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

The plan completely fails to recognise the on-going work by the National Infrastructure Commission (NIC) to accommodate
over a million new homes in the Cambridge-Milton Keynes-Oxford arc. There needs to be greater acknowledgement about
the role Aylesbury Vale District Council (AVDC) must play in shaping the future of the city as part of the 2050 spatial vision
and the plan needs a specific policy that deals with how this will be accommodated until 2033 which is the time period for the
plan.

Full text:

Please find attached representations and a supporting appendix in respect of the Regulation 19 consultation on the VALP.

Object

VALP Proposed Submission

Representation ID: 2549

Received: 14/12/2017

Respondent: Buckinghamshire County Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

School place provision - BCC have set out a position statement for education provision across
the district, highlighting where infrastructure proposals for new or expanded schools have been
agreed and included in the Infrastructure Delivery Plan.

Full text:

We have taken this final opportunity to highlight a number of outstanding concerns and suggested
amendments for the adopted Vale of Aylesbury Local Plan. These points include clarification on:
 The assessment of housing need and how the Government's position on the methodology may
affect the plan over the plan period.
 School place provision - BCC have set out a position statement for education provision across
the district, highlighting where infrastructure proposals for new or expanded schools have been
agreed and included in the Infrastructure Delivery Plan.
2
 Suggested amendments to site specific policies - Highways Development Management,
Flooding and Public Rights of Way have set out a number of suggested amendments to ensure
consistency throughout and to provide greater opportunities for improving connectivity via
sustainable modes of travel and strategic flood risk management.
 Suggested amendments to policies C4 Protection of public rights of way, D1 Detailed
Infrastructure on Green Infrastructure, H6 Housing mix, BE2 Design of new development,
Policy BE1 Heritage Assets. BCC is asking for further clarity with regards to the proposed
content of the Design SPD, the reference to Lifetime Homes within the Aylesbury Garden
Town supporting text and how this links to policy H6 Housing Mix, and suggested amendments
to policies on Heritage Assets and Archaeological Interest.
 General comments in relation to health and wellbeing - our Public Health team have set out a
number of suggestions to allow for a greater emphasis on health and wellbeing throughout the
plan, as well as seeking clarification on the assessment of the cumulative impact of new
development on existing and new residents.
 Suggested amendments and areas of clarification on the Level 2 Strategic Flood Risk
Assessment Final Report and Aylesbury Vale District Flood Risk Sequential Test