Aylesbury Vale Area

S6 Gypsy, Traveller and Travelling Showpeople provision

Showing comments and forms 1 to 15 of 15

Object

VALP Proposed Submission

Representation ID: 350

Received: 04/12/2017

Respondent: Boarstall Parish Meeting

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

Object to S6 and the inclusion of Oaksview Park, Boarstall as a allocation. Permanent permission has been refused on this site numerous times, the views of the development control committee, PINs, Parish Council and locals have been ignored. There is a oversupply of sites in the vicinity. Its close to the MOD site and prison, other sites have been objected to by them. The site has a dominant and unnatural impact on the open countryside. There are 20 plots on site, not 13. Doesn't meet the criteria.

Full text:

I believe that S6. Gypsy, traveler and travelling show people provision and more specifically
Table 4. Oaksview Park, Boarstall. to be unsound as indicated above, and therefore should be removed from the plan.

It should be noted that the content of my representation is not intended as a comment regarding objection to planning consent but merely on the inclusion of this site within the VALP

Whilst I acknowledge the need for Gypsy and traveler sites in the district the allocation of this site is ill conceived and therefore not sound

1.1. The site has been occupied for a number of years with temporary or no permission, 5 hearings for planning permission have been heard by the development control committee, all have overwhelmingly found the site unsuitable for permanent occupation. The inspectorate has heard two appeals for the site and again found it as unsuitable for anything but a temporary site until AVDC located a suitable site.

1.2. The plan has identified this site with no reference to the significant number of alternative sites within a 5 mile radius, not only within AVDC but also the Cherwell district. This oversupply in the vicinity has been demonstrated by this sites under occupancy over the years; to the extent that the owners were sub-letting plots to eastern European economic migrants.

1.3. The site has been refused planning permission on so many occasions in the past why do the authors presume it will be awarded permission in the future?

2. I fail to see how the plan has complied with the duty to cooperate as it disregards the views of many.

2.1. It disregards the repeated decisions of its own development control committee

2.2. It disregards the repeated decisions of the planning inspectorate

2.3. It disregards the repeated objections of the parish council

2.4. It disregards the repeated objections from the residents adjacent to the site who have spent many thousands on security to minimize the number of break ins and vandalism from children residing on the site

2.5 The site lies within a few metres of a Ministry Of Defence, live munitions training ground and the close to Bullingdon Prison. The adjacent Cherwell District Council received an application for a site further away from the MOD boundary than this particular site. Following consultation, permission was refused after objection from the MOD and prison, AVDC have not consulted with these parties or the Military or Civil Police, and the adjoining parishes of Arncott, Murcott and Piddington.

3. I fail to see how a plan could be legally compliant that is in flagrant disregard of the development control committee member (elected Councilor's) repeated decision; it suggests that AVDC are making policy not its councilors.

4. The inclusion of this inappropriate site and systemic policy of AVDC over recent years to grant permanent permission to traveler sites it has previously refused permission to is a clear indication of its own failure to identify appropriate sites; on this basis the plan cannot possibly be considered to be a positively prepared policy.

5. Given the development control committee and inspectorates decisions, the authors of this plan have attempted to now justify the site on the basis of greater regulation of the site, they have done this in full knowledge that the site has flouted conditions imposed upon it and enforcement have been unable to influence this. The authors have not commented on the major reason for prior refusals, its dominant and unnatural effect on the open country side. On this basis its inclusion cannot be considered as justified or effective.

6. The VALP state the site is for 13 plots whilst the Authors have unfettered knowledge that is divided into 20 plots; I see the naming of 13 sites as a clear attempt to mislead the Inspector on compliance with the size recommendation within National Policy for gypsy and traveler sites. The authors have publically acknowledged non- compliance and defended it on the basis of it being the most appropriate "identified" site, i.e. 1 of 1. The site does not meet the defined criteria.

a. It has reasonable access to existing local services and facilities (a. including shops, schools,
healthcare and public transport). Sites should either be within or close to existing
sustainable settlements or with good access to major roads and/or public transport
b. Have safe and convenient vehicular access without giving rise to unacceptable impacts on
highway safety
c. Be able to achieve a reasonable level of visual and acoustic privacy for both people living
on the site and those living nearby
d. Not have an significantly adverse impact on environmental assets such as open
countryside, landscapes, the historic environment, biodiversity, waterways, open space and
green infrastructure
e. The size and scale of the site and the number of caravans stationed is appropriate to the
size and density of the local settled community, and does not dominate the nearest settled
community
f. The site should not be located where there is a risk of flooding or be affected by
environmental hazards that may effect residents health or welfare
g. The site must be capable of being adequately serviced by drinking water, utilities and
sewerage disposal facilities
h. Sites should remain small in scale - no more normally than 15 pitches on any one site

Object

VALP Proposed Submission

Representation ID: 358

Received: 04/12/2017

Respondent: Janet Marie MacTavish

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

Object to S6 and inclusion of Oakview Park, Boarstall as a allocation. Permanent permission has been refused on this site numerous times, the views of the development control committee, PINs, Parish Council and locals have been ignored. There is a oversupply of sites in the vicinity. Its close to the MOD site and prison, other sites have been objected to by them. The site has a dominant and unnatural impact on the open countryside. There are 20 plots on site, not 13. Doesn't meet the criteria.

Full text:

I believe that S6. Gypsy, traveler and travelling show people provision and more specifically
Table 4. Oaksview Park, Boarstall. to be unsound as indicated above, and therefore should be removed from the plan.

It should be noted that the content of my representation is not intended as a comment regarding objection to planning consent but merely on the inclusion of this site within the VALP

Whilst I acknowledge the need for Gypsy and traveler sites in the district the allocation of this site is ill conceived and therefore not sound

1.1. The site has been occupied for a number of years with temporary or no permission, 5 hearings for planning permission have been heard by the development control committee, all have overwhelmingly found the site unsuitable for permanent occupation. The inspectorate has heard two appeals for the site and again found it as unsuitable for anything but a temporary site until AVDC located a suitable site.

1.2. The plan has identified this site with no reference to the significant number of alternative sites within a 5 mile radius, not only within AVDC but also the Cherwell district. This oversupply in the vicinity has been demonstrated by this sites under occupancy over the years; to the extent that the owners were sub-letting plots to eastern European economic migrants.

1.3. The site has been refused planning permission on so many occasions in the past why do the authors presume it will be awarded permission in the future?

2. I fail to see how the plan has complied with the duty to cooperate as it disregards the views of many.

2.1. It disregards the repeated decisions of its own development control committee

2.2. It disregards the repeated decisions of the planning inspectorate

2.3. It disregards the repeated objections of the parish council

2.4. It disregards the repeated objections from the residents adjacent to the site who have spent many thousands on security to minimize the number of break ins and vandalism from children residing on the site

2.5 The site lies within a few metres of a Ministry Of Defence, live munitions training ground and the close to Bullingdon Prison. The adjacent Cherwell District Council received an application for a site further away from the MOD boundary than this particular site. Following consultation, permission was refused after objection from the MOD and prison, AVDC have not consulted with these parties or the Military or Civil Police, and the adjoining parishes of Arncott, Murcott and Piddington.

3. I fail to see how a plan could be legally compliant that is in flagrant disregard of the development control committee member (elected Councilor's) repeated decision; it suggests that AVDC are making policy not its councilors.

4. The inclusion of this inappropriate site and systemic policy of AVDC over recent years to grant permanent permission to traveler sites it has previously refused permission to is a clear indication of its own failure to identify appropriate sites; on this basis the plan cannot possibly be considered to be a positively prepared policy.

5. Given the development control committee and inspectorates decisions, the authors of this plan have attempted to now justify the site on the basis of greater regulation of the site, they have done this in full knowledge that the site has flouted conditions imposed upon it and enforcement have been unable to influence this. The authors have not commented on the major reason for prior refusals, its dominant and unnatural effect on the open country side. On this basis its inclusion cannot be considered as justified or effective.

6. The VALP state the site is for 13 plots whilst the Authors have unfettered knowledge that is divided into 20 plots; I see the naming of 13 sites as a clear attempt to mislead the Inspector on compliance with the size recommendation within National Policy for gypsy and traveler sites. The authors have publically acknowledged non- compliance and defended it on the basis of it being the most appropriate "identified" site, i.e. 1 of 1. The site does not meet the defined criteria.

a. It has reasonable access to existing local services and facilities (a. including shops, schools,
healthcare and public transport). Sites should either be within or close to existing
sustainable settlements or with good access to major roads and/or public transport
b. Have safe and convenient vehicular access without giving rise to unacceptable impacts on
highway safety
c. Be able to achieve a reasonable level of visual and acoustic privacy for both people living
on the site and those living nearby
d. Not have an significantly adverse impact on environmental assets such as open
countryside, landscapes, the historic environment, biodiversity, waterways, open space and
green infrastructure
e. The size and scale of the site and the number of caravans stationed is appropriate to the
size and density of the local settled community, and does not dominate the nearest settled
community
f. The site should not be located where there is a risk of flooding or be affected by
environmental hazards that may effect residents health or welfare
g. The site must be capable of being adequately serviced by drinking water, utilities and
sewerage disposal facilities
h. Sites should remain small in scale - no more normally than 15 pitches on any one site

Object

VALP Proposed Submission

Representation ID: 359

Received: 02/12/2017

Respondent: Unknown

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

Object to S6 and inclusion of Oakview Park, Boarstall as a allocation. Permanent permission has been refused on this site numerous times, the views of the development control committee, PINs, Parish Council and locals have been ignored. There is a oversupply of sites in the vicinity. Its close to the MOD site and prison, other sites have been objected to by them. The site has a dominant and unnatural impact on the open countryside. There are 20 plots on site, not 13. Doesn't meet the criteria.

Full text:

I believe that S6. Gypsy, traveler and travelling show people provision and more specifically
Table 4. Oaksview Park, Boarstall. to be unsound as indicated above, and therefore should be removed from the plan.

It should be noted that the content of my representation is not intended as a comment regarding objection to planning consent but merely on the inclusion of this site within the VALP

Whilst I acknowledge the need for Gypsy and traveler sites in the district the allocation of this site is ill conceived and therefore not sound

1.1. The site has been occupied for a number of years with temporary or no permission, 5 hearings for planning permission have been heard by the development control committee, all have overwhelmingly found the site unsuitable for permanent occupation. The inspectorate has heard two appeals for the site and again found it as unsuitable for anything but a temporary site until AVDC located a suitable site.

1.2. The plan has identified this site with no reference to the significant number of alternative sites within a 5 mile radius, not only within AVDC but also the Cherwell district. This oversupply in the vicinity has been demonstrated by this sites under occupancy over the years; to the extent that the owners were sub-letting plots to eastern European economic migrants.

1.3. The site has been refused planning permission on so many occasions in the past why do the authors presume it will be awarded permission in the future?

2. I fail to see how the plan has complied with the duty to cooperate as it disregards the views of many.

2.1. It disregards the repeated decisions of its own development control committee

2.2. It disregards the repeated decisions of the planning inspectorate

2.3. It disregards the repeated objections of the parish council

2.4. It disregards the repeated objections from the residents adjacent to the site who have spent many thousands on security to minimize the number of break ins and vandalism from children residing on the site

2.5 The site lies within a few metres of a Ministry Of Defence, live munitions training ground and the close to Bullingdon Prison. The adjacent Cherwell District Council received an application for a site further away from the MOD boundary than this particular site. Following consultation, permission was refused after objection from the MOD and prison, AVDC have not consulted with these parties or the Military or Civil Police, and the adjoining parishes of Arncott, Murcott and Piddington.

3. I fail to see how a plan could be legally compliant that is in flagrant disregard of the development control committee member (elected Councilor's) repeated decision; it suggests that AVDC are making policy not its councilors.

4. The inclusion of this inappropriate site and systemic policy of AVDC over recent years to grant permanent permission to traveler sites it has previously refused permission to is a clear indication of its own failure to identify appropriate sites; on this basis the plan cannot possibly be considered to be a positively prepared policy.

5. Given the development control committee and inspectorates decisions, the authors of this plan have attempted to now justify the site on the basis of greater regulation of the site, they have done this in full knowledge that the site has flouted conditions imposed upon it and enforcement have been unable to influence this. The authors have not commented on the major reason for prior refusals, its dominant and unnatural effect on the open country side. On this basis its inclusion cannot be considered as justified or effective.

6. The VALP state the site is for 13 plots whilst the Authors have unfettered knowledge that is divided into 20 plots; I see the naming of 13 sites as a clear attempt to mislead the Inspector on compliance with the size recommendation within National Policy for gypsy and traveler sites. The authors have publically acknowledged non- compliance and defended it on the basis of it being the most appropriate "identified" site, i.e. 1 of 1. The site does not meet the defined criteria.

a. It has reasonable access to existing local services and facilities (a. including shops, schools,
healthcare and public transport). Sites should either be within or close to existing
sustainable settlements or with good access to major roads and/or public transport
b. Have safe and convenient vehicular access without giving rise to unacceptable impacts on
highway safety
c. Be able to achieve a reasonable level of visual and acoustic privacy for both people living
on the site and those living nearby
d. Not have an significantly adverse impact on environmental assets such as open
countryside, landscapes, the historic environment, biodiversity, waterways, open space and
green infrastructure
e. The size and scale of the site and the number of caravans stationed is appropriate to the
size and density of the local settled community, and does not dominate the nearest settled
community
f. The site should not be located where there is a risk of flooding or be affected by
environmental hazards that may effect residents health or welfare
g. The site must be capable of being adequately serviced by drinking water, utilities and
sewerage disposal facilities
h. Sites should remain small in scale - no more normally than 15 pitches on any one site

Object

VALP Proposed Submission

Representation ID: 367

Received: 04/12/2017

Respondent: Piddington Parish Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

Piddington Parish Council wishes to object in the strongest possible terms to the proposal to include a gypsy/travellers site at Boarstall into the AVDC Local Plan.The proposal constitutes development within the open countryside, which would be an intrusive feature detracting from, and to the detriment of, the character and appearance of the area, and is contrary to all sustainable development criteria.

Full text:

Please see attachment.

Object

VALP Proposed Submission

Representation ID: 457

Received: 06/12/2017

Respondent: Leafgrove Ltd

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation:

VALP fails all of the necessary criteria for inclusion:

1. The site does not have planning permission and has been previously judged as unsuitable
2. is not legally compliant.
a. is in flagrant disregard of repeated decisions made by the Planning Inspectorate and the Development Control Committee.
3. does not comply with the duty to co-operate.
a. disregards the views of all the stakeholders
4. The VALP is not sound on the grounds that it;
Is not positively prepared, (section 4)
Is not justified, (section 5)
Is not effective, (section 5)
Is not consistent with National Policy, (section 6)

Full text:

I believe that S6. Gypsy, traveler and travelling show people provision and more specifically
Table 4. Oaksview Park, Boarstall. to be unsound as indicated above, and therefore should be removed from the plan.

It should be noted that the content of my representation is not intended as a comment regarding objection to planning consent but merely on the inclusion of this site within the VALP (Vale of Aylesbury Local Plan)

Whilst I acknowledge the need for Gypsy and traveler sites in the district, the allocation of this site is ill-conceived and therefore not sound.

1. The VALP is Unsound
1.1. The site has been occupied for a number of years with temporary or no permission, 5 hearings for planning permission have been heard by the development control committee, all have overwhelmingly found the site unsuitable for permanent occupation. The inspectorate has heard two appeals for the site and again found it as unsuitable for anything but a temporary site until AVDC located a suitable site.
1.2. The plan has identified this site with no reference to the significant number of alternative sites within a 5-mile radius, not only within AVDC, but also the Cherwell district. This oversupply in the vicinity has been demonstrated by this sites under occupancy over the years; to the extent that the owners were sub-letting plots to eastern European economic migrants.
1.3. The site has been refused planning permission on so many occasions in the past why do the authors presume it will be awarded permission in the future?

2. Duty to Co-operate
2.1. The VALP fails to comply with the duty to cooperate as it disregards the views of all the stakeholders, including the consultants and other subject matter experts advising AVDC.
2.2. It disregards the repeated decisions of its own Development Control Committee.
2.3. It disregards the repeated decisions of the Planning Inspectorate.
2.4. It disregards the repeated objections of the Parish Council.
2.5. It disregards repeated objections from the residents adjacent to the site, who have spent many thousands of pounds on additional security measures to minimise the quantity and impact of break-ins and vandalism proven to be perpetrated by the occupants of the site.
2.6. The site lies within a few meters of a Ministry of Defence, live munitions training ground and the close to Bullingdon Prison. The adjacent Cherwell District Council received an application for a site further away from the MOD boundary than this particular site. Following consultation, permission was refused after objection from the MOD and prison. AVDC have not consulted with these parties, or the Military or Civil Police, or the adjoining parishes of Arncott, Murcott and Piddington.

3. Legally Compliant Local Plan
3.1. The VALP fails to be legally compliant while it remains in flagrant disregard of repeated decisions made by the Planning Inspectorate and the Development Control Committee; the latter being made up of elected Councilors. This suggests that employees of AVDC are making policy, not our elected Councilors. This is fundamentally overrides the remit of the elected Councilors.

4. Positively Prepared Local Plan
4.1. The inclusion of this inappropriate site and systemic policy of AVDC over recent years to grant permanent permission to traveller sites it has previously refused permission for, is a clear indication of its own failure to identify appropriate sites; on this basis, the plan cannot possibly be considered to be a positively prepared policy.

5. Justified or Effective Local Plan
5.1. Given the development control committee and inspectorates decisions, the authors of this plan have attempted to now justify the site on the basis of greater regulation of the site. They have done this in full knowledge that the site has flouted conditions imposed upon it, while planning enforcement remains ineffectual.
5.2. The authors of the local plan have failed to comment on the major reason for prior refusals; its dominant and unnatural effect on the open countryside. On this basis, its inclusion cannot be considered as justified or effective.

6. Consistent with National Policy
6.1. The VALP states that the site is for 13 plots. However, the Authors have known since 2005 that the site is actually divided into 20 plots; The assignment of 13 plots is a clear attempt to mislead the Inspector into believing that the site is in compliance with the VALP itself, and National Policy for Gypsy and Traveller sites (refer here: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/457420/Final_planning_and_travellers_policy.pdf)
6.2. The authors have publicly acknowledged non-compliance with local and national policy, and attempted to defend it on the basis of it being the most appropriate "identified" site, i.e. 1 of 1.

The site does not even meet the criteria stated in the VALP itself:

a. It has reasonable access to existing local services and facilities (a. including shops, schools, healthcare and public transport). Sites should either be within or close to existing
sustainable settlements or with good access to major roads and/or public transport

b. Have safe and convenient vehicular access without giving rise to unacceptable impacts on highway safety

c. Be able to achieve a reasonable level of visual and acoustic privacy for both people living
on the site and those living nearby

d. Not have an [sic] significantly adverse impact on environmental assets such as open
countryside, landscapes, the historic environment, biodiversity, waterways, open space and
green infrastructure

e. The size and scale of the site and the number of caravans stationed is appropriate to the
size and density of the local settled community, and does not dominate the nearest settled
community

f. The site should not be located where there is a risk of flooding or be affected by
environmental hazards that may effect [sic] residents [sic] health or welfare

g. The site must be capable of being adequately serviced by drinking water, utilities and
sewerage disposal facilities

h. Sites should remain small in scale - no more normally than 15 pitches on any one site

Object

VALP Proposed Submission

Representation ID: 458

Received: 06/12/2017

Respondent: Mr James D. Stallard

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation:

1. The site does not have planning permission and has been previously judged as unsuitable on numerous occasions.
a. The VALP is in flagrant disregard of repeated decisions made by the Planning Inspectorate and the Development Control Committee.
a. The VALP disregards the views of all the stakeholders, including local residents, local councilors, the Ministry of Defence, Bullingdon Prison, the consultants and other subject matter experts advising AVDC.

Full text:

I believe that S6. Gypsy, traveler and travelling show people provision and more specifically
Table 4. Oaksview Park, Boarstall. to be unsound as indicated above, and therefore should be removed from the plan.

It should be noted that the content of my representation is not intended as a comment regarding objection to planning consent but merely on the inclusion of this site within the VALP (Vale of Aylesbury Local Plan)

Whilst I acknowledge the need for Gypsy and traveler sites in the district, the allocation of this site is ill-conceived and therefore not sound.

1. The VALP is Unsound
1.1. The site has been occupied for a number of years with temporary or no permission, 5 hearings for planning permission have been heard by the development control committee, all have overwhelmingly found the site unsuitable for permanent occupation. The inspectorate has heard two appeals for the site and again found it as unsuitable for anything but a temporary site until AVDC located a suitable site.
1.2. The plan has identified this site with no reference to the significant number of alternative sites within a 5-mile radius, not only within AVDC, but also the Cherwell district. This oversupply in the vicinity has been demonstrated by this sites under occupancy over the years; to the extent that the owners were sub-letting plots to eastern European economic migrants.
1.3. The site has been refused planning permission on so many occasions in the past why do the authors presume it will be awarded permission in the future?

2. Duty to Co-operate
2.1. The VALP fails to comply with the duty to cooperate as it disregards the views of all the stakeholders, including the consultants and other subject matter experts advising AVDC.
2.2. It disregards the repeated decisions of its own Development Control Committee.
2.3. It disregards the repeated decisions of the Planning Inspectorate.
2.4. It disregards the repeated objections of the Parish Council.
2.5. It disregards repeated objections from the residents adjacent to the site, who have spent many thousands of pounds on additional security measures to minimise the quantity and impact of break-ins and vandalism proven to be perpetrated by the occupants of the site.
2.6. The site lies within a few meters of a Ministry of Defence, live munitions training ground and the close to Bullingdon Prison. The adjacent Cherwell District Council received an application for a site further away from the MOD boundary than this particular site. Following consultation, permission was refused after objection from the MOD and prison. AVDC have not consulted with these parties, or the Military or Civil Police, or the adjoining parishes of Arncott, Murcott and Piddington.

3. Legally Compliant Local Plan
3.1. The VALP fails to be legally compliant while it remains in flagrant disregard of repeated decisions made by the Planning Inspectorate and the Development Control Committee; the latter being made up of elected Councilors. This suggests that employees of AVDC are making policy, not our elected Councilors. This is fundamentally overrides the remit of the elected Councilors.

4. Positively Prepared Local Plan
4.1. The inclusion of this inappropriate site and systemic policy of AVDC over recent years to grant permanent permission to traveller sites it has previously refused permission for, is a clear indication of its own failure to identify appropriate sites; on this basis, the plan cannot possibly be considered to be a positively prepared policy.

5. Justified or Effective Local Plan
5.1. Given the development control committee and inspectorates decisions, the authors of this plan have attempted to now justify the site on the basis of greater regulation of the site. They have done this in full knowledge that the site has flouted conditions imposed upon it, while planning enforcement remains ineffectual.
5.2. The authors of the local plan have failed to comment on the major reason for prior refusals; its dominant and unnatural effect on the open countryside. On this basis, its inclusion cannot be considered as justified or effective.

6. Consistent with National Policy
6.1. The VALP states that the site is for 13 plots. However, the Authors have known since 2005 that the site is actually divided into 20 plots; The assignment of 13 plots is a clear attempt to mislead the Inspector into believing that the site is in compliance with the VALP itself, and National Policy for Gypsy and Traveller sites (refer here: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/457420/Final_planning_and_travellers_policy.pdf)
6.2. The authors have publicly acknowledged non-compliance with local and national policy, and attempted to defend it on the basis of it being the most appropriate "identified" site, i.e. 1 of 1.

The site does not even meet the criteria stated in the VALP itself:

a. It has reasonable access to existing local services and facilities (a. including shops, schools, healthcare and public transport). Sites should either be within or close to existing
sustainable settlements or with good access to major roads and/or public transport

b. Have safe and convenient vehicular access without giving rise to unacceptable impacts on highway safety

c. Be able to achieve a reasonable level of visual and acoustic privacy for both people living
on the site and those living nearby

d. Not have an [sic] significantly adverse impact on environmental assets such as open
countryside, landscapes, the historic environment, biodiversity, waterways, open space and
green infrastructure

e. The size and scale of the site and the number of caravans stationed is appropriate to the
size and density of the local settled community, and does not dominate the nearest settled
community

f. The site should not be located where there is a risk of flooding or be affected by
environmental hazards that may effect [sic] residents [sic] health or welfare

g. The site must be capable of being adequately serviced by drinking water, utilities and
sewerage disposal facilities

h. Sites should remain small in scale - no more normally than 15 pitches on any one site

Object

VALP Proposed Submission

Representation ID: 563

Received: 06/12/2017

Respondent: Unknown

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation:

The proposed allocation of Oaksview Park, Boarstall fails all of the necessary criteria for inclusion:

1. The site does not have planning permission and has been previously judged as unsuitable on numerous occasions.
2. The VALP is not legally compliant.
a. The VALP is in flagrant disregard of repeated decisions made by the Planning Inspectorate and the Development Control Committee.
3. The VALP does not comply with the duty to co-operate.
a. The VALP disregards the views of all the stakeholders, including local residents, local councilors, the Ministry of Defence, Bullingdon Prison, the consultants and other subject matter experts advising AVDC.
4. The VALP is not sound on the grounds that it;
a. Is not positively prepared, refer section 4;
b. Is not justified, refer section 5;
c. Is not effective, refer section 5;
d. Is not consistent with National Policy, refer section 6.

Full text:

I believe that S6. Gypsy, traveler and travelling show people provision and more specifically
Table 4. Oaksview Park, Boarstall. to be unsound as indicated above, and therefore should be removed from the plan.

It should be noted that the content of my representation is not intended as a comment regarding objection to planning consent but merely on the inclusion of this site within the VALP (Vale of Aylesbury Local Plan)

Whilst I acknowledge the need for Gypsy and traveler sites in the district, the allocation of this site is ill-conceived and therefore not sound.

1. The VALP is Unsound
1.1. The site has been occupied for a number of years with temporary or no permission, 5 hearings for planning permission have been heard by the development control committee, all have overwhelmingly found the site unsuitable for permanent occupation. The inspectorate has heard two appeals for the site and again found it as unsuitable for anything but a temporary site until AVDC located a suitable site.
1.2. The plan has identified this site with no reference to the significant number of alternative sites within a 5-mile radius, not only within AVDC, but also the Cherwell district. This oversupply in the vicinity has been demonstrated by this sites under occupancy over the years; to the extent that the owners were sub-letting plots to eastern European economic migrants.
1.3. The site has been refused planning permission on so many occasions in the past why do the authors presume it will be awarded permission in the future?

2. Duty to Co-operate
2.1. The VALP fails to comply with the duty to cooperate as it disregards the views of all the stakeholders, including the consultants and other subject matter experts advising AVDC.
2.2. It disregards the repeated decisions of its own Development Control Committee.
2.3. It disregards the repeated decisions of the Planning Inspectorate.
2.4. It disregards the repeated objections of the Parish Council.
2.5. It disregards repeated objections from the residents adjacent to the site, who have spent many thousands of pounds on additional security measures to minimise the quantity and impact of break-ins and vandalism proven to be perpetrated by the occupants of the site.
2.6. The site lies within a few meters of a Ministry of Defence, live munitions training ground and the close to Bullingdon Prison. The adjacent Cherwell District Council received an application for a site further away from the MOD boundary than this particular site. Following consultation, permission was refused after objection from the MOD and prison. AVDC have not consulted with these parties, or the Military or Civil Police, or the adjoining parishes of Arncott, Murcott and Piddington.

3. Legally Compliant Local Plan
3.1. The VALP fails to be legally compliant while it remains in flagrant disregard of repeated decisions made by the Planning Inspectorate and the Development Control Committee; the latter being made up of elected Councilors. This suggests that employees of AVDC are making policy, not our elected Councilors. This is fundamentally overrides the remit of the elected Councilors.

4. Positively Prepared Local Plan
4.1. The inclusion of this inappropriate site and systemic policy of AVDC over recent years to grant permanent permission to traveller sites it has previously refused permission for, is a clear indication of its own failure to identify appropriate sites; on this basis, the plan cannot possibly be considered to be a positively prepared policy.

5. Justified or Effective Local Plan
5.1. Given the development control committee and inspectorates decisions, the authors of this plan have attempted to now justify the site on the basis of greater regulation of the site. They have done this in full knowledge that the site has flouted conditions imposed upon it, while planning enforcement remains ineffectual.
5.2. The authors of the local plan have failed to comment on the major reason for prior refusals; its dominant and unnatural effect on the open countryside. On this basis, its inclusion cannot be considered as justified or effective.

6. Consistent with National Policy
6.1. The VALP states that the site is for 13 plots. However, the Authors have known since 2005 that the site is actually divided into 20 plots; The assignment of 13 plots is a clear attempt to mislead the Inspector into believing that the site is in compliance with the VALP itself, and National Policy for Gypsy and Traveller sites (refer here: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/457420/Final_planning_and_travellers_policy.pdf)
6.2. The authors have publicly acknowledged non-compliance with local and national policy, and attempted to defend it on the basis of it being the most appropriate "identified" site, i.e. 1 of 1.

The site does not even meet the criteria stated in the VALP itself:

a. It has reasonable access to existing local services and facilities (a. including shops, schools, healthcare and public transport). Sites should either be within or close to existing
sustainable settlements or with good access to major roads and/or public transport

b. Have safe and convenient vehicular access without giving rise to unacceptable impacts on highway safety

c. Be able to achieve a reasonable level of visual and acoustic privacy for both people living
on the site and those living nearby

d. Not have an [sic] significantly adverse impact on environmental assets such as open
countryside, landscapes, the historic environment, biodiversity, waterways, open space and
green infrastructure

e. The size and scale of the site and the number of caravans stationed is appropriate to the
size and density of the local settled community, and does not dominate the nearest settled
community

f. The site should not be located where there is a risk of flooding or be affected by
environmental hazards that may effect [sic] residents [sic] health or welfare

g. The site must be capable of being adequately serviced by drinking water, utilities and
sewerage disposal facilities

h. Sites should remain small in scale - no more normally than 15 pitches on any one site


If your representation is more than 100 words, please provide a brief summary here:

The proposed provision for Gypsy, traveler and travelling show people, described in section 6, table 4 (Oaksview Park, Boarstall) of the VALP fails all of the necessary criteria for inclusion:

1. The site does not have planning permission and has been previously judged as unsuitable on numerous occasions.
2. The VALP is not legally compliant.
a. The VALP is in flagrant disregard of repeated decisions made by the Planning Inspectorate and the Development Control Committee.
3. The VALP does not comply with the duty to co-operate.
a. The VALP disregards the views of all the stakeholders, including local residents, local councilors, the Ministry of Defence, Bullingdon Prison, the consultants and other subject matter experts advising AVDC.
4. The VALP is not sound on the grounds that it;
a. Is not positively prepared, refer section 4;
b. Is not justified, refer section 5;
c. Is not effective, refer section 5;
d. Is not consistent with National Policy, refer section 6.

Please specify the changes needed to be made to make the Plan sound/legally compliant:

1. The inclusion of this site in the VALP should be immediately withdrawn.
2. A condition must be placed on acceptance of the revised VALP such that;
a. An alternative, appropriate site is identified and secured by AVDC within a timescale defined by the Planning Inspectorate with appropriate penalties for continued failure.






Object

VALP Proposed Submission

Representation ID: 733

Received: 12/12/2017

Respondent: Mr Lawrence Odell

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation:

Object to S6 and inclusion of Oakview Park, Boarstall as a allocation. Permanent permission has been refused on this site numerous times, the views of the development control committee, PINs, Parish Council and locals have been ignored. There is a oversupply of sites in the vicinity. Its close to the MOD site and prison, other sites have been objected to by them. The site has a dominant and unnatural impact on the open countryside. There are 20 plots on site, not 13. Doesn't meet the criteria.

Full text:

I believe that S6. Gypsy, traveler and travelling show people provision and more specifically
Table 4. Oaksview Park, Boarstall. to be unsound as indicated above, and therefore should be removed from the plan.

It should be noted that the content of my representation is not intended as a comment regarding objection to planning consent but merely on the inclusion of this site within the VALP (Vale of Aylesbury Local Plan)

Whilst I acknowledge the need for Gypsy and traveler sites in the district, the allocation of this site is ill-conceived and therefore not sound.

1. The VALP is Unsound
1.1. The site has been occupied for a number of years with temporary or no permission, 5 hearings for planning permission have been heard by the development control committee, all have overwhelmingly found the site unsuitable for permanent occupation. The inspectorate has heard two appeals for the site and again found it as unsuitable for anything but a temporary site until AVDC located a suitable site.
1.2. The plan has identified this site with no reference to the significant number of alternative sites within a 5-mile radius, not only within AVDC, but also the Cherwell district. This oversupply in the vicinity has been demonstrated by this sites under occupancy over the years; to the extent that the owners were sub-letting plots to eastern European economic migrants.
1.3. The site has been refused planning permission on so many occasions in the past why do the authors presume it will be awarded permission in the future?

2. Duty to Co-operate
2.1. The VALP fails to comply with the duty to cooperate as it disregards the views of all the stakeholders, including the consultants and other subject matter experts advising AVDC.
2.2. It disregards the repeated decisions of its own Development Control Committee.
2.3. It disregards the repeated decisions of the Planning Inspectorate.
2.4. It disregards the repeated objections of the Parish Council.
2.5. It disregards repeated objections from the residents adjacent to the site, who have spent many thousands of pounds on additional security measures to minimise the quantity and impact of break-ins and vandalism proven to be perpetrated by the occupants of the site.
2.6. The site lies within a few meters of a Ministry of Defence, live munitions training ground and the close to Bullingdon Prison. The adjacent Cherwell District Council received an application for a site further away from the MOD boundary than this particular site. Following consultation, permission was refused after objection from the MOD and prison. AVDC have not consulted with these parties, or the Military or Civil Police, or the adjoining parishes of Arncott, Murcott and Piddington.

3. Legally Compliant Local Plan
3.1. The VALP fails to be legally compliant while it remains in flagrant disregard of repeated decisions made by the Planning Inspectorate and the Development Control Committee; the latter being made up of elected Councilors. This suggests that employees of AVDC are making policy, not our elected Councilors. This is fundamentally overrides the remit of the elected Councilors.

4. Positively Prepared Local Plan
4.1. The inclusion of this inappropriate site and systemic policy of AVDC over recent years to grant permanent permission to traveller sites it has previously refused permission for, is a clear indication of its own failure to identify appropriate sites; on this basis, the plan cannot possibly be considered to be a positively prepared policy.

5. Justified or Effective Local Plan
5.1. Given the development control committee and inspectorates decisions, the authors of this plan have attempted to now justify the site on the basis of greater regulation of the site. They have done this in full knowledge that the site has flouted conditions imposed upon it, while planning enforcement remains ineffectual.
5.2. The authors of the local plan have failed to comment on the major reason for prior refusals; its dominant and unnatural effect on the open countryside. On this basis, its inclusion cannot be considered as justified or effective.

6. Consistent with National Policy
6.1. The VALP states that the site is for 13 plots. However, the Authors have known since 2005 that the site is actually divided into 20 plots; The assignment of 13 plots is a clear attempt to mislead the Inspector into believing that the site is in compliance with the VALP itself, and National Policy for Gypsy and Traveller sites (refer here: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/457420/Final_planning_and_travellers_policy.pdf)
6.2. The authors have publicly acknowledged non-compliance with local and national policy, and attempted to defend it on the basis of it being the most appropriate "identified" site, i.e. 1 of 1.

The site does not even meet the criteria stated in the VALP itself:

a. It has reasonable access to existing local services and facilities (a. including shops, schools, healthcare and public transport). Sites should either be within or close to existing
sustainable settlements or with good access to major roads and/or public transport

b. Have safe and convenient vehicular access without giving rise to unacceptable impacts on highway safety

c. Be able to achieve a reasonable level of visual and acoustic privacy for both people living
on the site and those living nearby

d. Not have an [sic] significantly adverse impact on environmental assets such as open
countryside, landscapes, the historic environment, biodiversity, waterways, open space and
green infrastructure

e. The size and scale of the site and the number of caravans stationed is appropriate to the
size and density of the local settled community, and does not dominate the nearest settled
community

f. The site should not be located where there is a risk of flooding or be affected by
environmental hazards that may effect [sic] residents [sic] health or welfare

g. The site must be capable of being adequately serviced by drinking water, utilities and
sewerage disposal facilities

h. Sites should remain small in scale - no more normally than 15 pitches on any one site

Object

VALP Proposed Submission

Representation ID: 829

Received: 12/12/2017

Respondent: Unknown

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation:

S6. Gypsy, traveler and travelling show people provision and more specifically
Table 4. Oaksview Park, Boarstall. to be unsound as indicated above, and therefore should be removed from the plan.

Full text:

I believe that S6. Gypsy, traveler and travelling show people provision and more specifically
Table 4. Oaksview Park, Boarstall. to be unsound as indicated above, and therefore should be removed from the plan.

It should be noted that the content of my representation is not intended as a comment regarding objection to planning consent but merely on the inclusion of this site within the VALP (Vale of Aylesbury Local Plan)

Whilst I acknowledge the need for Gypsy and traveler sites in the district, the allocation of this site is ill-conceived and therefore not sound.

1. The VALP is Unsound
1.1. The site has been occupied for a number of years with temporary or no permission, 5 hearings for planning permission have been heard by the development control committee, all have overwhelmingly found the site unsuitable for permanent occupation. The inspectorate has heard two appeals for the site and again found it as unsuitable for anything but a temporary site until AVDC located a suitable site.
1.2. The plan has identified this site with no reference to the significant number of alternative sites within a 5-mile radius, not only within AVDC, but also the Cherwell district. This oversupply in the vicinity has been demonstrated by this sites under occupancy over the years; to the extent that the owners were sub-letting plots to eastern European economic migrants.
1.3. The site has been refused planning permission on so many occasions in the past why do the authors presume it will be awarded permission in the future?

2. Duty to Co-operate
2.1. The VALP fails to comply with the duty to cooperate as it disregards the views of all the stakeholders, including the consultants and other subject matter experts advising AVDC.
2.2. It disregards the repeated decisions of its own Development Control Committee.
2.3. It disregards the repeated decisions of the Planning Inspectorate.
2.4. It disregards the repeated objections of the Parish Council.
2.5. It disregards repeated objections from the residents adjacent to the site, who have spent many thousands of pounds on additional security measures to minimise the quantity and impact of break-ins and vandalism proven to be perpetrated by the occupants of the site.
2.6. The site lies within a few meters of a Ministry of Defence, live munitions training ground and the close to Bullingdon Prison. The adjacent Cherwell District Council received an application for a site further away from the MOD boundary than this particular site. Following consultation, permission was refused after objection from the MOD and prison. AVDC have not consulted with these parties, or the Military or Civil Police, or the adjoining parishes of Arncott, Murcott and Piddington.

3. Legally Compliant Local Plan
3.1. The VALP fails to be legally compliant while it remains in flagrant disregard of repeated decisions made by the Planning Inspectorate and the Development Control Committee; the latter being made up of elected Councilors. This suggests that employees of AVDC are making policy, not our elected Councilors. This is fundamentally overrides the remit of the elected Councilors.

4. Positively Prepared Local Plan
4.1. The inclusion of this inappropriate site and systemic policy of AVDC over recent years to grant permanent permission to traveller sites it has previously refused permission for, is a clear indication of its own failure to identify appropriate sites; on this basis, the plan cannot possibly be considered to be a positively prepared policy.

5. Justified or Effective Local Plan
5.1. Given the development control committee and inspectorates decisions, the authors of this plan have attempted to now justify the site on the basis of greater regulation of the site. They have done this in full knowledge that the site has flouted conditions imposed upon it, while planning enforcement remains ineffectual.
5.2. The authors of the local plan have failed to comment on the major reason for prior refusals; its dominant and unnatural effect on the open countryside. On this basis, its inclusion cannot be considered as justified or effective.

6. Consistent with National Policy
6.1. The VALP states that the site is for 13 plots. However, the Authors have known since 2005 that the site is actually divided into 20 plots; The assignment of 13 plots is a clear attempt to mislead the Inspector into believing that the site is in compliance with the VALP itself, and National Policy for Gypsy and Traveller sites (refer here: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/457420/Final_planning_and_travellers_policy.pdf)
6.2. The authors have publicly acknowledged non-compliance with local and national policy, and attempted to defend it on the basis of it being the most appropriate "identified" site, i.e. 1 of 1.

Support

VALP Proposed Submission

Representation ID: 882

Received: 14/12/2017

Respondent: Great & Little Kimble cum Marsh Parish Council

Agent: Mr Neil Homer

Representation:

We welcome the absence of any site allocations for this purpose on land adjoining our Parish. There are already a number of pitches in this remote, small area and this is considered to be sufficient, without undermining any further the openness of the gap between the villages of our Parish and the new Garden Town, within which they lie, or increasing the demand for local services that are absent in our rural area.

Full text:

We welcome the absence of any site allocations for this purpose on land adjoining our Parish. There are already a number of pitches in this remote, small area and this is considered to be sufficient, without undermining any further the openness of the gap between the villages of our Parish and the new Garden Town, within which they lie, or increasing the demand for local services that are absent in our rural area.

Object

VALP Proposed Submission

Representation ID: 986

Received: 13/12/2017

Respondent: Arncott Parish Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

Object to the allocation of Oaksview Park, Boarstall. It is a isolated site in a prominent position in open countryside. It overlooks residential properties and size is not in keeping with the appearance and character of that open and rural area. There are 19 pitches on the site plan, not 13. It has poor access to services, Arncott is nearest village, there are no footpaths or public transport and Arncott only has limited facilities.

The Oaksview Park site has been unlawfully occupied since June 2004. Several applications have been made, all being refused except for temporary permission in 2009.

Full text:

From email sent 2/12/17: Arncott Parish Council objects strongly to the proposal in the AVLP to
site a permanent gypsy and traveller site within a few hundred metres
of Arncott Village. While Arncott is classified as a category A
village within the CDC Local Plan, planners have acknowledged that it
does not have the facilities which would normally be expected of a
village of this category - it has a pub and a shop, but no school and
the nearest doctor's surgery open on a regular basis is in Bicester.
The Village has a limited and irregular bus service, and expects bus
users to leave the bus while it goes into St George's Barracks and
wait in Arncott for some 20 minutes until it resumes its journey.
A site in this location therefore is not sustainable other than in a
private car.

From emailed response form 13/12/17:
With reference to the proposed submission of the Vale of Aylesbury Local Plan 2013 - 2033 dated November 2017, policy S6, page 51, table 4.
Whilst Arncott Parish Council acknowledge the national need to provide suitable sites for the Gypsy and Traveller communities, it disagrees with and is strongly opposed to the proposed inclusion in the local plan document of Oaksview Park, Boarstall being considered as an appropriate and sustainable site for the possible permanent residence of Gypsies, Travellers and / or Travelling Showpeople.
Oaksview Park is an isolated site located in a prominent position in open countryside. The site overlooks local residential properties and its presence and size is not in keeping with the appearance and character of that open and rural area. Page 51, table 4 in the proposed plan indicates the potential number of pitches to be allocated as thirteen. Previous planning applications and submitted site plans will show the number of pitches as nineteen. The site can hardly be considered as small scale.
The site has very poor sustainability. It does not have ready access to local schools, public transport, health centres, shops, other services or facilities. Arncott is the nearest village to the site and is approximately 1/2 - ¾ mile distant. There are no footpaths from the site into the village. The site does not have a public transport service.

Although Arncott village is classified as a category 'A' village within the CDC Local Plan, the planners acknowledge that the village does not have the facilities that a category 'A' village would be expected to have. Arncott has a limited bus service, a public house, a small hotel and a shop. The nearest school is in the village of Ambrosden. The nearest health centre that is open on a regular basis is in Bicester.
The Oaksview Park site has been unlawfully occupied since June 2004. Since that time several applications for planning permission have been submitted together with the many associated documents. All of the applications and associated documents have been considered at length by AVDC planning control. With the exception of temporary permission being granted in 2009 for a period of three years, all other applications have been refused - the latest refusal being AVDC document 16/03442/APP dated 31st August 2017.
AVDC's own planning control department have consistently refused to grant planning permission to the site for each application and the reasons for each refusal are typically the same.

Object

VALP Proposed Submission

Representation ID: 1903

Received: 13/12/2017

Respondent: Thornborough Parish Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

* Thornborough Parish Council support Nash PC's concerns, given in detail in their submission, about the needs of the Gypsy and Traveller community.

Full text:

Thornborough Parish Council response to the VALP

* The overall numbers of new houses for the Vale is unsustainable without major infrastructure changes and not enough thought has been taken for major infrastructure changes. Thornborough Parish Council are not confident that what has been proposed will cope with the extra people, traffic, demand on services etc.

* Thornborough Parish Council supports allocating development to settlements on a "case by case basis", rather than as generic percentages based on hierarchy classification, but thinks that not enough evidence is presented in the Plan to explain how the actual numbers have been derived.

* Thornborough Parish Council are concerned about current plans that will have an impact on sustainability. There are currently several developments in the north of Buckinghamshire that will not count towards the Aylesbury Vale Housing numbers but will have an impact on local roads leading to more congestion and a worsening living environment. New housing estates should be environmentally sustainable and ecologically rich, for example hard surfacing should be permeable to allow water to permeate to the water-table and not be lost as run-off with the consequent effect of flooding. This needs strong and robust policies to force developers to design well.

* The Government emphasis on denser housing stock will inevitably lead to smaller and smaller amenity space which will impact on health and well-being, this should be addressed. It will also put pressure on smaller sites to take houses in backyards and gardens. This could have an adverse impact on the nature of the historic environment, the local ecology (gardens are often refuges for wildlife and their loss would be detrimental, and the loss of hedgerows which are ecologically significant as highways, a food source and protection. The natural and historic environment also need protection with robust policies.

* Neighbourhood Plans need to be given due weight in Policy. Thornborough Parish Council believes that the Plan lacks clarity on the status of Neighbourhood Plans made already within the District. Section 8 deals only with new NDPs coming forward. There also appears to be a lack of consistency in approach to NDPs throughout. The relationship between the VALP and existing NDPs is not clear and therefore not robust.

* Co-operation between neighbouring districts - There appears to be an assumption that unmet needs identified from other neighbouring districts to the south can be met by housing allocations in the north of the district,, while there also appears to have been little consultation or co-operation with neighbouring district councils to the north - South Oxfordshire District Council; Cherwell District Council; South Northants District Council and Milton Keynes Council.

* Housing - Thornborough Parish Council believe that the figure of 25% Affordable Housing is not enough has not taken into account other evidence such as rising figures in Housing Register. There is also not enough consideration given to housing mix.

* Enforcement Issues. Throughout the VALP there is no mention of enforcement as a topic; the word appears twice, once in relation to listed building, the other relating to work/living spaces. The whole planning policy is merely an ambition unless there is some form of effective enforcement so it is surprising that there is no policy at all relating to it. This has been a continuing issue in Thornborough for many years with notable lack of enforcement at sites with un-approved building.
* In section 11.34 it states that Aylesbury Vale is in a state of Water stress, meaning it has poor overall water quality and quantity of water resources hindering the achievement of the Good status under the Water Framework Directive. This is a major issue that must be addressed and the VALP needs a more definitive plan regarding water stress. There is a considerable concern that even limited development in many older settlements will put strain on drainage and water services, which latter is not fully addressed.

* Employment Opportunities - the lack of new employment opportunities for the increased number of people in the planned dwellings will increase commuting and this congestion and air pollution throughout the Vale. More thought needs to be given to this issue.

* Thornborough Parish Council wishes to see this Plan proceed and meet the deadline of submission to DCLG by 31 March, as failure would mean another 3 years and a new Plan would have to be based on a 55% uplift in housing need; in that time everywhere would continue to be vulnerable to speculative developers

* Thornborough Parish Council note that there is no plan for dealing with the possible impact of the Oxford- Cambridge expressway. We assume that this will necessitate a review of the VALP once the route is known.

* Thornborough Parish Council support Nash PC's concerns, given in detail in their submission, about the needs of the Gypsy and Traveller community.

Support

VALP Proposed Submission

Representation ID: 2091

Received: 14/12/2017

Respondent: Historic England

Representation:

we note the intention to allocate additional pitches for Gypsies, Travellers and Travelling Showpeople. According to our records, none of the proposed sites would be likely to affect any designated heritage assets.

Full text:

See attachment for full representation.

Object

VALP Proposed Submission

Representation ID: 2390

Received: 14/12/2017

Respondent: The Environment Agency

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

Boarstall - Traveller site

This site does not appear to have a sewage connection. The according to geological
maps of the area, the underling strata is also is likely to be relatively low permeability,
as such it is not clear if there are options for disposal of foul waters to ground. We
expect the groundwater aquifers to be protected from pollution.

Full text:

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

Object

VALP Proposed Submission

Representation ID: 2643

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:

In addition to defined Gypsy's and Travellers and Travelling Showpeople, the policy seeks to provide additional pitches for all 'unknown households' i.e all of those where it is unknown whether the occupants meet the planning definition of Gypsy's and Travellers or Travelling Showpeople. This is contrary to the Council's own evidence base and national policy.

Full text:

1. Policy S6 of the Local Plan establishes a requirement for 84 (net) additional pitches for travelling or unknown Gypsies and Travellers and two (net) additional plots for travelling or unknown Travelling Showpeople.
2. National policy in the NPPF is clear at paragraph 4 that in terms of providing for the needs of Gypsy's and Travellers that 'This Framework should be read in conjunction with the Government's planning policy for traveller sites'. And at Footnote 34 that 'The Planning Policy for traveller sites sets out how travellers' accommodation needs should be assessed'.
3. The Government's definition of Gypsy's and Travellers is contained within its document 'Planning Policy for Traveller Sites' (PPTS) (August 2015). As referenced in the supporting text to Policy S6, the Government definition of Gypsy's and Travellers was amended within this document to specifically exclude 'Persons...who have ceased to travel permanently'. The PPTS definition must therefore be the starting point for assessing the need for additional Gypsy and Traveller pitches within the District.
4. ORS were commissioned to produce the Aylesbury Vale, Chiltern, South Bucks and Wycombe 'Gypsy Traveller Accommodation Assessment' (GTAA) in order to provide a robust assessment of current and future need for Gypsy, traveller and Travelling Showpeople accommodation within those authorities. The GTAA outlines that of those interviewed for the study, 4 Gypsy and Traveller households met the most up to date planning definition within Aylesbury Vale and on that basis, there is a need for just 8 additional Gypsy and Traveller pitches within the District.

5. A further 20 households did not meet the planning definition, whilst the status of a further 87 is unknown, either because they refused to be interviewed or could not be contacted. There were no identified Travelling Showpeople.
6. The GTAA confirms at paragraph 7.28 that if all of the unknown households were to meet the planning definition, additional need could rise by a further 76 pitches. However, the GTAA also outlines that ORS data has been collected nationally from over 1,800 household interviews since the changes to the PPTS were introduced in 2015. This data confirms that of those interviewed approximately 10% of households met the correct planning definition of Gypsy's and Travellers, whilst in some local authorities (most notably in London), that percentage falls to zero.
7. On that basis it is concluded in the GTAA at Paragraph 7.27 that only a small proportion of the unknown households will require new pitches when it states that:
''This would suggest that it is likely that only a small proportion of the potential need identified from these households will need new Gypsy and Traveller pitches, and that the needs of the majority will need to be addressed through other means' (emphasis added).
8. The GTAA discusses further the treatment of unknown households at Paragraph 1.9 when it states that:
''Councils will need to carefully consider how to address the needs associated with unknown Travellers as it is unlikely that all of this need will need to be addressed through the provision of conditioned Gypsy or Traveller pitches. In terms of Local Plan policies the Councils could consider the use of a specific site allocation/protection policy for those households that do meet the planning definition, together with a criteria-based policy (as suggested in PPTS) for any unknown households that do provide evidence that they meet the planning definition'' (emphasis added).
9. And further at paragraph 1.22 that:
'Only the need from those households who meet the planning definition and from those of the unknown households who subsequently demonstrate that they meet it should be considered as need arising from the GTAA' (emphasis added).

10. The Council's approach to the provision of Gypsy and Traveller pitches is outlined in the supporting text and at Table 4, which identifies a total of 69 additional pitches for Gypsy's and Travellers. Table 6 identifies 2 additional pitches for Travelling Showpeople. It suggests that the proposed allocations will meet the needs for all of the 'unknowns' for the first 10 years of the Plan period. A further 8 pitches are planned for later in the Plan period so that in total 76 additional pitches would be provided - sufficient to meet in full the maximum possible requirement for 'unknown' households. We fundamentally object to this approach which is contrary to the Council's own evidence base in the form of the GTAA and the NPPF.
11. Based on its own evidence base, the Council has incorrectly and unnecessarily sought to over-provide Gypsy and Traveller pitches to meet the needs of all 'unknown' households. Instead the Council should plan for no more than the 8 pitches known to be required by those meeting the Government's own definition of Gypsy's Travellers and for those 'unknown' households that subsequently demonstrate that they meet the definition. ORS evidence suggests that this is likely to be around 10%. This would result in a further 8 pitches for Gypsy's and Travellers and only 1 for Travelling Showpeople, i.e. 17 additional pitches in total.
12. In terms of providing additional pitches, paragraph 1.8 of the GTAA suggests that:
''The need arising from households that meet the planning definition should be addressed through site allocation/intensification/expansion policies. Consideration will also need to be given to the allocation of pitches on public sites''.
13. Table 4 shows clearly that the true number of additional pitches could comfortably be accommodated by expanding or intensifying provision on a small number of existing sites. Policy D10 outlines a range of criteria that Gypsy and Traveller sites should meet, including safe and convenient vehicular access (criterion b.) access to services (criterion g.) and a maximum of size of 15 pitches (criterion h.) A number of the existing sites identified at Table 4 could be expanded without exceeding the maximum suggested figure of 15 pitches and furthermore, it is clear that the consented sites already comply with the remaining criteria at Policy D10 including access to services etc.

4
Changes Sought
14. Amend Policy S6 to accurately reflect the Council's won evidence base, making it clear that no more than 16 pitches for Gypsy's and Travellers and 1 for Travelling Showpeople will be allocated within the Plan. The Council's strategy for the provision of this significantly reduced number of pitches should be to provide them on expanded / intensified existing sites which already meet the locational requirements of Policy D10.