Aylesbury Vale Area

S9 Monitoring and review

Showing comments and forms 1 to 21 of 21

Object

VALP Proposed Submission

Representation ID: 687

Received: 13/12/2017

Respondent: Whaddon Parish Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

Unmet housing needs should be located in the most sustainable area nearest the area of need , and not just simply 'dumped' in the areas of least resistance.

Full text:

Policy S9 WPC object to sub heading b. Aylesbury Vale is bounded by eight other local authority areas, and this policy as worded is an open invitation to for authorities to use AVDC as a 'dumping ground' for unmet housing needs if other authorities can find justifiable ways of limiting or fixing the number of houses that can be allocated in their own plans. WPC use Wycombe as an example who appear to be unjustly lowering their development densities by simply using AONB and Green belt landscape constraints as justification. Additionally, If any alternative major development site is presented or further promoted post adoption of this plan, then an appropriate sustainability exercise must be undertaken based on any new information that has come forward since - i.e. approved route of Oxford - Cambridge Expressway. It is insufficient to just accept any new site simply because it might be available - it must be properly considered in the light of any new strategic circumstance.

Object

VALP Proposed Submission

Representation ID: 789

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? Yes

Representation:

Bovis Homes object to Policy S9, 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 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 positive commitment in Policy S9 to undertake a review of the Local Plan in the stated circumstances is welcomed.

However, the inclusion of Policy S9 is not an appropriate or effective response to the fundamental matters of soundness set out in the submitted objections to Policies S2 and S3 in terms of the identification of housing needs, the spatial strategy and the housing land supply. Moreover, such a "commitment" to a Review cannot be enforced if the Council decide, for whatever reason, not to honour the commitment in the policy and the identified development needs will not then be addressed. Those matters must, therefore, be directly addressed now before the Local Plan can be found sound.

Notwithstanding that, a key theme of the NPPF and its presumption in favour of sustainable development is the importance of having an up to date Local Plan (paras 12, 17 & 209). The Local Plan needs to be underpinned by an up to date evidence, and the assessment of housing needs in the Borough and wider HMAs is fundamental to that. The policy should, therefore, also include a specific reference to a review being triggered by the emergence of new evidence of housing need indicating that further development allocations are required.

Soundness:
For the reasons set out above, Bovis Homes object to Policy S9, 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 inconsistent with national policy in that it does not fully reflect the Government's priorities and policies in terms of enabling sustainable development.

Object

VALP Proposed Submission

Representation ID: 915

Received: 14/12/2017

Respondent: Chiltern Area of Outstanding Natural Beauty Conservation Board

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

The Chilterns Conservation Board is concerned that this policy provides so readily for the undermining of the development plan. Development should be plan-led. It should not be the case that a single policy becoming out of date because of a national policy change, or a single indicator shown not to be not achieving the Plan's objectives, or the slow delivery of a single site in the trajectory, bins the whole plan.

Full text:

The Chilterns Conservation Board is concerned that this policy provides so readily for the undermining of the development plan. Development should be plan-led. It should not be the case that a single policy becoming out of date because of a national policy change, or a single indicator shown not to be not achieving the Plan's objectives, or the slow delivery of a single site in the trajectory, bins the whole plan.

Object

VALP Proposed Submission

Representation ID: 998

Received: 14/12/2017

Respondent: Revera Limited

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation:

upon adoption of VALP (even assuming housing requirement remains as proposed) there will have been under-delivery in almost every year since 2013/14 with needs across the HMA falling to Aylesbury Vale but not having been met. Upon adoption they will need to apply a 20% buffer to afford the appropriate weight to housing proposals due to significant shortfall in provision across the HMA since 2013.
Effect of the application of necessary 20% buffer on adoption would result in a five-year land supply shortfall of circa 600 dwellings. This needs to be addressed within VALP through identification of additional deliverable allocations.

Full text:

Please see attachments

Paragraph 3.80 suggests that there is not a record of persistent under-delivery in Aylesbury Vale and that accordingly it is appropriate to apply a 5% buffer.
The Council assess the record of delivery against the objectively assessed need for Aylesbury Vale in isolation, which is the correct approach prior to the confirmation of the contribution to the unmet needs of neighbouring authorities through the VALP examination. Table 2 of the Five-Year Housing Land Supply Position Statement, August 2017 identifies that whilst there was under-delivery in the majority of years up until 2012/13, the recent record of delivery justifies the application of a 5% buffer.
However, upon adoption of the VALP (even assuming that the housing requirement remains as proposed) there will have been under-delivery in almost every year since 2013/14 with the needs across the HMA falling to Aylesbury Vale but not having been met. Accordingly, upon adoption there will be a necessity to apply a 20% buffer to afford the appropriate weight to housing proposals given the significant shortfall in provision across the HMA since 2013.
The effect of the application of the necessary 20% buffer on adoption would result in a five-year land supply shortfall of circa 600 dwellings. This will need to be addressed within the VALP through the identification of additional deliverable allocations.
Policy S9 (Monitoring and review)

Paragraph 1.7 of the Vale of Aylesbury Local Plan (VALP) suggests that Government policy is to deliver 250,000 homes per annum nationally. However, this figure is not identified in Government policy. The most recent evidence of the required number of homes was identified as at least 300,000 new homes per annum in the 'Building More Homes' report to the House of Lords Select Committee on Economic Affairs in July 2016. The Government have responded to this evidence (and older assessments including the Barker Report) and are currently consulting on a national distribution to deliver at least 266,000 new homes per annum nationally. The reference in paragraph 1.7 therefore not only conflicts with the available evidence, it also suggests that the VALP has been prepared with the objective of delivering a level of housing below that required nationally.

Paragraph 1.8 continues to identify a requirement of 19,400 new homes to respond to the needs of Aylesbury Vale (excluding any contributions to the unmet needs of neighbouring authorities). This figure is based upon the Buckinghamshire Housing and Economic Development Needs Assessment (HEDNA) Update Addendum, September 2017 which contains corrections to the Buckinghamshire HEDNA Update: Final Report, December 2016.
Paragraph 47 of the National Planning Policy Framework (NPPF) identifies that Local Planning Authorities (LPAs) should use their evidence base to ensure that their Local Plan meets the full, objectively assessed need (OAN) for the Housing Market Area (HMA) rather than an LPA boundary (unless they are coterminous). This has been underlined in several legal judgments1. This is necessary to ensure that account is taken of the inter-relationships between the various LPAs and a consistent approach is taken to these. However, the HEDNA assesses the OAN for each LPA in isolation, using different assumptions for each. The necessary result of this inconsistency means that the OAN has not been established for the HMA, contrary to the NPPF.
It is also important to note that the Department for Communities and Local Government (DCLG) has recently consulted on a standardised methodology for identifying the local housing need. This has arisen from the Local Plans Expert Group and the Housing White Paper, both of which were subject to consultation, as well as from professional input from a wide range of experts including the Planning Inspectorate and the Bar.

Paragraph 1.11 identifies that there is insufficient capacity to meet the OAN in the areas south of Aylesbury Vale. In the following paragraph 1.12, there is calculated to be an unmet need of 8,000 homes.
However, this is all predicated on the OAN identified in the HEDNA which adopts inconsistent and negative assumptions, contrary to the available evidence to reduce the OAN. The population is growing far faster than anticipated by the latest sub-national population projections, and yet even if the OAN was calculated on the basis of these population projections this would produce an unmet need of 8,965 homes (based on the OAN of 27,065 for the remainder of Buckinghamshire (= 51,051 - 23,986) and the capacity of 18,100 homes identified in the Memorandum of Understanding, July 2017).
Furthermore, the Luton Local Plan was adopted in November 2017 and this identifies that there is a need for 400 dwellings which relates to Aylesbury Vale, which is not being addressed elsewhere.
As a result, the VALP should make provision for at least 33,350 homes to address the rounded OAN (of 24,000), the rounded unmet need (of 8,950) and the unmet need of Luton (of 400). These figures will increase significantly, once the standardised methodology becomes part of national policy and so additional provision should be supported or planned for (including through the early review).
This compares to the identified housing requirement in paragraph 1.12 of 27,400 homes. It is therefore clear, that even if the VALP is submitted in advance of the revised NPPF, it will contain a housing requirement that is 5,950 homes short of meeting the OAN across the HMA (unless other sites can be identified across the remainder of Buckinghamshire to contribute to this unmet need). However, in paragraph 3.17 it is identified that it is expected that 28,830 homes will be delivered in the plan period, which reduces the shortfall to 4,334 homes.

Policy S2 makes provision for a total of 27,400 homes which is significantly below the minimum OAN of 33,350. Therefore additional mechanisms will need to be identified to address the resultant shortfall. This should include the identification of additional sites now as well as the identification of new settlements through the proposed early review.
Policy S2 identifies that the primary focus of strategic levels of growth will be at Aylesbury, Buckingham, Winslow, Wendover and Haddenham. It then continues to identify that growth adjacent to Milton Keynes will also be allocated. The Policy also identifies that development at medium villages, including Bierton, will be at a scale in keeping with the local character and setting.
Whilst this approach is supported, as set out in our representations to Policies S3 and D2, our client retains an objection to the "downgrading" of Bierton to a medium village which is clearly a sustainable location in close proximity to Aylesbury and to other new development, i.e. Land East of Aylesbury (Kingsbrook). Bierton should therefore be reclassified to a "larger village" as originally assessed. If the Council are minded to maintain the classification of Bierton as a medium village the characteristics and context of the settlement should be recognised with a more appropriate level of growth than that currently proposed in the VALP.

Table 2 identifies the proposed settlement hierarchy and housing development based on the proposals
of Policy S2.
Paragraph 3.20 identifies that the settlement hierarchy including the ranking of settlements identified in
the Settlement Hierarchy Assessment, September 2017, forms the basis of the proposed distribution
between settlements.
The Settlement Hierarchy Assessment, September 2017 identifies that Bierton (which meets 6 criteria)
is more sustainable than Stewkley (5 criteria) and equally as sustainable as Cheddington, Great
Horwood, Maids Moreton, Marsh Gibbon, Newton Longville and Weston Turville, and yet each and every
one of these settlements are proposed to receive greater levels of growth.
Indeed, Table 2 indicates that 101 dwellings have already been permitted in the less sustainable
settlement of Stewkley which compares to the 23 permitted in Bierton. This provides a strong indication
that Bierton should receive (or at the very least be allowed to receive) a level of growth commensurate
with its sustainability, in excess of that which has already been proved to be sustainable at the less
sustainable settlement of Stewkley.
Similarly, in some of the equally sustainable settlements, namely Maids Moreton, Marsh Gibbon and
Newton Longville, the number of dwellings permitted is in excess of that at Bierton and yet additional
allocations are proposed in these settlements. Indeed, Maids Moreton is planned to receive 171
dwellings, Marsh Gibbon is planned to receive 47 and Newton Longville 48, as compared to the 23
dwellings at Bierton.
Policy S3 (Settlement hierarchy and cohesive development spatial strategy for growth)
If your representation is more than 100 words, please provide a brief summary here:
Pegasus therefore, in accordance with the representations submitted for the 'Draft Plan for Summer
2016 Consultation', continue to object to the "downgrading" of Bierton, which is clearly a sustainable
location and with the development to the south (i.e. Land East of Aylesbury - Kingsbrook) has outline
planning permission for 2,450 homes, 10 hectares of employment land and further development such
as two primary schools and community facilities, thereby providing a range of facilities and services
which will be even closer those provided by Aylesbury only 1.8 miles away.
Paragraph 4.152 identifies that no allocations are made at either Bierton or Weston Turville owing to
their proximity to Aylesbury Garden Town. This does not take account of the impacts of the proposed
allocations at Aylesbury Garden Town which include a highways access in Bierton. Bierton will be
directly affected by the highways impacts associated with large scale residential development, but will
not receive the benefits associated with modest housing provision. This cannot be considered to be
sustainable in terms of the three dimensions of sustainability (providing adverse social, economic and
environmental impacts from the nearby development without any beneficial impacts associated with
these).
As a result of this, the proposed distribution in the VALP does not reflect the sustainability of
settlements. Additional provisions, either in the form of allocations and/or mechanisms to allow
development beyond the settlement envelope should be embedded in the VALP.
It is therefore necessary to provide for development in Bierton commensurate with its size and scale.
On behalf of our client, Pegasus has promoted through the SHLAA and previous representations to the
emerging Local Plan, several sites at Bierton - refs: BIE004, BIE005, HUL004. A location plan is
attached which shows these sites in relation to Bierton. These sites are not subject to any statutory
environmental or landscape designations and nor are they located in any Local Landscape Area or
Area of Attractive Landscape
Policy S3 seeks to resist development that would compromise the open character of the countryside
between settlements. Whilst the objective of this Policy accords with the NPPF, the Policy is not
sufficiently precise. Any development beyond the current built form, including that on allocated sites
(either within the VALP or neighbourhood plans), or as exceptional development (see Policy D4 and
H2 for example) will to some extent compromise certain elements of the character of the countryside
between settlements. The blanket application of the Policy as worded would prevent any such
development and would thereby prevent the housing requirement (or any other development
requirements) being delivered.
Indeed, paragraph 109 of the NPPF requires that such protection is only afforded to valued landscapes.
As such, the Policy as worded, is not consistent with the NPPF, it is not justified and it will not be
effective as it could be used to undermine the required development.

Object

VALP Proposed Submission

Representation ID: 1055

Received: 14/12/2017

Respondent: Jackson Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

As set out elsewhere in representations 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: 1179

Received: 14/12/2017

Respondent: Lands Improvement Holdings Plc

Agent: Indigo Planning Limited

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation:

Given the substantial shortfall against FOAN identified in Section 2, it is vitally important that
Policy S9 is amended to ensure that it contains a robust and definitive review mechanism to
ensure it is effective, justified and positively prepared. The Council must plan to respond to
key changing circumstances which will significantly impact its housing and economic needs
which include the Government's standard methodology for calculating housing needs and
the Oxford to Cambridge Expressway.

Full text:

See attachment for full representation


S2, AGT1, S2, S9, D1, H1, H6, H7, BE4

Object

VALP Proposed Submission

Representation ID: 1519

Received: 14/12/2017

Respondent: Lands Improvement Holdings (LIH)

Agent: Savills Oxford

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation:

LIH has set out above the need to take on board a number of strategic issues in the VALP rather than rely on
an early review. The evidence is clear now that such a review will be required. As has been demonstrated at
other local plan examinations, where there is such clear evidence of strategic issues and/or deficiencies these
should be taken in to account within the emerging plan and not 'kicked along the road' for some date in the
future.

Full text:

Please see the attached representations to the VALP pre-submission public consultation made on behalf of Lands Improvement Holdings (LIH). This email contains the following attachments:

L 171214 RL Representations to VALP pre-submission
Response forms to the following- Chapter 2; Policy D2; Policy D5; Policy S2; Policy S3; Policy S9.

Object

VALP Proposed Submission

Representation ID: 1607

Received: 14/12/2017

Respondent: Waldridge Garden Village Consortium

Agent: Pegasus Group (on behalf of Jeremy Elgin)

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

The trigger mechanisms are not sufficiently precise to ensure that housing is delivered as intended.

Full text:

Please find attached representations to the VALP prepared on behalf of the Waldridge Garden Village Consortium

Object

VALP Proposed Submission

Representation ID: 1620

Received: 14/12/2017

Respondent: Gladman Developments Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

The policy lacks the necessary detail and triggers to ensure it is effective.

Full text:

Please see attached representation and appendices.

Object

VALP Proposed Submission

Representation ID: 1694

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:

Although RPS agrees that a strong monitoring policy is needed, the scale of the shortfall is already significant and would trigger this policy. The Council already recognises through this policy that the future housing need will increase, however the Council makes no provision through the VALP to meet this.

Were the Council to bring forward a monitoring policy, RPS consider that this should be clearer in the triggers for review. As currently stated a plan review would commence if site allocations fail to be delivered at the rate expected in the plan. At which year would this occur?

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: 1880

Received: 14/12/2017

Respondent: GRE Assets

Agent: Lichfields

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Representation:

The assessment and reasonable alternatives set out in the SA Technical Annex for Aston Clinton in support of the SA , is underpinned by a point in time assessment of need s, does not consider how population and new development within the district (including the provision of new schools) may affect the District needs and provision, and does not consider a smaller scale growth alternative for Aston Clinton. As such, the VALPs proposed spatial strategy, set out in Policy S2 has not been informed by robust evidence or an objective view on the reasonable alternatives, and is therefore not justified.

Full text:

On behalf of our client, GRE Assets please find below their representations to the Proposed Submission Vale of Aylesbury Local Plan Regulation 19 consultation, available for comment until the 14th December 2017. The representations have been prepared by Lichfields.

The representations take the form of a report which encompasses our clients response to specific policies contained within the plan, and includes the requisite forms.

Object

VALP Proposed Submission

Representation ID: 1891

Received: 14/12/2017

Respondent: Granborough Parish Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

The GPC is extremely concerned about the need to review the VALP within a very short time of its adoption to accommodate further government requirements for housing. If the proposed unmet need figures from the other DC's are accepted, this could be taken as an acceptance that these authorities are "full" and will look for yet further development in AVDC to meet identified need in their areas which are in the main serving London and the Thames corridor. The GPC's concerns are further exacerbated by the proposals for the Oxford - Cambridge Express way which will generate the demand from Government for even more housing and commercial sites to be identified in the centre/north of AVDC on a scale which will potentially dwarf those required so far. Implicit in this is the prospect that AVDC could be seen as a prime area for massive scale development simply because it is currently rural and does not have the benefit of statutory protection.

Full text:

The Granborough Parish Council (GPC) has considered the PROPOSED SUBMISSION - VALE OF AYLESBURY LOCAL PLAN 2013- 2033 (VALP) and wishes to make the following observations.
1. The GPC welcomes the revised submission to be submitted in early 2018 as it believes that Aylesbury Vale District Council has taken regard to many of the comments made during the 2016 consultation exercise. The GPC also notes that the comments made on the earlier draft will be passed to the Inspector at the time of the Inspection, hence the GPC does not intend to repeat some of the comments it made in 2016.

2. The GPC fully recognises the need for the plan to be submitted early in 2018

3. The GPC is particularly pleased to note that in respect of Granborough and other smaller settlements/villages that the proposal to specify the number of properties to be built has been replaced with the concept that the growth in such smaller villages will be met through a combination of sites allocated in a neighbourhood plan (if one exists) and on sites coming forward as part of the development management process. The GPC does however still have some concerns about the cumulative impact of such development where smaller villages share limited infrastructure, in particular schools. The concern is that this may result in children in the smaller villages, without schools, being displaced from the normal catchment schools due them being filled by children from the development in the locality of the school.

4. The GPC is concerned as to the figures proposed of 25% for affordable housing as part of developments of over 11 properties (gross) or 0.3 ha. This figure would appear to be lower than that being proposed by other neighbouring local authorities. As the provision of affordable housing would appear to be essential to maintain existing communities due to the high price of housing, the GPC would wish to see consideration being given to increasing this percentage to 30%. GPC is concerned that there appears to be nothing in the VALP which will actively deliver affordable housing to smaller villages where the proposed (albeit welcomed) policies are aimed to prevent the development of sites of a scale to generate a need for affordable housing. We appear to be in a "catch 22" situation where a smaller village recognises the need for a small number of affordable housing to allow people to remain in the village, but these cannot be provided

5. The GPC is still concerned as to the overall impact on the plan of meeting the unmet need from the other Buckinghamshire Districts. Whilst GPC recognises the need to cooperate, it still believes that the apparent willingness of AVDC to accommodate some 8000 properties which are over and above the number identified as being needed in AVDC has an overall negative impact on the viability and acceptability of the VALP. It is the acceptance of this number of properties by AVDC which has meant that AVDC has had to identify sites which are, at the very least, unpopular with local communities and in some circumstances contrary to the declared wishes of local communities as contained in their approved neighbourhood plans.

One of the reasons why other authorities are claiming that they cannot meet their identified housing need is by proposing low housing densities, and thus not maximising the sites available to them even having regard to the constraints of green belt and AONB's. The proposed housing densities for Wycombe appear far lower than proposed by AVDC hence GPC believes that AVDC has at this time made over-provision for properties which the other DC's could accommodate, if they proposed higher densities. This must bring into question the soundness of neighbouring local plan proposals, whilst at the same time indicating that AVDC can accommodate them.

The GPC is extremely concerned about the need to review the VALP within a very short time of its adoption to accommodate further government requirements for housing. If the proposed unmet need figures from the other DC's are accepted, this could be taken as an acceptance that these authorities are "full" and will look for yet further development in AVDC to meet identified need in their areas which are in the main serving London and the Thames corridor. The GPC's concerns are further exacerbated by the proposals for the Oxford - Cambridge Express way which will generate the demand from Government for even more housing and commercial sites to be identified in the centre/north of AVDC on a scale which will potentially dwarf those required so far. Implicit in this is the prospect that AVDC could be seen as a prime area for massive scale development simply because it is currently rural and does not have the benefit of statutory protection.

Support

VALP Proposed Submission

Representation ID: 1904

Received: 14/12/2017

Respondent: Central Bedfordshire Council

Representation:

CBC further supports the identification of the need for an early review of the Vale of Aylesbury Local Plan to consider the potential for new housing at RAF Halton once it closes as well as the potential for a new settlement to help meet future growth requirements. This would need to be considered within the contest of the Cambridge­ Milton Keynes-Oxford Corridor and the government aspirations for significant growth to meet housing demand.

Full text:

see attachment

Object

VALP Proposed Submission

Representation ID: 1956

Received: 14/12/2017

Respondent: Careys New Homes

Agent: Bidwells

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Representation:

An early review of the VALP is essential given the uncertainty of housing numbers within the HMA and
pending changes to Government guidance on calculating housing requirements and changes to the NPPF.
It is however necessary to provide greater clarity and certainty on the timing for a review of the VALP. The
policy should explicitly state when the VALP will be re-adopted following a review.

Full text:

On behalf of my client, Careys New Homes, I am pleased to submit the attached (4 no. PDFs) response to the VALP Proposed Submission consultation in respect of land at Wingrave.

Object

VALP Proposed Submission

Representation ID: 1973

Received: 14/12/2017

Respondent: Persimmon Homes Midlands

Agent: Bidwells

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

Considering that the VALP does not adequately meet the OAN (refer to comments under Policy S2). As
currently drafted, an early review of the VALP is essential given the uncertainty of housing numbers within
the HMA and pending changes to Government guidance on calculating housing requirements and changes
to the NPPF. It is however necessary to provide greater clarity and certainty on the timing for a review of
the VALP. The policy should explicitly state when the replacement VALP will be adopted following a review.

Full text:

As it stands, the VALP is not sound and hence there are a number of changes required to the plan including a number of strategic and development management policies as identified in the submitted representation letter. In summary, we consider that the following policies are unsound and for reasons stated above, do not meet the test of soundness: Policy S2 'Spatial Strategy for Growth'; Policy S3 'Settlement Hierarchy and Cohesive Development'; Policy H1 'Affordable Housing'; Policy H5 'Self/Custom Build Housing'; Policy H6 'Housing Mix'; Policy H7 'Dwelling Sizes'; Policy T5 'Vehicle Parking'; and Policy T7 'Electric Vehicle Infrastructure'. My client's site at Calvert Green represents an achievable, suitable and deliverable allocation that is part brownfield to support the necessary housing growth for Aylesbury Vale.

Object

VALP Proposed Submission

Representation ID: 1999

Received: 14/12/2017

Respondent: Society of Merchant Ventures

Agent: Savills Reading

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation:

Policy S9 states that the VALP will be reviewed, or proposals for alternative sustainable sites considered favourably (subject to compliance with other policies) in certain circumstances.
If the need for a review of the District's housing requirement is not accepted to provide for the full OAN in this Plan, this policy needs to be more robust.
See further details in the attached covering letter.

Full text:

On behalf of our Client, the Society of Merchant Venturers, please find attached our representations to the Proposed Submission Version of the Vale of Aylesbury Local Plan consultation.

Object

VALP Proposed Submission

Representation ID: 2027

Received: 14/12/2017

Respondent: Crest Strategic Projects

Agent: Savills Southampton

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

should provide some degree of flexibility and positive supply, to defend against any unavoidable delay to plan review. As part of this, an automatic trigger for an uplift of the housing requirement, applicable from two years from plan adoption should be considered, dependent on available land supply.

Both Policy S9 and Policy D2 should be amended as shown below, with the former being clearer as to the review mechanism, and the latter enabling sustainable and well-located sites adjacent at Strategic Settlements to come forward. This would be a criteria-based policy enabled should there be no sufficient 5-year housing land supply.

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: 2061

Received: 14/12/2017

Respondent: Persimmon Homes North London

Agent: Woolf Bond Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

As drafted, the policy relies upon a review of the Plan to allocate sites for
development in the event the site allocations in the VALP are not coming forward
at the rate expected in the Plan. This fails to provide for a justified and/or
effective Plan.

Full text:

Please find, on behalf of our Client, Persimmon Homes (North London) Ltd, the paperwork relating to the current consultation on the proposed Submission Version Vale of Aylesbury Local Plan.

Attached is a completed response form, reps letter and location plans.

Object

VALP Proposed Submission

Representation ID: 2220

Received: 14/12/2017

Respondent: The Guinness Partnership

Agent: Woolf Bond Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

We support the inclusion of a monitoring and review policy but object to the proposed wording.
3.30. As drafted, the policy relies upon a review of the Plan to allocate sites for development in the event the site allocations in the VALP are not coming forward at the rate expected in the Plan. This fails to provide for a justified and/or effective Plan.

Full text:

Please find attached the necessary paperwork on behalf of our Client The Guinness Partnership and the representations regarding the consultation for the Submission Version VALP.

Attached is a completed response form, reps letter and location plans.

Object

VALP Proposed Submission

Representation ID: 2655

Received: 08/12/2017

Respondent: FCC Environment

Agent: Sirius Yorkshire

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

The Buckinghamshire Growth Strategy (BGS) sets the economic development strategy and vision for the County of Buckinghamshire to 2050. The BGS proposes a Joint Spatial Strategy for the County that will set the growth framework for the delivery of the 105,000 new homes identified up to 2050. The objectives for a Joint Buckinghamshire Spatial Plan are supported and must be fully recognised and set out within the emerging VALP in order to plan coherently and comprehensively the next phase (and phases) of development that will be required beyond the early review of the Local Plan.

Full text:

These Representations:
consider a need for further strategic direction within its policies in relation to the growth aspirations for the District as a result of the Cambridge-Milton-Keynes-Oxford (CMKO) Corridor; at present it is considered the VALP is not planning spatially for long term growth and investment beyond what will be an adopted Local Plan with a very limited shelf life;
consider the strategic policies to restrict growth in rural areas preventing an opportunity to enhance the sustainability of existing rural communities, contrary to the provisions of the NPPF;
consider the assessment of Site CAL003, and other adjoining land, as inaccurate within the HELAA and that further strategic consideration should be given to site allocations at Calvert Green as an opportunity to improve the sustainability of an existing community with limited facilities;
identify the FCC landholding as a highly strategic location which can facilitate a new settlement in the Calvert area which would contribute towards the long term growth requirements for the District and provide the opportunity to co-locate energy consumers to an existing supply (Greatmoor EfW); this should be recognised within the strategic policies of the VALP.

Officer note: see attachment for full representation

Object

VALP Proposed Submission

Representation ID: 2709

Received: 13/12/2017

Respondent: Mr David Vowles

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

Policies S9 and D2 contain ambiguities in respect of the actin to be taken in the event that housing delivery falls short of what is required and, indeed, in respect of what those requirements are.

Full text:

There are a number of ambiguities in the plan in respect of bringing forward new housing allocations if existing allocations are not delivered at the expected rate.
Paragraph 3.78 states that the housing trajectory sets out when the delivery "can reasonably be expected". It is therefore a projection and not a target.
Policies S9 and D2 deal with the situation arising when housing delivery falls short of the rate expected (i.e. the housing trajectory). In effect they imply that the trajectory is a target. Is this the intention?
Policy D2 refers to delivery "across the district". This seems to suggest that new allocations will need to be made only if there is a district wide shortfall of the rate at which new allocations are coming forward and not if there is no overall shortfall but there is a shortfall in a particular settlement. The intention needs to be made clear.
Whilst monitoring is to be carried out "at least annually" (policy S9) over what period is it intended that a shortfall would trigger the need to allocate new sites? I suggest that only a shortfall occurring over a sustained period (3 years?) should require such action.
It is also unclear where any shortfall should be made up in the event that district-wide rates fall below the expected level. Is it the intention that the shortfall should be met in the settlement(s) where it occurs, or is it the intention that it can be met anywhere in the district?
As the allocations made in the plan are based on a 'capacity' approach, rather than local need, any shortfall replacement should also be based on a capacity (i.e. the most sustainable sites) wherever this is located in the district; and not necessarily in the settlement(s) where the shortfall occurs. In any event such new sites should meet criteria c) to h) of policy D2.
Presumably in those larger and medium villages (and Wendover, other than Halton Camp) where no new allocations are made in the plan (i.e. 9 of the 12 larger villages and 13 of the 19 medium villages) there is no capacity beyond existing commitments. Similarly in those larger and medium villages where allocations have been made these presumably represent the full capacity of the village, meaning that any additional allocations, if they can be found, must replace existing, under performing allocations (and not be in addition to them).
How does this relate to the requirement to maintain a 5 year supply of developable sites? This requirement is based on a housing target of 7862 dwellings over the 5-year period from 2018/19 to 2022/23 (see Table 3 of the Housing Land Supply Soundness document). This is well below the housing trajectory projection of 8655 for this period.