MM080
Object
VALP Main Modifications
Representation ID: 2742
Received: 11/11/2019
Respondent: Hollins Strategic Land
Legally compliant? No
Sound? No
Policy D2, as proposed with main modifications, would be ineffective in positively responding to potential failures in housing delivery by not making allowances for sustainable sites located outside and adjacent to settlement boundaries in made neighbourhood plans.
Removal of last part of criteria c under D2 (Proposals for non-allocated sites at strategic settlements, larger villages and medium villages), i.e. REMOVE "except where there is a made neighbourhood plan which defines a settlement or development boundary, where the site should be located entirely within that settlement boundary".
Policy D2 (Proposals for non-allocated sites at strategic settlements, larger villages and medium villages) is partly aimed to be a positive response in circumstances when the VALP fails to be delivering housing as anticipated and instances where allocated sites do not come forward at all or at the rate expected in the housing trajectory.
However, the modification as proposed is not positively prepared, nor justified, and would result in conflicts with made Neighbourhood Plans which define settlement boundaries in a less rigid way and restrictive way. Some neighbourhood plans define settlement boundaries to simply delineate between built form and open countryside, whilst others are silent on what decision makers do with proposed development outside of settlement boundaries. Where housing delivery across the district shows that allocated sites are not being delivered at the anticipated rate, Policy D2 would result in an unnecessary further hurdle in bringing sustainable development forward to compensate, particularly as it would be much more restrictive than many existing neighbourhood plans. Criteria C fails to recognise the different interpretation and policy wording of settlement boundaries in various neighbourhood plans in the district.
In order for Policy D2 to be effective Criteria C should be amended to ensure sustainable development located within or adjacent to existing settlement boundaries in made neighbourhood plan areas is supported. Given the development plan as a whole would be the VALP and neighbourhood plans read together, if there is a failure in meeting the required needs during the life of the plan period, it would require a more flexible and positive approach to Policy D2 than what is being proposed, particularly in light of many sustainable large and medium villages either preparing or having made a neighbourhood plan.
Policy D2, as proposed with main modifications, would therefore be ineffective in positively responding to potential failures in housing delivery.
Object
VALP Main Modifications
Representation ID: 2990
Received: 12/12/2019
Respondent: Arnold White Estates
Agent: Arrow Planning Ltd
Legally compliant? Yes
Sound? No
MM070 There is a new Policy D2 'Delivering site allocations in the rest of the district' on
p124 of the modified Plan. MM080 This refers also to a different Policy D2 which is actually
Policy D3 in the Modified Plan.
The apparent exclusion of 'agricultural buildings' from being converted (or developed) to
residential is contrary to the GDPO Class Q (15.4.15) which allows conversion up to 5 units
in former agricultural buildings.
D3 Proposals for non-allocated sites at strategic settlements, larger villages and medium villages
The * qualifying c. should read
*The existing developed footprint is defined as the continuous built form of the village, and generally excludes
remote individual buildings and groups of dispersed buildings. The exclusion covers former agricultural barns
that have been converted, agricultural buildings (but does not preclude permitted development for
converting agricultural buildings to residential - GDPO Class Q 15.4.15) and associated land on the edge of
the village and gardens, paddocks and other undeveloped land within the curtilage of buildings on the edge of
the settlement where the land relates more to the surrounding countryside than to the built-up area of the
village.
On behalf of my client Arnold White Estates Ltd I attach our representations on the forms provided. I draw your attention to the difficulty I have found in making these submissions. The Schedule of Modifications does not show the relevant page numbers in the Plan as proposed to be modified, which means cross-referencing is very difficult. For example, in the Modifications Schedule MM027 shows a modification to para 4.7 at p62. The Modified Plan shows this as para 4.9 at p67. The Modification Schedule and the Modified Plan should have the same page and paragraph numbers. Also, for example, there are two Policies D2. In the forms I have sought to group linked Main Modifications on one form where a combined response is then provided. Where necessary I have inserted a blank page to accommodate text that would not fit within the box provided. I trust all of my text will be captured.
Support
VALP Main Modifications
Representation ID: 3138
Received: 26/11/2019
Respondent: Armstrong Rigg Planning
The amendment to criteria c) of policy D2 is supported
NA
See attached document
Object
VALP Main Modifications
Representation ID: 3265
Received: 11/12/2019
Respondent: Gleeson Strategic Land
Legally compliant? Not specified
Sound? Not specified
This policy sets out circumstances where development of non-allocated sites will be permitted, listing criteria that need to be fulfilled.
The proposed Main Modifications seek to insert the word 'Exceptionally' at the start of the supporting paragraph relating to 'Larger scale development'. However, it is considered that the insertion of this word is unnecessary - the circumstances under which further development would be permitted on non-allocated sites is confirmed within the text that follows.
Dear Sir / Madam
VALE OF AYLESBURY LOCAL PLAN - MAIN MODIFICATIONS CONSULTATION
Your Ref: 31567
Gleeson Strategic Land Limited and Linden Homes ("hereafter referred to as Gleeson/Linden") control the land edged red on the enclosed site plan. We participated in earlier rounds of public consultation for the Vale of Aylesbury Local Plan ("VALP") and now provide our comments on the Main Modifications Consultation.
Policy S2 Spatial strategy for growth
Gleeson/Linden continue to support Policy S2 in terms of its objectives to:
(i) Deliver at least 28,600 new homes; and
(ii) accommodate this development sustainably with a focus on the identified strategic settlements.
In this regard Gleeson / Linden also continue to support the identification of Winslow as one of five key 'strategic settlements'. The re-opening of Winslow Railway Station on the 'East-West Rail' line significantly enhances the sustainability of Winslow.
However, and whilst housing numbers for four out of these five settlements have been reduced (Aylesbury Garden Town aside), we would note that the housing requirement for Buckingham, Haddenham and Winslow state that growth will be a certain figure, rather than a minimum or 'around' as is the case for Wendover.
On the basis that the aspiration is to deliver at least 28,600 the terminology for these settlements could be interpreted as a ceiling. Therefore, for consistency, the figures for all strategic settlements which feed into the overarching housing requirement figure should be a minimum or 'around' figure. The policy wording in relation to S2 parts b, c and d should therefore be revised as follows:
b. Buckingham will accommodate growth of at least 2,166359 new homes. This growth will enhance the town centre and its function as a market town, and will support sustainable economic growth in the north of the district.
c. Haddenham will accommodate growth of at least 1,03251 new homes. This will be supported by infrastructure and recognise the important role of Haddenham and
Thame railway station.
d. Winslow will accommodate growth of at least 8971,166 new homes, linked with the development of East-West Rail and the new railway station in Winslow
Policy D3 Proposal for non-allocated sites at strategic settlements, larger villages and medium villages
This policy sets out circumstances where development of non-allocated sites will be permitted, listing criteria that need to be fulfilled.
The proposed Main Modifications seek to insert the word 'Exceptionally' at the start of the supporting paragraph relating to 'Larger scale development'. However, it is considered that the insertion of this word is unnecessary - the circumstances under which further development would be permitted on non-allocated sites is confirmed within the text that follows.
We trust that these comments are taken into consideration in the finalising of the VALP.
Yours faithfully
John Smith
Planning Manager
Object
VALP Main Modifications
Representation ID: 3451
Received: 17/12/2019
Respondent: LDA Design
Legally compliant? Yes
Sound? No
The addition of the word 'Exceptionally' in Policy D3 implies that even if development
proposals determined in line with Policy D3 meet all of the criteria c - h, then it would still only be granted 'exceptionally'. This is unclear and unnecessary. Policy wording already includes the word 'only'.
My client is supportive of the change to the wording of criterion c.
(officer summary)
See attached document which is submitted on behalf of Figar Land Limited.
Object
VALP Main Modifications
Representation ID: 3506
Received: 09/01/2020
Respondent: Barratt Homes
Agent: Graham Bloomfield
Legally compliant? Not specified
Sound? No
The principle of the proposed Modification is supported given the need to meet additional requirements for growth. This seeks to introduce some flexibility for the delivery of larger scale development at Larger Villages and Medium Villages where other allocations are not delivered as expected. It is suggested that additional flexibility is incorporated into policy wording to reflect the circumstances of our client's strategic opportunity at Park Manor.
The suggested Modifications fail to reflect the priorities and opportunities for this part of the plan area, and do not provide a clear direction for how policies for non-allocated sites might be assessed.
Proposed changes to Policy D3 Part 2(c)
be located within or adjacent to the existing developed footprint of the settlement or complement the strategic opportunities for growth at North East Aylesbury Vale * except where there is a made neighbourhood plan which includes defines a settlement or development boundary, where the site is should be located entirely within that settlement boundary
see attachment
Object
VALP Main Modifications
Representation ID: 3551
Received: 18/11/2019
Respondent: Mr David Vowles
Legally compliant? Not specified
Sound? No
The footnote to policy D2 refers (twice) to "villages" when the policy covers towns a well as villages. The footnote should therefore refer (twice) to "settlement" rather than "village".
Replace "village" with "settlement" (twice) in footnote to Policy D2.
See attachments