Aylesbury Vale Area

D2 Proposals for non-allocated sites at strategic settlements, larger villages and medium villages

Showing comments and forms 1 to 30 of 47

Object

VALP Proposed Submission

Representation ID: 313

Received: 01/12/2017

Respondent: Cllr Warren Whyte

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

To allow for organic natural growth of rural villages, carefully situated buildings should be considered in areas that are supported by residents or the parish council, such as infilling between former agricultural buildings and village edges that do not form a strong edge. By there nature, many villages "bleed" into the countryside, and flexibility should be permitted. A recent example in Akeley which has been refused several times is seen as an absurdity to the village, especially when the occasional windfall site would enhance the slow natural growth of villages.

Full text:

To allow for organic natural growth of rural villages, carefully situated buildings should be considered in areas that are supported by residents or the parish council, such as infilling between former agricultural buildings and village edges that do not form a strong edge. By there nature, many villages "bleed" into the countryside, and flexibility should be permitted. A recent example in Akeley which has been refused several times is seen as an absurdity to the village, especially when the occasional windfall site would enhance the slow natural growth of villages.

Object

VALP Proposed Submission

Representation ID: 500

Received: 13/12/2017

Respondent: Mr Andrew Docherty

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

There should be consideration of de-allocation of sites in certain circumstances.
There should be a sustainable hierarchy of release of any non-allocated sites.
Where there is a made Neighbourhood Plan (NP), non- allocated sites should not be released without a prior review of the NP.
Add 'important views' to para g.
Support for para c restrictions at made NP settlements.

Full text:

Proposed Policy D2 could encourage developers to bring forward non-allocated sites by holding back allocated land (already held in their land banks). Where allocated sites are being held back without a good planning reason, de-allocation should be considered at the first Local Plan Review.
Policy D2 should state that the basis of the release of any non-allocated sites would:
i) follow the basic hierarchy of sites' strategy of the VALP - set out in proposed Policies S2 and S3;
ii) in so doing, then prioritise settlements which do not have adopted Neighbourhood Plans; and
iii) only allow the release of non-allocated sites following an analysis of the delivery delay and by potential de-allocation at the LP review of sites not delivering; and
iv) allow for a review of any made/adopted Neighbourhood Plan before release of a non-allocated site

It is requested that 'important views' should be added to the 'assets' listed in para g.

There is support for the restriction of any potential additional sites to within made Neighbourhood Plan Settlement boundaries in para c.

Object

VALP Proposed Submission

Representation ID: 590

Received: 11/12/2017

Respondent: Dr Geoffrey Harris

Number of people: 22

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The terms and approach of Policy D2, applied to Edlesborough, produce a situation which is inconsistent and perverse; and where the Neighbourhood Plan subverts the authority of the Local Plan to set policy and strategic direction.

Allocation EDL021 contravenes or is inconsistent with 7 of the 8 key criteria of Policy D2; most significantly, that proposals for development should not 'comprise partial development of a larger site'. This is explicitly the case for EDL021.

If the level of housing provision must be maintained, an alternative site is available which infringes the criteria of Policy D2 to a substantially lesser degree.

Full text:

First, the terms and approach of Policy D2 within the draft AVDC Local Plan, when applied to Edlesborough, produce a position which is seriously inconsistent and perverse; and where the comparative merits of competing sites for development will not be adjudicated upon equitably. Paragraph 184 of the National Planning Policy Framework requires that local plans should clearly set out their strategic priorities, and that: 'Neighbourhood Plans should reflect these policies and neighbourhoods should positively support them' The Edlesborough Neighbourhood Plan contravenes almost all of the Local Plan criteria to guide the nature, characteristics, location and scale of development in this village. The Neighbourhood Plan should not be given, as it has in this case, a wholly unjustified and inappropriate status that seeks to subvert the authority of the Local Plan to set the strategic direction and policy framework for neighbourhood plans. Second, the Local Plan does not consider it appropriate to allocate further land for development in Edlesborough. This is confirmed by Table 2 on page 38. Consequently, new sites proposed for residential development should be assessed under the 8 important criteria set out under Policy D2. The Edlesborough Neighbourhood Pan allocation EDL021 either contravenes, or is inconsistent with 7 of these 8 key criteria. Most significantly, Policy D2 specifies that proposals for development should not 'comprise partial development of a larger site (page 115 Policy D2 point b). This is, clearly and explicitly, the case with the field EDL021. This proposed allocation explicitly embodies 'the partial development of a larger site', to which, furthermore, there are no natural boundaries or barriers to further extensive development. Moreover, the explanatory subscript referring to Policy D2 point c would appear fundamentally to exclude field EDL021 from being part of an agreed neighbourhood plan. Third, if it is considered necessary to maintain the overall scale of development on Edlesborough provided for in the draft Local Plan (176 dwellings Table 2 page 38), then the estimated capacity of site EDL021 (80 dwellings) is capable of being replaced by an alternative site of comparable capacity which infringes the criteria of Policy D2 to a substantially lesser degree. To the best of our knowledge, and after making relevant enquiries, there has been no competent and fully detailed evaluation of either the comparative or individual characteristics of the two areas of land concerned.

Object

VALP Proposed Submission

Representation ID: 791

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 Summary:

Bovis Homes object to Policy D2, 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 OAN will be met within the plan period;
-is not justified in that it is not the most appropriate strategy and has not properly considered reasonable alternative strategies;
-is not effective in that the policy is unduly restrictive; and
-is inconsistent with national policy in that it does not fully reflect the Government's priorities and policies in terms of enabling sustainable development and supporting rural communities.

Full text:

Bovis Homes' objection to Policy S3 highlights that the development strategy in the Local Plan fails to address the NPPF's policy imperative to support thriving rural communities as it makes inadequate provision at the identified Large and Medium Villages to meet their development needs over the plan period. That will have a significant negative impact on the role and function of a number of the sustainable villages in the District.

That concern is exacerbated by Policy D2 that seeks to prevent the any development coming forward unless the site is allocated for such. That approach effectively removes any flexibility to embrace potential sustainable development opportunities as they arise where there maybe wider socio-economic benefits that outweighs any harm, or that harm can be appropriately mitigated. Moreover, the policy approach is predicated on the assumption that the housing needs will be met in full by the development allocations in the Local Plan. The concerns highlighted in relation to Policies S2 and S3 demonstrate why that assumption is incorrect.

Whilst Policy D2 purports to allow development where the monitoring of housing delivery indicates that allocated sites are not being delivered at the anticipated rates, the unduly restrictive terms of the policy that add further layers of "protection" by reiterating matters that are more appropriately addressed by other policies within the Local Plan, will have the effect of preventing other sustainable development opportunities coming to address shortfalls in provision. That is contrary to the requirement of the NPPF's presumption in favour of sustainable development means that requires the Local Plan to be sufficient flexibility to adapt to rapid change (para 14).

For example, part (g) requires development not to have any adverse impact on environmental assets such as landscape, historic environment, biodiversity, waterways, open space and green infrastructure. Clearly, however, it is inevitable that any development of a greenfield site will have some degree of impact on some of these assets. The policy does not allow the relative value of those matters or the scope for mitigation to be considered, or critically whether the socio-economic benefits that would arise from the development would outweigh any harm,

Policy D2 should, therefore, be revised to avoid restricting sustainable development in order to reflect the NPPF's presumption in favour of sustainable development and the requirement to meet objectively assessed needs with sufficient flexibility to adapt to change.

Soundness:
For the reasons set out above, Bovis Homes object to Policy D2, which is considered unsound on the basis that it:
- has not been positively prepared as it is not based on a strategy that will ensure that the objectively assessed housing needs will be met within the plan period;
- is not justified in that it is not the most appropriate strategy and has not properly considered reasonable alternative strategies;
- is not effective in that the policy is unduly restrictive; and
- is inconsistent with national policy in that it does not fully reflect the Government's priorities and policies in terms of enabling sustainable development and supporting rural communities.

Object

VALP Proposed Submission

Representation ID: 811

Received: 13/12/2017

Respondent: Cheddington Parish Council

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Representation Summary:

Cheddington Parish Council (CPC) would like to make the following points:
a) CPC is concerned that the general rate of 25% affordable housing undermines their own figure of 35% included in its adopted Neighbourhood Plan.
b) CPC is concerned in respect of Paragraph 4.159 that any additional development in Cheddington should be returned to the Parish Council for agreement in a further referendum within the updating process of the Cheddington Neighbourhood Plan.

Full text:

Cheddington Parish Council (CPC) makes the following points to the Inspector.
1. Whilst understanding the reasoning for the general rate of 25% affordable housing to be included in any development of 11 dwellings or more, CPC is somewhat concerned that this undermines their own figure of 35% included in its adopted Neighbourhood Plan.
The figure in this and other NP's was compiled under advice from AVDC the local planning authority to ensure needs of local communities were met. Naturally evidence for need must be shown when applications are considered but it is felt that this lower figure, proposed in the VALP, will undermine efforts to allow those communities to develop as was envisaged in those NP's. We would propose that exception be made where a NP states a higher figure and evidence of need can be provided.

2. Despite sites having been identified under the LPA's HELAA some were discounted under the NP process and in this LP's compilation.
In that respect Paragraph 4.159 of VALP states "additional development in medium villages that are not allocated in either the LP or NP will only be permitted in exceptional circumstances where it can be demonstrated that sites allocated are not coming forward at the rate anticipated" Policy D2 and paragraph 4.122 should at least use the same terminology.
Further though and to strengthen those policies we would propose that any prospective inclusion of those sites within the LPA's consideration should be returned to the Parish Council for agreement in a further referendum within the updating process of their NP.
Also, that if the same land owner that has a pending permission to develop within a NP area that also has a site identified by HELAA, but not included in the NP or LP, this may not be considered by the LPA for benefit of any 5 year housing supply (for example) due to lack of the permitted site being developed or withheld / delayed for any reason.

Object

VALP Proposed Submission

Representation ID: 867

Received: 14/12/2017

Respondent: AB Planning & Development Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

It is inappropriate in the policy and in criterion (a) to include the word "small" as it is too restrictive and takes no account of local circumstance.

Full text:

It is inappropriate in the policy and in criterion (a) to include the word "small" as it is too restrictive and takes no account of local circumstance.

Support

VALP Proposed Submission

Representation ID: 884

Received: 14/12/2017

Respondent: Great & Little Kimble cum Marsh Parish Council

Agent: Mr Neil Homer

Representation Summary:

We support the strategy for limiting housing development in rural areas beyond the strategic site allocations and the built up areas of identified settlements.

Full text:

We support the strategy for limiting housing development in rural areas beyond the strategic site allocations and the built up areas of identified settlements.

Object

VALP Proposed Submission

Representation ID: 939

Received: 14/12/2017

Respondent: Chiltern Area of Outstanding Natural Beauty Conservation Board

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The 'within or adjacent to the existing developed footprint of the settlement' is particularly problematic, suggest delete 'or adjacent'. Otherwise once a greenfield development has been allowed, can another one take place on the greenfield land beyond that? What control is there over incremental creep outwards of villages, and how will cumulative effects be taken into account? How will rural exceptions sites ever be delivered if land adjacent to villages is allowed for market housing? If there is slow delivery of an allocation there should be no expectation that a site in the AONB or its setting is released.

Full text:

The 'within or adjacent to the existing developed footprint of the settlement' is particularly problematic, suggest delete 'or adjacent'. Otherwise once a greenfield development has been allowed, can another one take place on the greenfield land beyond that? What control is there over incremental creep outwards of villages, and how will cumulative effects be taken into account? How will rural exceptions sites ever be delivered if land adjacent to villages is allowed for market housing? If there is slow delivery of an allocation there should be no expectation that a site in the AONB or its setting is released.

Object

VALP Proposed Submission

Representation ID: 1054

Received: 14/12/2017

Respondent: Mr Cameron Branston

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Objects to D2.
Recognises the significance of the document and welcomes the new capacity-based approach to housing targets. There is concern from residents, Grendon Underwood Parish Council, Brill Society and Brill Parish Council that despite the pre-existing planning policy, that developers may try to build in and around the villages in unsuitable locations. Infrastructure is required to support new development.

Full text:

I have largely raised my concerns directly to planners, VALP Scrutiny Committee and in the previous consultation.

In responding to this draft strategy, I recognise the significance of this document, which will act a roadmap for the next 30 years for Aylesbury Vale District Council. Furthermore, I am largely satisfied that the villages within my Ward of Grendon Underwood & Brill will find the required protection in the Vale of Aylesbury Local Plan to keep safe the rural nature of their communities.

Having spoken with residents in my district ward it is clear that they understand the challenges face by Aylesbury Vale District Council. Large numbers of residents have cited affordable housing as being a vital priority whilst maintaining the picturesque rural landscape of Grendon Underwood & Brill Ward. Consequently, where practicable, I support the use of the Rural Exception Scheme to develop affordable housing for local residents.

I welcome the new approach to developing housing targets to ensure that it is capacity-based thereby eliminating the housing targets for villages across the Vale. The HELAA indicated that no suitable locations were available for communities such as Brill and only a few in Grendon Underwood.

Based on my conversations with residents, Grendon Underwood Parish Council, Brill Society and the Brill Parish Council , there is clear concern, despite the pre-existing planning policy, that developers may to try to build in and around the villages within the Ward of Grendon Underwood & Brill in unsuitable locations. Residents in villages such as Grendon Underwood which is likely to see smaller developments detailed a need for greater infrastructure including public transport.

Object

VALP Proposed Submission

Representation ID: 1075

Received: 14/12/2017

Respondent: Society of Merchant Ventures

Agent: Savills Reading

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Policy D2 only supports additional development (i.e. non-allocated sites) on land adjacent to the existing developed footprint of the settlement in the circumstances where the Council's monitoring of delivery across the district shows that the allocated sites are not being delivered at the anticipated rate and subject to a number of criteria.
This Policy will not deliver sufficient flexibility in the Plan to respond to changes in circumstances i.e. Government's changed methodology to calculating housing need.
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: 1078

Received: 14/12/2017

Respondent: Persimmon Homes North London

Agent: Woolf Bond Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Our clients have a controlling interest in land at Buckland Road, Aston Clinton
and Broughton Lane, Bierton, and object to the omission of the sites as housing
allocations in Policy D2.

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: 1102

Received: 14/12/2017

Respondent: Trustees of the Pitstone Townlands Charity

Agent: Bidwells

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

The VALP contains no site-specific policies for existing commitments.
There is a need for a new Doctors Surgery to serve the village and outlying areas. The Practice Manager of the Rothchild Surgery has confirmed the need. There is no provision either within VALP or NP for this facility. It is a use which falls with a general D1 use.
For the reasons stated in the HBF submissions there is no justification for the reduced housing numbers and the identification of this site to provide for the part of the unmet need will contribute to the shortfall in housing numbers.

Full text:

VALP 2013-2033 PROPOSED SUBMISSION NOV 2017
HOUSING NEED - PIT007.
We act on behalf of the Trustees of the Pitstone Townlands Charity who own the site identified as PIT007 which is shown as an existing commitment as of 31st March 2017. The commitment being identified in the Pitstone NP as Safeguarded for D1 use (education).
Our clients endorse the submissions made by the Home Builders Federation and do not repeat the case made, particularly with regard to Housing Needs.
The VALP contains no site-specific policies for existing commitments. With regard to our client's Land North of Marsworth Road it should be identified for a mix use of residential, Education and Doctors Surgery.
There is a need for a new Doctors Surgery to serve the village and outlying areas. The Practice Manager of the Rothchild Surgery has confirmed the need. There is no provision either within VALP or NP for this facility. It is a use which falls with a general D1 use.
For the reasons stated in the HBF submissions there is no justification for the reduced housing numbers and the identification of this site to provide for the part of the unmet need will contribute to the shortfall in housing numbers.
The charity would retain ownership of some of the dwellings to provide accommodation for the local villages.

Object

VALP Proposed Submission

Representation ID: 1117

Received: 14/12/2017

Respondent: CALA Homes Limited

Agent: Hunter Page Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

Land set out in the accompanying letter at Bierton and Grendon Underwood be allocated for housing.

Full text:

Please find attached our representation made on behalf of CALA Homes Limited in relation to the Submission Version of the Aylesbury Vale Local Plan.

Please note that the following PDF attachments form the appendices to the Representation letter:

* Appendix 1 - Appeal Decision Land at Leasows Chipping Campden (APP/F1610/W/16/3165805): Appeal Decision - Cotswolds.pdf

* Appendix 2 - Site Location Plan Land to the West of Gib Lane, Bierton: 3143 P 100.pdf

* Appendix 3 - Site Location Plan Land adjacent to Ivy Cottage, Main Street, Grendon Underwood: 2997.100 B Location Plan(1).pdf

Object

VALP Proposed Submission

Representation ID: 1350

Received: 14/12/2017

Respondent: Bellway Homes Ltd, Bellcross Co. Ltd and Fosbern Manufacturing Ltd

Agent: Armstrong Rigg Planning

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

The wording of criteria c from this policy should be amended as follows, to more closely reflect the wording of relevant policies within the relevant neighbourhood plan, as follows:
c. be located within or adjacent to the existing developed footprint of the settlement or, where there is a made neighbourhood plan, whose policies expressly restrict development beyond settlement boundary limits, the site is located entirely within that settlement boundary.

Full text:

On behalf of our clients Bellway Homes Ltd, Bellcross Co. Ltd and Fosbern Manufacturing Ltd and their interests in land west of AVDLP allocation BU.1 (BUC043), Moreton Road, Buckingham please find attached our representation. This comments on policies S2, D2, B-BUC043, H1, H5, H6 and BE2.

Object

VALP Proposed Submission

Representation ID: 1356

Received: 14/12/2017

Respondent: Taylor Wimpey South Midlands

Agent: Armstrong Rigg Planning

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

This policy anticipates a situation where housing delivery drops below expected rates. A flexible and positive policy response to this should be adopted.
Our suggestion of including deliverable housing sites as reserve sites, could be included at criteria C of the policy. In the circumstances described the need to restrict development within neighbourhood plan settlement boundaries is considered unduly restrictive and could favour otherwise more constrained, less suitable sites in settlements where no neighbourhood plan is in place.
As noted at paragraph 1.20 of the VALP existing neighbourhood plans which have been made are not based on this Local Plan.

Full text:

On behalf of our clients Taylor Wimpey South Midlands in relation to interests in land South of Weston Road, Great Horwood please find attached our representations to the VALP. This includes comments on S2, D2, Delivering the allocated sites at Medium Villages, H1 and BE2

Object

VALP Proposed Submission

Representation ID: 1396

Received: 14/12/2017

Respondent: Edward Ware Homes

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Policy D2 is too restrictive. There is no definition of 'small scale' trying to establish a definition would be fruitless as one would expect different definitions depending upon whether a site is in a village or one of the strategic settlements.

The supporting text at paragraph 4.122 says that unallocated sites will not normally be permitted. The housing requirement should be expressed as a minimum figure. It is likely to restrict development that constitutes sustainable development.

It does not allow for a proper balancing exercise to be undertaken.

Specific comments made on criteria e, f and g.

Full text:

VALP consultation- land at Pond Close, Newton Longville, attached representations (including map pf site) to the VALP consultation on behalf of Edward Ware Homes.

Text where there is more than the summary:

4.151 to 4.154

Paragraph 4.154 seeks to prevent development at medium villages (where it is not allocated) and allow it 'only in exceptional circumstances where it can be demonstrated that sites allocated are not coming forward at the rate anticipated'.
This is not justified and is too restrictive. The NPPF is clear that the emphasis is to boost housing supply. The wording of the policy incorrectly and inappropriately plans for the Council to fail to provide sufficient housing before allowing development to occur at villages. Such an approach is at odds with the NPPF and the approach to achieving sustainable development.
Land south of Pond Close, Newton Longville
Given the sustainability credentials of the village and its proximity to Milton Keynes it is considered that Newton Longville should accommodate more development than the proposed allocation of 17 dwellings (currently the subject of a planning application). Paragraph 4.152 confirms that there are suitable sites and that the most sustainable site has been selected. This indicates that the village can accommodate more development.
The site at Pond Close adjoins the village to its southern boundary. It would form a logical extension to the settlement. Access can be achieved from Pond Close. There is a bus stop about 80m from the site.
The site slopes upward from east to west and trees mark the site boundaries. As such, the site is visually enclosed.
It is understood that the landowner for the adjoining land to the south east of the site(the remainder of SHLAA siteNLV002)is also promoting their land for development, and as such the parcels should be considered both individually, and in combination.

D2 Policy

D2 is too restrictive and seeks to limit development on sites not allocated by the Development Plan to 'small scale areas' within built up areas. There is no definition of 'small scale' and we would suggest that in any case, trying to establish a definition would be fruitless as one would expect different definitions depending upon whether a site is in a village or one of the strategic settlements.
The supporting text at paragraph 4.122 says that unallocated sites will not normally be permitted on the basis that the level of growth is being met by proposed allocations. But the housing requirement should be expressed as a minimum figure and the NPPF is very clear that a fundamental objective of the planning system is to boost housing supply.
The policy is therefore unclear, inappropriate and unjustified and is likely to restrict development that constitutes sustainable development.
The policy does allow flexibility for sites to come forward where delivery of housing is failing, but we consider that it is not appropriate for the VALP policies to plan to fail. The NPPF is very clear that the emphasis should be to meet the full objectively assessed needs.
In addition, the policy states that additional development will 'only' be permitted where housing delivery is not being maintained. This does not allow for the proper balancing exercise to be undertaken whereby positive material considerations should be balanced against any conflict with the Development Plan.
Criterion e) requires that development should not 'adversely affect its character and appearance '. However, all development is likely to result in some harm, however limited that harm is.
Similarly, in respect to criteria f)and g), it will not always possible to retain all natural features on a site or have no adverse impact on environmental assets. Therefore, the policy should be worded flexibly to take account of this.

H6

Policy H6 proposes that all new residential development should meet Category 2 of Approved Document M, that 10% of market housing should meet Category 3 and 15% of affordable housing should meet Category 3.
NPPG (56-002) requires that these optional standards can only be justified where the Local Planning Authority has gathered evidence to demonstrate the need.
Whilst the HEDNA suggests that these needs are likely to increase, there is no justification currently for requiring 10% of market housing to meet Category 3 in response to the need for 2.3%; or for requiring that 15% of affordable housing should meet Category 3 in response to the need for 7.1%.
Furthermore, the provision of extra care units has not been tested in the Viability Assessment and as such the effects of this policy are unknown.
The opportunity for such extra care accommodation could be provided at the new settlement/s once these are identified in the early review.
The policy encourages specialist types of housing at 'all residential schemes'. This appears to leave sufficient flexibility but we are concerned that the policy approach is 'subject to taking account of viability'. This suggests that even very small schemes may have to disprove that it cannot include specialist housing.
Such provision should be supported within policy but there is currently no justification for the levels of provision identified in H6.

S2

Policy S2 makes provision for a total of 27,400 homes. 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 almost certainly increase significantly, once the standardised methodology becomes part of national policy and so additional provision should be supported or planned for (including through early review). The standardised methodology identifies an annual local housing need of 1,499 in Aylesbury Vale and 3,039 across Buckinghamshire. This compares to the proposed annual housing requirement of 970 in Aylesbury Vale and 2,310 across Buckinghamshire.
Therefore additional mechanisms will need to be identified now to address the resultant shortfall. This will need to include the identification of new sites in the Plan and through the proposed early review.
The wording of the policy will also need to be reviewed, as it states that provision will be made for 27,400 homes when paragraph 3.17 identifies that 29,016 homes have already been identified. This means that the policy as drafted will be ineffective and that it will be instantly obsolete.
The policy identifies only 1,095 dwellings to be delivered at the 19 medium villages. The medium villages are therefore accommodating quite limited growth and we consider that this figure, referred to by criterion 'h)', should be expressed as a minimum figure.
Presenting the figure as a minimum is important because, as stated above, the housing requirement is likely to increase and additional housing sites will need to be found.
Relatively limited growth is being proposed at the medium village and we consider that additional sites exist at these villages to support their sustainable growth and also help deliver the required housing. Sites at medium villages can make an important contribution to early housing delivery as they provide a different product to larger urban extensions and can often be quicker to deliver.
Paragraph 3.16 states that the future growth of medium villages reflects the capacity of these settlements to accommodate development. We question what this capacity is based on. For example, the Settlement Hierarchy (September 2017) evidence paper confirms Newton Longville to have a population of 1,111 and to meet 6 of the sustainability criteria, but only 17 dwellings will be allocated.
In comparison, Maids Moreton has a population of 847 and meets 6 criteria, yet 170 dwellings are to be allocated at the settlement.
Furthermore, paragraph 4.152 confirms that there is an 'excess' of suitable sites, so the most sustainable has been selected'. If Newton Longville has similar sustainability credentials to a settlement that will accommodate 170 dwellings and suitable sites are available at Newton Longville, we consider that there is no reason to limit sustainable growth at Newton Longville.

T7

We are concerned that the viability of providing electric charging points has not been assessed.
Furthermore, whilst we support the move toward electric vehicles, our experience is that trying to require this via planning policy is problematic. For example, there is no single 'charging point' design and different vehicles use different charging plug types. Future land ownership issues on sites when the properties are sold can cause problems for the routing/laying out of charging cables, and requiring communal charging creates problems with electricity billing and management of parking spaces for EV vehicles.
In addition, EV technology is also moving very quickly and any local plan policy that is too specific is likely to become outdated very quickly. Wireless charging is being developed for example, destination charging is increasingly important and it is also predicted that people will own and drive cars differently in the future.
Consumers are also buying EV's in ever greater numbers, and it is not considered necessary, or appropriate, for planning policy to be over prescriptive in this regard.

Object

VALP Proposed Submission

Representation ID: 1453

Received: 13/12/2017

Respondent: Mr David Vowles

Legally compliant? Not specified

Sound? No

Duty to co-operate? Yes

Representation Summary:

Policy D2 should be clarified and reference to medium villages deleted to take Account of the Rural Exceptions Policy (H2) and my suggestedd changes to Policies S2, S3 and Table 2

Full text:

Policy should be clarified and reference to medium villages deleted to take Account of the Rural Exceptions Policy (H2) and my suggestedd changes to Policies S2, S3 and Table 2

Object

VALP Proposed Submission

Representation ID: 1487

Received: 13/12/2017

Respondent: The Fingask Association

Agent: Rural Solutions

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Criteria a) and b) are overly restrictive. In accordance with the NPPF, the location of development should be assessed on its sustainable development merits and allow for sustainable development to be brought forward. This draft policy has the effect of restricting sustainable development from coming forward. All applications should be considered on their own merits.
On the above basis this policy is not effective or in accordance with national policy.

Full text:

Please find attached representations prepared by Rural Solutions Ltd, on behalf of The Fingask Association.

The Fingask Association control and manage the site known as 'Land north of Avenue Road' in Maids Moreton.

The following documents comprise our representations:

- Representations report prepared by Rural Solutions;
- Appendix 1 - Comparative sites review of potential landscape, visual and ecological issues assessment (Anthony Jellard Associates);
- Appendix 2 - Suitability of land north of Avenue Road, Maids Moreton (Ref:MMO001) (Rural Solutions);
- Appendix 3 - Heritage Statement (Graham Frecknall Architecture and Design);
- Appendix 4 - Extended Phase 1 Habitat Survey inc. Hedgerow Survey (John Campion Associates Ltd); and
- Appendix 5 - Landscape and Visual Assessment (Anthony Jellard Associates).

Object

VALP Proposed Submission

Representation ID: 1521

Received: 14/12/2017

Respondent: Lands Improvement Holdings (LIH)

Agent: Savills Oxford

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Policy D2 is a restrictive policy that is not in accordance with the permissive approach set out in the NPPF.

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: 1530

Received: 14/12/2017

Respondent: Catesby Estates Limited

Agent: Barton Willmore

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

This approach is not however considered to accord with the requirements of the NPPF for a Local Plan
to be 'positively prepared' and should be considered unsound. Indeed, as currently drafted, Policy D2
would restrict housing insofar that it does not allow for a balanced judgement to be made when
assessing the suitability of individual development proposals. Instead, draft Policy D2 simply aligns
itself to the delivery of allocated sites within the emerging VALP.

No definition or guidance is
provided by the Council as to what will be regarded as a 'timely manner'.

Full text:

Please find enclosed a copy of our representations to the VALP proposed submission consultation, submitted on behalf of Catesby Estates Limited.

Object

VALP Proposed Submission

Representation ID: 1622

Received: 14/12/2017

Respondent: Gladman Developments Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Policy as drafted is too restrictive. Needs to provide greater flexibility for delivery outside of the allocations.

Full text:

Please see attached representation and appendices.

Object

VALP Proposed Submission

Representation ID: 1695

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 Summary:

The new policy bears no relation to a potential new settlement. This new policy takes a very conservative view of facilitating development, indicating that only small scale development will be permitted, unless the Council's monitoring of housing land indicates dips in delivery that would leave the Plan-led approach vulnerable.

As indicated elsewhere in this report, RPS would urge caution in taking such a restrictive view in the Local Plan, particularly in light of a potential discrepancy in the calculation of housing need. RPS considers that this policy should be rewritten in a more flexible way.

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).

Support

VALP Proposed Submission

Representation ID: 1720

Received: 14/12/2017

Respondent: Wates Developments Ltd.

Agent: Boyer Planning Ltd

Representation Summary:

The allocation of the site BUC046 in the VALP is fully supported. The technical work undertaken to date confirms that a scheme of 420 dwellings could be successfully achieved on the site. Wates full endorses the allocation and the number of dwellings proposed and makes a separate representation on the site allocation policy criteria.

Full text:

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

Object

VALP Proposed Submission

Representation ID: 1722

Received: 14/12/2017

Respondent: Mr Roger Williams

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The plan is unsound because it applies different environmental protection policies to villages not according to the environmental circumstances but to their size category.

This is of particular importance to the hilltop village Brill the special character of which would be threatened by the policy D2 which allows for development outside the village footprint.

Full text:

Policy D2
1.0 Introduction
1.1 The plan is unsound because it applies different environmental protection policies to villages not according to the environmental circumstances but to their size category.
1.2 The abandonment of the mechanistic approach of the Draft Consultation Document which resulted in 96 houses being allocated to Brill by applying crude percentages according to their size categorisation is welcome. However, the Submission Document is unsound as it still adopts a mechanistic approach to categorising villages as small, medium or large and then applying policies which do not take into account qualitative factors. The result of this is that Brill, which is categorised as a Medium Village is afforded less protection from unsuitable development than smaller Villages Because:
(a) Policy D2 (p.115) (development at Strategic Settlements, Large and Medium Villages) allows for expansion outside the development footprint, whereas Policy D3 (p 144) (development at Smaller Villages) restricts development to within the village footprint. Also:
(b) Unlike Small Villages, being included in the Medium Villages category implies the need to "make some contribution to meeting the housing needs of the district" (p 134 para 4.152). Also:
(c) There is an implication in the "Delivering the allocated sites" section (para 4.152) that subject to more certainly about access, the HELAA sites (Housing and Economic Land Availability Assessment May 2016) at Brill could be developed. Yet, the HELAA assessments rejected at the 4 Brill sites on other than just grounds access.

2.0 The Need for Qualitative Factors to be Included
The standardisation of approach of Policy D2 to development in all settlements, other than Small Villages, fails to take account of the considerable differences in the character and settings of the settlements. Specifically for Brill its historic character, hilltop and landscape setting. (The particular constraints applying to Brill were endorsed by the conclusions of the HELAA assessment). This special character would be threatened by indiscriminate development "outside the development footprint of the village" as allowed by Policy D 2.

Object

VALP Proposed Submission

Representation ID: 1752

Received: 14/12/2017

Respondent: Landseer Properties Ltd

Agent: BB Architecture and Planning

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

We consider the specific strategic policies and delivery policies; and the approach to distribution
through the HELAA and settlement hierarchy are intrinsically flawed and therefore not sound or
Framework compliant.
Overall the housing policies proposed seek to restrict the significant boost in housing required by
Framework para. 47, and seemingly offer no room for manoeuvre for new development, particularly
in the rural areas that is over and above the commitments and allocations of housing proposed in the
plan.

Full text:

SEE ATTACHMENTS

Object

VALP Proposed Submission

Representation ID: 1834

Received: 14/12/2017

Respondent: Rectory Homes Limited

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

he policy states that in the event of allocated sites not being delivered at the anticipated rate, then the policy will not be applied. Further clarity in the policy is required as to the circumstances that would trigger this event, for instance if the Council's Housing Land Supply Statement identifies a shortfall in housing land supply with a need to release additional land resources.

Full text:

Please find attached representations submitted by Rectory Homes in response to the consultation on the Vale of Aylesbury Local Plan Proposed Submission, together with an appended report which forms part of the supporting evidence to these representations.

Object

VALP Proposed Submission

Representation ID: 1933

Received: 14/12/2017

Respondent: Revera Limited

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

An objection remains in respect of the lack of any allocation to Bierton (which continues to be "downgraded" to a Medium Settlement), which has been subsumed into the housing requirement of Aylesbury. Our objection to the reclassification of Bierton from a Larger Village to a Medium Village still remain valid.
The principle of the approach in Policy D2 is to be welcomed as this provides sufficient flexibility to respond to housing shortfalls as they arise.

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: 1957

Received: 14/12/2017

Respondent: Careys New Homes

Agent: Bidwells

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Representation Summary:

Whilst we do not object specifically to Policy D2, I would like to reiterate that we consider that proposed
development of my client's site at Wingrave represents an achievable, suitable and deliverable site to
support the necessary housing growth for Aylesbury Vale as detailed under our response to Policy S2 and
we request the request the allocation of the site for housing.

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: 1966

Received: 14/12/2017

Respondent: Edward Ware Homes

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Policy D2 is too restrictive. There is no definition of 'small scale' trying to establish a definition would be fruitless as one would expect different definitions depending upon whether a site is in a village or one of the strategic settlements.

The supporting text at paragraph 4.122 says that unallocated sites will not normally be permitted. The housing requirement should be expressed as a minimum figure. It is likely to restrict development that constitutes sustainable development.

It does not allow for a proper balancing exercise to be undertaken.

Specific comments made on criteria e, f and g.

Full text:

VALP consultation- land at Broadway, Grendon Underwood

Please find the attached representations to the VALP consultation on behalf of Edward Ware Homes. (includes a layout plan for one of the sites and a site boundary plan for the other)


Full text if there is more than the summary:

Para 4.151-4.154

Paragraph 4.154 seeks to prevent development at medium villages (where it is not allocated) and allow it 'only in exceptional circumstances where it can be demonstrated that sites allocated are not coming forward at the rate anticipated'.
This is not justified and is too restrictive. The NPPF is clear that the emphasis is to boost housing supply. The wording of the policy incorrectly and inappropriately plans for the Council to fail to provide sufficient housing before allowing development to occur at villages. Such an approach is at odds with the NPPF and the approach to achieving sustainable development.
Land east of Broadway, Grendon Underwood
Edward Ware Homes is promoting a circa 3.5ha site located to the south of the village, located behind development off Main Street (see enclosed plan) for residential development.
The site was the subject of an outline planning application (ref 16/03170/AOP) and a dismissed appeal (ref 3169545) for 82 dwellings.
The appeal Inspector concluded that thatproposed development would result in a significant harmful impact on the character and appearance of the landscape and setting of Grendon Underwood.
However, in Common Ground, the Council accepted that:
* *The site is in a sustainable location for housing development in principle,
* *Grendon Underwood has a range of services and facilities that make it a sustainable location for housing,
* *The provision of 82 dwellings at the village was acceptable in principle,
* *There are no technical reasons (e.g. agricultural land, highway, ecology, flooding or drainage) that would prevent the development

The appeal Inspector did not reach a different conclusion on the above points. Thus, the acceptability of the site in principle to provide housing,is firmly established.
Given our comments regarding the need to increase the housing requirement andthe futureneed to increase housing numbers in response to the standardised methodology, we suggest thatadditional sites need to be allocated in the VALP and the site should be identified for residential development.
In response to concerns raised by the Inspector we have enlarged the site areafrom that of the application and appeal to include additional land to the southso that:
* *Residential developmentparcelsretainand respondto the Public Right of Way
* *Views from the PROW of the church retained
* *Additional public open space and landscaping is provided, to create a stronger landscape screento the site and village edge
* *Public open space adjoining the existing playing fields and playground

As such, the landscape harm that the Inspector identified can be reduced, and the site canhelp meet the housing shortfall.
A framework plan showing the enlarged site area and a suggestion of how development could be provided on the site is submitted.
We consider that medium villages should deliver more housing development than the Plan currently proposes and that this site presents an ideal opportunity to help meet housing need. The site is deliverable and can come forward very quickly.
Land to the south of Darley's Close, Grendon Underwood
Edward Ware Homes also has an interest in land south of Darley's Close. All, or part of this site could be allocated for residential development.
The site adjoins the existing settlement boundary and is in close proximity to local services.

D2

Policy D2 is too restrictive and seeks to limit development on sites not allocated by the Development Plan to 'small scale areas' within built up areas. There is no definition of 'small scale' and we would suggest that in any case, trying to establish a definition would be fruitless as one would expect different definitions depending upon whether a site is in a village or one of the strategic settlements.
The supporting text at paragraph 4.122 says that unallocated sites will not normally be permitted on the basis that the level of growth is being met by proposed allocations. But the housing requirement should be expressed as a minimum figure and the NPPF is very clear that a fundamental objective of the planning system is to boost housing supply.
The policy is therefore unclear, inappropriate and unjustified and is likely to restrict development that constitutes sustainable development.
The policy does allow flexibility for sites to come forward where delivery of housing is failing, but we consider that it is not appropriate for the VALP policies to plan to fail. The NPPF is very clear that the emphasis should be to meet the full objectively assessed needs.
In addition, the policy states that additional development will 'only' be permitted where housing delivery is not being maintained. This does not allow for the proper balancing exercise to be undertaken whereby positive material considerations should be balanced against any conflict with the Development Plan.
Criterion e) requires that development should not 'adversely affect its character and appearance '. However, all development is likely to result in some harm, however limited that harm is.
Similarly, in respect to criteria f)and g), it will not always possible to retain all natural features on a site or have no adverse impact on environmental assets. Therefore, the policy should be worded flexibly to take account of this.

H6

Optional Standards
Policy H6 proposes that all new residential development should meet Category 2 of Approved Document M, that 10% of market housing should meet Category 3 and 15% of affordable housing should meet Category 3.
NPPG (56-002) requires that these optional standards can only be justified where the Local Planning Authority has gathered evidence to demonstrate the need.
Whilst the HEDNA suggests that these needs are likely to increase, there is no justification currently for requiring 10% of market housing to meet Category 3 in response to the need for 2.3%; or for requiring that 15% of affordable housing should meet Category 3 in response to the need for 7.1%.
Furthermore, the provision of extra care units has not been tested in the Viability Assessment and as such the effects of this policy are unknown.
The opportunity for such extra care accommodation could be provided at the new settlement/s once these are identified in the early review.
The policy encourages specialist types of housing at 'all residential schemes'. This appears to leave sufficient flexibility but we are concerned that the policy approach is 'subject to taking account of viability'. This suggests that even very small schemes may have to disprove that it cannot include specialist housing.
Such provision should be supported within policy but there is currently no justification for the levels of provision identified in Policy H6

S2

Policy S2 makes provision for a total of 27,400 homes. 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 almost certainly increase significantly, once the standardised methodology becomes part of national policy and so additional provision should be supported or planned for (including through early review). The standardised methodology identifies an annual local housing need of 1,499 in Aylesbury Vale and 3,039 across Buckinghamshire. This compares to the proposed annual housing requirement of 970 in Aylesbury Vale and 2,310 across Buckinghamshire.
Therefore additional mechanisms will need to be identified now to address the resultant shortfall. This will need to include the identification of new sites in the Plan and through the proposed early review.
The wording of the policy will also need to be reviewed, as it states that provision will be made for 27,400 homes when paragraph 3.17 identifies that 29,016 homes have already been identified. This means that the policy as drafted will be ineffective and that it will be instantly obsolete.
The policy identifies only 1,095 dwellings to be delivered at the 19 medium villages. The medium villages are therefore accommodating quite limited growth and we consider that this figure, referred to by criterion 'h)', should be expressed as a minimum figure.
Presenting the figure as a minimum is important because, as stated above, the housing requirement is likely to increase and additional housing sites will need to be found.
Relatively limited growth is being proposed at the medium village and we consider that additional sites exist at these villages to support their sustainable growth and also help deliver the required housing. Sites at medium villages can make an important contribution to early housing delivery as they provide a different product to larger urban extensions and can often be quicker to deliver.
Paragraph 3.16 states that the future growth of medium villages reflects the capacity of these settlements to accommodate development. We question what this capacity is based on. For example, the Settlement Hierarchy (September 2017) evidence paper confirms Grendon Underwood to have a population of 1,111 and to meet 7 of the sustainability criteria.
In comparison, Maids Moreton has a population of 847 and meets 6 criteria, yet 170 dwellings are to be allocated at the settlement.

T7

We are concerned that the viability of providing electric charging points has not been assessed.
Furthermore, whilst we support the move toward electric vehicles, our experience is that trying to require this via planning policy is problematic. For example, there is no single 'charging point' design and different vehicles use different charging plug types. Future land ownership issues on sites when the properties are sold can cause problems for the routing/laying out of charging cables, and requiring communal charging creates problems with electricity billing and management of parking spaces for EV vehicles.
In addition, EV technology is also moving very quickly and any local plan policy that is too specific is likely to become outdated very quickly. Wireless charging is being developed for example, destination charging is increasingly important and it is also predicted that people will own and drive cars differently in the future.
Consumers are also buying EV's in ever greater numbers, and it is not considered necessary, or appropriate, for planning policy to be over prescriptive in this regard.

Object

VALP Proposed Submission

Representation ID: 1993

Received: 14/12/2017

Respondent: Aylesbury Vale Estates LLP

Agent: Savills Reading

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

this policy is unduly restrictive and onerous. The Policy seeks to restrict proposals for non-allocated residential development within the built up areas of the strategic settlements, larger and medium villages to small-scale areas of land via infill and development that consolidates existing settlement patterns. The Policy will only support additional (i.e. large-scale) development on brownfield land (and land adjacent to the existing developed footprint of the settlement) in the circumstances where the Council's monitoring of delivery across the district shows that the allocated sites are not being delivered at the anticipated rate and subject to a number of criteria.

Full text:

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