Aylesbury Vale Area

FMM016

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Object

VALP Further Main Modifications

Representation ID: 3881

Received: 09/02/2021

Respondent: Vistry Group

Agent: Define Planning & Design

Legally compliant? Yes

Sound? No

Representation Summary:

Officer summary:
Whilst there has been a marginal increase in the number of dwellings to be delivered in large villages in the
plan period, FMM016 (which seeks to modify Spatial Strategy for Growth Table 1 and sets out the composition of completions and commitments by settlement hierarchy level) makes it clear that the increase in delivery at large
villages has occurred as a result of prior completions and existing commitments earlier on in the plan period, rather
than being derived from the provision of any further allocations within the ‘large villages.’
Whilst the marginal increase in the provision of housing at large villages is welcomed, the modified plan fails to
allocate a sufficient quantum of development for the remainder of the plan period, and as such fails to support
large villages. To achieve this, and also to allow for an increased buffer over AVDC’s housing requirement, AVDC should maximise the potential of existing allocations.
Given that there are no technical constraints that would limit the site’s capacity to 26 dwellings, the capacity of
‘Land South of Creslow Way, Stone’ (STO008) should be increased to c. 60 dwellings.

Change suggested by respondent:

The modified housing trajectory (as proposed to be modified through FMM106) should be further modified to
identify a development capacity of c. 60 dwellings at ‘Land South of Creslow Way, Stone’ (STO008) rather than 26 dwellings as currently drafted in order to achieve an efficient use of land. The overall housing supply (as modified by FMM001) and other relevant alterations (e.g. the buffer as modified by FMM012) should be modified in light of this change, and the allocation policy should also be updated to reflect this.

Full text:

FMM001 proposes a reduction in the District’s overall housing supply during the plan period (2013-2033), from
30,233 to 30,134 dwellings. Indeed, that alteration is also reflected in FMM012, which notes that this results in a
reduction in the buffer of housing that is to be provided above the overall housing requirement from 5.7% (as per
the previous iteration of the plan) to 5.4%.
The reduction in the total number of dwellings to be delivered across the plan period is informed directly by the housing trajectory, which is proposed to be amended through FMM106. Notably, those amendments have resulted in reductions to delivery from D-AGT2 South West Aylesbury (reduced to 1,300 dwellings in the plan period from 1,400 dwellings) and D-AGT3 Aylesbury North of A41 (reduced to 600 dwellings in the plan period from 757 dwellings previously).
Whilst the amendments to the trajectories of those sites are welcome, the broader point still stands that the
District’s housing supply is still largely dependent on delivery from a number of large sites within the same
settlement (most notably Aylesbury town). Indeed, the housing trajectory as modified by FMM106 anticipates that 8,877 dwellings are to be delivered within the six strategic allocations surrounding Aylesbury (D-AGT1 to D-AGT6) between 2020 and 2033; which comes in addition to the delivery of 3,036 dwellings within those developments in
the plan period to date (April 2013 – April 2020). Clearly, that is a significant proportion of AVDC’s supply to be
delivered from just 6 sites, and indeed delivery from those sites totals some 40% of the District’s supply.
Whilst the inclusion of large, strategic sites within AVDC’s trajectory is of course sound in principle, the reliance on
large developments in a single settlement fails to reflect that larger sites frequently stall during the course of their
development. The Letwin Review of Build Out (Final Report, October 2018) succinctly captures the reasons for the reduction of the build out rates of larger sites (such as the aforementioned allocations D-AGT1 to D-AGT6).
Firstly, the Letwin Report highlights that delays can often occur at the early stages of development as a result of the
complexities of delivering the necessary transport and utilities-based infrastructure to accommodate development
of this scale. That is a particularly relevant consideration given the nature of the proposed development sites
adjacent to Aylesbury town, and indeed the revised policies maps (as proposed to be modified by FMM107)
highlight the significant road infrastructure that is still required to be delivered to facilitate those development sites.
Specifically, the modified policies map highlights that delivery of the Eastern Link Road North, Eastern Link Road
South, Southern Link Road, South East Aylesbury Link Road, the Stoke Mandeville A4010 Realignment, and the
South West Aylesbury Link Road have yet to be completed. That infrastructure provision directly relates to parcels
AGT1, AGT2, AGT3, and AGT4, and as such their deliverability is dependent on the timely delivery of it. Indeed,
whilst it is accepted that the majority of those infrastructure projects are nearing completion, AVDC must be aware
that the delivery of large pieces of infrastructure is volatile, and that delays can occur for a multitude of reasons
even in the latter stages of a project.
As such, whilst modified under FMM106 to marginally improve the realism of the timelines for delivery, it is
considered that the amended Housing Trajectory still does not reflect the reality of delivering a number of large
sites around Aylesbury town. Indeed, the Housing Trajectory suggests that residential delivery at AGT4 will
commence from 2022/23 (as little as four months after the highways project is scheduled to be completed), and
that delivery at the residual areas of AGT1 and AGT2 will commence in 2024/25. Those timescales fail to take into
consideration those complexities, and the need for those developments to first navigate through the planning
application process.
If and when those issues have been overcome, the Letwin Report also notes that build out rate can be limited by the
effective market absorption rate of developments. Indeed, the report concludes that “the homogeneity of the types
and tenures of the homes on offer on these sites, and the limits on the rate at which the market will absorb such
homogenous products, are the fundamental drivers of the slow rate of build out” (paragraph 1.7). This is particularly
prevalent given the sheer concentration of new housing to the settlement of Aylesbury. Evidently, a considerable
number of dwellings will be delivered in the Garden Town at the same time and, in reflection of the findings of the
Letwin Report, the release of these units onto the open market could effectively flood the market. Given that the
absorption of properties can directly stall the build-out of sites, this may be a considerable issue within a settlement
where six allocations are delivering some 40% of AVDC’s supply of housing over the plan period.
That is not to say, however, that the modified housing trajectory should reduce its aspiration to deliver larger sites.
However, with the reduced buffer now proposed within the modified VALP of just 5.4% (see FMM012) there is even
less scope for slippage in the delivery of these clearly complex sites. Therefore, it is Vistry Group’s position that the
buffer should be increased further to allow flexibility in AVDC’s supply of land and to ensure that there is certainty
that the plan can deliver over the plan period. Until that approach is taken, the plan cannot be considered
“effective” in accordance with NPPF Paragraph 35c.
Specifically, the Letwin Report finds that “we will continue to need more new housing both on the smaller sites and
on large sites” (paragraph 1.8 (b)), which reflects the findings of the NPPF that “small and medium sized sites can
make an important contribution to meeting the housing requirement of an area, and are often built-out relatively
quickly” (paragraph 68). The suggested amendment would therefore ensure that the plan is in accordance with the
NPPF in that regard.
In that light, and to address AVDC’s reliance on large sites and ensure that their land supply has sufficient flexibility,
AVDC should maximise the potential of small-medium sites. Indeed, whilst the plan proposes to allocate ‘Land South
of Creslow Way, Stone’ (STO008) for residential development, it puts forward a site capacity of just 26 dwellings,
which fails to take into consideration the suite of technical and environmental assessments that have previously
been submitted that demonstrate a more suitable capacity of c. 60 dwellings. The allocation policy, as currently drafted, fails to ensure an “efficient use of land” therefore as required by NPPF paragraph 122.
As such, to allow for an increased buffer of dwellings in the Council’s supply and to demonstrate an ‘efficient use of land’ in accordance with NPPF paragraph 122, the capacity of ‘Land at Creslow Way, Stone’ should be increased to 60 dwellings.

Whilst FMM001 proposes a reduction in the District’s overall housing supply during the plan period (2013-2033),
from 30,233 to 30,134 dwellings, FMM008 specifies that there has been an increase in housing provision at ‘large
villages’ over the plan period from 2,271 dwellings to 2,408 dwellings. Whilst the marginal increase in delivery at
‘large villages’ is welcomed, the VALP should ensure that it maximises development potential at such settlements,
given that the NPPF makes it clear that “planning policies should identify opportunities for villages to grow and
thrive”, and that development in such locations supports local services and the provision of infrastructure (NPPF
paragraph 78).
Indeed, whilst there has been a marginal increase in the number of dwellings to be delivered in large villages in the
plan period, FMM016 (which seeks to modify Spatial Strategy for Growth Table 1 and sets out the composition of
completions and commitments by settlement hierarchy level) makes it clear that the increase in delivery at large
villages has occurred as a result of prior completions and existing commitments earlier on in the plan period, rather
than being derived from the provision of any further allocations within the ‘large villages.’
Thus, notwithstanding that modification, the modified plan seeks to allocate land for just 26 dwellings within ‘large
villages’ in the remainder of the plan period. That is clearly an insufficient level of development for the remaining 13
years of the plan period across all villages and fails to reflect that, as identified in the settlement hierarchy, large
villages “have at least reasonable access to facilities and services and public transport, making them sustainable
locations for development”. Indeed, the allocation of such a small number of dwellings across the remainder of the
plan period fails to maximise the potential of such settlements, and certainly does not provide the investment that
such settlements require in order to support the provision of local services and facilities; and as such is contrary to
the aforementioned NPPF paragraph 78.
Indeed, it is notable that the figure is lower than the number of dwellings to be delivered from allocations at
‘medium villages’ (39 dwellings as per MM016), which appears to be at odds with a settlement hierarchy that
should fundamentally underpin the distribution of development in the District.
As such, it is Vistry Group’s position that the number of dwellings to be delivered at ‘large villages’, as proposed to
be modified by FMM008 and FMM016, should be increased further still through the identification of an increased
quantum of development through upcoming allocations (rather than commitments outside of the local plan review
process). That approach would also help to provide an increased buffer above AVDC’s housing requirement to
address the District’s dependence on large sites (please refer to Vistry Group’s representations to FMM001,
FMM012 and FMM106 for further commentary on this matter). Specifically, the increase in the number of
dwellings to be delivered at such locations should be achieved by maximising delivery from already allocated sites.
Indeed, a suite of technical and environmental assessments have been submitted in relation to ‘Land at Creslow Way, Stone’ (STO008) that identifies that the site is suitable to accommodate the development of c. 60 dwellings, rather than 26 dwellings as currently suggested. Those submissions identified that there are no technical or environmental constraints that would limit the capacity of the site to 26 dwellings and that the site could effectively accommodate a development size of circa 60 dwellings. That position was noted within the previous consultation and, whilst Vistry Group recognises that the Inspector has stated that AVDC’s response to not increasing the site’s capacity has been accepted, that response was generic in its nature and offered no technical-based justification for the decision not to maximise the available capacity on land that forms an integral part of an existing proposed allocation within a large village.
Indeed, the current allocation confirms that AVDC recognise the site’s suitability for residential development.
However, by limiting the site area and potential capacity, AVDC are unduly restricting potential development and
residential land delivery in this location, and thus are failing to promote an “efficient use of land” in accordance with NPPF paragraph 122.
As such, the capacity of site STO008 (Land South of Creslow Way, Stone) as identified in the housing trajectory thatis proposed to be modified by FMM106 should be updated to 60 dwellings both to maximise the efficient use of the site and to allow for a further buffer above the Council’s housing requirement. To accommodate that, the policies map for Stone, proposed to be amended under FMM107, should be further amended to include the whole of Vistry Group’s site ownership, with the landscape buffer amended to reflect the boundary of that land.