Aylesbury Vale Area

H1 Affordable housing

Showing comments and forms 1 to 30 of 56

Object

VALP Proposed Submission

Representation ID: 160

Received: 11/12/2017

Respondent: Mr David Saunders

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Policy H1 introduces a general requirement for affordable housing which might be less appropriate for specific neighbourhood areas than the requirements in existing neighbourhood plans for those areas. However this policy, being more recent, would override the neighbouthood plan policies, contrary to national policy. The attached pdf file gives a detailed explanation of the cause of this anomaly and proposes a solution.

Full text:

Policy H1 introduces a general requirement for affordable housing which might be less appropriate for specific neighbourhood areas than the requirements in existing neighbourhood plans for those areas. However this policy, being more recent, would override the neighbouthood plan policies, contrary to national policy. The attached pdf file gives a detailed explanation of the cause of this anomaly and proposes a solution.

Object

VALP Proposed Submission

Representation ID: 376

Received: 05/12/2017

Respondent: Mr Phil Yerby

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

No development should be allowed if a higher quota of 35% cannot be met. If this plan is to have any credibility about genuinely providing houses for those in need then this policy needs to be enforceable.

The council have openly ignored this already in their own site at Woodlands where they have allowed themselves to come forward with 20% affordable houses which makes a mockery of the current policy. This policy will openly be 'abused' as it allows a 'get out' clause from the outset.

Full text:

No development should be allowed if a higher quota of 35% cannot be met. If this plan is to have any credibility about genuinely providing houses for those in need then this policy needs to be enforceable.

The council have openly ignored this already in their own site at Woodlands where they have allowed themselves to come forward with 20% affordable houses which makes a mockery of the current policy. This policy will openly be 'abused' as it allows a 'get out' clause from the outset.

Object

VALP Proposed Submission

Representation ID: 402

Received: 06/12/2017

Respondent: Ms Alison Watt

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The term "affordable housing" covers both social rented and shared ownership (among other forms of tenure). Many people who need affordable housing do not have access to shared ownership, both because of its cost and the need to qualify for a mortgage. Therefore, in order to meet the housing need of AVDC, the VALP should define what proportion of affordable housing should be social rented. South Oxfordshire, stipulates 75% social rented in its draft Local Plan. Given the lack of other evidence of need for social rented housing, AVDC should adopt a similar proportion.

Full text:

The term "affordable housing" covers both social rented and shared ownership (among other forms of tenure). Many people who need affordable housing do not have access to shared ownership, both because of its cost and the need to qualify for a mortgage. Therefore, in order to meet the housing need of AVDC, the VALP should define what proportion of affordable housing should be social rented. South Oxfordshire, stipulates 75% social rented in its draft Local Plan. Given the lack of other evidence of need for social rented housing, AVDC should adopt a similar proportion.

Object

VALP Proposed Submission

Representation ID: 451

Received: 12/12/2017

Respondent: Hampden Fields Action Group

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

No development should be allowed if a higher quota of 35% affordable housing cannot be met. If the VALP is to have any credibility about genuinely providing houses for those in need then this policy must be enforceable. This policy will openly be 'abused' as it allows a 'get out' clause from the outset.The council have openly ignored this already in their own development at Woodlands where they have allowed themselves to come forward with 20% affordable houses which makes a mockery of the current policy.

Full text:

No development should be allowed if a higher quota of 35% affordable housing cannot be met. If the VALP is to have any credibility about genuinely providing houses for those in need then this policy must be enforceable. This policy will openly be 'abused' as it allows a 'get out' clause from the outset.The council have openly ignored this already in their own development at Woodlands where they have allowed themselves to come forward with 20% affordable houses which makes a mockery of the current policy.

Object

VALP Proposed Submission

Representation ID: 576

Received: 14/12/2017

Respondent: Mr Andrew Docherty

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

It is recommended that the proportion of affordable housing sought in Proposed Policy H1 be increased to 35%. This would accord with the figure used in some Neighbourhood Plans.
A higher figure should be the starting point, as in other Districts in the County, with developers having to make a viability case for a reduced figure.

Full text:

It is recommended that the proportion of affordable housing sought in Proposed Policy H1 be increased to 35%. This would accord with the figure used in some Neighbourhood Plans.
A higher figure should be the starting point, as in other Districts in the County, with developers having to make a viability case for a reduced figure.

Object

VALP Proposed Submission

Representation ID: 654

Received: 12/12/2017

Respondent: Great Horwood Parish Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Please see attached document.

Full text:

Please see attached document.

Object

VALP Proposed Submission

Representation ID: 694

Received: 12/12/2017

Respondent: Mr Alan Sherwell

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

The figure of 25% is too low to meet the District's needs and there needs to be a distinction between affordable housing (which is cheaper than market housing but, generally not affordable to most) and social housing. There is a chronic need for rented accommodation that is not private sector rented. I would be prepared to accept 25% if there was a stipulation that half of it would be social housing for rent - otherwise, the requirement should be at least 33% if not more.

Full text:

The figure of 25% is too low to meet the District's needs and there needs to be a distinction between affordable housing (which is cheaper than market housing but, generally not affordable to most) and social housing. There is a chronic need for rented accommodation that is not private sector rented. I would be prepared to accept 25% if there was a stipulation that half of it would be social housing for rent - otherwise, the requirement should be at least 33% if not more.

Object

VALP Proposed Submission

Representation ID: 698

Received: 13/12/2017

Respondent: Whaddon Parish Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

25% affordable housing, in some cases, including sites proposed in 'made' neighbourhood plans, is simply not high enough.

Full text:

The social/affordable housing, as worded at present is unsound. It states:
Residential developments of 11 or more dwellings gross or sites of 0.3ha or more will be
required to provide a minimum of 25% affordable homes on site. In addition: ...
The proportion of 25% has been selected after considering evidence from the Buckinghamshire
HEDNA, and the AVDC Viability Assessment Final Report. The Viability Assessment does however state, 'that different proportions could be appropriate for different sites'. For instance, a greenfield site should be capable of supporting a greater proportion of affordable houses than a brownfield site, which is very which is very likely to incur remedial land improvement costs.
The VALP recognises this at the Salden Chase housing allocation ( DNLV001) which proposes at least 30% affordable new housing.

In respect to sub heading 'b' regarding developers a site as being 'financially unviable', please see our response to Policy S5.

Object

VALP Proposed Submission

Representation ID: 720

Received: 13/12/2017

Respondent: Haddenham Village Society

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Representation Summary:

Paragraph 5.11 states "Alternative housing delivery methods that may include affordable housing, such as Community Land Trusts and Community Right to Build, will be considered in line with national policy and in accordance with Policy H1 Affordable Housing." Yet there is no mention of alternative housing delivery methods in Policy H1

Full text:

Paragraph 5.11 states "Alternative housing delivery methods that may include affordable housing, such as Community Land Trusts and Community Right to Build, will be considered in line with national policy and in accordance with Policy H1 Affordable Housing." Yet there is no mention of alternative housing delivery methods in Policy H1

Object

VALP Proposed Submission

Representation ID: 861

Received: 14/12/2017

Respondent: Vale of Aylesbury Housing Trust

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

the requirement to provide 25% affordable housing on sites of 11 units or more has decreased from 31% proposed in Summer 2016.

Will provision of 6,850 affordable homes address demand over 16 years when there are 3893 applicants registered on BucksHomesChoice in November 2017? Of these 2,307 are in bands A-D and eligible for affordable rented housing.

The 6850 figure quoted equates to 25% of the total number of homes rather than 25% of homes on schemes with an affordable housing requirement, which will be a lower figure.

officer note: reassigned from 1.15 to H1 for relevance

Full text:

Although based on the 21.3% requirement identified by the HEDNA (December 2016) the requirement to provide 25% affordable housing on sites of 11 units or more has decreased from 31% proposed in Summer 2016.

Will provision of 6,850 affordable homes address demand over 16 years when there are 3893 applicants registered on BucksHomesChoice in November 2017? Of these 2,307 are in bands A-D and eligible for affordable rented housing.

The 6850 figure quoted equates to 25% of the total number of homes rather than 25% of homes on schemes with an affordable housing requirement, which will be a lower figure.

Object

VALP Proposed Submission

Representation ID: 864

Received: 14/12/2017

Respondent: Vale of Aylesbury Housing Trust

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

the requirement to provide 25% affordable housing on sites of 11 units or more has decreased from 31% proposed in Summer 2016.

Will provision of 6,850 affordable homes address demand over 16 years when there are 3893 applicants registered on BucksHomesChoice in November 2017? Of these 2,307 are in bands A-D and eligible for affordable rented housing.

The 6850 figure quoted equates to 25% of the total number of homes rather than 25% of homes on schemes with an affordable housing requirement, which will be a lower figure.

Officer Note: reassigned to H1 from 1.13 for relevance

Full text:

Although based on the 21.3% requirement identified by the HEDNA (December 2016) the requirement to provide 25% affordable housing on sites of 11 units or more has decreased from 31% proposed in Summer 2016.

Will provision of 6,850 affordable homes address demand over 16 years when there are 3893 applicants registered on BucksHomesChoice in November 2017? Of these 2,307 are in bands A-D and eligible for affordable rented housing.

The 6850 figure quoted equates to 25% of the total number of homes rather than 25% of homes on schemes with an affordable housing requirement, which will be a lower figure.

Object

VALP Proposed Submission

Representation ID: 904

Received: 14/12/2017

Respondent: Mr R Horton

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

The amount of Affordable housing on larger developments should be 35% however on the AVDC own site Woodlands there is only 20% of Affordable housing.

Full text:

The amount of Affordable housing on larger developments should be 35% however on the AVDC own site Woodlands there is only 20% of Affordable housing.

Object

VALP Proposed Submission

Representation ID: 941

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 policy should be amended to secure affordable housing contributions on smaller sites in AONBs and Designated Rural Areas, in line with the latest guidance (See Government Planning Practice Guidance on Planning Obligations para 017).
The smaller site provisions apply to rural areas designated under s157 of the 1985 Housing Act, including National Parks, AONBs and Designated Rural Areas, which includes many parishes in Aylesbury Vale (see lists available here www.legislation.gov.uk/uksi/1997/625/schedule/1/made of whole parishes covered eg Ivinghoe, Edlesborough, and here
www.legislation.gov.uk/uksi/1997/625/schedule/2/made of mapped part parishes including Haddenham, Aston Clinton, Wendover etc.
The South Oxfordshire emerging local plan takes this approach.

Full text:

The policy should be amended to secure affordable housing contributions on smaller sites in AONBs and Designated Rural Areas, in line with the latest guidance (See Government Planning Practice Guidance on Planning Obligations para 017).
The smaller site provisions apply to rural areas designated under s157 of the 1985 Housing Act, including National Parks, AONBs and Designated Rural Areas, which includes many parishes in Aylesbury Vale (see lists available here www.legislation.gov.uk/uksi/1997/625/schedule/1/made of whole parishes covered eg Ivinghoe, Edlesborough, and here
www.legislation.gov.uk/uksi/1997/625/schedule/2/made of mapped part parishes including Haddenham, Aston Clinton, Wendover etc.
The South Oxfordshire emerging local plan takes this approach.

Object

VALP Proposed Submission

Representation ID: 1057

Received: 21/12/2017

Respondent: Dandara Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Object to H1: supports objective of policy. Clustering of maximum figure of affordable housing should be applied flexibly having regard to communities created following development.

Full text:

Dear Sir / Madam,

Town and Country Planning Act 1990
Representations to Proposed Submission VALP

Dandara Ltd for Land North of Aston Road and West of Stanbridge Road, Haddenham
Dandara Ltd purchased land located to the north of Aston Road and west of Stanbridge Road in Haddenham which benefits from outline planning permission for the following description of development:

"Construction of 280 no. dwellings, including 35 no. age - restricted dwellings, with associated garages, parking, estate roads, footways, pedestrian linkages, public open space, burial ground, community sports facility, strategic landscaping, drainage and other associated works" (ref. 14/02666/AOP).

Reserved Matter applications have been submitted to the Council under refs. 17/01841/ADP and 17/04543/ADP for four phases of development, with phases 1 and 2 due to commence on site in January 2018. These representations therefore focus on policies which would potentially impact upon the deliverability and viability of the development.

We would comment on the following policies contained within the November 2017 Proposed Submission draft Vale of Aylesbury Local Plan (VALP) 2013-33:

Dandara Ltd supports the objective of Policy H1 'Affordable Housing' seeking to secure a minimum of 25% affordable housing associated with qualifying developments. Whilst we also support the objective of "the affordable homes will be expected to be integrated throughout the development site", this should be applied flexibly taking into account the objective of creating mixed communities and the realities and costs associated with future management by registered providers. Our experience of the application of this policy is that the Council apply their 'clustering' policy of no more than 15 affordable housing units rigidly, without considering how neighbourhoods or communities would develop following scheme completion. As an example, affordable housing units that have a garden-to-garden relationship but do not share a common street or approach should not automatically be considered as representing a 'cluster' as the creation of mixed-tenure neighbourhoods are principally defined by the streets on which the houses are located, the source of daily interaction with neighbours, rather than who one shares a rear garden boundary with. The supporting text to the policy should recognise that any 'clustering' figure will be applied flexibly having regard to those communities created following development and the principal day-to-day interactions that will result;

Policy H5 'Self/Custom Build Housing' will expect developments proposing 100 dwellings and above to provide a percentage of serviced plots for sale to self / custom builders. Whilst the principle of supporting the self / custom build industry is supported, any policy requirement should be informed by entries contained within the self-build and custom housebuilding register alongside a consideration of deliverability and viability. If the Council is to require major developments to include such plots, it is imperative that they can be brought forward in parallel with the main development; do not conflict with the wider development in respect of scale, appearance or timescales; and are taken into account from a viability perspective given that such plots would be provided at below market value;

Dandara Ltd is supportive of the wording associated with Policy H6 whereby housing mix contained within the most up-to-date HEDNA "... are however a guide rather than a requirement as they may need to be varied on the basis of specific circumstances or evidence" (para. 5.55). The Council should apply flexibility when considering housing mix on individual sites including site specific considerations such as location, viability and market demand and whether the delivery of a higher proportion of smaller dwellings within urban areas may allow for more family sized housing to be delivered on Greenfield sites on the edge of urban areas and villages whilst maintaining close to the recommended HEDNA mix across the District as a whole;

Policy H6 'Housing Mix' requires "larger residential development schemes proposing 100 dwellings and above in strategic settlements will be expected to provide an element of self-contained extra care dwellings as part of the overall mix". The Council should ensure that the provision of extra care dwellings is fully taken into account within viability assessments associated with individual sites especially considering other cumulative 'planning gain' requirements such as affordable housing and self / custom build. It is noted that 'larger residential development schemes' in the policy refers to more than 300 houses which is a definition that should be retained within supporting para. 5.61;

Likewise, Policy H6 'Housing Mix' requires a proportion of new homes in developments to achieve Category 2 and Category 3 of Approved Document M: Volume 1 (Accessible and Adaptable Dwellings). Whilst such an objective is supported, the Council should again consider any viability implications of such standards especially taking into account the suite of 'planning gain' requirements including affordable housing, self / custom build and extra care provision. The supporting policy and evidence base should be in full accordance with Planning Practice Guidance (PPG) para: 008, ref ID: 56-008-20160519;

Policy H7 'Dwelling Sizes' is unevidenced and in conflict with national policy. If the Council is proposing a policy relating to 'dwelling sizes', any standard should accord with the 'Technical Housing Standards - Nationally Described Space Standard' (March 2015). PPG is clear that "where a Local Planning Authority (or qualifying body) wishes to require an internal space standard, they should only do so by reference in their Local Plan to the nationally described space standard" (para: 018, ref ID: 56-018-20150327). Policy H7 should therefore be deleted or amended to refer to nationally described space standards;

Dandara Ltd supports the principle of Policy BE2 'Design of New Development' requiring consideration of "the local distinctiveness and vernacular character of the locality". When considering local distinctiveness and vernacular character the supporting text should make clear that this includes all surrounding development not simply those elements of the townscape that the Council consider to be 'higher quality'. Our experience with the Authority is that they adopt a very narrow definition of local distinctiveness and vernacular character which often does not consider the broad range of building styles, materials and ages but rather focuses on those elements, most notably Conservation Areas or listed buildings, that the Council consider should be given elevated weight rather than considered as part of a balanced assessment of the collective character of the locality.

In summary, we consider that the Proposed Submission VALP is currently unsound as not being 'effective' due to the potential viability implications of individual policies - affordable housing, self / custom build, accessibility standards, extra care - not being considered cumulatively. In addition, we consider that Policy H7 is not 'consistent with national policy' by suggesting the application of an internal space standard not in accordance with the nationally described version.

I trust these representations are of interest and if you need any additional information or clarification on the points contained herein, please do not hesitate to contact me.

Yours faithfully,

John Richards,
Associate Director, Planning

Object

VALP Proposed Submission

Representation ID: 1118

Received: 14/12/2017

Respondent: Kier Property

Agent: Planning Potential

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The current wording of Policy H1, which seeks a minimum of 25% affordable housing leaves ambiguity in what the Council will be seeking and subsequently gives rise to uncertainty. As such, we suggest that Policy H1 is amended to "for residential developments of 11 or more dwellings gross or sites of 0.3ha or more, the council will seek a minimum of 25% affordable homes on site, subject to viability". This will give confidence to developers looking to invest.

Full text:

Please find the attached letter of representations for the proposed submission Vale of Aylesbury Local Plan dated 14/12/17 on behalf of our client, Kier Property. In addition, please find our completed response form, site location plan and our previous representations attached.

Object

VALP Proposed Submission

Representation ID: 1181

Received: 14/12/2017

Respondent: Lands Improvement Holdings Plc

Agent: Indigo Planning Limited

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

We object to the requirement for a financial assessment to justify a shortfall in affordable
housing provision to be "open-book". Financial assessments can contain commercially
sensitive information and discretion is required to ensure that information can be presented
exclusively to the Council when required.

Full text:

See attachment for full representation


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

Object

VALP Proposed Submission

Representation ID: 1212

Received: 14/12/2017

Respondent: Mr A.P. Smart

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

This is a vital topic. The proportion of affordable housing should be higher. Why is it so low? This needs to be explained.

Full text:

I have a number of points that I wish to respond to. This has been difficult due to the very short period given for this consultation. I am commenting on those matters where I have an informed opinion. There are a number of location that I feel unable to properly comment on (partly due to time constraints given for this consultation).

3.3 and Policy S1

This section is based on the assumption that building more houses will make the Vale area more prosperous and a better place to live. This is not so. Cramming ever more houses into an area that already suffers from significant traffic issues will not bring growth. I am already making day-to-day choices about whether it is worth going into Aylesbury because of the volume of traffic. More houses will make this worse. This extra housing does not offer any solution, only further worsening of current problems. This is not an effective strategy. The transport problems have to solved first. It is not adequate to hope that somehow more building will eventually solve the problem.

3.15 New Settlement

Why has this been dropped. Surely this is a better way to proceed. This indicates a serious lack of long-term strategy. This should be reviewed and re-opened.

3.22 Countryside gaps

Keeping the identity of villages and separate developments is very important and there should be a very strong statement or guarantee that such gaps are to be preserved. I have already seen many planned schemes which seek to undermine this objective (Hampden Fields being one such example, A41 Woodlands is another). This must stop. The assurance given are too weak.

4.125 RAF Halton

Putting an additional 1,000 houses in this area will be major problem. The road infrastructure is deficient and there are a small number of pinch points that make the road communication system vulnerable. Wendover is already pushed to capacity. There is already a lack of car parking in Wendover. This will make it worse. where are the people in Halton expected to shop and go to school? This is another example of the merging of settlements.

D-AGT4

Many of the points relate to flood issues and the problems that must be dealt with (largely aspirational in nature). Why is housing planned for this flood zone? I thought there was a national strategy to stop building on flood zones. This is madness.

The lack of detail regarding traffic is a concern. This plan will see a massive increase in traffic on the A41 in particular. This is planning negligence. Having backed-up traffic on the A41 (both ways) will not make Aylesbury more prosperous or help people have a better life. This is already a problem. I see a Park and Ride is planned. Is this an indication that the planners think the traffic problems will be as bad as those experienced by Oxford?

Policy H1 Affordable Housing

This is a vital topic. The proportion of affordable housing should be higher. Why is it so low? This needs to be explained.


In my opinion, this plan is not truly strategic. Long term strategy has been replaced buy a large number of ad-hoc schemes which the planners hope may go some way to meeting the end objectives. In doing this, there has been insufficient consideration given to important matters such as transport and maintaining the separate identities of settlements. These matters have to addressed first, to meet the existing problems. Just because it is physically possible to build houses at a location does not mean that it should happen. The linage between building more houses and an improvement for the people of Aylesbury Vale is not clearly made. It is too aspirational.

Object

VALP Proposed Submission

Representation ID: 1290

Received: 14/12/2017

Respondent: Mrs Pauline Day

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object, H1

Policy Hl: Affordable housing
All large developments should offer 35% affordable housing. The council's own Woodlands development only provides 20%. This will allow other developers to ignore the policy. The Plan is therefore not Justified (and probably not Consistent with national policy) in this important aspect.

Full text:

I object to this development as follows :

3.3 and Policy S1 Sustainable development
Placing too many houses in too small an area will ultimately lead to traffic problems that will lead to economic stagnation. This is neither a Justified nor an Effective strategy.


3.15 New settlement
AVDC should think long term and strategically and include a new town from the outset. The current Plan is not Justified as the most appropriate strategy.


3.22 Preserving character and identities of neighbouring settlements and resisting development compromising open countryside between settlements
The wording "will seek to preserve" is too weak. As an example, the planned developments at Hampden Fields and Stoke Mandeville entirely coalesce the villages with Aylesbury. This is not an Effective approach.


4.14 Aylesbury Town Centre
When planning to make Aylesbury Town Centre more attractive, AVDC need to consider more seriously the impact on town centre traffic from all the extra housing around the town. This element of the Plan is not Justified nor Effective for this reason.

4.16 Aylesbury Transport Strategy ATS
1) The ATS is based on flawed modelling, criticised by BCC's own Transport Consultants AECOM. This is not sound because a robust evidence base is missing.
2) Key parts of the "orbital strategy" are "aspirational" which means they will not happen until at least the next plan in 2034 and beyond. The Plan is therefore neither Positively Prepared nor Effective.

4.17 Interventions including outer link roads
The orbital roads are unlikely to take traffic away from the town centre in any meaningful way. 16,000 extra houses around Aylesbury will have a severe impact on the transport system. Because the evidence base is lacking, the interventions are neither objectively assessed, based on sound evidence, nor Effective.

Policy Dl: Delivering Aylesbury Garden Town
The sheer amount of growth cannot be accommodated in a sustainable way. Not Justified.

D-AGTl South Aylesbury
1) This creates coalescence between Aylesbury, Stoke Mandeville and Hampden Hall. Not Justified as the most appropriate strategy, therefore.
2) Placing 1,000+ houses, schools and other development along the South East Aylesbury Link Road creates a severe impact on the gyratory system and the surrounding road network. This means that it is not Effective in terms of sound infrastructure planning.


D-AGT3 Aylesbury north of A41 (Woodlands)
The amount of development in this location will have a severe impact on the local transport system especially the A41. Not Justified nor Effective.


D-AGT4 Aylesbury south of A41 (Hampden Fields)
1) The impact on the road system on the A41, A413 and gyratory system will be severe. Not Effective.
2) See also comments on 3.22

4.125 RAF Halton
The potential impact of 1,000 houses on the surrounding road network needs to be carefully assessed using a valid traffic model. Raises question of Positive Preparation.

Policy Hl: Affordable housing
All large developments should offer 35% affordable housing. The council's own Woodlands development only provides 20%. This will allow other developers to ignore the policy. The Plan is therefore not Justified (and probably not Consistent with national policy) in this important aspect.


7.16 East-West Rail
The VALP does not recognise the significance of East-West Rail to the Vale with energy or commitment. It is a 'key' infrastructure project and should be fully embraced. The current VALP cannot be said to put forward the 'most appropriate strategy' as a Justified plan would.


7.20 Oxford - Cambridge Expressway
Government support this scheme so AVDC needs to show that it is actively planning to capitalise on the opportunities for transport, housing and facilities that the scheme will bring forward. This is not 'Consistent with national policy'.

9.38 Air quality requirements on developers
Air quality is vital to health. The Council should commit in this Plan to positive policies and actions to improve air quality. Without this, this aspect of the Plan is not Positively Prepared nor Justified.

Object

VALP Proposed Submission

Representation ID: 1313

Received: 14/12/2017

Respondent: Mr John Day

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object, H1

Policy Hl: Affordable housing
All large developments should offer 35% affordable housing. The council's own Woodlands development only provides 20%. This will allow other developers to ignore the policy. The Plan is therefore not Justified (and probably not Consistent with national policy) in this important aspect.

Full text:

I object to this development as follows:

3.3 and Policy S1 Sustainable development
Placing too many houses in too small an area will ultimately lead to traffic problems that will lead to economic stagnation. This is neither a Justified nor an Effective strategy.


3.15 New settlement
AVDC should think long term and strategically and include a new town from the outset. The current Plan is not Justified as the most appropriate strategy.


3.22 Preserving character and identities of neighbouring settlements and resisting development compromising open countryside between settlements
The wording "will seek to preserve" is too weak. As an example, the planned developments at Hampden Fields and Stoke Mandeville entirely coalesce the villages with Aylesbury. This is not an Effective approach.


4.14 Aylesbury Town Centre
When planning to make Aylesbury Town Centre more attractive, AVDC need to consider more seriously the impact on town centre traffic from all the extra housing around the town. This element of the Plan is not Justified nor Effective for this reason.

4.16 Aylesbury Transport Strategy ATS
1) The ATS is based on flawed modelling, criticised by BCC's own Transport Consultants AECOM. This is not sound because a robust evidence base is missing.
2) Key parts of the "orbital strategy" are "aspirational" which means they will not happen until at least the next plan in 2034 and beyond. The Plan is therefore neither Positively Prepared nor Effective.

4.17 Interventions including outer link roads
The orbital roads are unlikely to take traffic away from the town centre in any meaningful way. 16,000 extra houses around Aylesbury will have a severe impact on the transport system. Because the evidence base is lacking, the interventions are neither objectively assessed, based on sound evidence, nor Effective.

Policy Dl: Delivering Aylesbury Garden Town
The sheer amount of growth cannot be accommodated in a sustainable way. Not Justified.

D-AGTl South Aylesbury
1) This creates coalescence between Aylesbury, Stoke Mandeville and Hampden Hall. Not Justified as the most appropriate strategy, therefore.
2) Placing 1,000+ houses, schools and other development along the South East Aylesbury Link Road creates a severe impact on the gyratory system and the surrounding road network. This means that it is not Effective in terms of sound infrastructure planning.


D-AGT3 Aylesbury north of A41 (Woodlands)
The amount of development in this location will have a severe impact on the local transport system especially the A41. Not Justified nor Effective.


D-AGT4 Aylesbury south of A41 (Hampden Fields)
1) The impact on the road system on the A41, A413 and gyratory system will be severe. Not Effective.
2) See also comments on 3.22

4.125 RAF Halton
The potential impact of 1,000 houses on the surrounding road network needs to be carefully assessed using a valid traffic model. Raises question of Positive Preparation.

Policy Hl: Affordable housing
All large developments should offer 35% affordable housing. The council's own Woodlands development only provides 20%. This will allow other developers to ignore the policy. The Plan is therefore not Justified (and probably not Consistent with national policy) in this important aspect.


7.16 East-West Rail
The VALP does not recognise the significance of East-West Rail to the Vale with energy or commitment. It is a 'key' infrastructure project and should be fully embraced. The current VALP cannot be said to put forward the 'most appropriate strategy' as a Justified plan would.


7.20 Oxford - Cambridge Expressway
Government support this scheme so AVDC needs to show that it is actively planning to capitalise on the opportunities for transport, housing and facilities that the scheme will bring forward. This is not 'Consistent with national policy'.

9.38 Air quality requirements on developers
Air quality is vital to health. The Council should commit in this Plan to positive policies and actions to improve air quality. Without this, this aspect of the Plan is not Positively Prepared nor Justified.

Object

VALP Proposed Submission

Representation ID: 1326

Received: 10/12/2017

Respondent: Mrs B Daniel

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

All large developments should offer 35% affordable housing. The council's own Woodlands development only provides 20%. This will allow other developers to ignore the policy. The Plan is therefore not Justified (and probably not Consistent with national policy) in this important aspect.

Full text:

SHORTLIST OF MOST RELEVANT SECTIONS, WITH COMMENTS
3.3 and Policy S1 Sustainable development
Placing too many houses in too small an area will ultimately lead to traffic problems that will lead to economic stagnation. This is neither a Justified nor an Effective strategy.

3.15 New settlement
AVDC should think long term and strategically and include a new town from the outset. The current Plan is not Justified as the most appropriate strategy.

3.22 Preserving character and identities of neighbouring settlements and resisting development compromising open countryside between settlements
The wording "will seek to preserve" is too weak. As an example, the planned developments at Hampden Fields and Stoke Mandeville entirely coalesce the villages with Aylesbury. This is not an Effective approach.

4.14 Aylesbury Town Centre
When planning to make Aylesbury Town Centre more attractive, AVDC need to consider more seriously the impact on town centre traffic from all the extra housing around the town. This element of the Plan is not Justified nor Effective for this reason.

4.16 Aylesbury Transport Strategy ATS
1) The ATS is based on flawed modelling, criticised by BCC's own Transport Consultants AECOM. This is not sound because a robust evidence base is missing.
2) Key parts of the "orbital strategy" are "aspirational" which means they will not happen until at least the next plan in 2034 and beyond. The Plan is therefore neither Positively Prepared nor Effective.

4.17 Interventions including outer link roads
The orbital roads are unlikely to take traffic away from the town centre in any meaningful way. 16,000 extra houses around Aylesbury will have a severe impact on the transport system. Because the evidence base is lacking, the interventions are neither objectively assessed, based on sound evidence, nor Effective.

Policy Dl: Delivering Aylesbury Garden Town
The sheer amount of growth cannot be accommodated in a sustainable way. Not Justified.

D-AGTl South Aylesbury
1) This creates coalescence between Aylesbury, Stoke Mandeville and Hampden Hall. Not Justified as the most appropriate strategy, therefore.
2) Placing 1,000+ houses, schools and other development along the South East Aylesbury Link Road creates a severe impact on the gyratory system and the surrounding road network. This means that it is not Effective in terms of sound infrastructure planning.

D-AGT3 Aylesbury north of A41 (Woodlands)
The amount of development in this location will have a severe impact on the local transport system especially the A41. Not Justified nor Effective.

D-AGT4 Aylesbury south of A41 (Hampden Fields)
1) The impact on the road system on the A41, A413 and gyratory system will be severe. Not Effective.
2) See also comments on 3.22

4.125 RAF Halton
The potential impact of 1,000 houses on the surrounding road network needs to be carefully assessed using a valid traffic model. Raises question of Positive Preparation.

Policy Hl: Affordable housing
All large developments should offer 35% affordable housing. The council's own Woodlands development only provides 20%. This will allow other developers to ignore the policy. The Plan is therefore not Justified (and probably not Consistent with national policy) in this important aspect.

7.16 East-West Rail
The VALP does not recognise the significance of East-West Rail to the Vale with energy or commitment. It is a 'key' infrastructure project and should be fully embraced. The current VALP cannot be said to put forward the 'most appropriate strategy' as a Justified plan would.

7.20 Oxford - Cambridge Expressway
Government support this scheme so AVDC needs to show that it is actively planning to capitalise on the opportunities for transport, housing and facilities that the scheme will bring forward. This is not 'Consistent with national policy'.

9.38 Air quality requirements on developers
Air quality is vital to health. The Council should commit in this Plan to positive policies and actions to improve air quality. Without this, this aspect of the Plan is not Positively Prepared nor Justified.

Brenda Daniel/Colin Doman

Object

VALP Proposed Submission

Representation ID: 1352

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 policy indicates it will be implemented in accordance with an Affordable Housing SPD, yet to have been produced. To fully understand its implications, the SPD should be made available now for public comment, or reference to the SPD in the policy should be omitted.

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: 1358

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:

The policy indicates it will be implemented in accordance with an Affordable Housing SPD, yet to have been produced. To fully understand its implications, the SPD should be made available now for public comment, or reference to the SPD in the policy should be omitted.

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: 1390

Received: 11/12/2017

Respondent: Mr Keith Waterman

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

All large developments should offer 35% affordable housing. The council's own Woodlands development only provides 20%. This will allow other developers to ignore the policy. The Plan is therefore not Justified (and probably not Consistent with national policy) in this important aspect.

Full text:

In response to the Draft Aylesbury Local Plan VALP, I set out my comments below.

Comments / Response

3.3 and Policy S1 Sustainable development
Placing too many houses within this small area will compound the current traffic problems and will lead to economic stagnation. This is neither a Justified nor an Effective strategy.


3.15 New settlement
AVDC should be thinking much longer term and more strategically and should include a full details for a new town from the outset. The current Plan is not Justified as the most appropriate strategy.


3.22 Preserving character and identities of neighbouring settlements and resisting development compromising open countryside between settlements
The wording "will seek to preserve" is meaningless and too easy to circumvent early on, with a weak excuse on "economic or practicability" grounds. A firm commitment linked to action is required to avoid an unacceptable fudge later on. As an example, the planned developments at Hampden Fields and Stoke Mandeville entirely coalesce the villages with Aylesbury. This is not an Effective approach.


4.14 Aylesbury Town Centre
When planning to make Aylesbury Town Centre more attractive, which is in itself will be a monumental task, AVDC need to consider more seriously the impact on town centre traffic from all the extra housing around the town. This element of the Plan is not Justified nor Effective for this reason.

4.16 Aylesbury Transport Strategy ATS
1) The ATS is based on flawed modelling, criticised by BCC's own Transport Consultants AECOM. This is not sound because a robust evidence base is missing.
2) Key parts of the "orbital strategy" are "aspirational" which means they will probably not happen and certainly not before the next plan in 2034. This issue needs to be addressed now before more development is planned or sanctioned. The Plan is therefore neither Positively Prepared nor Effective.

4.17 Interventions including outer link roads
The orbital roads are unlikely to take traffic away from the town centre in any meaningful way. 16,000 extra houses around Aylesbury will have a severe impact on the transport system and congestion around the town centre. While the evidence base is lacking, the interventions are neither objectively assessed, based on sound evidence, nor Effective.

Policy Dl: Delivering Aylesbury Garden Town
The sheer amount of growth proposed cannot be accommodated in a sustainable way. Not Justified.

D-AGTl South Aylesbury
1) This creates coalescence between Aylesbury, Stoke Mandeville and Hampden Hall. Therefore Not Justified as the most appropriate strategy. Where next, absorb Weston Turville and Wendover into the same conurbation?
2) Placing 1,000+ houses, schools and other development along the South East Aylesbury Link Road creates a severe impact on the gyratory system and the surrounding road network. This means that it is not Effective in terms of sound infrastructure planning. The proposed Stoke Mandeville bypass as part of HS2 will do nothing to alleviate congestion problems except in the immediate area near the church and school. This new development will quickly negate any benefits gained therefrom.


D-AGT3 Aylesbury north of A41 (Woodlands)
The amount of development in this location will have a severe impact on the local transport system especially the A41. Not Justified nor Effective.


D-AGT4 Aylesbury south of A41 (Hampden Fields)
1) The impact on the road system on the A41, A413 and gyratory system will be severe/catastrophic. Not Effective.
2) See also comments on 3.22

4.125 RAF Halton
The potential impact of 1,000 houses on the surrounding road network needs to be carefully assessed and integrated using a valid traffic model. Raises question of Positive Preparation.

Policy Hl: Affordable housing
All large developments should offer 35% affordable housing. The council's own Woodlands development only provides 20%. This will allow other developers to ignore the policy. The Plan is therefore not Justified (and probably not Consistent with national policy) in this important aspect.


7.16 East-West Rail
The VALP does not recognise the significance of East-West Rail to the Vale with energy or commitment. It is a 'key' infrastructure project and should be fully embraced. The current VALP cannot be said to put forward the 'most appropriate strategy' as a Justified plan would.


7.20 Oxford - Cambridge Expressway
Government support this scheme so AVDC needs to show that it is actively planning to capitalise on the opportunities for transport, housing and facilities that the scheme will bring forward. This is not 'Consistent with national policy'.

9.38 Air quality requirements on developers
Air quality is vital to health. The Council should commit in this Plan to positive policies and actions to improve air quality. Without this, this aspect of the Plan is not Positively Prepared nor Justified.

Aylesbury town centre must be one of the least attractive county towns with nothing to attract shoppers. If you need to go shopping it is necessary to travel to Milton Keynes, High Wycombe or Oxford. The town looks like it is dying on its feet and all that is proposed is to increase housing density and encroach onto valuable green space around the town.

There appear to be many empty office buildings that have been unoccupied for a long time with little prospect that they will attract new tenants. The trend nowadays seems to encourage working from home to reduce the need for expensive office space and AVDC needs to acknowledge this trend. Restrictions on areas reserved for commercial premises should be revisited to put the land or buildings back to full use. This would help to regenerate Aylesbury as a vibrant town that people want to visit before taking more and more green land around the edges.

Notwithstanding the above, traffic congestion gets progressively worse year on year. There needs to be a much greater vision for the town and the area first before expanding housing provision on green land to satisfy aggressive housing developers (land bank managers).


Regards
Keith Waterman

Object

VALP Proposed Submission

Representation ID: 1428

Received: 11/12/2017

Respondent: Mr Marcus Joy

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Policy Hl: Affordable housing
All large developments should offer 35% affordable housing. The council's own Woodlands development only provides 20%. This will allow other developers to ignore the policy. The Plan is therefore not Justified (and probably not Consistent with national policy) in this important aspect.

Full text:

My objection is submitted on the basis of the below concerns:
3.3 and Policy S1 Sustainable development
Far too many houses are being built in an area that will not be able to accommodate the traffic. Non effective strategy.
3.22 Preserving character and identities of neighbouring settlements and resisting development compromising open countryside between settlements
The wording "will seek to preserve" is very ambiguous and does not provide any assurance on preserving the countryside.

4.14 Aylesbury Town Centre
AVDC need to consider more seriously the impact on town centre traffic from all the extra housing around the town. The desire for people to use the town centre is already low due to congestion and poor shopping, so this element of the Plan is not Justified nor Effective.

4.16 Aylesbury Transport Strategy ATS
The ATS is based on flawed modelling, criticised by BCC's own Transport Consultants AECOM. How can you use an industry accredited consultancy to advise you and then ignore what they say? This particular point is of grave concern as it infers incompetence.

4.17 Interventions including outer link roads
16,000 extra houses around Aylesbury will have a severe impact on the already crowded road network. This basically puts a conservative estimate of 16,000 extra cars into the road network and because the evidence base is lacking, the interventions are neither objectively assessed, based on sound evidence, nor Effective.

D-AGTl South Aylesbury
1) This creates coalescence between Aylesbury, Stoke Mandeville and Hampden Hall. Not Justified as the most appropriate strategy, therefore.
2) Placing 1,000+ houses, schools and other development along the South East Aylesbury Link Road creates a severe impact on the gyratory system and the surrounding road network. This means that it is not Effective in terms of sound infrastructure planning.

D-AGT4 Aylesbury south of A41 (Hampden Fields)
The impact on the road system on the A41, A413 and gyratory system will be severe. Not Effective.

4.125 RAF Halton
The potential impact of 1,000 houses on the surrounding road network needs to be carefully assessed using a valid traffic model. How can the village of Wendover and the National Trust woodlands possibly accommodate this sharp rise in traffic? Raises question of Positive Preparation.

Policy Hl: Affordable housing
All large developments should offer 35% affordable housing. The council's own Woodlands development only provides 20%. This will allow other developers to ignore the policy. The Plan is therefore not Justified (and probably not Consistent with national policy) in this important aspect.

7.16 East-West Rail
The VALP does not recognise the significance of East-West Rail to the Vale with energy or commitment. The Chiltern Line is already running at high capacity during peak hours and rail strategy is vital to future development. It is a 'key' infrastructure project and should be fully embraced. The current VALP cannot be said to put forward the 'most appropriate strategy' as a Justified plan would.

9.38 Air quality requirements on developers
Air quality is vital to health. The Council should commit in this Plan to positive policies and actions to improve air quality. Without this, this aspect of the Plan is not Positively Prepared nor Justified.

Regards,
Marcus Joy.

Object

VALP Proposed Submission

Representation ID: 1432

Received: 12/12/2017

Respondent: Winslow Town Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The reduction in percentage and quantum of affordable housing to be delivered, compared with that previously shown in the draft VALP, does not appear rational when there is a recognised national shortage of such housing.

Full text:

Winslow Town Council Objections to the Vale of Aylesbury Local Plan (VALP)
Winslow Town Council (WTC) welcomes the creation of a new Local Plan to cover Aylesbury Vale District. The approval of VALP will remove uncertainties in local planning - but it is important that the Plan is sound, and not open to further challenge. WTC also recognises that national Government proposals for the Cambridge-Milton Keynes-Oxford Arc, as reflected in statements in the Autumn 2017 Budget, suggest that it will be necessary over the coming few years to revise VALP to accommodate greater levels of development in the area than are currently envisaged. Such matters, however, are for the future. The immediate priority is to review and revise the currently drafted VALP, and to that end WTC offers the following objections to matters which it considers need to be reviewed and revised before VALP would be sound and consistent with relevant national planning policies.
0 Summary
Winslow Town Council considers that there are elements of the submission VALP which are unsound and need to be modified. These are:
1. The allocation of sites in strategic settlements with made or emerging Neighbourhood Plans, contrary to national policy.
2. Raising to 55% the increase in housing numbers for Winslow, the least sustainable of all the strategic settlements
3. Flaws in the Buckinghamshire Memorandum of Understanding
4. Insufficient affordable housing on qualifying sites
5. Under-delivery of new homes in large villages
6. Understating the growth in population during the Plan period as about 35,000 rather than 60,000
1 Site specific allocation for housing growth
1.1 In Table 2 of the Vale of Aylesbury Plan, there is an allocation of a single site for housing growth in Winslow which is contrary to:
(a) NPPF para 185 covering the key aim/promise of Neighbourhood Planning which enables communities to decide where new homes should be located;
(b) various Ministerial Statements along the same lines; and
(c) para 1.20 of the proposed Submission VALP which confirms that made Neighbourhood Plans can determine how development will take place in their area.
1.2 This aspect of the Plan is therefore unsound and not 'justified' as the most appropriate policy because it is not consistent with national planning policy. It will be for WTC, with its made Neighbourhood Plan, to bring forward an update and revision of Winslow Neighbourhood Plan (WNP) following the approval of VALP. The updated WNP, following robust consultation with the local community, will need to identify how and where any housing growth required in an agreed VALP is to be accommodated, including (if and where necessary) any extension to the WNP's settlement boundary. Both Buckingham and Haddenham are also Strategic Settlements which have a Neighbourhood Plan, and in which VALP has also identified allocated sites for housing development contrary to the same national planning policy.
1.3 This reflects previous correspondence from WTC to AVDC (dated 13th October 2017) on this very issue which refers to the inspector's conclusions for the Maidstone Local Plan, where target housing numbers were seen as an appropriate mechanism to use for an area with a made or emerging Neighbourhood Plan.
Proposed modification:
1.4 To meet WTC's objection this issue should be addressed by VALP stating the target figure of additional housing that needs to be accommodated in an updated WNP, perhaps indicating that one option for locating this might be on the identified land to the east of Great Horwood Road. An equivalent change also should be made to VALP in respect of other areas which have a made or emerging Neighbourhood Plan.
2 Scale of housing growth for Winslow
2.1 In Table 2 and the allocation of Site ref WIN001 on page 126, the level of housing growth proposed for Winslow, which WTC considers to be the least sustainable of the strategic settlements in the Vale (See WTC's initial Strategic Settlements Sustainability Assessment, below), has apparently been increased arbitrarily to 55%. In the draft VALP, the proposed growth was 50%, which the Town Council objected to as being, comparatively, unreasonable when infrastructure provision was considered in relation to the other strategic settlements.
Aylesbury Vale Strategic Settlements Sustainability Assessment for VALP (by WTC)
Aylesbury
Buckingham
Haddenham
Wendover
Winslow
Housing
Close to areas with unmet housing need
3
1
5
4
2
Transport
Train to London, Birmingham, Oxford
4
1
5
4
2
Express bus to nearby centres
5
4
3
1
3
Access to motorway network
3
4
5
3
1
Bypass for through traffic
3
4
5
4
1
Services
Extendable employment sites
5
4
3
2
1
Modern medical centre / surgery
4
3
5
2
1
Access to major retail / leisure / employment centre (Aylesbury or MK)
5
1
3
4
2
TOTAL SCORE
32
22
34
24
13
Each settlement is given a score from 1 to 5 in each row, with 5 representing the greatest level of sustainability.
2.2 The requirement for Winslow to deliver new homes, above those detailed in the WNP, has increased from 402 in the draft VALP to 585 in the submission VALP, an increase of 45%. The housing growth proposed for Buckingham, the second largest strategic settlement in the Vale, with its much stronger infrastructure compared with that of Winslow, has seen its housing growth reduced from 2,612 (50%) in the draft VALP to 2,312 (45%) in the submission VALP. These changes in the proposed growth figures are not explained, appear counter-intuitive and lack any rationale to support them. A report to AVDC's Scrutiny Committee for VALP in September 2017 said that: the Council has worked with town and parish councils to identify sites which can be allocated through revisions to their neighbourhood plans. Winslow is not alone in being able to confirm that no such consultation took place. If the process has been simply to establish a suitable site for housing growth and use its capacity as the level of housing growth to be proposed for a community, then this process would appear to be fundamentally unsound.
Proposed modification:
2.3 WTC proposes that VALP should set a more reasonable and sustainable increase in the number of additional homes within Winslow over and above the 35% increase already detailed in the made WNP. WTC suggests that an increase of about 300 homes over and above those already provided for in the made WNP would be more appropriate in the circumstances. It will be for a future revised WNP to determine, with the benefit of local public consultation, where the additional housing should be located to achieve the required strategic housing provision.
3 Memorandum of Understanding
3.1 The Buckinghamshire Memorandum of Understanding (MoU) between Aylesbury Vale DC, Wycombe DC, Chiltern DC, South Bucks DC and Bucks Thames Valley LEP (mentioned in paragraph 1.12 of VALP) is, in WTC's opinion, a flawed document. It is the MoU that seeks to justify the requirement for Aylesbury Vale to accommodate the unmet need of 8000 additional homes elsewhere in the Bucks Housing Market Area.
3.2 The Agreement in the MoU in paragraph 2.1(d) states - That the following level of unmet housing need within respective local plan periods up to 2033 will be accommodated in the Vale of Aylesbury Plan. This absolute agreement by AVDC to accommodate 5,725 homes (21% of the VALP total) as unmet housing need from Chiltern and South Bucks in VALP, when those Districts' joint draft Local Plan will not be published until the middle of 2018 and when the figure represents over 44% of the Full Objectively Assessed Need for Chiltern and South Bucks, appears to be an unsound commitment. Similarly, the accommodation of 2,275 homes (8.3% of the VALP total), as unmet need for Wycombe District, in light of the recent publication of the submission Wycombe District Local Plan (WDLP), appears equally unsound.
3.3 WTC believes that Wycombe District Council (WDC) has not recognised its duty and responsibility in these days of 'exceptional circumstances' for the effective delivery of housing, because it has not demonstrated a robust approach to maximise the delivery of new housing within the District's boundary in order to meet its own Full Objectively Assessed Need (FOAN). As a consequence, the WDLP has not followed a strategy which seeks to meet the District's FOAN for new homes during the Plan period. This leads WTC to conclude that the plan has not been positively prepared and is therefore unsound in respect of its provision for housing development. The following paragraphs explain why WTC has come to this view.
3.4 WDLP Policy DM34 specifies that new housing developments should provide (WTC's emphasis in bold):
(a) Opportunities to enhance existing and provide new green infrastructure have been maximised, including delivering long lasting measurable net gains.
(b) In all cases, development is required as a minimum to: Secure adequate buffers to valuable habitats and
(c) Achieve a future canopy cover of at least 25% of the site area on sites outside of the town centres and 0.5HA or more
3.5 These requirements, together with other luxuries and 'nice to haves', significantly limit the area of developable land for housing on allocated sites, and therefore limit the scale of housing development that can be accommodated. WTC believes that this Policy cannot, under the prevailing circumstances, be justified as it does not represent the most appropriate strategy, when considered against the reasonable alternatives and is not based on proportionate evidence. The Plan offers no justification for this highly questionable policy, which therefore leads WTC to the view that WDLP is unsound in this respect.
Evidence
3.6 Paragraph 4.38 of the WDLP states The Council has thoroughly reviewed the scope for meeting its housing needs within the District. However it does not consider the option of increasing housing densities in order to more fully meet the District's FOAN. The WDLP includes large allocated sites for housing delivering less than 10 dwellings per hectare e.g. - HW4 Abbey Barn 4 - 11.32 hectares - 100 homes at 8.8 dwellings per hectare (dph) and HW6 Gomm Valley and Ashwells - 72.8 hectares - 530 homes at 7.3 dph.
3.7 By way of comparison, WNP, where AONB and Green Belt are not a consideration, delivers its housing growth on identified sites at more than 30 dph and delivers satisfactory provision of green space for each housing development site. Even taking into account the difficulties of the terrain in parts of the High Wycombe area, WTC believes that the identified sites could be developed at appreciably higher densities than are currently proposed, and thereby absorb more, if not all, of the District's FOAN. Similarly, it is WTC's belief that the Princes Risborough expansion area is capable of delivering many more homes than are committed in the WDLP.
3.8 The WDLP only allocates 57 hectares of previously designated Green Belt land for housing, to deliver 1,100 new homes at 19.3 dph. This represents a mere 0.4% of the District's Green Belt, in a District with 48% Green Belt, amounting to over 14,000 hectares. Many LPAs in a similar position to WDC have recognised that, in order to meet the housing need identified by the FOAN, it is necessary to recognise the 'exceptional circumstances*' and to reallocate poorly performing areas of Green Belt for housing development in order to fully meet their own FOAN. A local example of such an approach is South Oxfordshire's Local Plan, where re-designated Green Belt land will deliver 5,500 new homes on 3 sites. Central Bedfordshire and Dacorum Councils are taking a similarly positive approach.
*The Housing Minister, Gavin Barwell, when speaking in relation to the Housing White Paper, said: "The green belt is 13% of the land. We can solve this crisis without having to take huge tracts out of the green belt. We are not going to weaken the protections; we have a clear manifesto promise and there is no need to take huge tracts of land out of the green belt to solve our housing crisis. They can take land out of the green belt in exceptional circumstances but they should have looked at every other alternative first." [emphasis added]
3.9 Criticisms of the WDLP, such as those of a failure to positively plan to maximise housing delivery in order to meet the FOAN and a reluctance to take a robust approach to the reallocation of poorly performing Green Belt land for housing development, will almost certainly also apply to the emerging Chiltern and South Bucks Local Plan. The MoU is a
document which appears to invite housing overspill into Aylesbury Vale and lacks checks and balances to ensure any unmet housing need has been demonstrably minimised.
Proposed modification:
3.10 The MoU (referenced in para 1.12) appears to be based on an unsound judgement of the opportunities that exist for the three southern districts of Buckinghamshire to deliver a greater proportion of their own FOAN. Following further detailed scrutiny of the figures in the MoU through the examination of the other relevant local plans, WTC believes that the unmet need housing targets for Aylesbury Vale District should be reduced, or alternatively the time scale over which those targets apply should be extended beyond the end of the plan period for VALP.
4 Affordable housing
4.1 The reduction in percentage and quantum of affordable housing to be delivered, compared with that previously shown in the draft VALP, does not appear rational when there is a recognised national shortage of such housing. The draft VALP proposed 31% of affordable homes on qualifying sites, which would have yielded about 8,800 affordable homes, whereas the submission VALP in Policy H1 only proposes 25% generating about 5,900 affordable homes. Evidence from CPRE, the National Housing Federation, Shelter, the Institute for Public Policy Research etc are all telling the same story, one of shortfalls of affordable housing delivery, more homelessness, an ever-increasing annual housing benefit bill etc. WTC understands that the Vale of Aylesbury Housing Trust (VAHT) has evidence that indicates that the provision of 6,000 affordable homes in Aylesbury Vale over the 20 year plan period will be significantly less than demand. When a neighbouring authority (WDC) demands 40% affordable homes on qualifying greenfield sites, why does VALP propose a very much lower target for the same Plan period within the same Bucks Housing Market Area?
Evidence
4.2 WTC considers the following paragraphs of the Affordable Housing section of the VALP Housing Topic Paper November 2017 in particular contain inaccuracies which have resulted in unsound conclusions regarding the percentage of affordable homes to be delivered on qualifying sites.
4.5 As set out in the HEDNA December 2016 to establish the past trends and current estimates of the need for affordable housing local authority data on homeless households and temporary accommodation, was considered alongside census data on concealed households and overcrowding together with information from the English Housing Survey, Housing Register and information from Housing benefit data on households unable to afford their housing costs. Based on this information the study concluded that there are 3,311 households currently in affordable housing need in the Buckinghamshire HMA who are unable to afford their own housing. Deducting those whose housing is not suitable and households that will release their housing back into the market leaves a net need of a 1,150 households who that are currently in affordable housing need who are unable to afford their own housing.
[VALP Housing Topic Paper November 2017]
4.3 On 8th December 2017 VAHT told WTC that:
"As of November 2017 there were nearly 3,900 applicants registered on Bucks Home Choice (BHC) within the Aylesbury Vale. Of these just over 2,300 are in bands A to D and eligible for affordable rented housing in the Vale. Around 1,600 are in band HO and may be eligible for rural exception properties or others with strict local connection criteria."
4.4 And Bedfordshire Pilgrims Housing Association (BPHA), the organisation which manages the register for shared ownership affordable homes in the Vale, told WTC that... the figures for Shared Ownership applicants for Aylesbury Vale since 2015 (based on applicant requests for 2, 3, 4, 5 bedrooms) were:
 2015 - 352
 2016 - 434
 2017 so far - 482
BPHA does not maintain a register of unmet need and these figures no longer appear to be available. When Catalyst managed the Shared Ownership Register, they recorded unmet need figures of 407 in 2010 steadily rising to 1,048 in 2014.
4.5 So in the past 3 years about 1,300 applications for shared ownership properties have been recorded. Paragraph 1.48 of VALP states that over the past 5 years an average of 1,127 dwellings were built each year. Out of this total, an average of 349 were affordable dwellings. With 25% of affordable homes allocated to shared ownership, over the past 5 years an average of just 87 shared ownership affordable properties have been delivered each year. This leaves an unmet need figure for the past 3 years alone of over 1,000 plus the backlog from 2014 and earlier.
4.6 From the above data, WTC concludes that the current unmet need for all types of affordable homes in Aylesbury Vale is over 5,000 and the evidence is of an increasing demand. Although this evidence would have been available to AVDC and its consultants it does not appear to have been considered. WTC's evidence from those 'at the coal face' indicates that the base figure for unmet need of 3,331 for all forms of affordable homes in December 2016 is incorrect. Para 1.47 of VALP states: The total number of households on the Bucks Home Choice housing register waiting for a social housing tenancy in April 2016 was over 3,000. (WTC believes this figure only relates to Aylesbury Vale, as opposed to the entire BHC area). This appears to suggest that no account was taken in the HEDNA of the need for shared ownership affordable homes.
4.8 Government requirements now prohibit the requirement for affordable housing applying to housing sites of 10 or less dwellings. As this is expected to be a significant proportion of new housing development in Aylesbury Vale the percentage of affordable housing needs to be increased to 25% to allow the total requirement of 4,200 affordable dwellings for the district to be achieved. This is of course provided that the proportion of affordable required does not generally render proposed housing developments in Aylesbury Vale unviable on the basis of paragraph 173 of the NPPF.
[VALP Housing Topic Paper November 2017]
4.7 This paragraph (4.8, above) only takes account of the FOAN for Aylesbury Vale and takes no account of the unmet need of 8,000 for the District Councils in the south of the County, where the LPAs are expecting delivery of affordable homes in accordance with their Local Plans. Wycombe's draft Local Plan requires 40% affordable homes on their own greenfield sites. If, say, 35% of the 8,000 unmet need homes included in VALP were required to be affordable, and if 85% of them were on qualifying sites, this would result in an additional requirement of about 2,400 affordable homes, resulting in a total of 6,600 affordable homes (representing about 29% of all new homes), not 5,900 as proposed by VALP. For the overall percentage delivery of affordable homes to be based solely on the Vale's requirements, when 29% of housing delivery will be for unmet need from other Districts, is a flawed approach and therefore unsound.
4.9 The council has engaged consultants Dixon Searle Partnership to advise it on viability. They have concluded that the 25% affordable housing requirement should be viable in almost all cases. They have further advised that the affordable housing requirement of 30% could be viable in some cases. The council has therefore set the 25% requirement as a minimum in the proposed affordable housing policy which will allow a higher provision where justified by viability. The viability information is however clear that a requirement higher than 30% would not be justified.
[VALP Housing Topic Paper November 2017]
4.8 WTC believes that the evidence in the submission VALP proves that a minimum figure much higher than 25% should be viable in almost all cases. As referred to above, Paragraph 1.48 of VALP advises that average annual housing delivery in the Vale for the past 5 years was 1,127, of which 349 was the average annual delivery of affordable homes. This represents a 31% delivery of new affordable homes across qualifying and non-qualifying sites.
4.9 In Paragraph 4.8 of the VALP Housing Topic Paper it says:
...the percentage of affordable housing needs to be increased ... . As 31% affordable homes has been delivered over all sites for the past 5 years this must mean that the percentage delivery figure on qualifying sites has been appreciably more than 31%. So a target higher than 31% has been shown to be viable.
4.10 Strategic communities with made Neighbourhood Plans in the Vale require at least 35% affordable housing delivery on qualifying sites. For both Winslow and Buckingham, for those sites identified in respective Neighbourhood Plans where planning applications have been approved or submitted, no issue as to the viability of the 35% figure has been raised.
4.11 Notwithstanding the above evidence that viability can be achieved at 35%, and there is more than sufficient demand at that level, the consultant's report in the Housing Topic Paper, para 4.9, only indicates - the affordable housing requirement of 30% could be viable in some cases. AVDC then erroneously concludes - The viability information is however clear that a requirement higher than 30% would not be justified. WTC considers this to be another unsound element underpinning the highly questionable 25% delivery figure for affordable housing proposed in VALP.
4.12 Finally WTC considers that setting a minimum target for affordable housing is not appropriate as developers will seek to design to such a minimum rather than deliver anything higher. It would be more prudent to set a realistic but challenging target percentage to be delivered - and accept that developers may be able to demonstrate viability problems in meeting the target in full on some specific sites.
Proposed modification:
4.13 WTC considers that, in respect of affordable homes delivery, VALP has not been positively prepared and is therefore unsound. WTC proposes that VALP be modified to set a minimum of 35% affordable housing delivery on qualifying sites. Alternatively, in recognition that the viable delivery of brownfield sites for housing can be more problematic than for greenfield sites, it could be more realistic to specify a minimum 40% for qualifying greenfield housing sites and a minimum 30% for brownfield sites.
5 Accommodating demographic growth in second-tier settlements
5.1 In VALP para 3.20 it is stated that
The settlement hierarchy is based on an assessment of population size, settlement connectivity and the availability of employment and other services and facilities. A draft settlement hierarchy has been consulted on, and a number of changes have been made to the conclusions as a result of comments received. A report has been produced setting out how the settlement hierarchy was established which is available on the Council's website. The proposed settlement hierarchy is set out in Table 2, along with the amount of housing to be accommodated at each settlement. The allocations for each settlement are based on the capacity of the settlement to accommodate housing growth, rather than a blanket percentage increase on existing housing stock as was previously proposed in the draft Plan. [WTC's emphasis added]
5.2 The emphasised section above appears to be flawed because the Plan gives no account of how the Plan has robustly established "the capacity of each settlement to accommodate housing growth." It is important to bear in mind that the district-wide housing growth in VALP is 36% without the buffer and total growth of 40% across the district including the buffer. Table 2 simply indicates the total amount of housing development per settlement as completions/commitments plus any allocations. Of the 11 larger villages (Stoke Mandeville is omitted because, we are informed, it is included in the Aylesbury figures), defined as such in the settlement hierarchy because of their superior infrastructure, only 5 have any allocations. Of those 11 larger villages, 8 are expected to deliver less than 20% housing growth. Four of them are not even expected to meet their own demographic growth to 2033. These are Stone (population over 2,600) 3.4% housing growth, Ivinghoe (population 1,000) 4.6%, Long Crendon (pop over 2,500) 9.5% and Wing (pop over 2,800) - 10.9%. Only Steeple Claydon with a 22.8% increase and Aston Clinton with a 40.3% increase in homes exceed 20% growth, whilst Waddesdon (including Fleet Marston) has 20% growth. The second tier in the Plan's settlement hierarchy comprises all the larger, more sustainable villages that have at least reasonable access to facilities and services and public transport, making them sustainable locations for development [WTC's emphasis added]. A Local Plan which does not demand that these second tier settlements should provide housing growth that meets their individual demographic growth as a minimum during the Plan period, would appear to be unsound.
Proposed modification:
5.3 WTC proposes that VALP be modified to require all 'large villages' to deliver appreciably more than the basic figure for demographic growth during the Plan period, bearing in mind that Aylesbury Vale is a growth area and that district-wide housing growth is more than 36%.
6 Population growth expectations
6.1 Para 1.35 of the submission VALP states that during the Plan period there will be a growth in population of about 35,000 (once allowance has been made for the growth which took place between 2011 and 2013). With growth of 27,300 homes in the Plan period, this figure for population growth appears to be under-stated. WTC drew attention to this at the draft VALP stage, but has received no explanation for the apparent discrepancy, nor any correction of it in the submission Plan.
Proposed modification:
6.2 The expected increase in the population of Aylesbury Vale in the plan period should be stated more accurately to be in excess of 60,000 based on the number of additional homes proposed.
7 Examination in Public
7.1 AVDC is asked to note that Winslow Town Council wishes to participate in the

Examination in Public.

Sean Carolan

Deputy Clerk

Object

VALP Proposed Submission

Representation ID: 1546

Received: 14/12/2017

Respondent: Barwood Land and Estates

Agent: Chilmark Consulting Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The approach taken in the HEDNA (as the key evidence base for policy H1) is inconsistent with the
standard and industry accepted approach to the definition and calculation of affordable housing
needs in accordance with the NPPG and practice elsewhere.

The proposed affordable housing requirement does not represent the full affordable housing need for
the District. The policy will not be effective in meeting affordable housing needs arising over the plan
period.

Full text:

Please find the enclose representations and covering letter with respect to the current Vale of Aylesbury Local Plan: Proposed Submission consultation.

Object

VALP Proposed Submission

Representation ID: 1623

Received: 14/12/2017

Respondent: Gladman Developments Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Unclear whether the proposed requirement will deliver sufficient scale to meet true affordable need.

Full text:

Please see attached representation and appendices.

Object

VALP Proposed Submission

Representation ID: 1635

Received: 14/12/2017

Respondent: W K Boxhall

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Not consistent with national policy therefore developers will continue to ignore it.

Full text:

3.3 & Policy S1 Sustainable development

Traffic problems within Aylesbury continue to increase and building more houses in this area will escalate them even more so.


3.15 New settlement

This would be a much better approach as building a completely new town would ensure all the infrastructure issues would be catered for.


3.22 Preserving character and identities of neighbouring settlements and resisting development compromising open countryside between settlements.

This has not been shown to date, eg Hampden Fields and Stoke Mandeville. The statement 'will seek to preserve' demonstrates yet again that words and actions are not aligned.


4.16 Aylesbury Transport Strategy

The models used are too old and have already been criticised by Transport consultants AECOM. This model needs to be updated in the light of previous growth and significant transport changes.

The plan is not all embracing and smacks of opportunism for funding from HS2 developments for one tiny route which yet again would create further traffic problems.

4.17 Interventions including outer link roads.

16000 extra houses around Aylesbury will have a severe impact on the transport system and any orbital roads are likely to compound them.

Policy D1: Delivering Aylesbury Garden Town

Pure fantasy. The growth cannot be managed and developed in a sustainable way, hence a new town development would be a better option.

D-AGT1, D-AGT3, D-AGT4

All will result in significant strains to the local transport system and in particular the A41, A413 and the Gyratory system.


Policy H1 Affordable Housing

Not consistent with national policy therefore developers will continue to ignore it.


9.38 Air Quality requirements on developers.

This is now vital to health and with the current volume of traffic around Aylesbury is a real cause for concern. Actions need to be include how this will be dealt with particularly with proposed link roads being planned through existing housing estates.

Object

VALP Proposed Submission

Representation ID: 1666

Received: 14/12/2017

Respondent: Mr William Spear

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

The Woodlands development only provides for 20% affordable housing which is not consistent with the national policy of 35%. Other developments may try to follow suit.

Full text:

Comments on the Vale of Aylesbury Local Plan

3.3 and Policy S1 Sustainable development
The strategy presented will not work because the building of too many houses in an area that is clearly too small will lead to severe traffic problems. Consequently rather than attract new business the increased congestion will have the opposite effect and thus reduce the level of economic activity. This is not to mention the impact on existing businesses that may consider relocating because of the increased congestion.

3.15 New settlement
A new town requires a long term vision and strategy and the current plan does not meet this requirement.

3.22 Preserving character and identities of neighbouring settlements and resisting development compromising open countryside between settlements
'Seeking to preserve' is an aspiration rather than a specific strategy, and leaves little confidence that AVDC will effectively maintain the individual identity of the villages around Aylesbury. A more robust strategy is required.
4.14 Aylesbury Town Centre

The current plan to make the town centre more attractive, does not take seriously the impact on the town centre of the extra housing. With current traffic levels, the town is already seriously congested and with all the new planned housing it will be gridlocked.
4.16 Aylesbury Transport Strategy ATS
The evidence base for the Transport Strategy is very limited and has been seriously criticized by Bucks County Council's transport consultants. In addition, much of the plan is 'aspirational' which in reality means it will never happen.

4.17 Interventions including outer link roads

The impact of 16,000 extra houses in reality means at least 30,000 extra vehicles which will have a catastrophic impact on the town's transport system. As mentioned in 4.14 the additional traffic will gridlock both the town centre and the main feeder roads (A41, A413, and A418) into and out of the town on a daily basis. This will lead to drivers seeking alternative routes and creating unsafe 'rat-runs' through residential housing areas. Likewise, there is little evidence to confirm the planned orbital routes will satisfactorily absorb the additional traffic and thus prevent the mayhem described above.

Policy Dl: Delivering Aylesbury Garden Town

The current plan does not demonstrate this can be effectively delivered because of the sheer volume of growth.
The planned growth
D-AGTl South Aylesbury

The plan demonstrates poor infrastructure development as it will merge Aylesbury, Stoke Mandeville and Hampden Hall and as such is not an appropriate or acceptable strategy. In addition, the planned housing will generate at least 2,000+ extra vehicles which will regularly gridlock the gyratory system and the surrounding roads. This again will lead to the creation of unsafe 'rat-runs' through residential areas.

D-AGT3 Aylesbury north of A41 (Woodlands)
The A41 in particular will be adversely affected by the planned development,, therefore, is neither effective nor justified.

D-AGT4 Aylesbury south of A41 (Hampden Fields)

1. The planned housing will generate a very significant number of extra vehicles which will lead to regular gridlock at the gyratory system and the A41 and A413. Again, this will lead to the creation of unsafe 'rat-runs' through residential areas.
2. The strategy of local villages maintaining individual identities is severely comprised with this development as Stoke Mandeville and Weston Turville will effectively become suburbs of Aylesbury.

4.125 RAF Halton

The closure of RAF Halton and the impact of 1,000+ new houses on the local infrastructure need to be properly evaluated, particularly in terms of the surrounding road network.

Policy Hl: Affordable housing

The Woodlands development only provides for 20% affordable housing which is not consistent with the national policy of 35%. Other developments may try to follow suit.
7.16 East-West Rail
The East-West rail link is major infrastructure project which is not exploited to the full by VALP. Opportunities such as this are rare and the local plan must take full advantage of the economic and social benefits it will bring to the area.
7.20 Oxford - Cambridge Expressway

See 7.16. Again, another major infrastructure project of which the plan fails to take full advantage.

9.38 Air quality requirements on developers
The plan does not commit to vital policies that will improve air quality

Support

VALP Proposed Submission

Representation ID: 1686

Received: 14/12/2017

Respondent: Buckinghamshire Fire & Rescue Service

Representation Summary:

We are supportive of this policy and, in particular, any measures that will increase the supply of affordable housing in locations where we have fire stations that operate under the 'on-call' or 'day crew' duty systems which require firefighters to live in close proximity to fire stations. We are finding it increasingly difficult to find new staff in many of these locations as rising house and rental prices have placed housing beyond the reach of many people in the demographic and occupational groups from which we typically recruit.

Full text:

Please find attached a letter containing our representations in relation to Vale of Aylesbury Local Plan.