Aylesbury Vale Area

FMM080

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Object

VALP Further Main Modifications

Representation ID: 3836

Received: 09/02/2021

Respondent: Turley Associates

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

We note that the revised text records that the proposed allocations fall short by 51 units. In our submission, that text should be amended to explain that this shortfall is against the five year requirement between 2020-2025. As we set out above this indicates that the LPA must apply a proactive approach to the determination of applications, by seeking to maximise the capacity of sites and by granting permission in a timely manner. Furthermore, we reiterate our submission that the VALP itself should be proactive enough to address this shortfall if such opportunities exist.

Full text:

Dear Sir / Madam
VALP FURTHER MAIN MODIFICATIONS CONSULTATION 2020-2021
We write to submit representations on behalf of our client, Hambledon Land to the consultation into the further main modifications to the Vale of Aylesbury Local Plan.
BACKGROUND
Hambledon Land is promoting a retirement and care community on land north west of Fremantle Court at Stoke Mandeville.
Land to the south-east of Fremantle Court, which is owned by Fremantle Trust, could deliver a second phase of specialist housing accessed through the existing entrance to Fremantle Court, should the Trust decide to bring it forward. A document setting out the form of development proposed at this site was submitted in response to the Main Modifications consultation and has been shared with the group preparing the Stoke Mandeville Neighbourhood Plan. This document showed how the proposals would comprise:
• Between 100 and 140 homes for the elderly on land to the north west of the existing Fremantle Court Care Home and the potential for 50 units in a later phase to the south east.
• A 17-acre nature reserve integrating and blending with the areas of built development – dedicated in perpetuity through a deed of covenant (with this located in the former Wycombe District part of Buckinghamshire Council).
• Communal facilities including restaurant/snack bar, education/hobby suite, fitness suite, health clinic, swimming pool and bowling green.
• Full access to all communal facilities and the nature reserve for new residents, Fremantle Court residents and the wider village community.

• Exceptionally designed energy efficient buildings and on-site renewables to assist in achieving zero carbon performance across the site.
• The creation of a wildlife habitat with a fully integrated environmental management plan to deliver a biodiversity and wider environmental net gain across the site.
• Footpath links to encourage recreational experiences with nature.
• An extension of the Stoke Mandeville Way to the site.
• A wide range of green travel options to reflect the zero carbon concept for the site.

REPRESENTATIONS
In light of Hambledon Land’s interests as explained above, these representations consider:
• ED243: Schedule of Proposed Further Main Modifications to the Modified VALP, namely those numbered FMM078 – FMM084;
• ED245 Proposed Further Modifications to the VALP Policies Maps
• ED246 Sustainability Appraisal of Further Main Modifications
ED243: Schedule of Proposed Further Main Modifications to the Modified VALP
FMM078
We welcome the additional analysis undertaken by the LPA to ensure that the VALP represents a more positive response to the need for C2 accommodation. We note from the proposed revision to paragraph 5.42 that although the level of completions/commitments since 2013 has increased, so has the remaining need (rising from 800 to 1,212).
We understand that the Council’s methodology for calculating the revised level of need for C2 accommodation is set out in document ED258 ‘Buckinghamshire Council Supporting Statement for VALP C2 Older Persons' Housing Allocations (November 2020)’.
The Council’s analysis in document ED258 explains that the further Main Modifications results in a small shortfall against the need for C2 accommodation. In our submission, this indicates that the LPA must apply a proactive approach to the determination of applications, by seeking to maximise the capacity of sites and by granting permission in a timely manner. Furthermore, in our submission, the VALP itself should be proactive enough to address this shortfall if such opportunities exist.
FMM079
We welcome the fact that the LPA has continued to recognise the importance of identifying specific deliverable sites to meet identified needs for C2 accommodation.
FMM080
We note that the revised text records that the proposed allocations fall short by 51 units. In our submission, that text should be amended to explain that this shortfall is against the five year requirement between 2020-2025. As we set out above this indicates that the LPA must apply a proactive approach to the determination of applications, by seeking to maximise the capacity of sites and by granting permission in a timely manner. Furthermore, we reiterate our submission that the VALP itself should be proactive enough to address this shortfall if such opportunities exist.

FMM081
The revised text to paragraph 5.46 indicates that the VALP will still result in a residual requirement for C2 accommodation which is not met by site specific allocations and as such the draft Policy maintains the approach of supporting broad locations for such development.
As we set out above, the scale of the residual need indicates that the LPA must apply a proactive approach to the determination of applications, by seeking to maximise the capacity of sites and by granting permission in a timely manner. Furthermore, we reiterate our submission that the VALP itself should be proactive enough to address this shortfall if such opportunities exist.
FMM082
We broadly welcome the specific identification of the land adjacent to Fremantle Court, Stoke Mandeville as a proposed allocation to meet the need for C2 accommodation between 2020 – 2025. In particular we note that the Council has considered the positive impact that this scheme could have by reducing the scale of unmet need through the Sustainability Appraisal (Document ED246). We do not repeat the content of the Sustainability Appraisal in these representations.
However we maintain concerns in relation to a number of factors:
• The proposed site area is indicated to be 0.38 hectares. This does not correspond to the area shown in document ED245 Proposed Further Modifications to the VALP Policies Maps.
• The treatment of the land south east of the Fremantle Court Care Home; and
• The references within Policy H6(b) to a nature reserve.
In our submission, the site area (in hectares) should be amended to reflect the eventual allocation.
In relation to the capacity of the site, Hambledon Land has reviewed its proposals for the land north west of Fremantle Court and now considers that area to have capacity for approximately 100 units (rather than the 100-140 previously promoted).
We note that the proposed allocation also includes land to the south east of Fremantle Court. That area of land does not form part of Hambledon Land’s proposals and was envisaged as a possible future phase of development.
In order to provide certainty, Hambledon Land consider that the proposed allocation of land adjacent to Fremantle Court should be amended to:
• Clarify that approximately 100 units are allocated on land to the north west of Fremantle Court. That then corresponds with the Hambledon Land promotion and as such ensures that the VALP reflects a scheme which is actively being promoted and could deliver accommodation to meet identified needs; and
• Identify the land to the south east of Fremantle Court as being safeguarded for a future phase of development. That then provides the LPA with a potential additional source of C2 accommodation to meet identified needs over the longer term.

The revised Policy wording indicates that the development on land adjacent to Fremantle Court is expected to provide a designated nature reserve. As the Council will be aware, that does form part of the Hambledon Land proposals, but not on land within the former Aylesbury Vale area which is to be covered by the VALP. The proposed nature reserve is on land formerly within Wycombe District. Whilst the nature reserve does form part of the Hambledon Land proposals, it would not be appropriate for this to be subject to the VALP allocation. As such we suggest that the supporting text be amended to explain that the allocation will be delivered in conjunction with a nature reserve located outside of the VALP area.
FMM083
We have no comments to make.
FMM084
An allocation of approximately 100 units to the north west of Fremantle Court would correspond with the Hambledon Land promotion and ensure that the VALP reflects a scheme which is actively being promoted and could deliver accommodation to meet identified needs.
We explain in these representations that the land to the south east of Fremantle Court was envisaged as a possible future phase of development and we have proposed that this area be safeguarded for a future phase of development. That then provides the LPA with a potential additional source of C2 accommodation to meet identified needs over the longer term.
ED245 Proposed Further Modifications to the VALP Policies Maps
The proposed further modifications to the VALP Policies Map shows an area of land to be allocated under Policy H6(b) adjacent to Fremantle Court, Stoke Mandeville, for C2 accommodation. As we have previously set out, Hambledon Land itself is promoting land to the north west of Fremantle Court and considers that this area has the capacity to accommodate approximately 100 units of accommodation.
We note that the proposed allocation also includes land to the south east of Fremantle Court. That area of land does not form part of Hambledon Land’s proposals and was envisaged as a possible future phase of development. We have proposed that this area be safeguarded for a future phase of development. That then provides the LPA with a potential additional source of C2 accommodation to meet identified needs over the longer term.
The proposed allocation currently includes the land occupied by the Fremantle Court Care Home. We consider that this area should be excluded from the allocation for the following reasons:
• The proposed allocation refers to the land adjacent to Fremantle Court; and
• The inclusion of the Fremantle Court Care Home within the allocation is likely to cause confusion and uncertainty to the users and occupiers of that building.
SUMMARY
Hambledon Land is promoting a scheme of 100 units of accommodation for the elderly on land to the north west of the existing Fremantle Court Care Home with the potential for 50 units in a later phase to the south east.

The Further Modifications to the VALP propose to allocate land adjacent to Fremantle Court, Stoke Mandeville for C2 accommodation under Policy H6(b) for approximately 100 units. Hambledon Land consider that this allocation should be amended to reflect the proposal for approximately 100 units on land to the north west of the existing Fremantle Court Care Home. The land to the south east of Fremantle Court is also shown on the Policies Map as being part of this allocation. However for the reasons we set out, this should be safeguarded as a possible future phase.
We would be grateful for the opportunity to discuss the proposals on the land adjacent to Fremantle Court with Officers in greater detail.
Yours sincerely
David Murray-Cox