Aylesbury Vale Area

H6 Housing Mix

Showing comments and forms 1 to 30 of 35

Object

VALP Proposed Submission

Representation ID: 597

Received: 14/12/2017

Respondent: The Buckingham Society

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

BUT Policy needs clarification.
Paragraph 5.61 states that an element of self-contained extra care dwellings are required in "larger" residential schemes in strategic settlements. But H6 refers to 100 dwellings as the threshold.
H7 There is no mention of Houses in Multiple Occupation (HMOs), which, as well as limiting square footage space per person, add a further strain on adjacent community facilities; e.g. parking.

Officer Note: changed from support to Object - due to criticism

Full text:

BUT Policy needs clarification.
Paragraph 5.61 states that an element of self-contained extra care dwellings are required in "larger" residential schemes in strategic settlements. But H6 refers to 100 dwellings as the threshold.
H7 There is no mention of Houses in Multiple Occupation (HMOs), which, as well as limiting square footage space per person, add a further strain on adjacent community facilities; e.g. parking.

Object

VALP Proposed Submission

Representation ID: 699

Received: 12/12/2017

Respondent: Mr Alan Sherwell

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Whilst I agree with what is in this section, th opportunity should be taken to re-enforce the need for rented social housing

Full text:

Whilst I agree with what is in this section, th opportunity should be taken to re-enforce the need for rented social housing

Object

VALP Proposed Submission

Representation ID: 794

Received: 13/12/2017

Respondent: Define (on behalf of Bovis Homes)

Agent: Define (on behalf of Bovis Homes)

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

For the reasons set out above, Bovis Homes object to Policy H6, which is considered unsound on the basis that it:
- is not justified in that it is not the most appropriate strategy and has not properly considered reasonable alternative strategies; and
- is inconsistent with national guidance in that it does not fully reflect the Government's objective to ensure the housing requirements are not prohibitive to the delivery of development.

Full text:

The policy aspiration to ensure the provision of a mix of housing types and sizes to meet identified needs in future developments is welcomed. However, paragraph 50 of the NPPF confirms that in order to deliver a wide choice of high quality homes, widen the opportunities for home ownership and create sustainable, inclusive and mixed communities, planning authorities should consider both the needs of different groups and local demand for such. In this respect, it is essential that the difference between need and demand is recognised, as whilst the need arising from smaller households might be for smaller properties, the actual demand is commonly still for larger properties. This is not surprising as the benefits to smaller households of having more flexible living accommodation in both the short and long terms are clear, and ultimately more sustainable if it means that residents can stay in their home if their household grows or their circumstances change.

Bovis Homes has no objection to the principle of sheltered and extra care accommodation being provided in appropriate locations, but questions the basis upon which self-contained extra care provision is required as a part of any development over 100 dwellings in size. This prescriptive approach does not take account of local need or the site and location specific constraints to delivery of specialist housing of this type.

Consequently, the Local Plan should seek to identify and allocate specific development sites to address these needs where they are required. Whilst it may then be appropriate to encourage the specialist housing provision referred to in the policy in general housing developments, provision must be based on robust and credible evidence that identifies an up to date local need, including the monitoring of market activity over the plan period to identify the ability of developers to deliver specialist housing across the differing locations within the District.

Moreover, whilst the reference to taking account of the impact on the viability of developments is welcomed, the deliverability of sustainable development cannot be compromised by unduly onerous policy requirements. The Council must, therefore, demonstrate that the policy and infrastructure requirements in the Local Plan (cumulatively) in terms of financial contributions are achievable and do not render development unviable (NPPF paragraphs 158, 173-174). That must be considered at this stage. There is no evidence to that effect at this point in time as these policy requirements have not been robustly considered Local Plan's Viability Report.

Similarly the prescriptive blanket approach to the provision of accessible and adaptable compliant homes in the last part of the policy has not been appropriately justified.

Soundness:
For the reasons set out above, Bovis Homes object to Policy H6, which is considered unsound on the basis that it:
- is not justified in that it is not the most appropriate strategy and has not properly considered reasonable alternative strategies; and
- is inconsistent with national guidance in that it does not fully reflect the Government's objective to ensure the housing requirements are not prohibitive to the delivery of development.

Object

VALP Proposed Submission

Representation ID: 1183

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:

The policy states that all housing should be delivered to meet building regulation standard
Category 2 or above (10% of market housing and 15% of affordable housing should meet Category 3). This is unduly onerous. If the Government wanted all housing to meet
Category 2 as a minimum, the building regulations would be amended accordingly, except
for 10% to be delivered to M4(3) standards (i.e. all new dwellings will need to exceed
building regulations category 1). This is an onerous requirement which exceeds building
regulation requirements and which could adversely impact the deliverability and viability of
housing coming forward across the District.

Full text:

See attachment for full representation


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

Object

VALP Proposed Submission

Representation ID: 1331

Received: 21/12/2017

Respondent: Dandara Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Object, H6: supportive of wording regarding housing mix in HEDNA being a guide rather than a requirement. Should apply flexibility to individual sites and include site specific considerations.

Provision of extra care dwellings should be fully taken into account within viability assessments for individual sites. Definition of 'larger residential development schemes' as over 300 homes should be retained in paragraph 5.61.

Supports objective of requiring a proportion of new homes in developments to achieve Categories 2 & 3 in Approved Doc M: Vol 1. Should consider viability implications of standards and be in accordance with Planning Policy Guidance.

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: 1345

Received: 14/12/2017

Respondent: Gleeson Strategic Land

Agent: Nexus Planning Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object, H6:
The requirement for Category 3 market and affordable homes should be subject to viability.

Full text:

Representations to Policy H6 'Housing Mix'

1. We support the requirement for new residential developments to deliver a mix of housing types and sizes to meet current and future housing needs, having regard to the most up to date evidence.

2. We also note the requirement that all developments of 100 homes or more in strategic settlements provide an element of self-contained extra care dwellings as part of this overall mix, or an equivalent amount in an alternative location.

3. Specifically we note the requirement that for all new residential development, 10% of market housing and 15% of affordable housing should meet Category 3 of Approved Document M Volume 1. Paragraph 5.62 of the supporting text to this policy confirms that this relates to building regulations categories relating to adaptations and wheelchair accessible homes. Category 3 specifically is identified as wheelchair user dwellings.

4. We do not object to the principle in this regard but clearly in some circumstances, it may not be appropriate or viable to make such provision. This could therefore preclude the delivery of much needed housing and affordable housing generally. Accordingly we consider that this requirement should be subject to the same caveat as extra care provision i.e. subject to it being viable.

Changes Sought

5. Amend Policy H6 to make it clear that the requirement for Category 3 market and affordable homes is subject to viability.

Object

VALP Proposed Submission

Representation ID: 1354

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 requirement to deliver a mix of housing types and sizes in line with an assessment of requirements across the whole HMA is considered unreasonable and unjustified.
Developers are well placed to understand market demand for the type of housing needed in a particular location.

The requirement expressed in the second paragraph of the policy for self-contained extra care dwellings is considered unduly onerous, in conflict with paragraph 5.61 of the VALP and not justified by reference to express evidence of need of the amount of this type of accommodation required. In the event the policy requirement is warranted it should be justified by direct evidence of need on a case by case basis.

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: 1397

Received: 14/12/2017

Respondent: Edward Ware Homes

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Policy H6 is not justified and is not sufficiently flexible to respond to the circumstances of individual sites. It also requires and inefficient and ineffective provision of extra care accommodation.

Full text:

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

Text where there is more than the summary:

4.151 to 4.154

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

D2 Policy

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

H6

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

S2

Policy S2 makes provision for a total of 27,400 homes. The VALP should make provision for at least 33,350 homes to address the rounded OAN (of 24,000), the rounded unmet need (of 8,950) and the unmet need of Luton (of 400).
These figures will almost certainly increase significantly, once the standardised methodology becomes part of national policy and so additional provision should be supported or planned for (including through early review). The standardised methodology identifies an annual local housing need of 1,499 in Aylesbury Vale and 3,039 across Buckinghamshire. This compares to the proposed annual housing requirement of 970 in Aylesbury Vale and 2,310 across Buckinghamshire.
Therefore additional mechanisms will need to be identified now to address the resultant shortfall. This will need to include the identification of new sites in the Plan and through the proposed early review.
The wording of the policy will also need to be reviewed, as it states that provision will be made for 27,400 homes when paragraph 3.17 identifies that 29,016 homes have already been identified. This means that the policy as drafted will be ineffective and that it will be instantly obsolete.
The policy identifies only 1,095 dwellings to be delivered at the 19 medium villages. The medium villages are therefore accommodating quite limited growth and we consider that this figure, referred to by criterion 'h)', should be expressed as a minimum figure.
Presenting the figure as a minimum is important because, as stated above, the housing requirement is likely to increase and additional housing sites will need to be found.
Relatively limited growth is being proposed at the medium village and we consider that additional sites exist at these villages to support their sustainable growth and also help deliver the required housing. Sites at medium villages can make an important contribution to early housing delivery as they provide a different product to larger urban extensions and can often be quicker to deliver.
Paragraph 3.16 states that the future growth of medium villages reflects the capacity of these settlements to accommodate development. We question what this capacity is based on. For example, the Settlement Hierarchy (September 2017) evidence paper confirms Newton Longville to have a population of 1,111 and to meet 6 of the sustainability criteria, but only 17 dwellings will be allocated.
In comparison, Maids Moreton has a population of 847 and meets 6 criteria, yet 170 dwellings are to be allocated at the settlement.
Furthermore, paragraph 4.152 confirms that there is an 'excess' of suitable sites, so the most sustainable has been selected'. If Newton Longville has similar sustainability credentials to a settlement that will accommodate 170 dwellings and suitable sites are available at Newton Longville, we consider that there is no reason to limit sustainable growth at Newton Longville.

T7

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

Object

VALP Proposed Submission

Representation ID: 1499

Received: 14/12/2017

Respondent: Corbally (Finmere) Group and Mrs Vanessa Tait

Agent: WYG

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Draft Policy H6 is not positively prepared and will not be effective. This is because it
doesn't deliver enough flexibility to allow housing mix to be considered on a site by site
basis, to ensure local housing need is met and without the applicability of any blanket
requirements, for example on extra care provision.

Full text:

Please find attached representations to the Proposed Submission Version of the Aylesbury Vale Local Plan, made on behalf of Corbally (Finmere) Group and Mrs Vanessa Tait.

Object

VALP Proposed Submission

Representation ID: 1533

Received: 14/12/2017

Respondent: Catesby Estates Limited

Agent: Barton Willmore

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

However, it is considered that the first paragraph to draft Policy H6 is inflexible as it does not take
into account viability or site specific circumstances.

Full text:

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

Object

VALP Proposed Submission

Representation ID: 1541

Received: 14/12/2017

Respondent: FI Real Estate Management

Agent: DPP Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:


Policy H6 incorrectly translates the 300 houses large site threshold in justification paragraph 5.61 in to the policy as 100 dwellings. This sets up an unnecessary and unacceptable prospect of smaller scale schemes, including apartment buildings, needing to justify why extra care cannot be provided, adding costs and delay to provision of housing development. Additionally, it is unclear how provision of extra care will be furthered by such a policy as it takes little consideration of the specific support facilities required, including on-site staff availability. Extra care housing should be promoted in a standalone, positive policy

Full text:

Please accept by way of this email the attached representations to the Vale of Aylesbury Local Plan Proposed Submission Consultation.

The attached representations are made on behalf FI Real Estate Management for whom we are acting as agent. Representations are submitted in relation to the policies and sections set out below:
* Policy E1
* Policy H6
* Section 13 - Central Aylesbury Policies Map

Object

VALP Proposed Submission

Representation ID: 1563

Received: 14/12/2017

Respondent: Inspire Villages Group

Agent: BB Architecture and Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The representation of Inspired Villages Group is set out in The Inspire Villages
supporting statement which is to be read with reports also attached to the email
submission.
Documents forming part of this representation are:
(separate attachments):
* Inspire Villages supporting statement
* Housing LIN doc: More Choice Greater Voice
* JLL report Retirement living
* The Market Opportunity (ECV report)
* Economic, social and environmental impacts of a typical care village
* Knight Frank report

Full text:

This representation/consultation response comprises:

1. Completed Representation form
2. Inspire Villages supporting statement
3. Housing LIN doc: More Choice Greater Voice
4. JLL report Retirement living
5. The Market Opportunity (ECV report)
6. Economic, social and environmental impacts of a typical care village
7. Knight Frank report

Object

VALP Proposed Submission

Representation ID: 1602

Received: 14/12/2017

Respondent: Waldridge Garden Village Consortium

Agent: Pegasus Group (on behalf of Jeremy Elgin)

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Policy H6 is not justified and is not sufficiently flexible to respond to the circumstances of individual sites. It also requires and inefficient and ineffective provision of extra care accommodation.

Full text:

Please find attached representations to the VALP prepared on behalf of the Waldridge Garden Village Consortium

Object

VALP Proposed Submission

Representation ID: 1629

Received: 14/12/2017

Respondent: Gladman Developments Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to the percentage requirement in relation to Building Regulations Part M4(3) (wheelchair user dwellings). Not properly considered the viability implications of proposed policy requirements.

Full text:

Please see attached representation and appendices.

Object

VALP Proposed Submission

Representation ID: 1687

Received: 14/12/2017

Respondent: Buckinghamshire Fire & Rescue Service

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

We recommend that a requirement for the installation of automatic fire suppression systems be included for Category 2 (accessible and adaptable) and Category 3 (wheelchair user) dwellings as occupants will face greater risk to life in the event of fire.

Full text:

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

Object

VALP Proposed Submission

Representation ID: 1701

Received: 14/12/2017

Respondent: Richborough Estates

Agent: RPS Planning & Development

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

This policy expects that all larger developments should provide an element of self-contained extra care dwellings as part of the over mix. Whilst this might be possible on very large sites (500+), this would/may not be possible or appropriate on sites below this general level of site and should either therefore be clarified or omitted from the plan.
Concern is raised in relation to the requirement for all residential developments to meet Category 2 standards for adapted homes with 10% of market homes meeting Category 3 standards. The evidence base for such specific requirements appear limited and the justification appears lacking, particularly the viability implications of imposing such stringent requirements

Full text:

Attached report makes comments to the Proposed Submission VALP, by RPS on behalf of our client Richborough Estates, contains full comments on the policies and includes at appendix 1 a Housing Need Technical Review by Barton Willmore (November 2017).

Object

VALP Proposed Submission

Representation ID: 1728

Received: 14/12/2017

Respondent: Persimmon Homes Ltd., and CALA homes Ltd

Agent: Turley Associates

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

larger residential developments, in Strategic
Settlements, will be expected to provide an element of self-contained extra care
dwellings, noting that delivery of such units at an 'alternative location' may be
acceptable if this is agreed to be more appropriate. We submit that this aspect of the
proposed policy is all-encompassing and inflexible, in both its wording and conception.
The 'blanket' requirement to provide extra care dwellings discourages effective
consideration of the specific needs of the locality. Furthermore, even though there is
some allowance for delivery at alternative locations, the proposed policy assumes that
land will be available (in suitable locations).

Full text:

Please find attached representations submitted on behalf of Persimmon Homes Ltd., and CALA homes Ltd., in relation to the Proposed Submission Vale of Aylesbury Local Plan (2017).

Object

VALP Proposed Submission

Representation ID: 1777

Received: 14/12/2017

Respondent: Ainscough Strategic Land

Agent: Turley Associates

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

The 'blanket' requirement to provide extra care dwellings
discourages effective consideration of the specific needs of the locality, and has no
regard to the suitability of a particular site or its capacity to accommodate extra care
units or indeed the viability of such proposals. We advise that extra care developments
often require a large building footprint and introduce large blocks of apartments. Such
developments are unlikely to be suitable in locations where this would (for example)
contrast with development density in the surrounding locality.

Full text:

Please find attached representations to the Pre Submission Vale of Aylesbury Local Plan Consultation prepared on behalf of Ainscough Strategic Land in relation to 'Land at the Former Marsworth Airfield, Marsworth, Buckinghamshire', which is being promoted through the emerging Local Plan for a residential led mixed use development.

Object

VALP Proposed Submission

Representation ID: 1802

Received: 14/12/2017

Respondent: Wates Developments Ltd.

Agent: Boyer Planning Ltd

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

The housing mix may need to vary depending on the specific circumstances. We object to the requirement for self-contained extra care dwellings on the site. There is no evidence to justify the provision or assess the impact on scheme viability. the policy should be deleted.

Full text:

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

Object

VALP Proposed Submission

Representation ID: 1803

Received: 14/12/2017

Respondent: Minton Health Care (Buckingham) Ltd

Agent: Alder King

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

consequences of the policy, is that the OAN may not be met due to C2 development wrongly being assumed as forming part of the supply. Conversely, it will be unclear to what extent institutional need is being met if the development being delivered is assumed to be specialist mainstream housing. Of these two issues, of greatest concern to Minton is the risk that institutional need is not appropriately planned for, something that it considers to be a credible issue given that there is no commitment within the plan to meet the need for this type of development.

Full text:

Please find attached our representation to the Vale of Aylesbury Local Plan.

Object

VALP Proposed Submission

Representation ID: 1840

Received: 14/12/2017

Respondent: Rectory Homes Limited

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

The policy as drafted contains very limited detail to guide both decision makers and applicants in terms of agreeing an appropriate housing mix on a potential development site. This lack of detail introduces uncertainty and ambiguity with the policy. consider the policy to be contrary to advice in paragraph 17 of the NPPF

Full text:

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

Object

VALP Proposed Submission

Representation ID: 1853

Received: 14/12/2017

Respondent: CALA Homes Limited

Agent: Hunter Page Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

It also seeks to remove or for greater justification to be provided for the blanket requirement for 15% of affordable housing to meet category 3 requirements - M4(3) (wheelchair user dwellings), of the Building Regulations.

Full text:

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

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

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

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

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

Object

VALP Proposed Submission

Representation ID: 1918

Received: 14/12/2017

Respondent: Home Builders Federation Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

not justified the requirement for all homes to be built to part M4(2) and for 10% of market homes and 15% of affordable homes to be built to part M4(3). With regard to Part M4(2), the evidence in the HEDNA suggests that as the population is ageing then all new homes should be made accessible . However, the HEDNA itself outlines that many of the existing older people are unlikely to move from their current homes and as such there is likely to be significantly less need for new homes to be built to part M4(2).

Full text:

Response by the House Builders Federation to the Regulation 19 consultation on
the Vale of Aylesbury Local Plan
Thank you for consulting the Home Builders Federation (HBF) on Vale of Aylesbury
Local Plan (VALP). The HBF is the principal representative body of the housebuilding
industry in England and Wales and our representations reflect the views of discussions
with our membership of national and multinational corporations through to regional
developers and small local housebuilders. Our members account for over 80% of all
new housing built in England and Wales in any one year.
We would like to submit the following representations on the Local Plan and we
would welcome, in due course, participating in hearings of the Examination in
Public.
Duty to Co-operate
We do not consider the Council's approach to the duty to co-operate is consistent with
national policy.
It would appear from the evidence that Aylesbury Vale District Council (AVDC) have
met the legal requirements of the Duty to Co-operate in relation to meeting housing
needs for the Housing Market Area (HMA). There is a clear agreement between the
Council's in the HMA to meet needs in full with the unmet needs from the other
authorities in the HMA be provided for by Aylesbury Vale District Council (AVDC). This
is set out in policy S2 and we welcome the broad approach that has been taken by the
Councils in seeking to meet the needs of the HMA.
However, we are concerned that this co-operation is based on a housing needs
assessment that seeks to significantly reduce the overall level of housing need for the
HMA compared to official projections. In particular the latest assessment of housing
need has reduced the demographic starting point for AVDC, and subsequently its
objective assessed housing need (OAN). This has in turn provided greater scope for the
needs of the other authorities in the HMA to be met by AVDC. We consider the
approach to assessing housing needs is flawed and that there is significantly less
capacity in AVDC than is being suggested. In fact if the standard methodology were to
be applied across the HMA, and current distributions maintained, there would be even
less scope to meet the full needs of the Housing Market Area.
2
If the full needs of the HMA cannot be met, which would appear to be the case at
present then the policy requirements of the duty to co-operate as set out in 178 to 181
of the NPPF will not have been addressed. To ensure the plan is compliant with the
policy requirements of the duty to c-operate further consideration as to how the needs
of the HMA will be met in full will be necessary.
Our key concerns regarding the assessment of needs is set out below.
Housing needs
In our earlier comments on housing needs to the AVDC we raised concerns regarding
the January 2016 Housing Economic Development Needs Assessment (HEDNA) and
the reduction in housing needs compared the 2015 HEDNA. However, since the
regulation 18 consultation the HEDNA has been updated again to take into account the
latest 2014 based population projections published in the summer of 2016 which has
resulted in a significant reduction on the assessment of housing needs. We would
support the Council in undertaking such an update which is in line with Planning
Practice Guidance, however, we are surprised as to the outcomes of the update.
Having examined the 2014 based Household Projections for the HMA we note that
between 2013 and 2033 total households were 1,925 higher than those in the 2012
based projections. The updated HEDNA though sets out a distinctly different projection
of household growth. Between 2013 and 2033 the updated HEDNA expects the
demographic starting point for assessing housing needs to be 2,826 less than the
previous HEDNA using the 2012 based household projections. It seems surprising that
the updated HEDNA would see the opposite trend to the official projections. Despite
this significant discrepancy we cannot find any explanation as to why the upward trend
in the official projections leads to a reduction in households using the Council's
methodology.
Of particular concern is the fact that the latest HEDNA anticipates that AVDC are
expected to see household growth that is significantly lower than that set out in the
original HEDNA. The reason why this concern is so important is that AVDC are
expecting to meet the unmet needs arising from the other authorities in the HMA. The
updated HEDNA shows a reduction in the total number of households expected to form
during the plan period in AVDC from 18,144 households using the 2012 based
projections to 16,933 using the 2014 based data. However, the 2014 based household
projections expected there to be 2,623 more households in 2033 than was expected in
the 2012 based projections. So, despite the 2014 based household projections showing
an increase when compared to the 2012 projections the updated HEDNA projects a
reduction in household growth for AVDC. As mentioned above, there is no explanation
as to why this has occurred and given that it has enabled the HMA to meet its needs we
would have expected this to be addressed in the evidence supporting the plan. In fact,
the most recent HEDNA continues to claim in paragraph 9 that the growth identified for
AVDC is "marginally lower" than the CLG starting point. We would suggest that a
reduction of 4,095 households is more than "marginally lower".
3
It is essential that the Council's in the HMA provide a clear justification as to the reason
for this significant reduction in the demographic starting point. There are inconsistencies
with both previous projections provided by the Council and those provided by the
Government and ONS. The approach taken by the Councils is not clear and is one of
the reasons why the Government have been looking to apply a standard methodology
for assessing housing needs. However, even before the latest consultation Planning
Practice Guidance (PPG) sets out that Government considers the official household
projections to be robust stating in paragraph 2a-017:
"The household projections produced by the Department for Communities and Local
Government are statistically robust and are based on nationally consistent
assumptions."
The latest consultation 'Planning for the Right Homes in the Right Planes' reiterates this
position with the standard methodology being based on the household projections.
Paragraph 16 of the consultation document states:
"The Office for National Statistics' projections for numbers of households in each local
authority are the most robust estimates of future growth."
We recognise that the PPG allows for some sensitivity testing but it also requires these
to be based on robust evidence. So whilst our initial response was positive, despite our
usual concerns regarding the use of the 10 year trend, there is insufficient justification
as to why the latest projections for the HMA have substantially reduced household
growth for AVDC from the original HEDNA and, most importantly, why they have moved
in the opposite direction to the DCLG household projections.
The latest consultation also sets out that across the HMA the Government would expect
the new methodology, if implemented, to require a more significant level of housing
delivery. Based on the Standard Methodology the HMA would need to deliver 3,039
dwellings per annum (dpa) compared to the 2,269 dpa that is the Councils' assessment
of housing need. With regard to the duty to co-operate and meeting needs across the
HMA there must be a concern that AVDC's needs assessment is 534 dpa lower than
the standard methodology. Given the constraints expressed by the other authorities
there will clearly be a need for AVDC to consider a further increase in its housing
requirement in order to address an ever increasing level of unmet need in the HMA.
There have also been wider concerns regarding the tendency of local authorities within
this area to underestimate the levels of housing needs. The recent National
Infrastructure Commission (NIC) report1 on the Cambridge-Milton Keynes-Oxford Arc
identified the tendency for local planning authorities in this area to run assessments that
produce lower level so f housing need than official projections. On page 26 of this report
the NIC states:
1 Partnering for Prosperity: A new deal for the Cambridge-Milton-Keynes Oxford Arc (National
Infrastructure Commission 2017)
4
"... there is good reason to believe that the methodology used in undertaking
assessments of local housing need can be conservative and mask high levels of unmet
need."
It would appear that the tendency to underestimate housing need is prevalent across
this region. If the long term economic growth and infrastructure plans that are required
for this area are to be realised then the assessments of housing need must not seek to
supress official demographic projections.
In conclusion we do not consider that the level of housing needs, as set out in the
updated HEDNA, to have been sufficiently justified. In particular we do not consider the
substantial reduction in household growth using the government's 2014 based data to
have been adequately explained. These reduce the overall level of need for the HMA
and thus enabling the HMA to meet its needs. If the lower level of need set out in the
latest HEDNA cannot be justified then this will have significant implications for the
progression of the other Local Plans in the HMA due to the significantly reduced
additional development capacity in AVDC.
In addition there is potential for the level of unmet need from the other authorities to be
higher than initially considered. Whilst only limited weight can be given to the
consultation as a whole it does give the clearest positon yet as to the degree to which
market signals should be taken into account. This would suggest that housing needs
across the other authorities in the HMA could also have been underestimated leaving a
more significant degree of unmet needs than has been considered by AVDC and its
partners.
So, whilst the co-operation would appear to be effective it is potentially based on
erroneous evidence. If there is insufficient justification for the reduction in housing
needs resulting from the updated HEDNA then there will be a need for the authorities in
the HMA to revisit their collective approach to meeting housing needs.
We would also like to mention that it would have been beneficial for all parties had the
authorities in the HMA taken a more strategic approach in preparing their Plans to allow
housing needs to be considered by a single inspector. This enables the approach to
assessing and meeting housing needs for an HMA to be considered just once and
would avoid repetition of debates. We have seen across the Country that a decision on
OAN for an HMA at one EIP can make it difficult for any inspector at subsequent EIPs
using the same evidence to potentially disagree with a colleague. As such we welcome
approaches to strategic planning such as those taken in the North Essex HMA where a
strategic plan for the whole area has been prepared and allows housing needs across
the three LPAs concerned to be considered at the same time.
S2 Spatial strategy for growth
The policy is unsound as the delivery expectations to support the other authorities in the
HMA are unjustified
5
As set out above we have concerns as to the approach taken by the Council in
assessing the housing needs for the HMA and in particular the OAN for AVDC. We do
not consider that there is sufficient justification to reduce the demographic starting point
for AVDC and that the DCLG household projections remain robust and should be used
as the baseline for assessing needs. If the household projections were used as the
starting point for considering needs and a 10% uplift were applied, as recommended in
the HEDNA, then AVDC's OAN for the plan period would be 23,129 (1,156 dpa). As
such the Council would continue to be able to meet its own needs but there would be
less capacity to support the other authorities in the HMA. However, given the
Government's latest consultation we would suggest that a 10% uplift for AVDC is too
low and we would suggest it be reconsidered prior to submission.
So whilst we welcome the approach taken by AVDC to set a housing requirement of
27,400 new homes we do not consider the level of growth to be sufficient to support the
other authorities in the HMA to the degree stated. This will require the Council and its
partner authorities to reconsider its approach to meeting the needs of the HMA. If
current distributions of need are continued then AVDC will need to include additional
allocations to offset the limited delivery elsewhere in the HMA. Alternatively the other
authorities could seek to increase their own housing requirements to make up for the
shortfall. We recognise that not all the LPAs in the HMA are at the same stage of plan
preparation and if further allocations cannot be made in this plan the policy must set out
the need for an early review based on the final requirements of the other LPAs in the
HMA.
The policy should also establish that the housing requirement as the minimum number
of homes that will be delivered. This is important in order to ensure that growth beyond
the requirement is supported by the Council. This would also be consistent with the
positive approach to planning required by paragraph 14 of the NPPF and the Council's
own position in table 1 of the VALP, which sets out the expectation that 28,850 new
homes will be delivered.
Housing trajectory
The HBF does not comment on the merits or otherwise of individual sites therefore our
representations are submitted without prejudice to any comments made by other parties
on the deliverability of specific sites included in the overall housing land supply, the fiveyear
housing land supply and housing trajectories. However, we want to stress the
importance of having realistic delivery expectations within any allocations to ensure the
deliverability of the plan across its lifetime. This is particularly important where there is a
reliance on strategic sites to deliver the majority of new homes within the plan period.
Delays to the delivery of strategic sites for any number of reasons could lead to the LPA
not being able to meet its housing requirement. A more cautious assessment of delivery
on strategic sites offset with the allocation of smaller sites will offer a more flexible and
sound housing trajectory.
H1 - Affordable housing
The policy is not sound as it is unjustified and inconsistent with national policy
6
Whilst we appreciate that the Council were looking to test scenarios prior to setting
policies, it would appear that full consideration has not been given to the cumulative
financial impact of those policies as required by paragraph 173 of the NPPF. For
example, the policies on electric vehicle charging and accessible homes have been
considered separately and only with regard to a 50-unit mixed scheme. In addition, the
requirements in policy H4 concerning the optional accessibility standards have not been
tested. The nearest assumption is for 70% M4(2) and 5% M4(3). Significantly lower
than the requirements of policy H4. Until further testing is carried out on the cumulative
impact of the policies as set out in the Local Plan it is not possible for the Council to
state that the Local Plan will not threaten the viability of development in the area.
We consider that the wording of the policy is not consistent with the core planning
principles set out in the NPPF and the requirement established in paragraph 17 for
Local Plans to:
"... provide a practical framework within which decisions can be made with a high
degree of predictability and efficiency".
The policy states that the Council will require "a minimum of 25%" of all homes provided
on appropriate sites to be affordable. This suggests that in some circumstances the
Council will seek a high proportion of affordable housing provision and increases the
uncertainty for the decision maker and applicant as to what the appropriate amount of
affordable housing provision should be. This is of increasing concern to our members
who, where affordable housing policies are set as minimums, are being asked to
provide evidence to justify meeting the minimums. There is a real danger that such
policies will generate additional and unnecessary justification for policy compliant
schemes.
In order to make this policy consistent with national policy we would suggest that the
word "minimum" is removed. This will provide the necessary certainty required of such a
policy for both decision maker and applicant.
H5 - Self/Custom Build Housing
The policy is unsound as it is not consistent with national policy and is ineffective.
Whilst we support the encouragement of self-build housing through the local plan we
consider the requirement for sites of over 100 to provide an unstated number of selfbuild
plots is not justified and inconsistent with national policy. Whilst we recognise that
Local Planning Authorities now have a duty to promote self-build housing we do not
consider the Council to have looked at sufficient options with regard to how it can
provide plots to support self-builders. Paragraph 57-024 of the PPG sets out a variety of
approaches that need to be considered - including the use of their own land. This is
reiterated in para 57-14 of the PPG which sets out the need for Council's to consider
how they can support the delivery of self-build plots through their housing strategy, land
disposal and regeneration functions. We cannot find any evidence as to the Council's
consideration of other reasonable approaches to delivery as suggested in PPG. Without
7
such consideration it would appear that the Council is seeking to place the burden for
delivery of self-build plots on house-builders without looking sufficiently at other delivery
mechanisms as set out in national guidance.
We also consider the policy to be inconsistent with the third bullet point of paragraph
57-025 of PPG. This outlines that the Council should engage with landowners and
encourage them to consider self-build and custom housebuilding. The approach taken
by the Council moves beyond encouragement and requires land owners to bring
forward plots. We would therefore suggest that the policy be deleted and replaced with
a policy that seeks to encourage the provision of self-build plots on developments of
over 100 units.
Where plots are not sold it is important that the Council's policy is clear as to when
these revert to the developer. At present this policy makes no such provision, as such it
is ineffective. We would suggest that the policy state that if a plot remains unsold after 6
months of it being offered on the open market then it should revert back to the
developer to be delivered as part of the overall scheme. We would also recommend
that if development of a purchased plot has not commenced within three years of
purchase that the buyer be refunded and the plot reverts to the developer. It is
important that plots should not be left empty to detriment of its neighbours or the
development as a whole.
H6 - Housing mix
Parts of the policy are unsound as they are not justified
We do not consider the Council to have justified the requirement for all homes to be
built to part M4(2) and for 10% of market homes and 15% of affordable homes to be
built to part M4(3). With regard to Part M4(2), the evidence in the HEDNA suggests that
as the population is ageing then all new homes should be made accessible to ensure
those older people who do move are able to acquire an accessible home. However, the
HEDNA itself outlines that many of the existing older people are unlikely to move from
their current homes and as such there is likely to be significantly less need for new
homes to be built to part M4(2). It is also likely that many of those who do move will
move to accommodation specifically built to meet the needs of older people and not to
general market housing. As such we do not think it is justified for all new homes to be
built to part M4(2) solely on the basis that there is an ageing population.
The proposal to require 10% of market homes as being M4(3) is contrary to national
policy. PPG sets out in paragraph 56-009 that the standard for wheelchair accessible
homes only to properties where the local authority is responsible for allocating or
nominating a person to live in that dwelling. This means that M4(3) can only be applied
to affordable homes and the policy should be amended to reflect this position.
We accept that there may be some need to ensure a proportion of new affordable
homes are wheelchair accessible. However, we do not consider there to be sufficient
evidence to support a policy requiring 15% of all affordable homes as being built to Part
M4(3). Firstly, the Local Plan sets out that nationally 7.1% of households living in
8
affordable accommodation which suggests that provision at 15% is much higher than
the number of wheelchair users requiring such homes. Secondly, no consideration has
been given, as required in PPG, to the existing stock of affordable homes that are
already accessible to wheelchair users. Without this evidence the Council cannot be
certain as to whether there will currently a surplus of such homes within the Borough.
It is also the case that the Council's viability assessment has not tested the viability of
providing the level of accessible housing set out in this policy. As set out above in our
representation ton policy H1 the proportion of homes to be provided as either M4(2) or
M4(3) has not been tested. In addition, it has only been tested with regard to one
scenario - a 50-unit mixed development. As the full cumulative impacts of the policies
set out in the plan have not been tested we do not consider there to be sufficient
justification to support the proportion of homes required by the policy to conform to the
optional accessibility standards.
H7 Dwelling sizes
This policy is unsound as it is not consistent with national policy and is unjustified
The policy is not consistent with the approach to setting internal space standards in
PPG. Paragraph 56-018 to 56-023 set out that if a Local Planning Authority has
sufficient evidence to support the introduction of minimum space standards they should
only do so by reference to the national described space standards. Any other approach
taken to setting space standards must, therefore, be considered unsound. However, in
addition to this fundamental principal the Council state in paragraph 5.68 there is no
evidence to suggest that homes are coming forward below the nationally described
space standards. If this is the case then seeking to apply an alternative standard is
unjustified and unhelpful as the wording of this policy provides no clear guidance as to
what should be considered "sufficient internal space".
Such a subjective assessment could lead to confusion amongst both the decision
maker and the applicant. This policy is therefore inconsistent with one of the core
planning principles set out in paragraph 17 of the NPPF which states that local plans
should provide a:
"practical framework within which decisions on planning applications can be made with
a high degree of predictability and efficiency"
We would also suggest that is inconsistent with paragraph 154 which states:
"Only policies that provide a clear indication as to how a decision maker should react to
a development proposal should be included in the plan"
Given these clear inconsistencies with national policy and guidance policy H7 should be
deleted from the Local Plan.
T5 Vehicle Parking and T7 Electric Vehicle Infrastructure
9
These policies are unsound as they are ineffective
Within both these policies the Council will look to set out elements of both these policies
as in Supplementary Planning Documents (SPD). However, we do not consider it
appropriate to set out in SPD elements of a policy (namely the number of charging
points, the minimum internal size of a garage and the level of parking) that will have a
direct role in the determination of planning application. As such they must be set out in
policy and open for debate at the Examination in Public. Without these details it is
impossible to consider the impact of these policies on viability, whether they are justified
and ultimately whether they will be effective.
Conclusion
At present we do not consider the plan to be sound. Whilst we are pleased with the
significant progress the Council has made in meeting its own needs and those of the
HMA we do not consider the Council has met the tests of soundness on the following
areas:
 Policy S2 sets out the degree to which AVDC is meeting the needs of other
authorities in the HMA but these are based on an unjustifiably low OAN. This
potentially impacts on the soundness of this policy and whether the HMA is
meeting its needs in full as required by the NPPF.
 The policy on affordable housing has not been adequately justified and does not
provide sufficient flexibility
 Policy H5 on self-build housing is inconsistent with national policy and is
ineffective as it as it does not consider how unsold sites will be treated.
 Requirements relating to accessible homes have not been sufficiently justified
either on the basis of needs or viability.
 Policy H7 on dwelling size departs completely from the approach set out in PPG
and as such is inconsistent with national policy, unjustified and ineffective.
 Policy T5 and T7 on parking and Electric Vehicle Infrastructure set out that the
level of provision required will be set out in SPD. These elements of the policy
will inform decision makers and should be considered as policy. As such they
should be included in the Local Plan.
We hope these representations are of assistance in taking the plan forward to the next stage of plan preparation and examination. I would also like to express my interest in attending any relevant hearing sessions at the Examination in Public. Should you
require any further clarification on the issues raised in this representation please
contact me.

Object

VALP Proposed Submission

Representation ID: 1940

Received: 14/12/2017

Respondent: CALA Homes

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Policy H6 is not justified and is not sufficiently flexible to respond to the circumstances of individual sites.

Full text:

Please find attached in 10no. emails the representations made by CALA Homes to the draft Local Plan.

Object

VALP Proposed Submission

Representation ID: 1960

Received: 14/12/2017

Respondent: Careys New Homes

Agent: Bidwells

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Representation Summary:

Based on the above, we consider that Policy H6 is unsound as the policy is unjustified in terms of its
evidence base and inconsistent with national policy.

Full text:

On behalf of my client, Careys New Homes, I am pleased to submit the attached (4 no. PDFs) response to the VALP Proposed Submission consultation in respect of land at Wingrave.

Object

VALP Proposed Submission

Representation ID: 1970

Received: 14/12/2017

Respondent: Edward Ware Homes

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Policy H6 is not justified and is not sufficiently flexible to respond to the circumstances of individual sites. It also requires and inefficient and ineffective provision of extra care accommodation.

Full text:

VALP consultation- land at Broadway, Grendon Underwood

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


Full text if there is more than the summary:

Para 4.151-4.154

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

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

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

D2

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

H6

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

S2

Policy S2 makes provision for a total of 27,400 homes. The VALP should make provision for at least 33,350 homes to address the rounded OAN (of 24,000), the rounded unmet need (of 8,950) and the unmet need of Luton (of 400).
These figures will almost certainly increase significantly, once the standardised methodology becomes part of national policy and so additional provision should be supported or planned for (including through early review). The standardised methodology identifies an annual local housing need of 1,499 in Aylesbury Vale and 3,039 across Buckinghamshire. This compares to the proposed annual housing requirement of 970 in Aylesbury Vale and 2,310 across Buckinghamshire.
Therefore additional mechanisms will need to be identified now to address the resultant shortfall. This will need to include the identification of new sites in the Plan and through the proposed early review.
The wording of the policy will also need to be reviewed, as it states that provision will be made for 27,400 homes when paragraph 3.17 identifies that 29,016 homes have already been identified. This means that the policy as drafted will be ineffective and that it will be instantly obsolete.
The policy identifies only 1,095 dwellings to be delivered at the 19 medium villages. The medium villages are therefore accommodating quite limited growth and we consider that this figure, referred to by criterion 'h)', should be expressed as a minimum figure.
Presenting the figure as a minimum is important because, as stated above, the housing requirement is likely to increase and additional housing sites will need to be found.
Relatively limited growth is being proposed at the medium village and we consider that additional sites exist at these villages to support their sustainable growth and also help deliver the required housing. Sites at medium villages can make an important contribution to early housing delivery as they provide a different product to larger urban extensions and can often be quicker to deliver.
Paragraph 3.16 states that the future growth of medium villages reflects the capacity of these settlements to accommodate development. We question what this capacity is based on. For example, the Settlement Hierarchy (September 2017) evidence paper confirms Grendon Underwood to have a population of 1,111 and to meet 7 of the sustainability criteria.
In comparison, Maids Moreton has a population of 847 and meets 6 criteria, yet 170 dwellings are to be allocated at the settlement.

T7

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

Object

VALP Proposed Submission

Representation ID: 1977

Received: 14/12/2017

Respondent: Persimmon Homes Midlands

Agent: Bidwells

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The reference to Building Regulations is too prescriptive. The policy must be sufficiently flexible to adapt to changing circumstances as required by the NPPF. It is too rigid to specify percentages of dwellings to meet Building Regulations and this should relate to the identified need. Viability testing will be considered on a case by case basis. In any event, it is not necessary to require adherence to Building Regulations within a development plan policy and this reference should be omitted. Policy H6 is unsound as the policy is unjustified in terms of its evidence base and inconsistent with national policy.

Full text:

As it stands, the VALP is not sound and hence there are a number of changes required to the plan including a number of strategic and development management policies as identified in the submitted representation letter. In summary, we consider that the following policies are unsound and for reasons stated above, do not meet the test of soundness: Policy S2 'Spatial Strategy for Growth'; Policy S3 'Settlement Hierarchy and Cohesive Development'; Policy H1 'Affordable Housing'; Policy H5 'Self/Custom Build Housing'; Policy H6 'Housing Mix'; Policy H7 'Dwelling Sizes'; Policy T5 'Vehicle Parking'; and Policy T7 'Electric Vehicle Infrastructure'. My client's site at Calvert Green represents an achievable, suitable and deliverable allocation that is part brownfield to support the necessary housing growth for Aylesbury Vale.

Object

VALP Proposed Submission

Representation ID: 1997

Received: 14/12/2017

Respondent: Aylesbury Vale Estates LLP

Agent: Savills Reading

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The Policy states that "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, or an equivalent amount in an alternative location if this is agreed to be more appropriate".
The contribution of any amount of self-contained extra care dwellings must be considered on a site by site basis and subject to viability and demand.

Full text:

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

Object

VALP Proposed Submission

Representation ID: 2056

Received: 14/12/2017

Respondent: Manlet Group Holdings

Agent: Barton Willmore LLP

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Requirement for self contained extra care housing may make development unviable

Full text:

25845 - Halton Lane, Wendover.

On behalf of our client, Manlet Group Holdings, please find attached representations to the VALP Proposed Submission Consultation

Object

VALP Proposed Submission

Representation ID: 2068

Received: 14/12/2017

Respondent: Persimmon Homes North London

Agent: Woolf Bond Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The proposed policy affords no consideration to development viability and the
subsequent impact that the provision of extra care dwellings may have on the
overall deliverability of a scheme or the provision of affordable homes.

On the basis of the foregoing, including the lack of a detailed viability assessment
to assess the commercial impact of such a blanket requirement, we are of the
view that Policy H6 is not justified nor effective and has the potential to impede
the delivery of sites of in excess of 100 dwellings.

Full text:

Please find, on behalf of our Client, Persimmon Homes (North London) Ltd, the paperwork relating to the current consultation on the proposed Submission Version Vale of Aylesbury Local Plan.

Attached is a completed response form, reps letter and location plans.