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Object

VALP Proposed Submission

S2 Spatial Strategy for Growth

Representation ID: 468

Received: 08/12/2017

Respondent: Arnold White Estates

Agent: Gardner Planning Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

ORS District number is flawed at 970 homes p.a., well below other sources - ONS (1,092), GL Hearn 2015 (1,326), DCLG (1,499). CMKOx figures will be even higher. Household figures rose in the 2014 based projections (from 18,404 to 21,028), but ORS figures fell (from 21,289 to 19,385). ORS uses 10-year migration but ONS is 5-year. ORS have raised this point many times but ONS has not agreed. ORS numbers are so different complete re-assessment is required.
5YHLS is wrongly calculated and cannot be demonstrated - inadequate provision is made for 'persistent under-performance'.

Full text:

I attach the response to the consultation on the Proposed Submission VALP on behalf of Arnold White Estates. This is in the format of a full written Response because it deals with matters that cannot be adequately set out in a simple form.
However, a completed facsimile of you form is attached as an appendix with contact details and a summary of the representations (by policy number on separate sheets).
Please acknowledge receipt, note that I wish to participate in the Examination and keep me advised of progress.

Full summary given where it was more than 100 words (more detail in the main report):

S2

1. In order for the Plan to be 'sound' it must be based on robust evidence. The ORS
HEDNA, and thus the basis for the housing numbers in Policy S2 of the PSVALP, is long
and detailed, but essentially flawed. Its robustness is challenged by comparison with
three other sources in which ORS arrives at an annual OAN (970 homes p.a. for the
District) which is well below these: the ONS household projections (1,092), the GL
Hearn 2015 HEDNA (1,326) and the DCLG new methodology (1,499). Even the early
versions of the VALP/HEDNA had a higher OAN based on ONS 2012 projections. Yet
when these figures rose in the 2014 based projections (from 18,404 to 21,028) the
ORS figures fell (from 21,289 to 19,385). Also, the adjustment for migration trends
and other adjustments seem to fluctuate wildly (compare fig 109 in October 2015
with fig 122 in September 2017).
2. The HEDNA's low number is based on an early assumption that the use of a 10-year
migration trend is superior to that which continues to be used by ONS, even though
ORS have raised this point many times in recent years and are likely to be in close
touch with ONS. The ORS methodology reduces the ONS 'demographic starting
point' by over 4,000 households or 19%. There are then many further 'adjustments'
which are very detailed but almost incomprehensible. Even without the higher
numbers of the DCLG new methodology, it fails the test of "simpler, quicker, and
more transparent". A principle of the new methodology is to add a margin well
above household projections. Whilst the DCLG 2017 consultation states that Plans
submitted before 31.3.17 "will continue with the current plan preparation", the ORS
HEDNA numbers are so different to those derived from other sources that a complete
re-assessment is required and the PSVALP should then be based on the new, simpler
and transparent methodology.
3. The GL Hearn 2015 HEDNA arrived at an OAN (without allowance for accommodating
unmet housing needs of adjoining Authorities) of 1,326 home p.a. mainly because it
added housing needs of greater economic growth. The Cambs-MK-Oxford Growth Corridor vision and proposals of 2017, supported in the Autumn Budget, reinforce
and extend that growth potential and the consequent need for more housing.
4. The provision for unmet housing needs of adjoining Authorities may be inadequate
when the new DCLG methodology is applied to their numbers which are significantly
higher than currently anticipated.
5. The 5-year housing land supply figures are wrongly calculated in PSVALP paras 3.78 -
3.80 and Table 7 because inadequate provision is made for 'persistent underperformance'
and the correct figures show that a 5-year supply cannot be provided.
This is contrary to NPPF para 47.
6. PSVALP Policy S2, in terms of housing numbers, is therefore unsound because it is
not:
* Positively prepared - the objectively assessed housing needs are not based on
clear and robust evidence, and unmet requirements from adjoining Authorities
may be higher than anticipated.
* Justified - this is not the most appropriate strategy based on the evidence.
* Consistent with national policy - no account is taken of the Housing White
Paper and the growth proposals for the Cambs-MK-Oxford Corridor; and
provision for the 5-year housing land supply is inadequate.

D1 & S2

1. Whilst the term "Garden Town" is unobjectionable, the reality is that all the
Aylesbury sites are just urban extensions, two of which (AGT5 Berryfields and AGT6
Kingsbrook) already have planning permission and two (AGT3 Aston Clinton and AGT4
Hampden Fields) are the subject of applications submitted in early 2016.
2. In reality, therefore, the majority of "Garden Town" already (or almost) has planning
permission. Only two sites AGT1 (South Aylesbury) and AGT2 (South-West Aylesbury)
effectively seem open to discussion.
3. In relation to PSVALP Policies CP2 and D1, this Response raises objections to the
proposed allocation of both sites:
* AGT1 (South Aylesbury, 1,000 homes) is a collection of 6 small sites in different
ownerships without highway access, such that delivery must be in doubt.
* AGT2 (South-West Aylesbury, 1,550 homes) is severely constrained by HS2 of
which the centre line forms the south-west boundary of the site such that for at
least 100m into the site there can be no housing, and even beyond that living
conditions would be uncomfortable. The conclusion of the Core Strategy
Inspector's report in June 2010 on this site was "This would have a major
impact on the deliverability and potentially, the viability of the SGA, through
significant land take in the SW site".
The Plan is therefore unsound because
Positively prepared - two major sites have been allocated not based on clear and
robust evidence.
Justified - this is not the most appropriate strategy based on the evidence. Two
other sites proposed by GPL/AWEL are more sustainable, provide significant
benefits, are deliverable and are not adversely affected by HS2.
Berryfields East
1. The AWEL Berryfields East site (Appendix 3 in Full Response) to the NW of Aylesbury
should be considered as part of the growth of Aylesbury as a 'garden town'. The site
was submitted in response to the 'call for sites' in April 2014. It has a gross area of
some 20ha and a net developable area of some 11ha, with a capacity for some 350
homes.
2. The HELAA response was to raise concerns about landscape, impact on the setting of
the Scheduled Ancient Monument and biodiversity. These were broadly the reasons
for rejecting an appeal on the site in 2012. However, the scheme has been radically
revised since then to take account of the reasons for dismissal and has been
considerably reduced in terms of site area and numbers of dwellings. The appeal
decision related to some 1,380 dwellings on the larger site of some 33ha net.
Appendix 3 shows the revised illustrative masterplan, which has regard to the
Inspector's findings, and, for comparison, the rejected masterplan.
3. As well as a substantial reduction in site area and numbers of dwellings, the revised
scheme demonstrates significant changes since the last scheme was dismissed 5
years ago:
* The Western Link Road is now constructed and the Berryfields development has
advanced which changes the character and appearance of the local countryside
and the setting of the SAM.
* A substantial gap is provided between the eastern boundary of the
development area and Weedon Hill Urban Extension further to the east.
* Extensive open countryside in the new scheme would enhance the countryside
setting.
* The need for housing growth around Aylesbury is much greater than in
2010/12, and this Response has demonstrated that the PSVALP will have a
shortfall in requirements of thousands of homes.
* The site is unaffected by HS2.
* The landscape objection falls away because of the LUC study which designates
the nearest landscape designation being the Quainton-Wing Hills, some 2.76
km from the site to the nearest point just south of Weedon.
4. The HELAA seems to be assessing the 2010 scheme which is now superseded. The
new proposals are achievable, suitable and deliverable (the site is in single
ownership), and all within 5 years.
5. The proposal for the 'Aylesbury Linear Park' is supported. The plan on p66 is
somewhat difficult to read in the vicinity of Berryfields East but shows this Park as the
open land south of the Western Relief Road partly on land in the same ownership as
Berryfields East. Development on Berryfields East would therefore facilitate this
section of the Linear Park/green infrastructure network. Such integration of
development and green infrastructure is encouraged in Policy I1:
The Council will work with partners to ensure that existing and new green
infrastructure is identified, planned, delivered, enhanced and managed in a
strategic way as an integral part of supporting sustainable communities and
sustainable growth. The Council will implement the most up-to-date green
infrastructure strategies. Green infrastructure networks whether existing or
potential are expected to be a key part of site masterplanning as required in the
VALP.
6. Berryfields East, capacity 350 dwellings, should therefore be added to the list of
sites for Aylesbury in Policies S2 and D1.
Waddesdon
1. Waddesdon has been 'under-scored' in the settlement hierarchy by one factor -
distance to a main settlement - based on inaccurate measurement (see paras 2.28 -
2.30 above). In fact, Waddesdon is a 'large' large village with extensive facilities
(including a school, retailing, employment, good public transport, police and fire
stations, hotel and stately home), but is fundamentally harmed by the passage of
heavy traffic on the A41, which bisects the settlement.
2. However, Waddesdon is classed as a 'large village' in the hierarchy, which means
(emphasis in bold):
* As stated in the introduction to this report, the settlement hierarchy purpose is
not only to identify the current role of settlements through the facilities and
services they provide, but also to help define a sustainable settlement hierarchy
to facilitate decisions through the Vale of Aylesbury Local Plan on which
settlements are best placed to accommodate future development.
* Larger, more sustainable villages that have at least a reasonable access to
facilities and services and public transport, making them sustainable locations
for development.
3. Despite this encouragement, there are no housing allocations in the PSVALP for
Waddesdon.
4. In several places PSVALP mentions that the impact of HS2 will have to be mitigated.
This is particularly important to the opportunities for development at Waddesdon.
Here, HS2 passes close to the north of Waddesdon and the proposed AWEL
development (Appendix 4) includes mitigation measures that will shield the village.
5. The Inspector's Report on the NP included the following extracts:
In my assessment, the promotion of this major development to the north of the
village, together with a projected A41 Relief Road, is a matter of strategic districtwide
importance which falls properly to be considered as part of the preparation of
the VALP.
6. In several places PSVALP mentions that the impact of HS2 will have to be mitigated.
This is particularly important to the opportunities for development at Waddesdon.
Here, HS2 passes close to the north of Waddesdon and the proposed AWEL
development (Appendix 4) includes mitigation measures that will shield the village.
7. The proposed development at Waddesdon (Appendix 4 in full Response) includes the
advantages as fully set out in the full Response, e.g.
* provision of some 600 homes, either in the context of the housing shortfall
detailed or as an opportunity site
* the creation of a Garden Village development
* facilitation of a relief road and improvements to the central area of the village
* provision of a village green
* improvement to the appearance of the site by removal of poor and redundant
agricultural buildings
8. These are interesting times when much of planning orthodoxy is being overturned in
order to meet society's real needs (especially housing). It is turning away from
negative stances of protectionism against development towards positive action which
benefits all parts of the community which it serves. The first policy (S1) in the DP
begins:
The council will work proactively with applicants to find solutions so that proposals
can be approved wherever possible, and to secure development that improves the
economic, social and environmental conditions in the area.
9. AVDC has the opportunity to put this into practice at Waddesdon and include the
AWEL development proposal as a strategic site in the Local Plan in Policies S2 and
D1.

Object

VALP Proposed Submission

D1 Delivering Aylesbury Garden Town

Representation ID: 1266

Received: 08/12/2017

Respondent: Arnold White Estates

Agent: Gardner Planning Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

Applies to D1&S2. Garden town sites are just urban extensions, most are committed apart from AGT1 and AGT2, both of which are objected too. AGT1 is a collection of 6 small sites in different ownerships without highway access, such that delivery must be in doubt. AGT2 is severely constrained by HS2 of which the centre line forms the south-west boundary of the site such that for at least 100m into the site there can be no housing, and even beyond that living conditions would be uncomfortable. Two alternative sites are proposed that are deliverable, details are provided in full text.

Full text:

I attach the response to the consultation on the Proposed Submission VALP on behalf of Arnold White Estates. This is in the format of a full written Response because it deals with matters that cannot be adequately set out in a simple form.
However, a completed facsimile of you form is attached as an appendix with contact details and a summary of the representations (by policy number on separate sheets).
Please acknowledge receipt, note that I wish to participate in the Examination and keep me advised of progress.

Full summary given where it was more than 100 words (more detail in the main report):

S2

1. In order for the Plan to be 'sound' it must be based on robust evidence. The ORS
HEDNA, and thus the basis for the housing numbers in Policy S2 of the PSVALP, is long
and detailed, but essentially flawed. Its robustness is challenged by comparison with
three other sources in which ORS arrives at an annual OAN (970 homes p.a. for the
District) which is well below these: the ONS household projections (1,092), the GL
Hearn 2015 HEDNA (1,326) and the DCLG new methodology (1,499). Even the early
versions of the VALP/HEDNA had a higher OAN based on ONS 2012 projections. Yet
when these figures rose in the 2014 based projections (from 18,404 to 21,028) the
ORS figures fell (from 21,289 to 19,385). Also, the adjustment for migration trends
and other adjustments seem to fluctuate wildly (compare fig 109 in October 2015
with fig 122 in September 2017).
2. The HEDNA's low number is based on an early assumption that the use of a 10-year
migration trend is superior to that which continues to be used by ONS, even though
ORS have raised this point many times in recent years and are likely to be in close
touch with ONS. The ORS methodology reduces the ONS 'demographic starting
point' by over 4,000 households or 19%. There are then many further 'adjustments'
which are very detailed but almost incomprehensible. Even without the higher
numbers of the DCLG new methodology, it fails the test of "simpler, quicker, and
more transparent". A principle of the new methodology is to add a margin well
above household projections. Whilst the DCLG 2017 consultation states that Plans
submitted before 31.3.17 "will continue with the current plan preparation", the ORS
HEDNA numbers are so different to those derived from other sources that a complete
re-assessment is required and the PSVALP should then be based on the new, simpler
and transparent methodology.
3. The GL Hearn 2015 HEDNA arrived at an OAN (without allowance for accommodating
unmet housing needs of adjoining Authorities) of 1,326 home p.a. mainly because it
added housing needs of greater economic growth. The Cambs-MK-Oxford Growth Corridor vision and proposals of 2017, supported in the Autumn Budget, reinforce
and extend that growth potential and the consequent need for more housing.
4. The provision for unmet housing needs of adjoining Authorities may be inadequate
when the new DCLG methodology is applied to their numbers which are significantly
higher than currently anticipated.
5. The 5-year housing land supply figures are wrongly calculated in PSVALP paras 3.78 -
3.80 and Table 7 because inadequate provision is made for 'persistent underperformance'
and the correct figures show that a 5-year supply cannot be provided.
This is contrary to NPPF para 47.
6. PSVALP Policy S2, in terms of housing numbers, is therefore unsound because it is
not:
* Positively prepared - the objectively assessed housing needs are not based on
clear and robust evidence, and unmet requirements from adjoining Authorities
may be higher than anticipated.
* Justified - this is not the most appropriate strategy based on the evidence.
* Consistent with national policy - no account is taken of the Housing White
Paper and the growth proposals for the Cambs-MK-Oxford Corridor; and
provision for the 5-year housing land supply is inadequate.

D1 & S2

1. Whilst the term "Garden Town" is unobjectionable, the reality is that all the
Aylesbury sites are just urban extensions, two of which (AGT5 Berryfields and AGT6
Kingsbrook) already have planning permission and two (AGT3 Aston Clinton and AGT4
Hampden Fields) are the subject of applications submitted in early 2016.
2. In reality, therefore, the majority of "Garden Town" already (or almost) has planning
permission. Only two sites AGT1 (South Aylesbury) and AGT2 (South-West Aylesbury)
effectively seem open to discussion.
3. In relation to PSVALP Policies CP2 and D1, this Response raises objections to the
proposed allocation of both sites:
* AGT1 (South Aylesbury, 1,000 homes) is a collection of 6 small sites in different
ownerships without highway access, such that delivery must be in doubt.
* AGT2 (South-West Aylesbury, 1,550 homes) is severely constrained by HS2 of
which the centre line forms the south-west boundary of the site such that for at
least 100m into the site there can be no housing, and even beyond that living
conditions would be uncomfortable. The conclusion of the Core Strategy
Inspector's report in June 2010 on this site was "This would have a major
impact on the deliverability and potentially, the viability of the SGA, through
significant land take in the SW site".
The Plan is therefore unsound because
Positively prepared - two major sites have been allocated not based on clear and
robust evidence.
Justified - this is not the most appropriate strategy based on the evidence. Two
other sites proposed by GPL/AWEL are more sustainable, provide significant
benefits, are deliverable and are not adversely affected by HS2.
Berryfields East
1. The AWEL Berryfields East site (Appendix 3 in Full Response) to the NW of Aylesbury
should be considered as part of the growth of Aylesbury as a 'garden town'. The site
was submitted in response to the 'call for sites' in April 2014. It has a gross area of
some 20ha and a net developable area of some 11ha, with a capacity for some 350
homes.
2. The HELAA response was to raise concerns about landscape, impact on the setting of
the Scheduled Ancient Monument and biodiversity. These were broadly the reasons
for rejecting an appeal on the site in 2012. However, the scheme has been radically
revised since then to take account of the reasons for dismissal and has been
considerably reduced in terms of site area and numbers of dwellings. The appeal
decision related to some 1,380 dwellings on the larger site of some 33ha net.
Appendix 3 shows the revised illustrative masterplan, which has regard to the
Inspector's findings, and, for comparison, the rejected masterplan.
3. As well as a substantial reduction in site area and numbers of dwellings, the revised
scheme demonstrates significant changes since the last scheme was dismissed 5
years ago:
* The Western Link Road is now constructed and the Berryfields development has
advanced which changes the character and appearance of the local countryside
and the setting of the SAM.
* A substantial gap is provided between the eastern boundary of the
development area and Weedon Hill Urban Extension further to the east.
* Extensive open countryside in the new scheme would enhance the countryside
setting.
* The need for housing growth around Aylesbury is much greater than in
2010/12, and this Response has demonstrated that the PSVALP will have a
shortfall in requirements of thousands of homes.
* The site is unaffected by HS2.
* The landscape objection falls away because of the LUC study which designates
the nearest landscape designation being the Quainton-Wing Hills, some 2.76
km from the site to the nearest point just south of Weedon.
4. The HELAA seems to be assessing the 2010 scheme which is now superseded. The
new proposals are achievable, suitable and deliverable (the site is in single
ownership), and all within 5 years.
5. The proposal for the 'Aylesbury Linear Park' is supported. The plan on p66 is
somewhat difficult to read in the vicinity of Berryfields East but shows this Park as the
open land south of the Western Relief Road partly on land in the same ownership as
Berryfields East. Development on Berryfields East would therefore facilitate this
section of the Linear Park/green infrastructure network. Such integration of
development and green infrastructure is encouraged in Policy I1:
The Council will work with partners to ensure that existing and new green
infrastructure is identified, planned, delivered, enhanced and managed in a
strategic way as an integral part of supporting sustainable communities and
sustainable growth. The Council will implement the most up-to-date green
infrastructure strategies. Green infrastructure networks whether existing or
potential are expected to be a key part of site masterplanning as required in the
VALP.
6. Berryfields East, capacity 350 dwellings, should therefore be added to the list of
sites for Aylesbury in Policies S2 and D1.
Waddesdon
1. Waddesdon has been 'under-scored' in the settlement hierarchy by one factor -
distance to a main settlement - based on inaccurate measurement (see paras 2.28 -
2.30 above). In fact, Waddesdon is a 'large' large village with extensive facilities
(including a school, retailing, employment, good public transport, police and fire
stations, hotel and stately home), but is fundamentally harmed by the passage of
heavy traffic on the A41, which bisects the settlement.
2. However, Waddesdon is classed as a 'large village' in the hierarchy, which means
(emphasis in bold):
* As stated in the introduction to this report, the settlement hierarchy purpose is
not only to identify the current role of settlements through the facilities and
services they provide, but also to help define a sustainable settlement hierarchy
to facilitate decisions through the Vale of Aylesbury Local Plan on which
settlements are best placed to accommodate future development.
* Larger, more sustainable villages that have at least a reasonable access to
facilities and services and public transport, making them sustainable locations
for development.
3. Despite this encouragement, there are no housing allocations in the PSVALP for
Waddesdon.
4. In several places PSVALP mentions that the impact of HS2 will have to be mitigated.
This is particularly important to the opportunities for development at Waddesdon.
Here, HS2 passes close to the north of Waddesdon and the proposed AWEL
development (Appendix 4) includes mitigation measures that will shield the village.
5. The Inspector's Report on the NP included the following extracts:
In my assessment, the promotion of this major development to the north of the
village, together with a projected A41 Relief Road, is a matter of strategic districtwide
importance which falls properly to be considered as part of the preparation of
the VALP.
6. In several places PSVALP mentions that the impact of HS2 will have to be mitigated.
This is particularly important to the opportunities for development at Waddesdon.
Here, HS2 passes close to the north of Waddesdon and the proposed AWEL
development (Appendix 4) includes mitigation measures that will shield the village.
7. The proposed development at Waddesdon (Appendix 4 in full Response) includes the
advantages as fully set out in the full Response, e.g.
* provision of some 600 homes, either in the context of the housing shortfall
detailed or as an opportunity site
* the creation of a Garden Village development
* facilitation of a relief road and improvements to the central area of the village
* provision of a village green
* improvement to the appearance of the site by removal of poor and redundant
agricultural buildings
8. These are interesting times when much of planning orthodoxy is being overturned in
order to meet society's real needs (especially housing). It is turning away from
negative stances of protectionism against development towards positive action which
benefits all parts of the community which it serves. The first policy (S1) in the DP
begins:
The council will work proactively with applicants to find solutions so that proposals
can be approved wherever possible, and to secure development that improves the
economic, social and environmental conditions in the area.
9. AVDC has the opportunity to put this into practice at Waddesdon and include the
AWEL development proposal as a strategic site in the Local Plan in Policies S2 and
D1.

Object

VALP Proposed Submission

S4 Green Belt

Representation ID: 1271

Received: 08/12/2017

Respondent: Arnold White Estates

Agent: Gardner Planning Ltd

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Representation Summary:

The text at para 3.31 and 3.33 is supported, but S4 needs to refer to a change of Green
Belt boundary.

Full text:

I attach the response to the consultation on the Proposed Submission VALP on behalf of Arnold White Estates. This is in the format of a full written Response because it deals with matters that cannot be adequately set out in a simple form.
However, a completed facsimile of you form is attached as an appendix with contact details and a summary of the representations (by policy number on separate sheets).
Please acknowledge receipt, note that I wish to participate in the Examination and keep me advised of progress.

Full summary given where it was more than 100 words (more detail in the main report):

S2

1. In order for the Plan to be 'sound' it must be based on robust evidence. The ORS
HEDNA, and thus the basis for the housing numbers in Policy S2 of the PSVALP, is long
and detailed, but essentially flawed. Its robustness is challenged by comparison with
three other sources in which ORS arrives at an annual OAN (970 homes p.a. for the
District) which is well below these: the ONS household projections (1,092), the GL
Hearn 2015 HEDNA (1,326) and the DCLG new methodology (1,499). Even the early
versions of the VALP/HEDNA had a higher OAN based on ONS 2012 projections. Yet
when these figures rose in the 2014 based projections (from 18,404 to 21,028) the
ORS figures fell (from 21,289 to 19,385). Also, the adjustment for migration trends
and other adjustments seem to fluctuate wildly (compare fig 109 in October 2015
with fig 122 in September 2017).
2. The HEDNA's low number is based on an early assumption that the use of a 10-year
migration trend is superior to that which continues to be used by ONS, even though
ORS have raised this point many times in recent years and are likely to be in close
touch with ONS. The ORS methodology reduces the ONS 'demographic starting
point' by over 4,000 households or 19%. There are then many further 'adjustments'
which are very detailed but almost incomprehensible. Even without the higher
numbers of the DCLG new methodology, it fails the test of "simpler, quicker, and
more transparent". A principle of the new methodology is to add a margin well
above household projections. Whilst the DCLG 2017 consultation states that Plans
submitted before 31.3.17 "will continue with the current plan preparation", the ORS
HEDNA numbers are so different to those derived from other sources that a complete
re-assessment is required and the PSVALP should then be based on the new, simpler
and transparent methodology.
3. The GL Hearn 2015 HEDNA arrived at an OAN (without allowance for accommodating
unmet housing needs of adjoining Authorities) of 1,326 home p.a. mainly because it
added housing needs of greater economic growth. The Cambs-MK-Oxford Growth Corridor vision and proposals of 2017, supported in the Autumn Budget, reinforce
and extend that growth potential and the consequent need for more housing.
4. The provision for unmet housing needs of adjoining Authorities may be inadequate
when the new DCLG methodology is applied to their numbers which are significantly
higher than currently anticipated.
5. The 5-year housing land supply figures are wrongly calculated in PSVALP paras 3.78 -
3.80 and Table 7 because inadequate provision is made for 'persistent underperformance'
and the correct figures show that a 5-year supply cannot be provided.
This is contrary to NPPF para 47.
6. PSVALP Policy S2, in terms of housing numbers, is therefore unsound because it is
not:
* Positively prepared - the objectively assessed housing needs are not based on
clear and robust evidence, and unmet requirements from adjoining Authorities
may be higher than anticipated.
* Justified - this is not the most appropriate strategy based on the evidence.
* Consistent with national policy - no account is taken of the Housing White
Paper and the growth proposals for the Cambs-MK-Oxford Corridor; and
provision for the 5-year housing land supply is inadequate.

D1 & S2

1. Whilst the term "Garden Town" is unobjectionable, the reality is that all the
Aylesbury sites are just urban extensions, two of which (AGT5 Berryfields and AGT6
Kingsbrook) already have planning permission and two (AGT3 Aston Clinton and AGT4
Hampden Fields) are the subject of applications submitted in early 2016.
2. In reality, therefore, the majority of "Garden Town" already (or almost) has planning
permission. Only two sites AGT1 (South Aylesbury) and AGT2 (South-West Aylesbury)
effectively seem open to discussion.
3. In relation to PSVALP Policies CP2 and D1, this Response raises objections to the
proposed allocation of both sites:
* AGT1 (South Aylesbury, 1,000 homes) is a collection of 6 small sites in different
ownerships without highway access, such that delivery must be in doubt.
* AGT2 (South-West Aylesbury, 1,550 homes) is severely constrained by HS2 of
which the centre line forms the south-west boundary of the site such that for at
least 100m into the site there can be no housing, and even beyond that living
conditions would be uncomfortable. The conclusion of the Core Strategy
Inspector's report in June 2010 on this site was "This would have a major
impact on the deliverability and potentially, the viability of the SGA, through
significant land take in the SW site".
The Plan is therefore unsound because
Positively prepared - two major sites have been allocated not based on clear and
robust evidence.
Justified - this is not the most appropriate strategy based on the evidence. Two
other sites proposed by GPL/AWEL are more sustainable, provide significant
benefits, are deliverable and are not adversely affected by HS2.
Berryfields East
1. The AWEL Berryfields East site (Appendix 3 in Full Response) to the NW of Aylesbury
should be considered as part of the growth of Aylesbury as a 'garden town'. The site
was submitted in response to the 'call for sites' in April 2014. It has a gross area of
some 20ha and a net developable area of some 11ha, with a capacity for some 350
homes.
2. The HELAA response was to raise concerns about landscape, impact on the setting of
the Scheduled Ancient Monument and biodiversity. These were broadly the reasons
for rejecting an appeal on the site in 2012. However, the scheme has been radically
revised since then to take account of the reasons for dismissal and has been
considerably reduced in terms of site area and numbers of dwellings. The appeal
decision related to some 1,380 dwellings on the larger site of some 33ha net.
Appendix 3 shows the revised illustrative masterplan, which has regard to the
Inspector's findings, and, for comparison, the rejected masterplan.
3. As well as a substantial reduction in site area and numbers of dwellings, the revised
scheme demonstrates significant changes since the last scheme was dismissed 5
years ago:
* The Western Link Road is now constructed and the Berryfields development has
advanced which changes the character and appearance of the local countryside
and the setting of the SAM.
* A substantial gap is provided between the eastern boundary of the
development area and Weedon Hill Urban Extension further to the east.
* Extensive open countryside in the new scheme would enhance the countryside
setting.
* The need for housing growth around Aylesbury is much greater than in
2010/12, and this Response has demonstrated that the PSVALP will have a
shortfall in requirements of thousands of homes.
* The site is unaffected by HS2.
* The landscape objection falls away because of the LUC study which designates
the nearest landscape designation being the Quainton-Wing Hills, some 2.76
km from the site to the nearest point just south of Weedon.
4. The HELAA seems to be assessing the 2010 scheme which is now superseded. The
new proposals are achievable, suitable and deliverable (the site is in single
ownership), and all within 5 years.
5. The proposal for the 'Aylesbury Linear Park' is supported. The plan on p66 is
somewhat difficult to read in the vicinity of Berryfields East but shows this Park as the
open land south of the Western Relief Road partly on land in the same ownership as
Berryfields East. Development on Berryfields East would therefore facilitate this
section of the Linear Park/green infrastructure network. Such integration of
development and green infrastructure is encouraged in Policy I1:
The Council will work with partners to ensure that existing and new green
infrastructure is identified, planned, delivered, enhanced and managed in a
strategic way as an integral part of supporting sustainable communities and
sustainable growth. The Council will implement the most up-to-date green
infrastructure strategies. Green infrastructure networks whether existing or
potential are expected to be a key part of site masterplanning as required in the
VALP.
6. Berryfields East, capacity 350 dwellings, should therefore be added to the list of
sites for Aylesbury in Policies S2 and D1.
Waddesdon
1. Waddesdon has been 'under-scored' in the settlement hierarchy by one factor -
distance to a main settlement - based on inaccurate measurement (see paras 2.28 -
2.30 above). In fact, Waddesdon is a 'large' large village with extensive facilities
(including a school, retailing, employment, good public transport, police and fire
stations, hotel and stately home), but is fundamentally harmed by the passage of
heavy traffic on the A41, which bisects the settlement.
2. However, Waddesdon is classed as a 'large village' in the hierarchy, which means
(emphasis in bold):
* As stated in the introduction to this report, the settlement hierarchy purpose is
not only to identify the current role of settlements through the facilities and
services they provide, but also to help define a sustainable settlement hierarchy
to facilitate decisions through the Vale of Aylesbury Local Plan on which
settlements are best placed to accommodate future development.
* Larger, more sustainable villages that have at least a reasonable access to
facilities and services and public transport, making them sustainable locations
for development.
3. Despite this encouragement, there are no housing allocations in the PSVALP for
Waddesdon.
4. In several places PSVALP mentions that the impact of HS2 will have to be mitigated.
This is particularly important to the opportunities for development at Waddesdon.
Here, HS2 passes close to the north of Waddesdon and the proposed AWEL
development (Appendix 4) includes mitigation measures that will shield the village.
5. The Inspector's Report on the NP included the following extracts:
In my assessment, the promotion of this major development to the north of the
village, together with a projected A41 Relief Road, is a matter of strategic districtwide
importance which falls properly to be considered as part of the preparation of
the VALP.
6. In several places PSVALP mentions that the impact of HS2 will have to be mitigated.
This is particularly important to the opportunities for development at Waddesdon.
Here, HS2 passes close to the north of Waddesdon and the proposed AWEL
development (Appendix 4) includes mitigation measures that will shield the village.
7. The proposed development at Waddesdon (Appendix 4 in full Response) includes the
advantages as fully set out in the full Response, e.g.
* provision of some 600 homes, either in the context of the housing shortfall
detailed or as an opportunity site
* the creation of a Garden Village development
* facilitation of a relief road and improvements to the central area of the village
* provision of a village green
* improvement to the appearance of the site by removal of poor and redundant
agricultural buildings
8. These are interesting times when much of planning orthodoxy is being overturned in
order to meet society's real needs (especially housing). It is turning away from
negative stances of protectionism against development towards positive action which
benefits all parts of the community which it serves. The first policy (S1) in the DP
begins:
The council will work proactively with applicants to find solutions so that proposals
can be approved wherever possible, and to secure development that improves the
economic, social and environmental conditions in the area.
9. AVDC has the opportunity to put this into practice at Waddesdon and include the
AWEL development proposal as a strategic site in the Local Plan in Policies S2 and
D1.

Object

VALP Proposed Submission

C3 Renewable Energy

Representation ID: 1272

Received: 08/12/2017

Respondent: Arnold White Estates

Agent: Gardner Planning Ltd

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Representation Summary:

Policy C3 is supported (logged as object as they wish to speak at the examination though)

Full text:

I attach the response to the consultation on the Proposed Submission VALP on behalf of Arnold White Estates. This is in the format of a full written Response because it deals with matters that cannot be adequately set out in a simple form.
However, a completed facsimile of you form is attached as an appendix with contact details and a summary of the representations (by policy number on separate sheets).
Please acknowledge receipt, note that I wish to participate in the Examination and keep me advised of progress.

Full summary given where it was more than 100 words (more detail in the main report):

S2

1. In order for the Plan to be 'sound' it must be based on robust evidence. The ORS
HEDNA, and thus the basis for the housing numbers in Policy S2 of the PSVALP, is long
and detailed, but essentially flawed. Its robustness is challenged by comparison with
three other sources in which ORS arrives at an annual OAN (970 homes p.a. for the
District) which is well below these: the ONS household projections (1,092), the GL
Hearn 2015 HEDNA (1,326) and the DCLG new methodology (1,499). Even the early
versions of the VALP/HEDNA had a higher OAN based on ONS 2012 projections. Yet
when these figures rose in the 2014 based projections (from 18,404 to 21,028) the
ORS figures fell (from 21,289 to 19,385). Also, the adjustment for migration trends
and other adjustments seem to fluctuate wildly (compare fig 109 in October 2015
with fig 122 in September 2017).
2. The HEDNA's low number is based on an early assumption that the use of a 10-year
migration trend is superior to that which continues to be used by ONS, even though
ORS have raised this point many times in recent years and are likely to be in close
touch with ONS. The ORS methodology reduces the ONS 'demographic starting
point' by over 4,000 households or 19%. There are then many further 'adjustments'
which are very detailed but almost incomprehensible. Even without the higher
numbers of the DCLG new methodology, it fails the test of "simpler, quicker, and
more transparent". A principle of the new methodology is to add a margin well
above household projections. Whilst the DCLG 2017 consultation states that Plans
submitted before 31.3.17 "will continue with the current plan preparation", the ORS
HEDNA numbers are so different to those derived from other sources that a complete
re-assessment is required and the PSVALP should then be based on the new, simpler
and transparent methodology.
3. The GL Hearn 2015 HEDNA arrived at an OAN (without allowance for accommodating
unmet housing needs of adjoining Authorities) of 1,326 home p.a. mainly because it
added housing needs of greater economic growth. The Cambs-MK-Oxford Growth Corridor vision and proposals of 2017, supported in the Autumn Budget, reinforce
and extend that growth potential and the consequent need for more housing.
4. The provision for unmet housing needs of adjoining Authorities may be inadequate
when the new DCLG methodology is applied to their numbers which are significantly
higher than currently anticipated.
5. The 5-year housing land supply figures are wrongly calculated in PSVALP paras 3.78 -
3.80 and Table 7 because inadequate provision is made for 'persistent underperformance'
and the correct figures show that a 5-year supply cannot be provided.
This is contrary to NPPF para 47.
6. PSVALP Policy S2, in terms of housing numbers, is therefore unsound because it is
not:
* Positively prepared - the objectively assessed housing needs are not based on
clear and robust evidence, and unmet requirements from adjoining Authorities
may be higher than anticipated.
* Justified - this is not the most appropriate strategy based on the evidence.
* Consistent with national policy - no account is taken of the Housing White
Paper and the growth proposals for the Cambs-MK-Oxford Corridor; and
provision for the 5-year housing land supply is inadequate.

D1 & S2

1. Whilst the term "Garden Town" is unobjectionable, the reality is that all the
Aylesbury sites are just urban extensions, two of which (AGT5 Berryfields and AGT6
Kingsbrook) already have planning permission and two (AGT3 Aston Clinton and AGT4
Hampden Fields) are the subject of applications submitted in early 2016.
2. In reality, therefore, the majority of "Garden Town" already (or almost) has planning
permission. Only two sites AGT1 (South Aylesbury) and AGT2 (South-West Aylesbury)
effectively seem open to discussion.
3. In relation to PSVALP Policies CP2 and D1, this Response raises objections to the
proposed allocation of both sites:
* AGT1 (South Aylesbury, 1,000 homes) is a collection of 6 small sites in different
ownerships without highway access, such that delivery must be in doubt.
* AGT2 (South-West Aylesbury, 1,550 homes) is severely constrained by HS2 of
which the centre line forms the south-west boundary of the site such that for at
least 100m into the site there can be no housing, and even beyond that living
conditions would be uncomfortable. The conclusion of the Core Strategy
Inspector's report in June 2010 on this site was "This would have a major
impact on the deliverability and potentially, the viability of the SGA, through
significant land take in the SW site".
The Plan is therefore unsound because
Positively prepared - two major sites have been allocated not based on clear and
robust evidence.
Justified - this is not the most appropriate strategy based on the evidence. Two
other sites proposed by GPL/AWEL are more sustainable, provide significant
benefits, are deliverable and are not adversely affected by HS2.
Berryfields East
1. The AWEL Berryfields East site (Appendix 3 in Full Response) to the NW of Aylesbury
should be considered as part of the growth of Aylesbury as a 'garden town'. The site
was submitted in response to the 'call for sites' in April 2014. It has a gross area of
some 20ha and a net developable area of some 11ha, with a capacity for some 350
homes.
2. The HELAA response was to raise concerns about landscape, impact on the setting of
the Scheduled Ancient Monument and biodiversity. These were broadly the reasons
for rejecting an appeal on the site in 2012. However, the scheme has been radically
revised since then to take account of the reasons for dismissal and has been
considerably reduced in terms of site area and numbers of dwellings. The appeal
decision related to some 1,380 dwellings on the larger site of some 33ha net.
Appendix 3 shows the revised illustrative masterplan, which has regard to the
Inspector's findings, and, for comparison, the rejected masterplan.
3. As well as a substantial reduction in site area and numbers of dwellings, the revised
scheme demonstrates significant changes since the last scheme was dismissed 5
years ago:
* The Western Link Road is now constructed and the Berryfields development has
advanced which changes the character and appearance of the local countryside
and the setting of the SAM.
* A substantial gap is provided between the eastern boundary of the
development area and Weedon Hill Urban Extension further to the east.
* Extensive open countryside in the new scheme would enhance the countryside
setting.
* The need for housing growth around Aylesbury is much greater than in
2010/12, and this Response has demonstrated that the PSVALP will have a
shortfall in requirements of thousands of homes.
* The site is unaffected by HS2.
* The landscape objection falls away because of the LUC study which designates
the nearest landscape designation being the Quainton-Wing Hills, some 2.76
km from the site to the nearest point just south of Weedon.
4. The HELAA seems to be assessing the 2010 scheme which is now superseded. The
new proposals are achievable, suitable and deliverable (the site is in single
ownership), and all within 5 years.
5. The proposal for the 'Aylesbury Linear Park' is supported. The plan on p66 is
somewhat difficult to read in the vicinity of Berryfields East but shows this Park as the
open land south of the Western Relief Road partly on land in the same ownership as
Berryfields East. Development on Berryfields East would therefore facilitate this
section of the Linear Park/green infrastructure network. Such integration of
development and green infrastructure is encouraged in Policy I1:
The Council will work with partners to ensure that existing and new green
infrastructure is identified, planned, delivered, enhanced and managed in a
strategic way as an integral part of supporting sustainable communities and
sustainable growth. The Council will implement the most up-to-date green
infrastructure strategies. Green infrastructure networks whether existing or
potential are expected to be a key part of site masterplanning as required in the
VALP.
6. Berryfields East, capacity 350 dwellings, should therefore be added to the list of
sites for Aylesbury in Policies S2 and D1.
Waddesdon
1. Waddesdon has been 'under-scored' in the settlement hierarchy by one factor -
distance to a main settlement - based on inaccurate measurement (see paras 2.28 -
2.30 above). In fact, Waddesdon is a 'large' large village with extensive facilities
(including a school, retailing, employment, good public transport, police and fire
stations, hotel and stately home), but is fundamentally harmed by the passage of
heavy traffic on the A41, which bisects the settlement.
2. However, Waddesdon is classed as a 'large village' in the hierarchy, which means
(emphasis in bold):
* As stated in the introduction to this report, the settlement hierarchy purpose is
not only to identify the current role of settlements through the facilities and
services they provide, but also to help define a sustainable settlement hierarchy
to facilitate decisions through the Vale of Aylesbury Local Plan on which
settlements are best placed to accommodate future development.
* Larger, more sustainable villages that have at least a reasonable access to
facilities and services and public transport, making them sustainable locations
for development.
3. Despite this encouragement, there are no housing allocations in the PSVALP for
Waddesdon.
4. In several places PSVALP mentions that the impact of HS2 will have to be mitigated.
This is particularly important to the opportunities for development at Waddesdon.
Here, HS2 passes close to the north of Waddesdon and the proposed AWEL
development (Appendix 4) includes mitigation measures that will shield the village.
5. The Inspector's Report on the NP included the following extracts:
In my assessment, the promotion of this major development to the north of the
village, together with a projected A41 Relief Road, is a matter of strategic districtwide
importance which falls properly to be considered as part of the preparation of
the VALP.
6. In several places PSVALP mentions that the impact of HS2 will have to be mitigated.
This is particularly important to the opportunities for development at Waddesdon.
Here, HS2 passes close to the north of Waddesdon and the proposed AWEL
development (Appendix 4) includes mitigation measures that will shield the village.
7. The proposed development at Waddesdon (Appendix 4 in full Response) includes the
advantages as fully set out in the full Response, e.g.
* provision of some 600 homes, either in the context of the housing shortfall
detailed or as an opportunity site
* the creation of a Garden Village development
* facilitation of a relief road and improvements to the central area of the village
* provision of a village green
* improvement to the appearance of the site by removal of poor and redundant
agricultural buildings
8. These are interesting times when much of planning orthodoxy is being overturned in
order to meet society's real needs (especially housing). It is turning away from
negative stances of protectionism against development towards positive action which
benefits all parts of the community which it serves. The first policy (S1) in the DP
begins:
The council will work proactively with applicants to find solutions so that proposals
can be approved wherever possible, and to secure development that improves the
economic, social and environmental conditions in the area.
9. AVDC has the opportunity to put this into practice at Waddesdon and include the
AWEL development proposal as a strategic site in the Local Plan in Policies S2 and
D1.

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