VALP Proposed Submission

16.112 Reps_November 2017
VALE OF AYLESBURY LOCAL PLAN 2013-2033
PROPOSED SUBMISSION REPRESENTATIONS
Policy S1
In general, there is no objection to a sustainable development policy being introduced into
the Local Plan. However, where this is to be introduced, it should fairly reflect the provisions
of Paragraph 14 of the NPPF other than where there are specific circumstances which apply
to Aylesbury Vale.
Particular objection is made to Paragraph A which sets out the tilted balance. Whilst the
way in which the tilted balance is to be applied reflects the NPPF, the trigger mechanism
does not; Paragraph A states that the only circumstances by which the tilted balance will
engage is where there are no policies relevant to a planning application.
This does not reflect the provisions of the NPPF which sets out that the tilted balance should
apply where the development plan is absent, silent or relevant policies are out-of-date.
Policy S1 should be amended to reflect these provisions.
Policy S2
It is appropriate for the Local Plan to identify the housing requirements over the plan period.
This should be expressed as a minima if it is to be consistent with the NPPF; as drafted Policy
S2 suggests that the housing requirements has a cap or limit.
In any event, objections are lodged to the total 27,400 houses to be delivered in the period
to 2033. This figure does not accurately reflect the full objectively assessed housing needs. It
is to be noted that the previous Vale of Aylesbury Local Plan had to be withdrawn, in part, as
a result of not meeting Objectively Assessed Housing Needs. Consequently, the Council must
do all it can to deliver housing and to boost significantly the supply in accordance with the
provisions of the NPPF.
The Council should also be aware that as drafted, Policy S2 is clearly a housing land supply
policy the purposes of Paragraph 49 of the NPPF in terms of the scale and distribution
requirements of the policy.
Policy S3
Our representations relate primarily to Aston Clinton, which is fairly identified as a larger
village given the significant range of shops, services and facilities contained within Aston
Clinton as well as the sustainability advantages given that Aston Clinton is only a short
distance from the main town within the administrative boundary of Aylesbury Vale.
In this context, it is unacceptable and the subject of objection that there are no allocated
sites identified for Aston Clinton. It is acknowledged that Aston Clinton has had a series of
completions in the recent past, however the approach taken in the emerging Local Plan
effectively turns its back on Aston Clinton for much of the plan period, extending to 2033,
once the existing commitments are brought forward and completed.
16.112 Reps_November 2017
This approach will undermine the economic, social and environmental sustainability
credentials of Aston Clinton and runs-counter to the overarching strategy which seeks to
deliver significant quantities of development at the larger villages given the important role
that they play in Aylesbury Vale. It is also a blanket policy of the type clearly resisted by the
PPG.
Policy S7
No specific objections are lodged to the provisions of Policy S7, however, it is important that
as applied it should not be read as providing some sort of sequential approach seeking to
utilise previously developed land in favour of greenfield land. If the policy were to be
applied in that manner, it would be inconsistent with the NPPF which does not contain any
such sequential approach.
Policy H5
As drafted, the policy is unnecessarily vague and does not set out what percentage of
serviced plots for sale to sell/custom builders will be required. It is also not clear why the
threshold of 100 dwellings was identified, nor whether a sliding scale of provision has been
considered.
Whilst it is important that a site by site assessment is undertaken, as set out in the policy,
broad parameters should be identified at this stage to provide certainty both to developers
and landowners, as well as those involved in the delivery of self/custom plots.
Policy T7
It is not clear why the threshold of 10 dwellings has been identified for the provision of electric
vehicle infrastructure. It is also unclear why a floorspace threshold of 760 sq.m has been
identified; in other policies setting a threshold the floorspace is typically 1,000 sq.m where it
relates to 10 or more dwellings.
In any event, electric vehicle infrastructure is expensive and weighs heavily on a cost plan. It
is also the case that there is different infrastructure requirements for different manufactures;
for example BMW charge infrastructure varies significantly from Tesla.
In the circumstances, the policy should identify that passive electric infrastructure should be
provided which can then converted to active electric vehicle infrastructure dependant on
the owners requirements.
Policy NE8
The provisions of Policy NE8 are inconsistent with the NPPF. Whereas the local plan policy
seeks to protect best and most versatile farmland for the longer term, the NPPF requirement is
to taken into account the economic and other benefits of best and most versatile
agricultural land.
As drafted therefore, Policy NE8 goes beyond the requirements of the NPPF and as a
consequence is unacceptable and the subject of objections.
It is also the case that the NPPF does not require that the benefits of the proposed
development outweigh the harm resulting from the significant loss of agricultural land. Where best and most versatile land is to be lost, this is to be weighed in the balance but it is 16.112 Reps_November 2017 not necessary for the benefits of housing to outweigh the loss of best and most versatile agricultural land as a simple two sides of the equation approach.

16.112 Reps_November 2017
VALE OF AYLESBURY LOCAL PLAN 2013-2033
PROPOSED SUBMISSION REPRESENTATIONS
Policy S1
In general, there is no objection to a sustainable development policy being introduced into
the Local Plan. However, where this is to be introduced, it should fairly reflect the provisions
of Paragraph 14 of the NPPF other than where there are specific circumstances which apply
to Aylesbury Vale.
Particular objection is made to Paragraph A which sets out the tilted balance. Whilst the
way in which the tilted balance is to be applied reflects the NPPF, the trigger mechanism
does not; Paragraph A states that the only circumstances by which the tilted balance will
engage is where there are no policies relevant to a planning application.
This does not reflect the provisions of the NPPF which sets out that the tilted balance should
apply where the development plan is absent, silent or relevant policies are out-of-date.
Policy S1 should be amended to reflect these provisions.
Policy S2
It is appropriate for the Local Plan to identify the housing requirements over the plan period.
This should be expressed as a minima if it is to be consistent with the NPPF; as drafted Policy
S2 suggests that the housing requirements has a cap or limit.
In any event, objections are lodged to the total 27,400 houses to be delivered in the period
to 2033. This figure does not accurately reflect the full objectively assessed housing needs. It
is to be noted that the previous Vale of Aylesbury Local Plan had to be withdrawn, in part, as
a result of not meeting Objectively Assessed Housing Needs. Consequently, the Council must
do all it can to deliver housing and to boost significantly the supply in accordance with the
provisions of the NPPF.
The Council should also be aware that as drafted, Policy S2 is clearly a housing land supply
policy the purposes of Paragraph 49 of the NPPF in terms of the scale and distribution
requirements of the policy.
Policy S3
Our representations relate primarily to Aston Clinton, which is fairly identified as a larger
village given the significant range of shops, services and facilities contained within Aston
Clinton as well as the sustainability advantages given that Aston Clinton is only a short
distance from the main town within the administrative boundary of Aylesbury Vale.
In this context, it is unacceptable and the subject of objection that there are no allocated
sites identified for Aston Clinton. It is acknowledged that Aston Clinton has had a series of
completions in the recent past, however the approach taken in the emerging Local Plan
effectively turns its back on Aston Clinton for much of the plan period, extending to 2033,
once the existing commitments are brought forward and completed.
16.112 Reps_November 2017
This approach will undermine the economic, social and environmental sustainability
credentials of Aston Clinton and runs-counter to the overarching strategy which seeks to
deliver significant quantities of development at the larger villages given the important role
that they play in Aylesbury Vale. It is also a blanket policy of the type clearly resisted by the
PPG.
Policy S7
No specific objections are lodged to the provisions of Policy S7, however, it is important that
as applied it should not be read as providing some sort of sequential approach seeking to
utilise previously developed land in favour of greenfield land. If the policy were to be
applied in that manner, it would be inconsistent with the NPPF which does not contain any
such sequential approach.
Policy H5
As drafted, the policy is unnecessarily vague and does not set out what percentage of
serviced plots for sale to sell/custom builders will be required. It is also not clear why the
threshold of 100 dwellings was identified, nor whether a sliding scale of provision has been
considered.
Whilst it is important that a site by site assessment is undertaken, as set out in the policy,
broad parameters should be identified at this stage to provide certainty both to developers
and landowners, as well as those involved in the delivery of self/custom plots.
Policy T7
It is not clear why the threshold of 10 dwellings has been identified for the provision of electric
vehicle infrastructure. It is also unclear why a floorspace threshold of 760 sq.m has been
identified; in other policies setting a threshold the floorspace is typically 1,000 sq.m where it
relates to 10 or more dwellings.
In any event, electric vehicle infrastructure is expensive and weighs heavily on a cost plan. It
is also the case that there is different infrastructure requirements for different manufactures;
for example BMW charge infrastructure varies significantly from Tesla.
In the circumstances, the policy should identify that passive electric infrastructure should be
provided which can then converted to active electric vehicle infrastructure dependant on
the owners requirements.
Policy NE8
The provisions of Policy NE8 are inconsistent with the NPPF. Whereas the local plan policy
seeks to protect best and most versatile farmland for the longer term, the NPPF requirement is
to taken into account the economic and other benefits of best and most versatile
agricultural land.
As drafted therefore, Policy NE8 goes beyond the requirements of the NPPF and as a
consequence is unacceptable and the subject of objections.
It is also the case that the NPPF does not require that the benefits of the proposed
development outweigh the harm resulting from the significant loss of agricultural land. Where best and most versatile land is to be lost, this is to be weighed in the balance but it is 16.112 Reps_November 2017 not necessary for the benefits of housing to outweigh the loss of best and most versatile agricultural land as a simple two sides of the equation approach.

16.112 Reps_November 2017
VALE OF AYLESBURY LOCAL PLAN 2013-2033
PROPOSED SUBMISSION REPRESENTATIONS
Policy S1
In general, there is no objection to a sustainable development policy being introduced into
the Local Plan. However, where this is to be introduced, it should fairly reflect the provisions
of Paragraph 14 of the NPPF other than where there are specific circumstances which apply
to Aylesbury Vale.
Particular objection is made to Paragraph A which sets out the tilted balance. Whilst the
way in which the tilted balance is to be applied reflects the NPPF, the trigger mechanism
does not; Paragraph A states that the only circumstances by which the tilted balance will
engage is where there are no policies relevant to a planning application.
This does not reflect the provisions of the NPPF which sets out that the tilted balance should
apply where the development plan is absent, silent or relevant policies are out-of-date.
Policy S1 should be amended to reflect these provisions.
Policy S2
It is appropriate for the Local Plan to identify the housing requirements over the plan period.
This should be expressed as a minima if it is to be consistent with the NPPF; as drafted Policy
S2 suggests that the housing requirements has a cap or limit.
In any event, objections are lodged to the total 27,400 houses to be delivered in the period
to 2033. This figure does not accurately reflect the full objectively assessed housing needs. It
is to be noted that the previous Vale of Aylesbury Local Plan had to be withdrawn, in part, as
a result of not meeting Objectively Assessed Housing Needs. Consequently, the Council must
do all it can to deliver housing and to boost significantly the supply in accordance with the
provisions of the NPPF.
The Council should also be aware that as drafted, Policy S2 is clearly a housing land supply
policy the purposes of Paragraph 49 of the NPPF in terms of the scale and distribution
requirements of the policy.
Policy S3
Our representations relate primarily to Aston Clinton, which is fairly identified as a larger
village given the significant range of shops, services and facilities contained within Aston
Clinton as well as the sustainability advantages given that Aston Clinton is only a short
distance from the main town within the administrative boundary of Aylesbury Vale.
In this context, it is unacceptable and the subject of objection that there are no allocated
sites identified for Aston Clinton. It is acknowledged that Aston Clinton has had a series of
completions in the recent past, however the approach taken in the emerging Local Plan
effectively turns its back on Aston Clinton for much of the plan period, extending to 2033,
once the existing commitments are brought forward and completed.
16.112 Reps_November 2017
This approach will undermine the economic, social and environmental sustainability
credentials of Aston Clinton and runs-counter to the overarching strategy which seeks to
deliver significant quantities of development at the larger villages given the important role
that they play in Aylesbury Vale. It is also a blanket policy of the type clearly resisted by the
PPG.
Policy S7
No specific objections are lodged to the provisions of Policy S7, however, it is important that
as applied it should not be read as providing some sort of sequential approach seeking to
utilise previously developed land in favour of greenfield land. If the policy were to be
applied in that manner, it would be inconsistent with the NPPF which does not contain any
such sequential approach.
Policy H5
As drafted, the policy is unnecessarily vague and does not set out what percentage of
serviced plots for sale to sell/custom builders will be required. It is also not clear why the
threshold of 100 dwellings was identified, nor whether a sliding scale of provision has been
considered.
Whilst it is important that a site by site assessment is undertaken, as set out in the policy,
broad parameters should be identified at this stage to provide certainty both to developers
and landowners, as well as those involved in the delivery of self/custom plots.
Policy T7
It is not clear why the threshold of 10 dwellings has been identified for the provision of electric
vehicle infrastructure. It is also unclear why a floorspace threshold of 760 sq.m has been
identified; in other policies setting a threshold the floorspace is typically 1,000 sq.m where it
relates to 10 or more dwellings.
In any event, electric vehicle infrastructure is expensive and weighs heavily on a cost plan. It
is also the case that there is different infrastructure requirements for different manufactures;
for example BMW charge infrastructure varies significantly from Tesla.
In the circumstances, the policy should identify that passive electric infrastructure should be
provided which can then converted to active electric vehicle infrastructure dependant on
the owners requirements.
Policy NE8
The provisions of Policy NE8 are inconsistent with the NPPF. Whereas the local plan policy
seeks to protect best and most versatile farmland for the longer term, the NPPF requirement is
to taken into account the economic and other benefits of best and most versatile
agricultural land.
As drafted therefore, Policy NE8 goes beyond the requirements of the NPPF and as a
consequence is unacceptable and the subject of objections.
It is also the case that the NPPF does not require that the benefits of the proposed
development outweigh the harm resulting from the significant loss of agricultural land. Where best and most versatile land is to be lost, this is to be weighed in the balance but it is 16.112 Reps_November 2017 not necessary for the benefits of housing to outweigh the loss of best and most versatile agricultural land as a simple two sides of the equation approach.

16.112 Reps_November 2017
VALE OF AYLESBURY LOCAL PLAN 2013-2033
PROPOSED SUBMISSION REPRESENTATIONS
Policy S1
In general, there is no objection to a sustainable development policy being introduced into
the Local Plan. However, where this is to be introduced, it should fairly reflect the provisions
of Paragraph 14 of the NPPF other than where there are specific circumstances which apply
to Aylesbury Vale.
Particular objection is made to Paragraph A which sets out the tilted balance. Whilst the
way in which the tilted balance is to be applied reflects the NPPF, the trigger mechanism
does not; Paragraph A states that the only circumstances by which the tilted balance will
engage is where there are no policies relevant to a planning application.
This does not reflect the provisions of the NPPF which sets out that the tilted balance should
apply where the development plan is absent, silent or relevant policies are out-of-date.
Policy S1 should be amended to reflect these provisions.
Policy S2
It is appropriate for the Local Plan to identify the housing requirements over the plan period.
This should be expressed as a minima if it is to be consistent with the NPPF; as drafted Policy
S2 suggests that the housing requirements has a cap or limit.
In any event, objections are lodged to the total 27,400 houses to be delivered in the period
to 2033. This figure does not accurately reflect the full objectively assessed housing needs. It
is to be noted that the previous Vale of Aylesbury Local Plan had to be withdrawn, in part, as
a result of not meeting Objectively Assessed Housing Needs. Consequently, the Council must
do all it can to deliver housing and to boost significantly the supply in accordance with the
provisions of the NPPF.
The Council should also be aware that as drafted, Policy S2 is clearly a housing land supply
policy the purposes of Paragraph 49 of the NPPF in terms of the scale and distribution
requirements of the policy.
Policy S3
Our representations relate primarily to Aston Clinton, which is fairly identified as a larger
village given the significant range of shops, services and facilities contained within Aston
Clinton as well as the sustainability advantages given that Aston Clinton is only a short
distance from the main town within the administrative boundary of Aylesbury Vale.
In this context, it is unacceptable and the subject of objection that there are no allocated
sites identified for Aston Clinton. It is acknowledged that Aston Clinton has had a series of
completions in the recent past, however the approach taken in the emerging Local Plan
effectively turns its back on Aston Clinton for much of the plan period, extending to 2033,
once the existing commitments are brought forward and completed.
16.112 Reps_November 2017
This approach will undermine the economic, social and environmental sustainability
credentials of Aston Clinton and runs-counter to the overarching strategy which seeks to
deliver significant quantities of development at the larger villages given the important role
that they play in Aylesbury Vale. It is also a blanket policy of the type clearly resisted by the
PPG.
Policy S7
No specific objections are lodged to the provisions of Policy S7, however, it is important that
as applied it should not be read as providing some sort of sequential approach seeking to
utilise previously developed land in favour of greenfield land. If the policy were to be
applied in that manner, it would be inconsistent with the NPPF which does not contain any
such sequential approach.
Policy H5
As drafted, the policy is unnecessarily vague and does not set out what percentage of
serviced plots for sale to sell/custom builders will be required. It is also not clear why the
threshold of 100 dwellings was identified, nor whether a sliding scale of provision has been
considered.
Whilst it is important that a site by site assessment is undertaken, as set out in the policy,
broad parameters should be identified at this stage to provide certainty both to developers
and landowners, as well as those involved in the delivery of self/custom plots.
Policy T7
It is not clear why the threshold of 10 dwellings has been identified for the provision of electric
vehicle infrastructure. It is also unclear why a floorspace threshold of 760 sq.m has been
identified; in other policies setting a threshold the floorspace is typically 1,000 sq.m where it
relates to 10 or more dwellings.
In any event, electric vehicle infrastructure is expensive and weighs heavily on a cost plan. It
is also the case that there is different infrastructure requirements for different manufactures;
for example BMW charge infrastructure varies significantly from Tesla.
In the circumstances, the policy should identify that passive electric infrastructure should be
provided which can then converted to active electric vehicle infrastructure dependant on
the owners requirements.
Policy NE8
The provisions of Policy NE8 are inconsistent with the NPPF. Whereas the local plan policy
seeks to protect best and most versatile farmland for the longer term, the NPPF requirement is
to taken into account the economic and other benefits of best and most versatile
agricultural land.
As drafted therefore, Policy NE8 goes beyond the requirements of the NPPF and as a
consequence is unacceptable and the subject of objections.
It is also the case that the NPPF does not require that the benefits of the proposed
development outweigh the harm resulting from the significant loss of agricultural land. Where best and most versatile land is to be lost, this is to be weighed in the balance but it is 16.112 Reps_November 2017 not necessary for the benefits of housing to outweigh the loss of best and most versatile agricultural land as a simple two sides of the equation approach.

16.112 Reps_November 2017
VALE OF AYLESBURY LOCAL PLAN 2013-2033
PROPOSED SUBMISSION REPRESENTATIONS
Policy S1
In general, there is no objection to a sustainable development policy being introduced into
the Local Plan. However, where this is to be introduced, it should fairly reflect the provisions
of Paragraph 14 of the NPPF other than where there are specific circumstances which apply
to Aylesbury Vale.
Particular objection is made to Paragraph A which sets out the tilted balance. Whilst the
way in which the tilted balance is to be applied reflects the NPPF, the trigger mechanism
does not; Paragraph A states that the only circumstances by which the tilted balance will
engage is where there are no policies relevant to a planning application.
This does not reflect the provisions of the NPPF which sets out that the tilted balance should
apply where the development plan is absent, silent or relevant policies are out-of-date.
Policy S1 should be amended to reflect these provisions.
Policy S2
It is appropriate for the Local Plan to identify the housing requirements over the plan period.
This should be expressed as a minima if it is to be consistent with the NPPF; as drafted Policy
S2 suggests that the housing requirements has a cap or limit.
In any event, objections are lodged to the total 27,400 houses to be delivered in the period
to 2033. This figure does not accurately reflect the full objectively assessed housing needs. It
is to be noted that the previous Vale of Aylesbury Local Plan had to be withdrawn, in part, as
a result of not meeting Objectively Assessed Housing Needs. Consequently, the Council must
do all it can to deliver housing and to boost significantly the supply in accordance with the
provisions of the NPPF.
The Council should also be aware that as drafted, Policy S2 is clearly a housing land supply
policy the purposes of Paragraph 49 of the NPPF in terms of the scale and distribution
requirements of the policy.
Policy S3
Our representations relate primarily to Aston Clinton, which is fairly identified as a larger
village given the significant range of shops, services and facilities contained within Aston
Clinton as well as the sustainability advantages given that Aston Clinton is only a short
distance from the main town within the administrative boundary of Aylesbury Vale.
In this context, it is unacceptable and the subject of objection that there are no allocated
sites identified for Aston Clinton. It is acknowledged that Aston Clinton has had a series of
completions in the recent past, however the approach taken in the emerging Local Plan
effectively turns its back on Aston Clinton for much of the plan period, extending to 2033,
once the existing commitments are brought forward and completed.
16.112 Reps_November 2017
This approach will undermine the economic, social and environmental sustainability
credentials of Aston Clinton and runs-counter to the overarching strategy which seeks to
deliver significant quantities of development at the larger villages given the important role
that they play in Aylesbury Vale. It is also a blanket policy of the type clearly resisted by the
PPG.
Policy S7
No specific objections are lodged to the provisions of Policy S7, however, it is important that
as applied it should not be read as providing some sort of sequential approach seeking to
utilise previously developed land in favour of greenfield land. If the policy were to be
applied in that manner, it would be inconsistent with the NPPF which does not contain any
such sequential approach.
Policy H5
As drafted, the policy is unnecessarily vague and does not set out what percentage of
serviced plots for sale to sell/custom builders will be required. It is also not clear why the
threshold of 100 dwellings was identified, nor whether a sliding scale of provision has been
considered.
Whilst it is important that a site by site assessment is undertaken, as set out in the policy,
broad parameters should be identified at this stage to provide certainty both to developers
and landowners, as well as those involved in the delivery of self/custom plots.
Policy T7
It is not clear why the threshold of 10 dwellings has been identified for the provision of electric
vehicle infrastructure. It is also unclear why a floorspace threshold of 760 sq.m has been
identified; in other policies setting a threshold the floorspace is typically 1,000 sq.m where it
relates to 10 or more dwellings.
In any event, electric vehicle infrastructure is expensive and weighs heavily on a cost plan. It
is also the case that there is different infrastructure requirements for different manufactures;
for example BMW charge infrastructure varies significantly from Tesla.
In the circumstances, the policy should identify that passive electric infrastructure should be
provided which can then converted to active electric vehicle infrastructure dependant on
the owners requirements.
Policy NE8
The provisions of Policy NE8 are inconsistent with the NPPF. Whereas the local plan policy
seeks to protect best and most versatile farmland for the longer term, the NPPF requirement is
to taken into account the economic and other benefits of best and most versatile
agricultural land.
As drafted therefore, Policy NE8 goes beyond the requirements of the NPPF and as a
consequence is unacceptable and the subject of objections.
It is also the case that the NPPF does not require that the benefits of the proposed
development outweigh the harm resulting from the significant loss of agricultural land. Where best and most versatile land is to be lost, this is to be weighed in the balance but it is 16.112 Reps_November 2017 not necessary for the benefits of housing to outweigh the loss of best and most versatile agricultural land as a simple two sides of the equation approach.

16.112 Reps_November 2017
VALE OF AYLESBURY LOCAL PLAN 2013-2033
PROPOSED SUBMISSION REPRESENTATIONS
Policy S1
In general, there is no objection to a sustainable development policy being introduced into
the Local Plan. However, where this is to be introduced, it should fairly reflect the provisions
of Paragraph 14 of the NPPF other than where there are specific circumstances which apply
to Aylesbury Vale.
Particular objection is made to Paragraph A which sets out the tilted balance. Whilst the
way in which the tilted balance is to be applied reflects the NPPF, the trigger mechanism
does not; Paragraph A states that the only circumstances by which the tilted balance will
engage is where there are no policies relevant to a planning application.
This does not reflect the provisions of the NPPF which sets out that the tilted balance should
apply where the development plan is absent, silent or relevant policies are out-of-date.
Policy S1 should be amended to reflect these provisions.
Policy S2
It is appropriate for the Local Plan to identify the housing requirements over the plan period.
This should be expressed as a minima if it is to be consistent with the NPPF; as drafted Policy
S2 suggests that the housing requirements has a cap or limit.
In any event, objections are lodged to the total 27,400 houses to be delivered in the period
to 2033. This figure does not accurately reflect the full objectively assessed housing needs. It
is to be noted that the previous Vale of Aylesbury Local Plan had to be withdrawn, in part, as
a result of not meeting Objectively Assessed Housing Needs. Consequently, the Council must
do all it can to deliver housing and to boost significantly the supply in accordance with the
provisions of the NPPF.
The Council should also be aware that as drafted, Policy S2 is clearly a housing land supply
policy the purposes of Paragraph 49 of the NPPF in terms of the scale and distribution
requirements of the policy.
Policy S3
Our representations relate primarily to Aston Clinton, which is fairly identified as a larger
village given the significant range of shops, services and facilities contained within Aston
Clinton as well as the sustainability advantages given that Aston Clinton is only a short
distance from the main town within the administrative boundary of Aylesbury Vale.
In this context, it is unacceptable and the subject of objection that there are no allocated
sites identified for Aston Clinton. It is acknowledged that Aston Clinton has had a series of
completions in the recent past, however the approach taken in the emerging Local Plan
effectively turns its back on Aston Clinton for much of the plan period, extending to 2033,
once the existing commitments are brought forward and completed.
16.112 Reps_November 2017
This approach will undermine the economic, social and environmental sustainability
credentials of Aston Clinton and runs-counter to the overarching strategy which seeks to
deliver significant quantities of development at the larger villages given the important role
that they play in Aylesbury Vale. It is also a blanket policy of the type clearly resisted by the
PPG.
Policy S7
No specific objections are lodged to the provisions of Policy S7, however, it is important that
as applied it should not be read as providing some sort of sequential approach seeking to
utilise previously developed land in favour of greenfield land. If the policy were to be
applied in that manner, it would be inconsistent with the NPPF which does not contain any
such sequential approach.
Policy H5
As drafted, the policy is unnecessarily vague and does not set out what percentage of
serviced plots for sale to sell/custom builders will be required. It is also not clear why the
threshold of 100 dwellings was identified, nor whether a sliding scale of provision has been
considered.
Whilst it is important that a site by site assessment is undertaken, as set out in the policy,
broad parameters should be identified at this stage to provide certainty both to developers
and landowners, as well as those involved in the delivery of self/custom plots.
Policy T7
It is not clear why the threshold of 10 dwellings has been identified for the provision of electric
vehicle infrastructure. It is also unclear why a floorspace threshold of 760 sq.m has been
identified; in other policies setting a threshold the floorspace is typically 1,000 sq.m where it
relates to 10 or more dwellings.
In any event, electric vehicle infrastructure is expensive and weighs heavily on a cost plan. It
is also the case that there is different infrastructure requirements for different manufactures;
for example BMW charge infrastructure varies significantly from Tesla.
In the circumstances, the policy should identify that passive electric infrastructure should be
provided which can then converted to active electric vehicle infrastructure dependant on
the owners requirements.
Policy NE8
The provisions of Policy NE8 are inconsistent with the NPPF. Whereas the local plan policy
seeks to protect best and most versatile farmland for the longer term, the NPPF requirement is
to taken into account the economic and other benefits of best and most versatile
agricultural land.
As drafted therefore, Policy NE8 goes beyond the requirements of the NPPF and as a
consequence is unacceptable and the subject of objections.
It is also the case that the NPPF does not require that the benefits of the proposed
development outweigh the harm resulting from the significant loss of agricultural land. Where best and most versatile land is to be lost, this is to be weighed in the balance but it is 16.112 Reps_November 2017 not necessary for the benefits of housing to outweigh the loss of best and most versatile agricultural land as a simple two sides of the equation approach.

16.112 Reps_November 2017
VALE OF AYLESBURY LOCAL PLAN 2013-2033
PROPOSED SUBMISSION REPRESENTATIONS
Policy S1
In general, there is no objection to a sustainable development policy being introduced into
the Local Plan. However, where this is to be introduced, it should fairly reflect the provisions
of Paragraph 14 of the NPPF other than where there are specific circumstances which apply
to Aylesbury Vale.
Particular objection is made to Paragraph A which sets out the tilted balance. Whilst the
way in which the tilted balance is to be applied reflects the NPPF, the trigger mechanism
does not; Paragraph A states that the only circumstances by which the tilted balance will
engage is where there are no policies relevant to a planning application.
This does not reflect the provisions of the NPPF which sets out that the tilted balance should
apply where the development plan is absent, silent or relevant policies are out-of-date.
Policy S1 should be amended to reflect these provisions.
Policy S2
It is appropriate for the Local Plan to identify the housing requirements over the plan period.
This should be expressed as a minima if it is to be consistent with the NPPF; as drafted Policy
S2 suggests that the housing requirements has a cap or limit.
In any event, objections are lodged to the total 27,400 houses to be delivered in the period
to 2033. This figure does not accurately reflect the full objectively assessed housing needs. It
is to be noted that the previous Vale of Aylesbury Local Plan had to be withdrawn, in part, as
a result of not meeting Objectively Assessed Housing Needs. Consequently, the Council must
do all it can to deliver housing and to boost significantly the supply in accordance with the
provisions of the NPPF.
The Council should also be aware that as drafted, Policy S2 is clearly a housing land supply
policy the purposes of Paragraph 49 of the NPPF in terms of the scale and distribution
requirements of the policy.
Policy S3
Our representations relate primarily to Aston Clinton, which is fairly identified as a larger
village given the significant range of shops, services and facilities contained within Aston
Clinton as well as the sustainability advantages given that Aston Clinton is only a short
distance from the main town within the administrative boundary of Aylesbury Vale.
In this context, it is unacceptable and the subject of objection that there are no allocated
sites identified for Aston Clinton. It is acknowledged that Aston Clinton has had a series of
completions in the recent past, however the approach taken in the emerging Local Plan
effectively turns its back on Aston Clinton for much of the plan period, extending to 2033,
once the existing commitments are brought forward and completed.
16.112 Reps_November 2017
This approach will undermine the economic, social and environmental sustainability
credentials of Aston Clinton and runs-counter to the overarching strategy which seeks to
deliver significant quantities of development at the larger villages given the important role
that they play in Aylesbury Vale. It is also a blanket policy of the type clearly resisted by the
PPG.
Policy S7
No specific objections are lodged to the provisions of Policy S7, however, it is important that
as applied it should not be read as providing some sort of sequential approach seeking to
utilise previously developed land in favour of greenfield land. If the policy were to be
applied in that manner, it would be inconsistent with the NPPF which does not contain any
such sequential approach.
Policy H5
As drafted, the policy is unnecessarily vague and does not set out what percentage of
serviced plots for sale to sell/custom builders will be required. It is also not clear why the
threshold of 100 dwellings was identified, nor whether a sliding scale of provision has been
considered.
Whilst it is important that a site by site assessment is undertaken, as set out in the policy,
broad parameters should be identified at this stage to provide certainty both to developers
and landowners, as well as those involved in the delivery of self/custom plots.
Policy T7
It is not clear why the threshold of 10 dwellings has been identified for the provision of electric
vehicle infrastructure. It is also unclear why a floorspace threshold of 760 sq.m has been
identified; in other policies setting a threshold the floorspace is typically 1,000 sq.m where it
relates to 10 or more dwellings.
In any event, electric vehicle infrastructure is expensive and weighs heavily on a cost plan. It
is also the case that there is different infrastructure requirements for different manufactures;
for example BMW charge infrastructure varies significantly from Tesla.
In the circumstances, the policy should identify that passive electric infrastructure should be
provided which can then converted to active electric vehicle infrastructure dependant on
the owners requirements.
Policy NE8
The provisions of Policy NE8 are inconsistent with the NPPF. Whereas the local plan policy
seeks to protect best and most versatile farmland for the longer term, the NPPF requirement is
to taken into account the economic and other benefits of best and most versatile
agricultural land.
As drafted therefore, Policy NE8 goes beyond the requirements of the NPPF and as a
consequence is unacceptable and the subject of objections.
It is also the case that the NPPF does not require that the benefits of the proposed
development outweigh the harm resulting from the significant loss of agricultural land. Where best and most versatile land is to be lost, this is to be weighed in the balance but it is 16.112 Reps_November 2017 not necessary for the benefits of housing to outweigh the loss of best and most versatile agricultural land as a simple two sides of the equation approach.