Aylesbury Vale Area

VALP Proposed Submission

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Object

VALP Proposed Submission

S9 Monitoring and review

Representation ID: 998

Received: 14/12/2017

Respondent: Revera Limited

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

upon adoption of VALP (even assuming housing requirement remains as proposed) there will have been under-delivery in almost every year since 2013/14 with needs across the HMA falling to Aylesbury Vale but not having been met. Upon adoption they will need to apply a 20% buffer to afford the appropriate weight to housing proposals due to significant shortfall in provision across the HMA since 2013.
Effect of the application of necessary 20% buffer on adoption would result in a five-year land supply shortfall of circa 600 dwellings. This needs to be addressed within VALP through identification of additional deliverable allocations.

Full text:

Please see attachments

Paragraph 3.80 suggests that there is not a record of persistent under-delivery in Aylesbury Vale and that accordingly it is appropriate to apply a 5% buffer.
The Council assess the record of delivery against the objectively assessed need for Aylesbury Vale in isolation, which is the correct approach prior to the confirmation of the contribution to the unmet needs of neighbouring authorities through the VALP examination. Table 2 of the Five-Year Housing Land Supply Position Statement, August 2017 identifies that whilst there was under-delivery in the majority of years up until 2012/13, the recent record of delivery justifies the application of a 5% buffer.
However, upon adoption of the VALP (even assuming that the housing requirement remains as proposed) there will have been under-delivery in almost every year since 2013/14 with the needs across the HMA falling to Aylesbury Vale but not having been met. Accordingly, upon adoption there will be a necessity to apply a 20% buffer to afford the appropriate weight to housing proposals given the significant shortfall in provision across the HMA since 2013.
The effect of the application of the necessary 20% buffer on adoption would result in a five-year land supply shortfall of circa 600 dwellings. This will need to be addressed within the VALP through the identification of additional deliverable allocations.
Policy S9 (Monitoring and review)

Paragraph 1.7 of the Vale of Aylesbury Local Plan (VALP) suggests that Government policy is to deliver 250,000 homes per annum nationally. However, this figure is not identified in Government policy. The most recent evidence of the required number of homes was identified as at least 300,000 new homes per annum in the 'Building More Homes' report to the House of Lords Select Committee on Economic Affairs in July 2016. The Government have responded to this evidence (and older assessments including the Barker Report) and are currently consulting on a national distribution to deliver at least 266,000 new homes per annum nationally. The reference in paragraph 1.7 therefore not only conflicts with the available evidence, it also suggests that the VALP has been prepared with the objective of delivering a level of housing below that required nationally.

Paragraph 1.8 continues to identify a requirement of 19,400 new homes to respond to the needs of Aylesbury Vale (excluding any contributions to the unmet needs of neighbouring authorities). This figure is based upon the Buckinghamshire Housing and Economic Development Needs Assessment (HEDNA) Update Addendum, September 2017 which contains corrections to the Buckinghamshire HEDNA Update: Final Report, December 2016.
Paragraph 47 of the National Planning Policy Framework (NPPF) identifies that Local Planning Authorities (LPAs) should use their evidence base to ensure that their Local Plan meets the full, objectively assessed need (OAN) for the Housing Market Area (HMA) rather than an LPA boundary (unless they are coterminous). This has been underlined in several legal judgments1. This is necessary to ensure that account is taken of the inter-relationships between the various LPAs and a consistent approach is taken to these. However, the HEDNA assesses the OAN for each LPA in isolation, using different assumptions for each. The necessary result of this inconsistency means that the OAN has not been established for the HMA, contrary to the NPPF.
It is also important to note that the Department for Communities and Local Government (DCLG) has recently consulted on a standardised methodology for identifying the local housing need. This has arisen from the Local Plans Expert Group and the Housing White Paper, both of which were subject to consultation, as well as from professional input from a wide range of experts including the Planning Inspectorate and the Bar.

Paragraph 1.11 identifies that there is insufficient capacity to meet the OAN in the areas south of Aylesbury Vale. In the following paragraph 1.12, there is calculated to be an unmet need of 8,000 homes.
However, this is all predicated on the OAN identified in the HEDNA which adopts inconsistent and negative assumptions, contrary to the available evidence to reduce the OAN. The population is growing far faster than anticipated by the latest sub-national population projections, and yet even if the OAN was calculated on the basis of these population projections this would produce an unmet need of 8,965 homes (based on the OAN of 27,065 for the remainder of Buckinghamshire (= 51,051 - 23,986) and the capacity of 18,100 homes identified in the Memorandum of Understanding, July 2017).
Furthermore, the Luton Local Plan was adopted in November 2017 and this identifies that there is a need for 400 dwellings which relates to Aylesbury Vale, which is not being addressed elsewhere.
As a result, the VALP should make provision for at least 33,350 homes to address the rounded OAN (of 24,000), the rounded unmet need (of 8,950) and the unmet need of Luton (of 400). These figures will increase significantly, once the standardised methodology becomes part of national policy and so additional provision should be supported or planned for (including through the early review).
This compares to the identified housing requirement in paragraph 1.12 of 27,400 homes. It is therefore clear, that even if the VALP is submitted in advance of the revised NPPF, it will contain a housing requirement that is 5,950 homes short of meeting the OAN across the HMA (unless other sites can be identified across the remainder of Buckinghamshire to contribute to this unmet need). However, in paragraph 3.17 it is identified that it is expected that 28,830 homes will be delivered in the plan period, which reduces the shortfall to 4,334 homes.

Policy S2 makes provision for a total of 27,400 homes which is significantly below the minimum OAN of 33,350. Therefore additional mechanisms will need to be identified to address the resultant shortfall. This should include the identification of additional sites now as well as the identification of new settlements through the proposed early review.
Policy S2 identifies that the primary focus of strategic levels of growth will be at Aylesbury, Buckingham, Winslow, Wendover and Haddenham. It then continues to identify that growth adjacent to Milton Keynes will also be allocated. The Policy also identifies that development at medium villages, including Bierton, will be at a scale in keeping with the local character and setting.
Whilst this approach is supported, as set out in our representations to Policies S3 and D2, our client retains an objection to the "downgrading" of Bierton to a medium village which is clearly a sustainable location in close proximity to Aylesbury and to other new development, i.e. Land East of Aylesbury (Kingsbrook). Bierton should therefore be reclassified to a "larger village" as originally assessed. If the Council are minded to maintain the classification of Bierton as a medium village the characteristics and context of the settlement should be recognised with a more appropriate level of growth than that currently proposed in the VALP.

Table 2 identifies the proposed settlement hierarchy and housing development based on the proposals
of Policy S2.
Paragraph 3.20 identifies that the settlement hierarchy including the ranking of settlements identified in
the Settlement Hierarchy Assessment, September 2017, forms the basis of the proposed distribution
between settlements.
The Settlement Hierarchy Assessment, September 2017 identifies that Bierton (which meets 6 criteria)
is more sustainable than Stewkley (5 criteria) and equally as sustainable as Cheddington, Great
Horwood, Maids Moreton, Marsh Gibbon, Newton Longville and Weston Turville, and yet each and every
one of these settlements are proposed to receive greater levels of growth.
Indeed, Table 2 indicates that 101 dwellings have already been permitted in the less sustainable
settlement of Stewkley which compares to the 23 permitted in Bierton. This provides a strong indication
that Bierton should receive (or at the very least be allowed to receive) a level of growth commensurate
with its sustainability, in excess of that which has already been proved to be sustainable at the less
sustainable settlement of Stewkley.
Similarly, in some of the equally sustainable settlements, namely Maids Moreton, Marsh Gibbon and
Newton Longville, the number of dwellings permitted is in excess of that at Bierton and yet additional
allocations are proposed in these settlements. Indeed, Maids Moreton is planned to receive 171
dwellings, Marsh Gibbon is planned to receive 47 and Newton Longville 48, as compared to the 23
dwellings at Bierton.
Policy S3 (Settlement hierarchy and cohesive development spatial strategy for growth)
If your representation is more than 100 words, please provide a brief summary here:
Pegasus therefore, in accordance with the representations submitted for the 'Draft Plan for Summer
2016 Consultation', continue to object to the "downgrading" of Bierton, which is clearly a sustainable
location and with the development to the south (i.e. Land East of Aylesbury - Kingsbrook) has outline
planning permission for 2,450 homes, 10 hectares of employment land and further development such
as two primary schools and community facilities, thereby providing a range of facilities and services
which will be even closer those provided by Aylesbury only 1.8 miles away.
Paragraph 4.152 identifies that no allocations are made at either Bierton or Weston Turville owing to
their proximity to Aylesbury Garden Town. This does not take account of the impacts of the proposed
allocations at Aylesbury Garden Town which include a highways access in Bierton. Bierton will be
directly affected by the highways impacts associated with large scale residential development, but will
not receive the benefits associated with modest housing provision. This cannot be considered to be
sustainable in terms of the three dimensions of sustainability (providing adverse social, economic and
environmental impacts from the nearby development without any beneficial impacts associated with
these).
As a result of this, the proposed distribution in the VALP does not reflect the sustainability of
settlements. Additional provisions, either in the form of allocations and/or mechanisms to allow
development beyond the settlement envelope should be embedded in the VALP.
It is therefore necessary to provide for development in Bierton commensurate with its size and scale.
On behalf of our client, Pegasus has promoted through the SHLAA and previous representations to the
emerging Local Plan, several sites at Bierton - refs: BIE004, BIE005, HUL004. A location plan is
attached which shows these sites in relation to Bierton. These sites are not subject to any statutory
environmental or landscape designations and nor are they located in any Local Landscape Area or
Area of Attractive Landscape
Policy S3 seeks to resist development that would compromise the open character of the countryside
between settlements. Whilst the objective of this Policy accords with the NPPF, the Policy is not
sufficiently precise. Any development beyond the current built form, including that on allocated sites
(either within the VALP or neighbourhood plans), or as exceptional development (see Policy D4 and
H2 for example) will to some extent compromise certain elements of the character of the countryside
between settlements. The blanket application of the Policy as worded would prevent any such
development and would thereby prevent the housing requirement (or any other development
requirements) being delivered.
Indeed, paragraph 109 of the NPPF requires that such protection is only afforded to valued landscapes.
As such, the Policy as worded, is not consistent with the NPPF, it is not justified and it will not be
effective as it could be used to undermine the required development.

Object

VALP Proposed Submission

1.7

Representation ID: 1917

Received: 14/12/2017

Respondent: Revera Limited

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

Paragraph 1.7 of the Vale of Aylesbury Local Plan (VALP) suggests Government policy is to deliver 250,000 homes per annum nationally. This figure is not identified in Government policy. The most recent evidence of required number of homes identified as at least 300,000 per annum in July 2016. Government responded to this and are currently consulting on a national distribution to deliver at least 266,000 new homes per annum nationally. Reference in paragraph 1.7 conflicts with available evidence and also suggests that the VALP has been prepared with the objective of delivering a level of housing below that required nationally

Full text:

Please see attachments

Paragraph 3.80 suggests that there is not a record of persistent under-delivery in Aylesbury Vale and that accordingly it is appropriate to apply a 5% buffer.
The Council assess the record of delivery against the objectively assessed need for Aylesbury Vale in isolation, which is the correct approach prior to the confirmation of the contribution to the unmet needs of neighbouring authorities through the VALP examination. Table 2 of the Five-Year Housing Land Supply Position Statement, August 2017 identifies that whilst there was under-delivery in the majority of years up until 2012/13, the recent record of delivery justifies the application of a 5% buffer.
However, upon adoption of the VALP (even assuming that the housing requirement remains as proposed) there will have been under-delivery in almost every year since 2013/14 with the needs across the HMA falling to Aylesbury Vale but not having been met. Accordingly, upon adoption there will be a necessity to apply a 20% buffer to afford the appropriate weight to housing proposals given the significant shortfall in provision across the HMA since 2013.
The effect of the application of the necessary 20% buffer on adoption would result in a five-year land supply shortfall of circa 600 dwellings. This will need to be addressed within the VALP through the identification of additional deliverable allocations.
Policy S9 (Monitoring and review)

Paragraph 1.7 of the Vale of Aylesbury Local Plan (VALP) suggests that Government policy is to deliver 250,000 homes per annum nationally. However, this figure is not identified in Government policy. The most recent evidence of the required number of homes was identified as at least 300,000 new homes per annum in the 'Building More Homes' report to the House of Lords Select Committee on Economic Affairs in July 2016. The Government have responded to this evidence (and older assessments including the Barker Report) and are currently consulting on a national distribution to deliver at least 266,000 new homes per annum nationally. The reference in paragraph 1.7 therefore not only conflicts with the available evidence, it also suggests that the VALP has been prepared with the objective of delivering a level of housing below that required nationally.

Paragraph 1.8 continues to identify a requirement of 19,400 new homes to respond to the needs of Aylesbury Vale (excluding any contributions to the unmet needs of neighbouring authorities). This figure is based upon the Buckinghamshire Housing and Economic Development Needs Assessment (HEDNA) Update Addendum, September 2017 which contains corrections to the Buckinghamshire HEDNA Update: Final Report, December 2016.
Paragraph 47 of the National Planning Policy Framework (NPPF) identifies that Local Planning Authorities (LPAs) should use their evidence base to ensure that their Local Plan meets the full, objectively assessed need (OAN) for the Housing Market Area (HMA) rather than an LPA boundary (unless they are coterminous). This has been underlined in several legal judgments1. This is necessary to ensure that account is taken of the inter-relationships between the various LPAs and a consistent approach is taken to these. However, the HEDNA assesses the OAN for each LPA in isolation, using different assumptions for each. The necessary result of this inconsistency means that the OAN has not been established for the HMA, contrary to the NPPF.
It is also important to note that the Department for Communities and Local Government (DCLG) has recently consulted on a standardised methodology for identifying the local housing need. This has arisen from the Local Plans Expert Group and the Housing White Paper, both of which were subject to consultation, as well as from professional input from a wide range of experts including the Planning Inspectorate and the Bar.

Paragraph 1.11 identifies that there is insufficient capacity to meet the OAN in the areas south of Aylesbury Vale. In the following paragraph 1.12, there is calculated to be an unmet need of 8,000 homes.
However, this is all predicated on the OAN identified in the HEDNA which adopts inconsistent and negative assumptions, contrary to the available evidence to reduce the OAN. The population is growing far faster than anticipated by the latest sub-national population projections, and yet even if the OAN was calculated on the basis of these population projections this would produce an unmet need of 8,965 homes (based on the OAN of 27,065 for the remainder of Buckinghamshire (= 51,051 - 23,986) and the capacity of 18,100 homes identified in the Memorandum of Understanding, July 2017).
Furthermore, the Luton Local Plan was adopted in November 2017 and this identifies that there is a need for 400 dwellings which relates to Aylesbury Vale, which is not being addressed elsewhere.
As a result, the VALP should make provision for at least 33,350 homes to address the rounded OAN (of 24,000), the rounded unmet need (of 8,950) and the unmet need of Luton (of 400). These figures will increase significantly, once the standardised methodology becomes part of national policy and so additional provision should be supported or planned for (including through the early review).
This compares to the identified housing requirement in paragraph 1.12 of 27,400 homes. It is therefore clear, that even if the VALP is submitted in advance of the revised NPPF, it will contain a housing requirement that is 5,950 homes short of meeting the OAN across the HMA (unless other sites can be identified across the remainder of Buckinghamshire to contribute to this unmet need). However, in paragraph 3.17 it is identified that it is expected that 28,830 homes will be delivered in the plan period, which reduces the shortfall to 4,334 homes.

Policy S2 makes provision for a total of 27,400 homes which is significantly below the minimum OAN of 33,350. Therefore additional mechanisms will need to be identified to address the resultant shortfall. This should include the identification of additional sites now as well as the identification of new settlements through the proposed early review.
Policy S2 identifies that the primary focus of strategic levels of growth will be at Aylesbury, Buckingham, Winslow, Wendover and Haddenham. It then continues to identify that growth adjacent to Milton Keynes will also be allocated. The Policy also identifies that development at medium villages, including Bierton, will be at a scale in keeping with the local character and setting.
Whilst this approach is supported, as set out in our representations to Policies S3 and D2, our client retains an objection to the "downgrading" of Bierton to a medium village which is clearly a sustainable location in close proximity to Aylesbury and to other new development, i.e. Land East of Aylesbury (Kingsbrook). Bierton should therefore be reclassified to a "larger village" as originally assessed. If the Council are minded to maintain the classification of Bierton as a medium village the characteristics and context of the settlement should be recognised with a more appropriate level of growth than that currently proposed in the VALP.

Table 2 identifies the proposed settlement hierarchy and housing development based on the proposals
of Policy S2.
Paragraph 3.20 identifies that the settlement hierarchy including the ranking of settlements identified in
the Settlement Hierarchy Assessment, September 2017, forms the basis of the proposed distribution
between settlements.
The Settlement Hierarchy Assessment, September 2017 identifies that Bierton (which meets 6 criteria)
is more sustainable than Stewkley (5 criteria) and equally as sustainable as Cheddington, Great
Horwood, Maids Moreton, Marsh Gibbon, Newton Longville and Weston Turville, and yet each and every
one of these settlements are proposed to receive greater levels of growth.
Indeed, Table 2 indicates that 101 dwellings have already been permitted in the less sustainable
settlement of Stewkley which compares to the 23 permitted in Bierton. This provides a strong indication
that Bierton should receive (or at the very least be allowed to receive) a level of growth commensurate
with its sustainability, in excess of that which has already been proved to be sustainable at the less
sustainable settlement of Stewkley.
Similarly, in some of the equally sustainable settlements, namely Maids Moreton, Marsh Gibbon and
Newton Longville, the number of dwellings permitted is in excess of that at Bierton and yet additional
allocations are proposed in these settlements. Indeed, Maids Moreton is planned to receive 171
dwellings, Marsh Gibbon is planned to receive 47 and Newton Longville 48, as compared to the 23
dwellings at Bierton.
Policy S3 (Settlement hierarchy and cohesive development spatial strategy for growth)
If your representation is more than 100 words, please provide a brief summary here:
Pegasus therefore, in accordance with the representations submitted for the 'Draft Plan for Summer
2016 Consultation', continue to object to the "downgrading" of Bierton, which is clearly a sustainable
location and with the development to the south (i.e. Land East of Aylesbury - Kingsbrook) has outline
planning permission for 2,450 homes, 10 hectares of employment land and further development such
as two primary schools and community facilities, thereby providing a range of facilities and services
which will be even closer those provided by Aylesbury only 1.8 miles away.
Paragraph 4.152 identifies that no allocations are made at either Bierton or Weston Turville owing to
their proximity to Aylesbury Garden Town. This does not take account of the impacts of the proposed
allocations at Aylesbury Garden Town which include a highways access in Bierton. Bierton will be
directly affected by the highways impacts associated with large scale residential development, but will
not receive the benefits associated with modest housing provision. This cannot be considered to be
sustainable in terms of the three dimensions of sustainability (providing adverse social, economic and
environmental impacts from the nearby development without any beneficial impacts associated with
these).
As a result of this, the proposed distribution in the VALP does not reflect the sustainability of
settlements. Additional provisions, either in the form of allocations and/or mechanisms to allow
development beyond the settlement envelope should be embedded in the VALP.
It is therefore necessary to provide for development in Bierton commensurate with its size and scale.
On behalf of our client, Pegasus has promoted through the SHLAA and previous representations to the
emerging Local Plan, several sites at Bierton - refs: BIE004, BIE005, HUL004. A location plan is
attached which shows these sites in relation to Bierton. These sites are not subject to any statutory
environmental or landscape designations and nor are they located in any Local Landscape Area or
Area of Attractive Landscape
Policy S3 seeks to resist development that would compromise the open character of the countryside
between settlements. Whilst the objective of this Policy accords with the NPPF, the Policy is not
sufficiently precise. Any development beyond the current built form, including that on allocated sites
(either within the VALP or neighbourhood plans), or as exceptional development (see Policy D4 and
H2 for example) will to some extent compromise certain elements of the character of the countryside
between settlements. The blanket application of the Policy as worded would prevent any such
development and would thereby prevent the housing requirement (or any other development
requirements) being delivered.
Indeed, paragraph 109 of the NPPF requires that such protection is only afforded to valued landscapes.
As such, the Policy as worded, is not consistent with the NPPF, it is not justified and it will not be
effective as it could be used to undermine the required development.

Object

VALP Proposed Submission

1.8

Representation ID: 1923

Received: 14/12/2017

Respondent: Revera Limited

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

Proposed housing requirement does not represent OAN as a result of the unjustified assumptions in the HEDNA and that is will continue to be significantly below the local housing need in the future. As a result, the housing requirement must be amended to reflect reasonable assumptions and provide for a min of 24,000 (23,986 rounded) to meet the needs of Aylesbury Vale in the interim

Full text:

Please see attachments

Paragraph 3.80 suggests that there is not a record of persistent under-delivery in Aylesbury Vale and that accordingly it is appropriate to apply a 5% buffer.
The Council assess the record of delivery against the objectively assessed need for Aylesbury Vale in isolation, which is the correct approach prior to the confirmation of the contribution to the unmet needs of neighbouring authorities through the VALP examination. Table 2 of the Five-Year Housing Land Supply Position Statement, August 2017 identifies that whilst there was under-delivery in the majority of years up until 2012/13, the recent record of delivery justifies the application of a 5% buffer.
However, upon adoption of the VALP (even assuming that the housing requirement remains as proposed) there will have been under-delivery in almost every year since 2013/14 with the needs across the HMA falling to Aylesbury Vale but not having been met. Accordingly, upon adoption there will be a necessity to apply a 20% buffer to afford the appropriate weight to housing proposals given the significant shortfall in provision across the HMA since 2013.
The effect of the application of the necessary 20% buffer on adoption would result in a five-year land supply shortfall of circa 600 dwellings. This will need to be addressed within the VALP through the identification of additional deliverable allocations.
Policy S9 (Monitoring and review)

Paragraph 1.7 of the Vale of Aylesbury Local Plan (VALP) suggests that Government policy is to deliver 250,000 homes per annum nationally. However, this figure is not identified in Government policy. The most recent evidence of the required number of homes was identified as at least 300,000 new homes per annum in the 'Building More Homes' report to the House of Lords Select Committee on Economic Affairs in July 2016. The Government have responded to this evidence (and older assessments including the Barker Report) and are currently consulting on a national distribution to deliver at least 266,000 new homes per annum nationally. The reference in paragraph 1.7 therefore not only conflicts with the available evidence, it also suggests that the VALP has been prepared with the objective of delivering a level of housing below that required nationally.

Paragraph 1.8 continues to identify a requirement of 19,400 new homes to respond to the needs of Aylesbury Vale (excluding any contributions to the unmet needs of neighbouring authorities). This figure is based upon the Buckinghamshire Housing and Economic Development Needs Assessment (HEDNA) Update Addendum, September 2017 which contains corrections to the Buckinghamshire HEDNA Update: Final Report, December 2016.
Paragraph 47 of the National Planning Policy Framework (NPPF) identifies that Local Planning Authorities (LPAs) should use their evidence base to ensure that their Local Plan meets the full, objectively assessed need (OAN) for the Housing Market Area (HMA) rather than an LPA boundary (unless they are coterminous). This has been underlined in several legal judgments1. This is necessary to ensure that account is taken of the inter-relationships between the various LPAs and a consistent approach is taken to these. However, the HEDNA assesses the OAN for each LPA in isolation, using different assumptions for each. The necessary result of this inconsistency means that the OAN has not been established for the HMA, contrary to the NPPF.
It is also important to note that the Department for Communities and Local Government (DCLG) has recently consulted on a standardised methodology for identifying the local housing need. This has arisen from the Local Plans Expert Group and the Housing White Paper, both of which were subject to consultation, as well as from professional input from a wide range of experts including the Planning Inspectorate and the Bar.

Paragraph 1.11 identifies that there is insufficient capacity to meet the OAN in the areas south of Aylesbury Vale. In the following paragraph 1.12, there is calculated to be an unmet need of 8,000 homes.
However, this is all predicated on the OAN identified in the HEDNA which adopts inconsistent and negative assumptions, contrary to the available evidence to reduce the OAN. The population is growing far faster than anticipated by the latest sub-national population projections, and yet even if the OAN was calculated on the basis of these population projections this would produce an unmet need of 8,965 homes (based on the OAN of 27,065 for the remainder of Buckinghamshire (= 51,051 - 23,986) and the capacity of 18,100 homes identified in the Memorandum of Understanding, July 2017).
Furthermore, the Luton Local Plan was adopted in November 2017 and this identifies that there is a need for 400 dwellings which relates to Aylesbury Vale, which is not being addressed elsewhere.
As a result, the VALP should make provision for at least 33,350 homes to address the rounded OAN (of 24,000), the rounded unmet need (of 8,950) and the unmet need of Luton (of 400). These figures will increase significantly, once the standardised methodology becomes part of national policy and so additional provision should be supported or planned for (including through the early review).
This compares to the identified housing requirement in paragraph 1.12 of 27,400 homes. It is therefore clear, that even if the VALP is submitted in advance of the revised NPPF, it will contain a housing requirement that is 5,950 homes short of meeting the OAN across the HMA (unless other sites can be identified across the remainder of Buckinghamshire to contribute to this unmet need). However, in paragraph 3.17 it is identified that it is expected that 28,830 homes will be delivered in the plan period, which reduces the shortfall to 4,334 homes.

Policy S2 makes provision for a total of 27,400 homes which is significantly below the minimum OAN of 33,350. Therefore additional mechanisms will need to be identified to address the resultant shortfall. This should include the identification of additional sites now as well as the identification of new settlements through the proposed early review.
Policy S2 identifies that the primary focus of strategic levels of growth will be at Aylesbury, Buckingham, Winslow, Wendover and Haddenham. It then continues to identify that growth adjacent to Milton Keynes will also be allocated. The Policy also identifies that development at medium villages, including Bierton, will be at a scale in keeping with the local character and setting.
Whilst this approach is supported, as set out in our representations to Policies S3 and D2, our client retains an objection to the "downgrading" of Bierton to a medium village which is clearly a sustainable location in close proximity to Aylesbury and to other new development, i.e. Land East of Aylesbury (Kingsbrook). Bierton should therefore be reclassified to a "larger village" as originally assessed. If the Council are minded to maintain the classification of Bierton as a medium village the characteristics and context of the settlement should be recognised with a more appropriate level of growth than that currently proposed in the VALP.

Table 2 identifies the proposed settlement hierarchy and housing development based on the proposals
of Policy S2.
Paragraph 3.20 identifies that the settlement hierarchy including the ranking of settlements identified in
the Settlement Hierarchy Assessment, September 2017, forms the basis of the proposed distribution
between settlements.
The Settlement Hierarchy Assessment, September 2017 identifies that Bierton (which meets 6 criteria)
is more sustainable than Stewkley (5 criteria) and equally as sustainable as Cheddington, Great
Horwood, Maids Moreton, Marsh Gibbon, Newton Longville and Weston Turville, and yet each and every
one of these settlements are proposed to receive greater levels of growth.
Indeed, Table 2 indicates that 101 dwellings have already been permitted in the less sustainable
settlement of Stewkley which compares to the 23 permitted in Bierton. This provides a strong indication
that Bierton should receive (or at the very least be allowed to receive) a level of growth commensurate
with its sustainability, in excess of that which has already been proved to be sustainable at the less
sustainable settlement of Stewkley.
Similarly, in some of the equally sustainable settlements, namely Maids Moreton, Marsh Gibbon and
Newton Longville, the number of dwellings permitted is in excess of that at Bierton and yet additional
allocations are proposed in these settlements. Indeed, Maids Moreton is planned to receive 171
dwellings, Marsh Gibbon is planned to receive 47 and Newton Longville 48, as compared to the 23
dwellings at Bierton.
Policy S3 (Settlement hierarchy and cohesive development spatial strategy for growth)
If your representation is more than 100 words, please provide a brief summary here:
Pegasus therefore, in accordance with the representations submitted for the 'Draft Plan for Summer
2016 Consultation', continue to object to the "downgrading" of Bierton, which is clearly a sustainable
location and with the development to the south (i.e. Land East of Aylesbury - Kingsbrook) has outline
planning permission for 2,450 homes, 10 hectares of employment land and further development such
as two primary schools and community facilities, thereby providing a range of facilities and services
which will be even closer those provided by Aylesbury only 1.8 miles away.
Paragraph 4.152 identifies that no allocations are made at either Bierton or Weston Turville owing to
their proximity to Aylesbury Garden Town. This does not take account of the impacts of the proposed
allocations at Aylesbury Garden Town which include a highways access in Bierton. Bierton will be
directly affected by the highways impacts associated with large scale residential development, but will
not receive the benefits associated with modest housing provision. This cannot be considered to be
sustainable in terms of the three dimensions of sustainability (providing adverse social, economic and
environmental impacts from the nearby development without any beneficial impacts associated with
these).
As a result of this, the proposed distribution in the VALP does not reflect the sustainability of
settlements. Additional provisions, either in the form of allocations and/or mechanisms to allow
development beyond the settlement envelope should be embedded in the VALP.
It is therefore necessary to provide for development in Bierton commensurate with its size and scale.
On behalf of our client, Pegasus has promoted through the SHLAA and previous representations to the
emerging Local Plan, several sites at Bierton - refs: BIE004, BIE005, HUL004. A location plan is
attached which shows these sites in relation to Bierton. These sites are not subject to any statutory
environmental or landscape designations and nor are they located in any Local Landscape Area or
Area of Attractive Landscape
Policy S3 seeks to resist development that would compromise the open character of the countryside
between settlements. Whilst the objective of this Policy accords with the NPPF, the Policy is not
sufficiently precise. Any development beyond the current built form, including that on allocated sites
(either within the VALP or neighbourhood plans), or as exceptional development (see Policy D4 and
H2 for example) will to some extent compromise certain elements of the character of the countryside
between settlements. The blanket application of the Policy as worded would prevent any such
development and would thereby prevent the housing requirement (or any other development
requirements) being delivered.
Indeed, paragraph 109 of the NPPF requires that such protection is only afforded to valued landscapes.
As such, the Policy as worded, is not consistent with the NPPF, it is not justified and it will not be
effective as it could be used to undermine the required development.

Object

VALP Proposed Submission

1.11

Representation ID: 1932

Received: 14/12/2017

Respondent: Revera Limited

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

The acceptance of unmet needs of neighbouring authorities with Aylesbury Vale is to be welcomed as this not only recognises the constraints in these authorities but also recognises the sustainability of Aylesbury Vale. Given the scale of the shortfall between the proposed provision and the OAN, additional provision should be made within the VALP now although it may also be appropriate to address some of this additional need through the early review once the effects of the standardised methodology and other material consideration are fully known.

Full text:

Please see attachments

Paragraph 3.80 suggests that there is not a record of persistent under-delivery in Aylesbury Vale and that accordingly it is appropriate to apply a 5% buffer.
The Council assess the record of delivery against the objectively assessed need for Aylesbury Vale in isolation, which is the correct approach prior to the confirmation of the contribution to the unmet needs of neighbouring authorities through the VALP examination. Table 2 of the Five-Year Housing Land Supply Position Statement, August 2017 identifies that whilst there was under-delivery in the majority of years up until 2012/13, the recent record of delivery justifies the application of a 5% buffer.
However, upon adoption of the VALP (even assuming that the housing requirement remains as proposed) there will have been under-delivery in almost every year since 2013/14 with the needs across the HMA falling to Aylesbury Vale but not having been met. Accordingly, upon adoption there will be a necessity to apply a 20% buffer to afford the appropriate weight to housing proposals given the significant shortfall in provision across the HMA since 2013.
The effect of the application of the necessary 20% buffer on adoption would result in a five-year land supply shortfall of circa 600 dwellings. This will need to be addressed within the VALP through the identification of additional deliverable allocations.
Policy S9 (Monitoring and review)

Paragraph 1.7 of the Vale of Aylesbury Local Plan (VALP) suggests that Government policy is to deliver 250,000 homes per annum nationally. However, this figure is not identified in Government policy. The most recent evidence of the required number of homes was identified as at least 300,000 new homes per annum in the 'Building More Homes' report to the House of Lords Select Committee on Economic Affairs in July 2016. The Government have responded to this evidence (and older assessments including the Barker Report) and are currently consulting on a national distribution to deliver at least 266,000 new homes per annum nationally. The reference in paragraph 1.7 therefore not only conflicts with the available evidence, it also suggests that the VALP has been prepared with the objective of delivering a level of housing below that required nationally.

Paragraph 1.8 continues to identify a requirement of 19,400 new homes to respond to the needs of Aylesbury Vale (excluding any contributions to the unmet needs of neighbouring authorities). This figure is based upon the Buckinghamshire Housing and Economic Development Needs Assessment (HEDNA) Update Addendum, September 2017 which contains corrections to the Buckinghamshire HEDNA Update: Final Report, December 2016.
Paragraph 47 of the National Planning Policy Framework (NPPF) identifies that Local Planning Authorities (LPAs) should use their evidence base to ensure that their Local Plan meets the full, objectively assessed need (OAN) for the Housing Market Area (HMA) rather than an LPA boundary (unless they are coterminous). This has been underlined in several legal judgments1. This is necessary to ensure that account is taken of the inter-relationships between the various LPAs and a consistent approach is taken to these. However, the HEDNA assesses the OAN for each LPA in isolation, using different assumptions for each. The necessary result of this inconsistency means that the OAN has not been established for the HMA, contrary to the NPPF.
It is also important to note that the Department for Communities and Local Government (DCLG) has recently consulted on a standardised methodology for identifying the local housing need. This has arisen from the Local Plans Expert Group and the Housing White Paper, both of which were subject to consultation, as well as from professional input from a wide range of experts including the Planning Inspectorate and the Bar.

Paragraph 1.11 identifies that there is insufficient capacity to meet the OAN in the areas south of Aylesbury Vale. In the following paragraph 1.12, there is calculated to be an unmet need of 8,000 homes.
However, this is all predicated on the OAN identified in the HEDNA which adopts inconsistent and negative assumptions, contrary to the available evidence to reduce the OAN. The population is growing far faster than anticipated by the latest sub-national population projections, and yet even if the OAN was calculated on the basis of these population projections this would produce an unmet need of 8,965 homes (based on the OAN of 27,065 for the remainder of Buckinghamshire (= 51,051 - 23,986) and the capacity of 18,100 homes identified in the Memorandum of Understanding, July 2017).
Furthermore, the Luton Local Plan was adopted in November 2017 and this identifies that there is a need for 400 dwellings which relates to Aylesbury Vale, which is not being addressed elsewhere.
As a result, the VALP should make provision for at least 33,350 homes to address the rounded OAN (of 24,000), the rounded unmet need (of 8,950) and the unmet need of Luton (of 400). These figures will increase significantly, once the standardised methodology becomes part of national policy and so additional provision should be supported or planned for (including through the early review).
This compares to the identified housing requirement in paragraph 1.12 of 27,400 homes. It is therefore clear, that even if the VALP is submitted in advance of the revised NPPF, it will contain a housing requirement that is 5,950 homes short of meeting the OAN across the HMA (unless other sites can be identified across the remainder of Buckinghamshire to contribute to this unmet need). However, in paragraph 3.17 it is identified that it is expected that 28,830 homes will be delivered in the plan period, which reduces the shortfall to 4,334 homes.

Policy S2 makes provision for a total of 27,400 homes which is significantly below the minimum OAN of 33,350. Therefore additional mechanisms will need to be identified to address the resultant shortfall. This should include the identification of additional sites now as well as the identification of new settlements through the proposed early review.
Policy S2 identifies that the primary focus of strategic levels of growth will be at Aylesbury, Buckingham, Winslow, Wendover and Haddenham. It then continues to identify that growth adjacent to Milton Keynes will also be allocated. The Policy also identifies that development at medium villages, including Bierton, will be at a scale in keeping with the local character and setting.
Whilst this approach is supported, as set out in our representations to Policies S3 and D2, our client retains an objection to the "downgrading" of Bierton to a medium village which is clearly a sustainable location in close proximity to Aylesbury and to other new development, i.e. Land East of Aylesbury (Kingsbrook). Bierton should therefore be reclassified to a "larger village" as originally assessed. If the Council are minded to maintain the classification of Bierton as a medium village the characteristics and context of the settlement should be recognised with a more appropriate level of growth than that currently proposed in the VALP.

Table 2 identifies the proposed settlement hierarchy and housing development based on the proposals
of Policy S2.
Paragraph 3.20 identifies that the settlement hierarchy including the ranking of settlements identified in
the Settlement Hierarchy Assessment, September 2017, forms the basis of the proposed distribution
between settlements.
The Settlement Hierarchy Assessment, September 2017 identifies that Bierton (which meets 6 criteria)
is more sustainable than Stewkley (5 criteria) and equally as sustainable as Cheddington, Great
Horwood, Maids Moreton, Marsh Gibbon, Newton Longville and Weston Turville, and yet each and every
one of these settlements are proposed to receive greater levels of growth.
Indeed, Table 2 indicates that 101 dwellings have already been permitted in the less sustainable
settlement of Stewkley which compares to the 23 permitted in Bierton. This provides a strong indication
that Bierton should receive (or at the very least be allowed to receive) a level of growth commensurate
with its sustainability, in excess of that which has already been proved to be sustainable at the less
sustainable settlement of Stewkley.
Similarly, in some of the equally sustainable settlements, namely Maids Moreton, Marsh Gibbon and
Newton Longville, the number of dwellings permitted is in excess of that at Bierton and yet additional
allocations are proposed in these settlements. Indeed, Maids Moreton is planned to receive 171
dwellings, Marsh Gibbon is planned to receive 47 and Newton Longville 48, as compared to the 23
dwellings at Bierton.
Policy S3 (Settlement hierarchy and cohesive development spatial strategy for growth)
If your representation is more than 100 words, please provide a brief summary here:
Pegasus therefore, in accordance with the representations submitted for the 'Draft Plan for Summer
2016 Consultation', continue to object to the "downgrading" of Bierton, which is clearly a sustainable
location and with the development to the south (i.e. Land East of Aylesbury - Kingsbrook) has outline
planning permission for 2,450 homes, 10 hectares of employment land and further development such
as two primary schools and community facilities, thereby providing a range of facilities and services
which will be even closer those provided by Aylesbury only 1.8 miles away.
Paragraph 4.152 identifies that no allocations are made at either Bierton or Weston Turville owing to
their proximity to Aylesbury Garden Town. This does not take account of the impacts of the proposed
allocations at Aylesbury Garden Town which include a highways access in Bierton. Bierton will be
directly affected by the highways impacts associated with large scale residential development, but will
not receive the benefits associated with modest housing provision. This cannot be considered to be
sustainable in terms of the three dimensions of sustainability (providing adverse social, economic and
environmental impacts from the nearby development without any beneficial impacts associated with
these).
As a result of this, the proposed distribution in the VALP does not reflect the sustainability of
settlements. Additional provisions, either in the form of allocations and/or mechanisms to allow
development beyond the settlement envelope should be embedded in the VALP.
It is therefore necessary to provide for development in Bierton commensurate with its size and scale.
On behalf of our client, Pegasus has promoted through the SHLAA and previous representations to the
emerging Local Plan, several sites at Bierton - refs: BIE004, BIE005, HUL004. A location plan is
attached which shows these sites in relation to Bierton. These sites are not subject to any statutory
environmental or landscape designations and nor are they located in any Local Landscape Area or
Area of Attractive Landscape
Policy S3 seeks to resist development that would compromise the open character of the countryside
between settlements. Whilst the objective of this Policy accords with the NPPF, the Policy is not
sufficiently precise. Any development beyond the current built form, including that on allocated sites
(either within the VALP or neighbourhood plans), or as exceptional development (see Policy D4 and
H2 for example) will to some extent compromise certain elements of the character of the countryside
between settlements. The blanket application of the Policy as worded would prevent any such
development and would thereby prevent the housing requirement (or any other development
requirements) being delivered.
Indeed, paragraph 109 of the NPPF requires that such protection is only afforded to valued landscapes.
As such, the Policy as worded, is not consistent with the NPPF, it is not justified and it will not be
effective as it could be used to undermine the required development.

Object

VALP Proposed Submission

D2 Proposals for non-allocated sites at strategic settlements, larger villages and medium villages

Representation ID: 1933

Received: 14/12/2017

Respondent: Revera Limited

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

An objection remains in respect of the lack of any allocation to Bierton (which continues to be "downgraded" to a Medium Settlement), which has been subsumed into the housing requirement of Aylesbury. Our objection to the reclassification of Bierton from a Larger Village to a Medium Village still remain valid.
The principle of the approach in Policy D2 is to be welcomed as this provides sufficient flexibility to respond to housing shortfalls as they arise.

Full text:

Please see attachments

Paragraph 3.80 suggests that there is not a record of persistent under-delivery in Aylesbury Vale and that accordingly it is appropriate to apply a 5% buffer.
The Council assess the record of delivery against the objectively assessed need for Aylesbury Vale in isolation, which is the correct approach prior to the confirmation of the contribution to the unmet needs of neighbouring authorities through the VALP examination. Table 2 of the Five-Year Housing Land Supply Position Statement, August 2017 identifies that whilst there was under-delivery in the majority of years up until 2012/13, the recent record of delivery justifies the application of a 5% buffer.
However, upon adoption of the VALP (even assuming that the housing requirement remains as proposed) there will have been under-delivery in almost every year since 2013/14 with the needs across the HMA falling to Aylesbury Vale but not having been met. Accordingly, upon adoption there will be a necessity to apply a 20% buffer to afford the appropriate weight to housing proposals given the significant shortfall in provision across the HMA since 2013.
The effect of the application of the necessary 20% buffer on adoption would result in a five-year land supply shortfall of circa 600 dwellings. This will need to be addressed within the VALP through the identification of additional deliverable allocations.
Policy S9 (Monitoring and review)

Paragraph 1.7 of the Vale of Aylesbury Local Plan (VALP) suggests that Government policy is to deliver 250,000 homes per annum nationally. However, this figure is not identified in Government policy. The most recent evidence of the required number of homes was identified as at least 300,000 new homes per annum in the 'Building More Homes' report to the House of Lords Select Committee on Economic Affairs in July 2016. The Government have responded to this evidence (and older assessments including the Barker Report) and are currently consulting on a national distribution to deliver at least 266,000 new homes per annum nationally. The reference in paragraph 1.7 therefore not only conflicts with the available evidence, it also suggests that the VALP has been prepared with the objective of delivering a level of housing below that required nationally.

Paragraph 1.8 continues to identify a requirement of 19,400 new homes to respond to the needs of Aylesbury Vale (excluding any contributions to the unmet needs of neighbouring authorities). This figure is based upon the Buckinghamshire Housing and Economic Development Needs Assessment (HEDNA) Update Addendum, September 2017 which contains corrections to the Buckinghamshire HEDNA Update: Final Report, December 2016.
Paragraph 47 of the National Planning Policy Framework (NPPF) identifies that Local Planning Authorities (LPAs) should use their evidence base to ensure that their Local Plan meets the full, objectively assessed need (OAN) for the Housing Market Area (HMA) rather than an LPA boundary (unless they are coterminous). This has been underlined in several legal judgments1. This is necessary to ensure that account is taken of the inter-relationships between the various LPAs and a consistent approach is taken to these. However, the HEDNA assesses the OAN for each LPA in isolation, using different assumptions for each. The necessary result of this inconsistency means that the OAN has not been established for the HMA, contrary to the NPPF.
It is also important to note that the Department for Communities and Local Government (DCLG) has recently consulted on a standardised methodology for identifying the local housing need. This has arisen from the Local Plans Expert Group and the Housing White Paper, both of which were subject to consultation, as well as from professional input from a wide range of experts including the Planning Inspectorate and the Bar.

Paragraph 1.11 identifies that there is insufficient capacity to meet the OAN in the areas south of Aylesbury Vale. In the following paragraph 1.12, there is calculated to be an unmet need of 8,000 homes.
However, this is all predicated on the OAN identified in the HEDNA which adopts inconsistent and negative assumptions, contrary to the available evidence to reduce the OAN. The population is growing far faster than anticipated by the latest sub-national population projections, and yet even if the OAN was calculated on the basis of these population projections this would produce an unmet need of 8,965 homes (based on the OAN of 27,065 for the remainder of Buckinghamshire (= 51,051 - 23,986) and the capacity of 18,100 homes identified in the Memorandum of Understanding, July 2017).
Furthermore, the Luton Local Plan was adopted in November 2017 and this identifies that there is a need for 400 dwellings which relates to Aylesbury Vale, which is not being addressed elsewhere.
As a result, the VALP should make provision for at least 33,350 homes to address the rounded OAN (of 24,000), the rounded unmet need (of 8,950) and the unmet need of Luton (of 400). These figures will increase significantly, once the standardised methodology becomes part of national policy and so additional provision should be supported or planned for (including through the early review).
This compares to the identified housing requirement in paragraph 1.12 of 27,400 homes. It is therefore clear, that even if the VALP is submitted in advance of the revised NPPF, it will contain a housing requirement that is 5,950 homes short of meeting the OAN across the HMA (unless other sites can be identified across the remainder of Buckinghamshire to contribute to this unmet need). However, in paragraph 3.17 it is identified that it is expected that 28,830 homes will be delivered in the plan period, which reduces the shortfall to 4,334 homes.

Policy S2 makes provision for a total of 27,400 homes which is significantly below the minimum OAN of 33,350. Therefore additional mechanisms will need to be identified to address the resultant shortfall. This should include the identification of additional sites now as well as the identification of new settlements through the proposed early review.
Policy S2 identifies that the primary focus of strategic levels of growth will be at Aylesbury, Buckingham, Winslow, Wendover and Haddenham. It then continues to identify that growth adjacent to Milton Keynes will also be allocated. The Policy also identifies that development at medium villages, including Bierton, will be at a scale in keeping with the local character and setting.
Whilst this approach is supported, as set out in our representations to Policies S3 and D2, our client retains an objection to the "downgrading" of Bierton to a medium village which is clearly a sustainable location in close proximity to Aylesbury and to other new development, i.e. Land East of Aylesbury (Kingsbrook). Bierton should therefore be reclassified to a "larger village" as originally assessed. If the Council are minded to maintain the classification of Bierton as a medium village the characteristics and context of the settlement should be recognised with a more appropriate level of growth than that currently proposed in the VALP.

Table 2 identifies the proposed settlement hierarchy and housing development based on the proposals
of Policy S2.
Paragraph 3.20 identifies that the settlement hierarchy including the ranking of settlements identified in
the Settlement Hierarchy Assessment, September 2017, forms the basis of the proposed distribution
between settlements.
The Settlement Hierarchy Assessment, September 2017 identifies that Bierton (which meets 6 criteria)
is more sustainable than Stewkley (5 criteria) and equally as sustainable as Cheddington, Great
Horwood, Maids Moreton, Marsh Gibbon, Newton Longville and Weston Turville, and yet each and every
one of these settlements are proposed to receive greater levels of growth.
Indeed, Table 2 indicates that 101 dwellings have already been permitted in the less sustainable
settlement of Stewkley which compares to the 23 permitted in Bierton. This provides a strong indication
that Bierton should receive (or at the very least be allowed to receive) a level of growth commensurate
with its sustainability, in excess of that which has already been proved to be sustainable at the less
sustainable settlement of Stewkley.
Similarly, in some of the equally sustainable settlements, namely Maids Moreton, Marsh Gibbon and
Newton Longville, the number of dwellings permitted is in excess of that at Bierton and yet additional
allocations are proposed in these settlements. Indeed, Maids Moreton is planned to receive 171
dwellings, Marsh Gibbon is planned to receive 47 and Newton Longville 48, as compared to the 23
dwellings at Bierton.
Policy S3 (Settlement hierarchy and cohesive development spatial strategy for growth)
If your representation is more than 100 words, please provide a brief summary here:
Pegasus therefore, in accordance with the representations submitted for the 'Draft Plan for Summer
2016 Consultation', continue to object to the "downgrading" of Bierton, which is clearly a sustainable
location and with the development to the south (i.e. Land East of Aylesbury - Kingsbrook) has outline
planning permission for 2,450 homes, 10 hectares of employment land and further development such
as two primary schools and community facilities, thereby providing a range of facilities and services
which will be even closer those provided by Aylesbury only 1.8 miles away.
Paragraph 4.152 identifies that no allocations are made at either Bierton or Weston Turville owing to
their proximity to Aylesbury Garden Town. This does not take account of the impacts of the proposed
allocations at Aylesbury Garden Town which include a highways access in Bierton. Bierton will be
directly affected by the highways impacts associated with large scale residential development, but will
not receive the benefits associated with modest housing provision. This cannot be considered to be
sustainable in terms of the three dimensions of sustainability (providing adverse social, economic and
environmental impacts from the nearby development without any beneficial impacts associated with
these).
As a result of this, the proposed distribution in the VALP does not reflect the sustainability of
settlements. Additional provisions, either in the form of allocations and/or mechanisms to allow
development beyond the settlement envelope should be embedded in the VALP.
It is therefore necessary to provide for development in Bierton commensurate with its size and scale.
On behalf of our client, Pegasus has promoted through the SHLAA and previous representations to the
emerging Local Plan, several sites at Bierton - refs: BIE004, BIE005, HUL004. A location plan is
attached which shows these sites in relation to Bierton. These sites are not subject to any statutory
environmental or landscape designations and nor are they located in any Local Landscape Area or
Area of Attractive Landscape
Policy S3 seeks to resist development that would compromise the open character of the countryside
between settlements. Whilst the objective of this Policy accords with the NPPF, the Policy is not
sufficiently precise. Any development beyond the current built form, including that on allocated sites
(either within the VALP or neighbourhood plans), or as exceptional development (see Policy D4 and
H2 for example) will to some extent compromise certain elements of the character of the countryside
between settlements. The blanket application of the Policy as worded would prevent any such
development and would thereby prevent the housing requirement (or any other development
requirements) being delivered.
Indeed, paragraph 109 of the NPPF requires that such protection is only afforded to valued landscapes.
As such, the Policy as worded, is not consistent with the NPPF, it is not justified and it will not be
effective as it could be used to undermine the required development.

Object

VALP Proposed Submission

S2 Spatial Strategy for Growth

Representation ID: 1934

Received: 14/12/2017

Respondent: Revera Limited

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

The policy provision is significantly below the minimum OAN and therefore additional mechanisms will
need to be identified to address the resultant shortfall.
Growth at medium villages is supported.

Full text:

Please see attachments

Paragraph 3.80 suggests that there is not a record of persistent under-delivery in Aylesbury Vale and that accordingly it is appropriate to apply a 5% buffer.
The Council assess the record of delivery against the objectively assessed need for Aylesbury Vale in isolation, which is the correct approach prior to the confirmation of the contribution to the unmet needs of neighbouring authorities through the VALP examination. Table 2 of the Five-Year Housing Land Supply Position Statement, August 2017 identifies that whilst there was under-delivery in the majority of years up until 2012/13, the recent record of delivery justifies the application of a 5% buffer.
However, upon adoption of the VALP (even assuming that the housing requirement remains as proposed) there will have been under-delivery in almost every year since 2013/14 with the needs across the HMA falling to Aylesbury Vale but not having been met. Accordingly, upon adoption there will be a necessity to apply a 20% buffer to afford the appropriate weight to housing proposals given the significant shortfall in provision across the HMA since 2013.
The effect of the application of the necessary 20% buffer on adoption would result in a five-year land supply shortfall of circa 600 dwellings. This will need to be addressed within the VALP through the identification of additional deliverable allocations.
Policy S9 (Monitoring and review)

Paragraph 1.7 of the Vale of Aylesbury Local Plan (VALP) suggests that Government policy is to deliver 250,000 homes per annum nationally. However, this figure is not identified in Government policy. The most recent evidence of the required number of homes was identified as at least 300,000 new homes per annum in the 'Building More Homes' report to the House of Lords Select Committee on Economic Affairs in July 2016. The Government have responded to this evidence (and older assessments including the Barker Report) and are currently consulting on a national distribution to deliver at least 266,000 new homes per annum nationally. The reference in paragraph 1.7 therefore not only conflicts with the available evidence, it also suggests that the VALP has been prepared with the objective of delivering a level of housing below that required nationally.

Paragraph 1.8 continues to identify a requirement of 19,400 new homes to respond to the needs of Aylesbury Vale (excluding any contributions to the unmet needs of neighbouring authorities). This figure is based upon the Buckinghamshire Housing and Economic Development Needs Assessment (HEDNA) Update Addendum, September 2017 which contains corrections to the Buckinghamshire HEDNA Update: Final Report, December 2016.
Paragraph 47 of the National Planning Policy Framework (NPPF) identifies that Local Planning Authorities (LPAs) should use their evidence base to ensure that their Local Plan meets the full, objectively assessed need (OAN) for the Housing Market Area (HMA) rather than an LPA boundary (unless they are coterminous). This has been underlined in several legal judgments1. This is necessary to ensure that account is taken of the inter-relationships between the various LPAs and a consistent approach is taken to these. However, the HEDNA assesses the OAN for each LPA in isolation, using different assumptions for each. The necessary result of this inconsistency means that the OAN has not been established for the HMA, contrary to the NPPF.
It is also important to note that the Department for Communities and Local Government (DCLG) has recently consulted on a standardised methodology for identifying the local housing need. This has arisen from the Local Plans Expert Group and the Housing White Paper, both of which were subject to consultation, as well as from professional input from a wide range of experts including the Planning Inspectorate and the Bar.

Paragraph 1.11 identifies that there is insufficient capacity to meet the OAN in the areas south of Aylesbury Vale. In the following paragraph 1.12, there is calculated to be an unmet need of 8,000 homes.
However, this is all predicated on the OAN identified in the HEDNA which adopts inconsistent and negative assumptions, contrary to the available evidence to reduce the OAN. The population is growing far faster than anticipated by the latest sub-national population projections, and yet even if the OAN was calculated on the basis of these population projections this would produce an unmet need of 8,965 homes (based on the OAN of 27,065 for the remainder of Buckinghamshire (= 51,051 - 23,986) and the capacity of 18,100 homes identified in the Memorandum of Understanding, July 2017).
Furthermore, the Luton Local Plan was adopted in November 2017 and this identifies that there is a need for 400 dwellings which relates to Aylesbury Vale, which is not being addressed elsewhere.
As a result, the VALP should make provision for at least 33,350 homes to address the rounded OAN (of 24,000), the rounded unmet need (of 8,950) and the unmet need of Luton (of 400). These figures will increase significantly, once the standardised methodology becomes part of national policy and so additional provision should be supported or planned for (including through the early review).
This compares to the identified housing requirement in paragraph 1.12 of 27,400 homes. It is therefore clear, that even if the VALP is submitted in advance of the revised NPPF, it will contain a housing requirement that is 5,950 homes short of meeting the OAN across the HMA (unless other sites can be identified across the remainder of Buckinghamshire to contribute to this unmet need). However, in paragraph 3.17 it is identified that it is expected that 28,830 homes will be delivered in the plan period, which reduces the shortfall to 4,334 homes.

Policy S2 makes provision for a total of 27,400 homes which is significantly below the minimum OAN of 33,350. Therefore additional mechanisms will need to be identified to address the resultant shortfall. This should include the identification of additional sites now as well as the identification of new settlements through the proposed early review.
Policy S2 identifies that the primary focus of strategic levels of growth will be at Aylesbury, Buckingham, Winslow, Wendover and Haddenham. It then continues to identify that growth adjacent to Milton Keynes will also be allocated. The Policy also identifies that development at medium villages, including Bierton, will be at a scale in keeping with the local character and setting.
Whilst this approach is supported, as set out in our representations to Policies S3 and D2, our client retains an objection to the "downgrading" of Bierton to a medium village which is clearly a sustainable location in close proximity to Aylesbury and to other new development, i.e. Land East of Aylesbury (Kingsbrook). Bierton should therefore be reclassified to a "larger village" as originally assessed. If the Council are minded to maintain the classification of Bierton as a medium village the characteristics and context of the settlement should be recognised with a more appropriate level of growth than that currently proposed in the VALP.

Table 2 identifies the proposed settlement hierarchy and housing development based on the proposals
of Policy S2.
Paragraph 3.20 identifies that the settlement hierarchy including the ranking of settlements identified in
the Settlement Hierarchy Assessment, September 2017, forms the basis of the proposed distribution
between settlements.
The Settlement Hierarchy Assessment, September 2017 identifies that Bierton (which meets 6 criteria)
is more sustainable than Stewkley (5 criteria) and equally as sustainable as Cheddington, Great
Horwood, Maids Moreton, Marsh Gibbon, Newton Longville and Weston Turville, and yet each and every
one of these settlements are proposed to receive greater levels of growth.
Indeed, Table 2 indicates that 101 dwellings have already been permitted in the less sustainable
settlement of Stewkley which compares to the 23 permitted in Bierton. This provides a strong indication
that Bierton should receive (or at the very least be allowed to receive) a level of growth commensurate
with its sustainability, in excess of that which has already been proved to be sustainable at the less
sustainable settlement of Stewkley.
Similarly, in some of the equally sustainable settlements, namely Maids Moreton, Marsh Gibbon and
Newton Longville, the number of dwellings permitted is in excess of that at Bierton and yet additional
allocations are proposed in these settlements. Indeed, Maids Moreton is planned to receive 171
dwellings, Marsh Gibbon is planned to receive 47 and Newton Longville 48, as compared to the 23
dwellings at Bierton.
Policy S3 (Settlement hierarchy and cohesive development spatial strategy for growth)
If your representation is more than 100 words, please provide a brief summary here:
Pegasus therefore, in accordance with the representations submitted for the 'Draft Plan for Summer
2016 Consultation', continue to object to the "downgrading" of Bierton, which is clearly a sustainable
location and with the development to the south (i.e. Land East of Aylesbury - Kingsbrook) has outline
planning permission for 2,450 homes, 10 hectares of employment land and further development such
as two primary schools and community facilities, thereby providing a range of facilities and services
which will be even closer those provided by Aylesbury only 1.8 miles away.
Paragraph 4.152 identifies that no allocations are made at either Bierton or Weston Turville owing to
their proximity to Aylesbury Garden Town. This does not take account of the impacts of the proposed
allocations at Aylesbury Garden Town which include a highways access in Bierton. Bierton will be
directly affected by the highways impacts associated with large scale residential development, but will
not receive the benefits associated with modest housing provision. This cannot be considered to be
sustainable in terms of the three dimensions of sustainability (providing adverse social, economic and
environmental impacts from the nearby development without any beneficial impacts associated with
these).
As a result of this, the proposed distribution in the VALP does not reflect the sustainability of
settlements. Additional provisions, either in the form of allocations and/or mechanisms to allow
development beyond the settlement envelope should be embedded in the VALP.
It is therefore necessary to provide for development in Bierton commensurate with its size and scale.
On behalf of our client, Pegasus has promoted through the SHLAA and previous representations to the
emerging Local Plan, several sites at Bierton - refs: BIE004, BIE005, HUL004. A location plan is
attached which shows these sites in relation to Bierton. These sites are not subject to any statutory
environmental or landscape designations and nor are they located in any Local Landscape Area or
Area of Attractive Landscape
Policy S3 seeks to resist development that would compromise the open character of the countryside
between settlements. Whilst the objective of this Policy accords with the NPPF, the Policy is not
sufficiently precise. Any development beyond the current built form, including that on allocated sites
(either within the VALP or neighbourhood plans), or as exceptional development (see Policy D4 and
H2 for example) will to some extent compromise certain elements of the character of the countryside
between settlements. The blanket application of the Policy as worded would prevent any such
development and would thereby prevent the housing requirement (or any other development
requirements) being delivered.
Indeed, paragraph 109 of the NPPF requires that such protection is only afforded to valued landscapes.
As such, the Policy as worded, is not consistent with the NPPF, it is not justified and it will not be
effective as it could be used to undermine the required development.

Object

VALP Proposed Submission

S3 Settlement hierarchy and cohesive development

Representation ID: 2696

Received: 14/12/2017

Respondent: Revera Limited

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

It is recognised that the strategic settlements in the settlement hierarchy offer the most sustainable opportunities to accommodate future development, however, the role of smaller settlements, such as Bierton, in close proximity to these growth centres must be recognised and emerging policies developed with sufficient flexibility so as to ensure those locations have the ability to respond positively, within the context of their locational specific circumstances, to opportunities for development.

Full text:

Please see attachments

Paragraph 3.80 suggests that there is not a record of persistent under-delivery in Aylesbury Vale and that accordingly it is appropriate to apply a 5% buffer.
The Council assess the record of delivery against the objectively assessed need for Aylesbury Vale in isolation, which is the correct approach prior to the confirmation of the contribution to the unmet needs of neighbouring authorities through the VALP examination. Table 2 of the Five-Year Housing Land Supply Position Statement, August 2017 identifies that whilst there was under-delivery in the majority of years up until 2012/13, the recent record of delivery justifies the application of a 5% buffer.
However, upon adoption of the VALP (even assuming that the housing requirement remains as proposed) there will have been under-delivery in almost every year since 2013/14 with the needs across the HMA falling to Aylesbury Vale but not having been met. Accordingly, upon adoption there will be a necessity to apply a 20% buffer to afford the appropriate weight to housing proposals given the significant shortfall in provision across the HMA since 2013.
The effect of the application of the necessary 20% buffer on adoption would result in a five-year land supply shortfall of circa 600 dwellings. This will need to be addressed within the VALP through the identification of additional deliverable allocations.
Policy S9 (Monitoring and review)

Paragraph 1.7 of the Vale of Aylesbury Local Plan (VALP) suggests that Government policy is to deliver 250,000 homes per annum nationally. However, this figure is not identified in Government policy. The most recent evidence of the required number of homes was identified as at least 300,000 new homes per annum in the 'Building More Homes' report to the House of Lords Select Committee on Economic Affairs in July 2016. The Government have responded to this evidence (and older assessments including the Barker Report) and are currently consulting on a national distribution to deliver at least 266,000 new homes per annum nationally. The reference in paragraph 1.7 therefore not only conflicts with the available evidence, it also suggests that the VALP has been prepared with the objective of delivering a level of housing below that required nationally.

Paragraph 1.8 continues to identify a requirement of 19,400 new homes to respond to the needs of Aylesbury Vale (excluding any contributions to the unmet needs of neighbouring authorities). This figure is based upon the Buckinghamshire Housing and Economic Development Needs Assessment (HEDNA) Update Addendum, September 2017 which contains corrections to the Buckinghamshire HEDNA Update: Final Report, December 2016.
Paragraph 47 of the National Planning Policy Framework (NPPF) identifies that Local Planning Authorities (LPAs) should use their evidence base to ensure that their Local Plan meets the full, objectively assessed need (OAN) for the Housing Market Area (HMA) rather than an LPA boundary (unless they are coterminous). This has been underlined in several legal judgments1. This is necessary to ensure that account is taken of the inter-relationships between the various LPAs and a consistent approach is taken to these. However, the HEDNA assesses the OAN for each LPA in isolation, using different assumptions for each. The necessary result of this inconsistency means that the OAN has not been established for the HMA, contrary to the NPPF.
It is also important to note that the Department for Communities and Local Government (DCLG) has recently consulted on a standardised methodology for identifying the local housing need. This has arisen from the Local Plans Expert Group and the Housing White Paper, both of which were subject to consultation, as well as from professional input from a wide range of experts including the Planning Inspectorate and the Bar.

Paragraph 1.11 identifies that there is insufficient capacity to meet the OAN in the areas south of Aylesbury Vale. In the following paragraph 1.12, there is calculated to be an unmet need of 8,000 homes.
However, this is all predicated on the OAN identified in the HEDNA which adopts inconsistent and negative assumptions, contrary to the available evidence to reduce the OAN. The population is growing far faster than anticipated by the latest sub-national population projections, and yet even if the OAN was calculated on the basis of these population projections this would produce an unmet need of 8,965 homes (based on the OAN of 27,065 for the remainder of Buckinghamshire (= 51,051 - 23,986) and the capacity of 18,100 homes identified in the Memorandum of Understanding, July 2017).
Furthermore, the Luton Local Plan was adopted in November 2017 and this identifies that there is a need for 400 dwellings which relates to Aylesbury Vale, which is not being addressed elsewhere.
As a result, the VALP should make provision for at least 33,350 homes to address the rounded OAN (of 24,000), the rounded unmet need (of 8,950) and the unmet need of Luton (of 400). These figures will increase significantly, once the standardised methodology becomes part of national policy and so additional provision should be supported or planned for (including through the early review).
This compares to the identified housing requirement in paragraph 1.12 of 27,400 homes. It is therefore clear, that even if the VALP is submitted in advance of the revised NPPF, it will contain a housing requirement that is 5,950 homes short of meeting the OAN across the HMA (unless other sites can be identified across the remainder of Buckinghamshire to contribute to this unmet need). However, in paragraph 3.17 it is identified that it is expected that 28,830 homes will be delivered in the plan period, which reduces the shortfall to 4,334 homes.

Policy S2 makes provision for a total of 27,400 homes which is significantly below the minimum OAN of 33,350. Therefore additional mechanisms will need to be identified to address the resultant shortfall. This should include the identification of additional sites now as well as the identification of new settlements through the proposed early review.
Policy S2 identifies that the primary focus of strategic levels of growth will be at Aylesbury, Buckingham, Winslow, Wendover and Haddenham. It then continues to identify that growth adjacent to Milton Keynes will also be allocated. The Policy also identifies that development at medium villages, including Bierton, will be at a scale in keeping with the local character and setting.
Whilst this approach is supported, as set out in our representations to Policies S3 and D2, our client retains an objection to the "downgrading" of Bierton to a medium village which is clearly a sustainable location in close proximity to Aylesbury and to other new development, i.e. Land East of Aylesbury (Kingsbrook). Bierton should therefore be reclassified to a "larger village" as originally assessed. If the Council are minded to maintain the classification of Bierton as a medium village the characteristics and context of the settlement should be recognised with a more appropriate level of growth than that currently proposed in the VALP.

Table 2 identifies the proposed settlement hierarchy and housing development based on the proposals
of Policy S2.
Paragraph 3.20 identifies that the settlement hierarchy including the ranking of settlements identified in
the Settlement Hierarchy Assessment, September 2017, forms the basis of the proposed distribution
between settlements.
The Settlement Hierarchy Assessment, September 2017 identifies that Bierton (which meets 6 criteria)
is more sustainable than Stewkley (5 criteria) and equally as sustainable as Cheddington, Great
Horwood, Maids Moreton, Marsh Gibbon, Newton Longville and Weston Turville, and yet each and every
one of these settlements are proposed to receive greater levels of growth.
Indeed, Table 2 indicates that 101 dwellings have already been permitted in the less sustainable
settlement of Stewkley which compares to the 23 permitted in Bierton. This provides a strong indication
that Bierton should receive (or at the very least be allowed to receive) a level of growth commensurate
with its sustainability, in excess of that which has already been proved to be sustainable at the less
sustainable settlement of Stewkley.
Similarly, in some of the equally sustainable settlements, namely Maids Moreton, Marsh Gibbon and
Newton Longville, the number of dwellings permitted is in excess of that at Bierton and yet additional
allocations are proposed in these settlements. Indeed, Maids Moreton is planned to receive 171
dwellings, Marsh Gibbon is planned to receive 47 and Newton Longville 48, as compared to the 23
dwellings at Bierton.
Policy S3 (Settlement hierarchy and cohesive development spatial strategy for growth)
If your representation is more than 100 words, please provide a brief summary here:
Pegasus therefore, in accordance with the representations submitted for the 'Draft Plan for Summer
2016 Consultation', continue to object to the "downgrading" of Bierton, which is clearly a sustainable
location and with the development to the south (i.e. Land East of Aylesbury - Kingsbrook) has outline
planning permission for 2,450 homes, 10 hectares of employment land and further development such
as two primary schools and community facilities, thereby providing a range of facilities and services
which will be even closer those provided by Aylesbury only 1.8 miles away.
Paragraph 4.152 identifies that no allocations are made at either Bierton or Weston Turville owing to
their proximity to Aylesbury Garden Town. This does not take account of the impacts of the proposed
allocations at Aylesbury Garden Town which include a highways access in Bierton. Bierton will be
directly affected by the highways impacts associated with large scale residential development, but will
not receive the benefits associated with modest housing provision. This cannot be considered to be
sustainable in terms of the three dimensions of sustainability (providing adverse social, economic and
environmental impacts from the nearby development without any beneficial impacts associated with
these).
As a result of this, the proposed distribution in the VALP does not reflect the sustainability of
settlements. Additional provisions, either in the form of allocations and/or mechanisms to allow
development beyond the settlement envelope should be embedded in the VALP.
It is therefore necessary to provide for development in Bierton commensurate with its size and scale.
On behalf of our client, Pegasus has promoted through the SHLAA and previous representations to the
emerging Local Plan, several sites at Bierton - refs: BIE004, BIE005, HUL004. A location plan is
attached which shows these sites in relation to Bierton. These sites are not subject to any statutory
environmental or landscape designations and nor are they located in any Local Landscape Area or
Area of Attractive Landscape
Policy S3 seeks to resist development that would compromise the open character of the countryside
between settlements. Whilst the objective of this Policy accords with the NPPF, the Policy is not
sufficiently precise. Any development beyond the current built form, including that on allocated sites
(either within the VALP or neighbourhood plans), or as exceptional development (see Policy D4 and
H2 for example) will to some extent compromise certain elements of the character of the countryside
between settlements. The blanket application of the Policy as worded would prevent any such
development and would thereby prevent the housing requirement (or any other development
requirements) being delivered.
Indeed, paragraph 109 of the NPPF requires that such protection is only afforded to valued landscapes.
As such, the Policy as worded, is not consistent with the NPPF, it is not justified and it will not be
effective as it could be used to undermine the required development.

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