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Object

VALP Proposed Submission

H1 Affordable housing

Representation ID: 1057

Received: 21/12/2017

Respondent: Dandara Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Object to H1: supports objective of policy. Clustering of maximum figure of affordable housing should be applied flexibly having regard to communities created following development.

Full text:

Dear Sir / Madam,

Town and Country Planning Act 1990
Representations to Proposed Submission VALP

Dandara Ltd for Land North of Aston Road and West of Stanbridge Road, Haddenham
Dandara Ltd purchased land located to the north of Aston Road and west of Stanbridge Road in Haddenham which benefits from outline planning permission for the following description of development:

"Construction of 280 no. dwellings, including 35 no. age - restricted dwellings, with associated garages, parking, estate roads, footways, pedestrian linkages, public open space, burial ground, community sports facility, strategic landscaping, drainage and other associated works" (ref. 14/02666/AOP).

Reserved Matter applications have been submitted to the Council under refs. 17/01841/ADP and 17/04543/ADP for four phases of development, with phases 1 and 2 due to commence on site in January 2018. These representations therefore focus on policies which would potentially impact upon the deliverability and viability of the development.

We would comment on the following policies contained within the November 2017 Proposed Submission draft Vale of Aylesbury Local Plan (VALP) 2013-33:

Dandara Ltd supports the objective of Policy H1 'Affordable Housing' seeking to secure a minimum of 25% affordable housing associated with qualifying developments. Whilst we also support the objective of "the affordable homes will be expected to be integrated throughout the development site", this should be applied flexibly taking into account the objective of creating mixed communities and the realities and costs associated with future management by registered providers. Our experience of the application of this policy is that the Council apply their 'clustering' policy of no more than 15 affordable housing units rigidly, without considering how neighbourhoods or communities would develop following scheme completion. As an example, affordable housing units that have a garden-to-garden relationship but do not share a common street or approach should not automatically be considered as representing a 'cluster' as the creation of mixed-tenure neighbourhoods are principally defined by the streets on which the houses are located, the source of daily interaction with neighbours, rather than who one shares a rear garden boundary with. The supporting text to the policy should recognise that any 'clustering' figure will be applied flexibly having regard to those communities created following development and the principal day-to-day interactions that will result;

Policy H5 'Self/Custom Build Housing' will expect developments proposing 100 dwellings and above to provide a percentage of serviced plots for sale to self / custom builders. Whilst the principle of supporting the self / custom build industry is supported, any policy requirement should be informed by entries contained within the self-build and custom housebuilding register alongside a consideration of deliverability and viability. If the Council is to require major developments to include such plots, it is imperative that they can be brought forward in parallel with the main development; do not conflict with the wider development in respect of scale, appearance or timescales; and are taken into account from a viability perspective given that such plots would be provided at below market value;

Dandara Ltd is supportive of the wording associated with Policy H6 whereby housing mix contained within the most up-to-date HEDNA "... are however a guide rather than a requirement as they may need to be varied on the basis of specific circumstances or evidence" (para. 5.55). The Council should apply flexibility when considering housing mix on individual sites including site specific considerations such as location, viability and market demand and whether the delivery of a higher proportion of smaller dwellings within urban areas may allow for more family sized housing to be delivered on Greenfield sites on the edge of urban areas and villages whilst maintaining close to the recommended HEDNA mix across the District as a whole;

Policy H6 'Housing Mix' requires "larger residential development schemes proposing 100 dwellings and above in strategic settlements will be expected to provide an element of self-contained extra care dwellings as part of the overall mix". The Council should ensure that the provision of extra care dwellings is fully taken into account within viability assessments associated with individual sites especially considering other cumulative 'planning gain' requirements such as affordable housing and self / custom build. It is noted that 'larger residential development schemes' in the policy refers to more than 300 houses which is a definition that should be retained within supporting para. 5.61;

Likewise, Policy H6 'Housing Mix' requires a proportion of new homes in developments to achieve Category 2 and Category 3 of Approved Document M: Volume 1 (Accessible and Adaptable Dwellings). Whilst such an objective is supported, the Council should again consider any viability implications of such standards especially taking into account the suite of 'planning gain' requirements including affordable housing, self / custom build and extra care provision. The supporting policy and evidence base should be in full accordance with Planning Practice Guidance (PPG) para: 008, ref ID: 56-008-20160519;

Policy H7 'Dwelling Sizes' is unevidenced and in conflict with national policy. If the Council is proposing a policy relating to 'dwelling sizes', any standard should accord with the 'Technical Housing Standards - Nationally Described Space Standard' (March 2015). PPG is clear that "where a Local Planning Authority (or qualifying body) wishes to require an internal space standard, they should only do so by reference in their Local Plan to the nationally described space standard" (para: 018, ref ID: 56-018-20150327). Policy H7 should therefore be deleted or amended to refer to nationally described space standards;

Dandara Ltd supports the principle of Policy BE2 'Design of New Development' requiring consideration of "the local distinctiveness and vernacular character of the locality". When considering local distinctiveness and vernacular character the supporting text should make clear that this includes all surrounding development not simply those elements of the townscape that the Council consider to be 'higher quality'. Our experience with the Authority is that they adopt a very narrow definition of local distinctiveness and vernacular character which often does not consider the broad range of building styles, materials and ages but rather focuses on those elements, most notably Conservation Areas or listed buildings, that the Council consider should be given elevated weight rather than considered as part of a balanced assessment of the collective character of the locality.

In summary, we consider that the Proposed Submission VALP is currently unsound as not being 'effective' due to the potential viability implications of individual policies - affordable housing, self / custom build, accessibility standards, extra care - not being considered cumulatively. In addition, we consider that Policy H7 is not 'consistent with national policy' by suggesting the application of an internal space standard not in accordance with the nationally described version.

I trust these representations are of interest and if you need any additional information or clarification on the points contained herein, please do not hesitate to contact me.

Yours faithfully,

John Richards,
Associate Director, Planning

Object

VALP Proposed Submission

H5 Self/custom build housing

Representation ID: 1330

Received: 21/12/2017

Respondent: Dandara Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Object to H5: policy requirement should be informed by entries in the self-build and custom housebuilding register and consider deliverability and viability. Self/ custom build plots in major developments should be brought forward in parallel with main development; should not conflict with scale, appearance or timescales; and should be taken into account from a viability perspective given that such plots would be provided at below market value.

Full text:

Dear Sir / Madam,

Town and Country Planning Act 1990
Representations to Proposed Submission VALP

Dandara Ltd for Land North of Aston Road and West of Stanbridge Road, Haddenham
Dandara Ltd purchased land located to the north of Aston Road and west of Stanbridge Road in Haddenham which benefits from outline planning permission for the following description of development:

"Construction of 280 no. dwellings, including 35 no. age - restricted dwellings, with associated garages, parking, estate roads, footways, pedestrian linkages, public open space, burial ground, community sports facility, strategic landscaping, drainage and other associated works" (ref. 14/02666/AOP).

Reserved Matter applications have been submitted to the Council under refs. 17/01841/ADP and 17/04543/ADP for four phases of development, with phases 1 and 2 due to commence on site in January 2018. These representations therefore focus on policies which would potentially impact upon the deliverability and viability of the development.

We would comment on the following policies contained within the November 2017 Proposed Submission draft Vale of Aylesbury Local Plan (VALP) 2013-33:

Dandara Ltd supports the objective of Policy H1 'Affordable Housing' seeking to secure a minimum of 25% affordable housing associated with qualifying developments. Whilst we also support the objective of "the affordable homes will be expected to be integrated throughout the development site", this should be applied flexibly taking into account the objective of creating mixed communities and the realities and costs associated with future management by registered providers. Our experience of the application of this policy is that the Council apply their 'clustering' policy of no more than 15 affordable housing units rigidly, without considering how neighbourhoods or communities would develop following scheme completion. As an example, affordable housing units that have a garden-to-garden relationship but do not share a common street or approach should not automatically be considered as representing a 'cluster' as the creation of mixed-tenure neighbourhoods are principally defined by the streets on which the houses are located, the source of daily interaction with neighbours, rather than who one shares a rear garden boundary with. The supporting text to the policy should recognise that any 'clustering' figure will be applied flexibly having regard to those communities created following development and the principal day-to-day interactions that will result;

Policy H5 'Self/Custom Build Housing' will expect developments proposing 100 dwellings and above to provide a percentage of serviced plots for sale to self / custom builders. Whilst the principle of supporting the self / custom build industry is supported, any policy requirement should be informed by entries contained within the self-build and custom housebuilding register alongside a consideration of deliverability and viability. If the Council is to require major developments to include such plots, it is imperative that they can be brought forward in parallel with the main development; do not conflict with the wider development in respect of scale, appearance or timescales; and are taken into account from a viability perspective given that such plots would be provided at below market value;

Dandara Ltd is supportive of the wording associated with Policy H6 whereby housing mix contained within the most up-to-date HEDNA "... are however a guide rather than a requirement as they may need to be varied on the basis of specific circumstances or evidence" (para. 5.55). The Council should apply flexibility when considering housing mix on individual sites including site specific considerations such as location, viability and market demand and whether the delivery of a higher proportion of smaller dwellings within urban areas may allow for more family sized housing to be delivered on Greenfield sites on the edge of urban areas and villages whilst maintaining close to the recommended HEDNA mix across the District as a whole;

Policy H6 'Housing Mix' requires "larger residential development schemes proposing 100 dwellings and above in strategic settlements will be expected to provide an element of self-contained extra care dwellings as part of the overall mix". The Council should ensure that the provision of extra care dwellings is fully taken into account within viability assessments associated with individual sites especially considering other cumulative 'planning gain' requirements such as affordable housing and self / custom build. It is noted that 'larger residential development schemes' in the policy refers to more than 300 houses which is a definition that should be retained within supporting para. 5.61;

Likewise, Policy H6 'Housing Mix' requires a proportion of new homes in developments to achieve Category 2 and Category 3 of Approved Document M: Volume 1 (Accessible and Adaptable Dwellings). Whilst such an objective is supported, the Council should again consider any viability implications of such standards especially taking into account the suite of 'planning gain' requirements including affordable housing, self / custom build and extra care provision. The supporting policy and evidence base should be in full accordance with Planning Practice Guidance (PPG) para: 008, ref ID: 56-008-20160519;

Policy H7 'Dwelling Sizes' is unevidenced and in conflict with national policy. If the Council is proposing a policy relating to 'dwelling sizes', any standard should accord with the 'Technical Housing Standards - Nationally Described Space Standard' (March 2015). PPG is clear that "where a Local Planning Authority (or qualifying body) wishes to require an internal space standard, they should only do so by reference in their Local Plan to the nationally described space standard" (para: 018, ref ID: 56-018-20150327). Policy H7 should therefore be deleted or amended to refer to nationally described space standards;

Dandara Ltd supports the principle of Policy BE2 'Design of New Development' requiring consideration of "the local distinctiveness and vernacular character of the locality". When considering local distinctiveness and vernacular character the supporting text should make clear that this includes all surrounding development not simply those elements of the townscape that the Council consider to be 'higher quality'. Our experience with the Authority is that they adopt a very narrow definition of local distinctiveness and vernacular character which often does not consider the broad range of building styles, materials and ages but rather focuses on those elements, most notably Conservation Areas or listed buildings, that the Council consider should be given elevated weight rather than considered as part of a balanced assessment of the collective character of the locality.

In summary, we consider that the Proposed Submission VALP is currently unsound as not being 'effective' due to the potential viability implications of individual policies - affordable housing, self / custom build, accessibility standards, extra care - not being considered cumulatively. In addition, we consider that Policy H7 is not 'consistent with national policy' by suggesting the application of an internal space standard not in accordance with the nationally described version.

I trust these representations are of interest and if you need any additional information or clarification on the points contained herein, please do not hesitate to contact me.

Yours faithfully,

John Richards,
Associate Director, Planning

Object

VALP Proposed Submission

H6 Housing Mix

Representation ID: 1331

Received: 21/12/2017

Respondent: Dandara Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

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

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

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

Full text:

Dear Sir / Madam,

Town and Country Planning Act 1990
Representations to Proposed Submission VALP

Dandara Ltd for Land North of Aston Road and West of Stanbridge Road, Haddenham
Dandara Ltd purchased land located to the north of Aston Road and west of Stanbridge Road in Haddenham which benefits from outline planning permission for the following description of development:

"Construction of 280 no. dwellings, including 35 no. age - restricted dwellings, with associated garages, parking, estate roads, footways, pedestrian linkages, public open space, burial ground, community sports facility, strategic landscaping, drainage and other associated works" (ref. 14/02666/AOP).

Reserved Matter applications have been submitted to the Council under refs. 17/01841/ADP and 17/04543/ADP for four phases of development, with phases 1 and 2 due to commence on site in January 2018. These representations therefore focus on policies which would potentially impact upon the deliverability and viability of the development.

We would comment on the following policies contained within the November 2017 Proposed Submission draft Vale of Aylesbury Local Plan (VALP) 2013-33:

Dandara Ltd supports the objective of Policy H1 'Affordable Housing' seeking to secure a minimum of 25% affordable housing associated with qualifying developments. Whilst we also support the objective of "the affordable homes will be expected to be integrated throughout the development site", this should be applied flexibly taking into account the objective of creating mixed communities and the realities and costs associated with future management by registered providers. Our experience of the application of this policy is that the Council apply their 'clustering' policy of no more than 15 affordable housing units rigidly, without considering how neighbourhoods or communities would develop following scheme completion. As an example, affordable housing units that have a garden-to-garden relationship but do not share a common street or approach should not automatically be considered as representing a 'cluster' as the creation of mixed-tenure neighbourhoods are principally defined by the streets on which the houses are located, the source of daily interaction with neighbours, rather than who one shares a rear garden boundary with. The supporting text to the policy should recognise that any 'clustering' figure will be applied flexibly having regard to those communities created following development and the principal day-to-day interactions that will result;

Policy H5 'Self/Custom Build Housing' will expect developments proposing 100 dwellings and above to provide a percentage of serviced plots for sale to self / custom builders. Whilst the principle of supporting the self / custom build industry is supported, any policy requirement should be informed by entries contained within the self-build and custom housebuilding register alongside a consideration of deliverability and viability. If the Council is to require major developments to include such plots, it is imperative that they can be brought forward in parallel with the main development; do not conflict with the wider development in respect of scale, appearance or timescales; and are taken into account from a viability perspective given that such plots would be provided at below market value;

Dandara Ltd is supportive of the wording associated with Policy H6 whereby housing mix contained within the most up-to-date HEDNA "... are however a guide rather than a requirement as they may need to be varied on the basis of specific circumstances or evidence" (para. 5.55). The Council should apply flexibility when considering housing mix on individual sites including site specific considerations such as location, viability and market demand and whether the delivery of a higher proportion of smaller dwellings within urban areas may allow for more family sized housing to be delivered on Greenfield sites on the edge of urban areas and villages whilst maintaining close to the recommended HEDNA mix across the District as a whole;

Policy H6 'Housing Mix' requires "larger residential development schemes proposing 100 dwellings and above in strategic settlements will be expected to provide an element of self-contained extra care dwellings as part of the overall mix". The Council should ensure that the provision of extra care dwellings is fully taken into account within viability assessments associated with individual sites especially considering other cumulative 'planning gain' requirements such as affordable housing and self / custom build. It is noted that 'larger residential development schemes' in the policy refers to more than 300 houses which is a definition that should be retained within supporting para. 5.61;

Likewise, Policy H6 'Housing Mix' requires a proportion of new homes in developments to achieve Category 2 and Category 3 of Approved Document M: Volume 1 (Accessible and Adaptable Dwellings). Whilst such an objective is supported, the Council should again consider any viability implications of such standards especially taking into account the suite of 'planning gain' requirements including affordable housing, self / custom build and extra care provision. The supporting policy and evidence base should be in full accordance with Planning Practice Guidance (PPG) para: 008, ref ID: 56-008-20160519;

Policy H7 'Dwelling Sizes' is unevidenced and in conflict with national policy. If the Council is proposing a policy relating to 'dwelling sizes', any standard should accord with the 'Technical Housing Standards - Nationally Described Space Standard' (March 2015). PPG is clear that "where a Local Planning Authority (or qualifying body) wishes to require an internal space standard, they should only do so by reference in their Local Plan to the nationally described space standard" (para: 018, ref ID: 56-018-20150327). Policy H7 should therefore be deleted or amended to refer to nationally described space standards;

Dandara Ltd supports the principle of Policy BE2 'Design of New Development' requiring consideration of "the local distinctiveness and vernacular character of the locality". When considering local distinctiveness and vernacular character the supporting text should make clear that this includes all surrounding development not simply those elements of the townscape that the Council consider to be 'higher quality'. Our experience with the Authority is that they adopt a very narrow definition of local distinctiveness and vernacular character which often does not consider the broad range of building styles, materials and ages but rather focuses on those elements, most notably Conservation Areas or listed buildings, that the Council consider should be given elevated weight rather than considered as part of a balanced assessment of the collective character of the locality.

In summary, we consider that the Proposed Submission VALP is currently unsound as not being 'effective' due to the potential viability implications of individual policies - affordable housing, self / custom build, accessibility standards, extra care - not being considered cumulatively. In addition, we consider that Policy H7 is not 'consistent with national policy' by suggesting the application of an internal space standard not in accordance with the nationally described version.

I trust these representations are of interest and if you need any additional information or clarification on the points contained herein, please do not hesitate to contact me.

Yours faithfully,

John Richards,
Associate Director, Planning

Object

VALP Proposed Submission

H7 Dwelling sizes

Representation ID: 1332

Received: 21/12/2017

Respondent: Dandara Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Object, H7: unevidenced and in conflict with national policy. If the Council is proposing a policy relating to 'dwelling sizes', any standard should accord with the 'Technical Housing Standards - Nationally Described Space Standard' (March 2015). PPG is clear that "where a Local Planning Authority (or qualifying body) wishes to require an internal space standard, they should only do so by reference in their Local Plan to the nationally described space standard" (para: 018, ref ID: 56-018-20150327). Policy H7 should therefore be deleted or amended to refer to nationally described space standards.

Full text:

Dear Sir / Madam,

Town and Country Planning Act 1990
Representations to Proposed Submission VALP

Dandara Ltd for Land North of Aston Road and West of Stanbridge Road, Haddenham
Dandara Ltd purchased land located to the north of Aston Road and west of Stanbridge Road in Haddenham which benefits from outline planning permission for the following description of development:

"Construction of 280 no. dwellings, including 35 no. age - restricted dwellings, with associated garages, parking, estate roads, footways, pedestrian linkages, public open space, burial ground, community sports facility, strategic landscaping, drainage and other associated works" (ref. 14/02666/AOP).

Reserved Matter applications have been submitted to the Council under refs. 17/01841/ADP and 17/04543/ADP for four phases of development, with phases 1 and 2 due to commence on site in January 2018. These representations therefore focus on policies which would potentially impact upon the deliverability and viability of the development.

We would comment on the following policies contained within the November 2017 Proposed Submission draft Vale of Aylesbury Local Plan (VALP) 2013-33:

Dandara Ltd supports the objective of Policy H1 'Affordable Housing' seeking to secure a minimum of 25% affordable housing associated with qualifying developments. Whilst we also support the objective of "the affordable homes will be expected to be integrated throughout the development site", this should be applied flexibly taking into account the objective of creating mixed communities and the realities and costs associated with future management by registered providers. Our experience of the application of this policy is that the Council apply their 'clustering' policy of no more than 15 affordable housing units rigidly, without considering how neighbourhoods or communities would develop following scheme completion. As an example, affordable housing units that have a garden-to-garden relationship but do not share a common street or approach should not automatically be considered as representing a 'cluster' as the creation of mixed-tenure neighbourhoods are principally defined by the streets on which the houses are located, the source of daily interaction with neighbours, rather than who one shares a rear garden boundary with. The supporting text to the policy should recognise that any 'clustering' figure will be applied flexibly having regard to those communities created following development and the principal day-to-day interactions that will result;

Policy H5 'Self/Custom Build Housing' will expect developments proposing 100 dwellings and above to provide a percentage of serviced plots for sale to self / custom builders. Whilst the principle of supporting the self / custom build industry is supported, any policy requirement should be informed by entries contained within the self-build and custom housebuilding register alongside a consideration of deliverability and viability. If the Council is to require major developments to include such plots, it is imperative that they can be brought forward in parallel with the main development; do not conflict with the wider development in respect of scale, appearance or timescales; and are taken into account from a viability perspective given that such plots would be provided at below market value;

Dandara Ltd is supportive of the wording associated with Policy H6 whereby housing mix contained within the most up-to-date HEDNA "... are however a guide rather than a requirement as they may need to be varied on the basis of specific circumstances or evidence" (para. 5.55). The Council should apply flexibility when considering housing mix on individual sites including site specific considerations such as location, viability and market demand and whether the delivery of a higher proportion of smaller dwellings within urban areas may allow for more family sized housing to be delivered on Greenfield sites on the edge of urban areas and villages whilst maintaining close to the recommended HEDNA mix across the District as a whole;

Policy H6 'Housing Mix' requires "larger residential development schemes proposing 100 dwellings and above in strategic settlements will be expected to provide an element of self-contained extra care dwellings as part of the overall mix". The Council should ensure that the provision of extra care dwellings is fully taken into account within viability assessments associated with individual sites especially considering other cumulative 'planning gain' requirements such as affordable housing and self / custom build. It is noted that 'larger residential development schemes' in the policy refers to more than 300 houses which is a definition that should be retained within supporting para. 5.61;

Likewise, Policy H6 'Housing Mix' requires a proportion of new homes in developments to achieve Category 2 and Category 3 of Approved Document M: Volume 1 (Accessible and Adaptable Dwellings). Whilst such an objective is supported, the Council should again consider any viability implications of such standards especially taking into account the suite of 'planning gain' requirements including affordable housing, self / custom build and extra care provision. The supporting policy and evidence base should be in full accordance with Planning Practice Guidance (PPG) para: 008, ref ID: 56-008-20160519;

Policy H7 'Dwelling Sizes' is unevidenced and in conflict with national policy. If the Council is proposing a policy relating to 'dwelling sizes', any standard should accord with the 'Technical Housing Standards - Nationally Described Space Standard' (March 2015). PPG is clear that "where a Local Planning Authority (or qualifying body) wishes to require an internal space standard, they should only do so by reference in their Local Plan to the nationally described space standard" (para: 018, ref ID: 56-018-20150327). Policy H7 should therefore be deleted or amended to refer to nationally described space standards;

Dandara Ltd supports the principle of Policy BE2 'Design of New Development' requiring consideration of "the local distinctiveness and vernacular character of the locality". When considering local distinctiveness and vernacular character the supporting text should make clear that this includes all surrounding development not simply those elements of the townscape that the Council consider to be 'higher quality'. Our experience with the Authority is that they adopt a very narrow definition of local distinctiveness and vernacular character which often does not consider the broad range of building styles, materials and ages but rather focuses on those elements, most notably Conservation Areas or listed buildings, that the Council consider should be given elevated weight rather than considered as part of a balanced assessment of the collective character of the locality.

In summary, we consider that the Proposed Submission VALP is currently unsound as not being 'effective' due to the potential viability implications of individual policies - affordable housing, self / custom build, accessibility standards, extra care - not being considered cumulatively. In addition, we consider that Policy H7 is not 'consistent with national policy' by suggesting the application of an internal space standard not in accordance with the nationally described version.

I trust these representations are of interest and if you need any additional information or clarification on the points contained herein, please do not hesitate to contact me.

Yours faithfully,

John Richards,
Associate Director, Planning

Object

VALP Proposed Submission

BE2 Design of new development

Representation ID: 1333

Received: 21/12/2017

Respondent: Dandara Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Object, BE2: supports principle of policy requiring consideration of local distinctiveness and vernacular character of locality. Should clarify this includes surrounding development, not just elements considered by Council as 'higher quality'. Experience with Authority is that they adopt a narrow definition of local distinctiveness. Doesn't consider range of building styles, materials and ages. Focuses on elements Council considers should be given higher weight, notably Conservation Areas or listed buildings.

Full text:

Dear Sir / Madam,

Town and Country Planning Act 1990
Representations to Proposed Submission VALP

Dandara Ltd for Land North of Aston Road and West of Stanbridge Road, Haddenham
Dandara Ltd purchased land located to the north of Aston Road and west of Stanbridge Road in Haddenham which benefits from outline planning permission for the following description of development:

"Construction of 280 no. dwellings, including 35 no. age - restricted dwellings, with associated garages, parking, estate roads, footways, pedestrian linkages, public open space, burial ground, community sports facility, strategic landscaping, drainage and other associated works" (ref. 14/02666/AOP).

Reserved Matter applications have been submitted to the Council under refs. 17/01841/ADP and 17/04543/ADP for four phases of development, with phases 1 and 2 due to commence on site in January 2018. These representations therefore focus on policies which would potentially impact upon the deliverability and viability of the development.

We would comment on the following policies contained within the November 2017 Proposed Submission draft Vale of Aylesbury Local Plan (VALP) 2013-33:

Dandara Ltd supports the objective of Policy H1 'Affordable Housing' seeking to secure a minimum of 25% affordable housing associated with qualifying developments. Whilst we also support the objective of "the affordable homes will be expected to be integrated throughout the development site", this should be applied flexibly taking into account the objective of creating mixed communities and the realities and costs associated with future management by registered providers. Our experience of the application of this policy is that the Council apply their 'clustering' policy of no more than 15 affordable housing units rigidly, without considering how neighbourhoods or communities would develop following scheme completion. As an example, affordable housing units that have a garden-to-garden relationship but do not share a common street or approach should not automatically be considered as representing a 'cluster' as the creation of mixed-tenure neighbourhoods are principally defined by the streets on which the houses are located, the source of daily interaction with neighbours, rather than who one shares a rear garden boundary with. The supporting text to the policy should recognise that any 'clustering' figure will be applied flexibly having regard to those communities created following development and the principal day-to-day interactions that will result;

Policy H5 'Self/Custom Build Housing' will expect developments proposing 100 dwellings and above to provide a percentage of serviced plots for sale to self / custom builders. Whilst the principle of supporting the self / custom build industry is supported, any policy requirement should be informed by entries contained within the self-build and custom housebuilding register alongside a consideration of deliverability and viability. If the Council is to require major developments to include such plots, it is imperative that they can be brought forward in parallel with the main development; do not conflict with the wider development in respect of scale, appearance or timescales; and are taken into account from a viability perspective given that such plots would be provided at below market value;

Dandara Ltd is supportive of the wording associated with Policy H6 whereby housing mix contained within the most up-to-date HEDNA "... are however a guide rather than a requirement as they may need to be varied on the basis of specific circumstances or evidence" (para. 5.55). The Council should apply flexibility when considering housing mix on individual sites including site specific considerations such as location, viability and market demand and whether the delivery of a higher proportion of smaller dwellings within urban areas may allow for more family sized housing to be delivered on Greenfield sites on the edge of urban areas and villages whilst maintaining close to the recommended HEDNA mix across the District as a whole;

Policy H6 'Housing Mix' requires "larger residential development schemes proposing 100 dwellings and above in strategic settlements will be expected to provide an element of self-contained extra care dwellings as part of the overall mix". The Council should ensure that the provision of extra care dwellings is fully taken into account within viability assessments associated with individual sites especially considering other cumulative 'planning gain' requirements such as affordable housing and self / custom build. It is noted that 'larger residential development schemes' in the policy refers to more than 300 houses which is a definition that should be retained within supporting para. 5.61;

Likewise, Policy H6 'Housing Mix' requires a proportion of new homes in developments to achieve Category 2 and Category 3 of Approved Document M: Volume 1 (Accessible and Adaptable Dwellings). Whilst such an objective is supported, the Council should again consider any viability implications of such standards especially taking into account the suite of 'planning gain' requirements including affordable housing, self / custom build and extra care provision. The supporting policy and evidence base should be in full accordance with Planning Practice Guidance (PPG) para: 008, ref ID: 56-008-20160519;

Policy H7 'Dwelling Sizes' is unevidenced and in conflict with national policy. If the Council is proposing a policy relating to 'dwelling sizes', any standard should accord with the 'Technical Housing Standards - Nationally Described Space Standard' (March 2015). PPG is clear that "where a Local Planning Authority (or qualifying body) wishes to require an internal space standard, they should only do so by reference in their Local Plan to the nationally described space standard" (para: 018, ref ID: 56-018-20150327). Policy H7 should therefore be deleted or amended to refer to nationally described space standards;

Dandara Ltd supports the principle of Policy BE2 'Design of New Development' requiring consideration of "the local distinctiveness and vernacular character of the locality". When considering local distinctiveness and vernacular character the supporting text should make clear that this includes all surrounding development not simply those elements of the townscape that the Council consider to be 'higher quality'. Our experience with the Authority is that they adopt a very narrow definition of local distinctiveness and vernacular character which often does not consider the broad range of building styles, materials and ages but rather focuses on those elements, most notably Conservation Areas or listed buildings, that the Council consider should be given elevated weight rather than considered as part of a balanced assessment of the collective character of the locality.

In summary, we consider that the Proposed Submission VALP is currently unsound as not being 'effective' due to the potential viability implications of individual policies - affordable housing, self / custom build, accessibility standards, extra care - not being considered cumulatively. In addition, we consider that Policy H7 is not 'consistent with national policy' by suggesting the application of an internal space standard not in accordance with the nationally described version.

I trust these representations are of interest and if you need any additional information or clarification on the points contained herein, please do not hesitate to contact me.

Yours faithfully,

John Richards,
Associate Director, Planning

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