Aylesbury Vale Area

VALP Proposed Submission

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Object

VALP Proposed Submission

1.12

Representation ID: 674

Received: 12/12/2017

Respondent: Wycombe District Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

We note there is an error within the VALP which
identifies 2,250 dwellings for Wycombe's unmet housing need. We ask that this is corrected
to be that set out in the July 2017 Memorandum of Understanding for 2,275 dwellings.

Full text:

HOUSING: This Memorandum of Understanding identifies that AVDC falls within the same Housing Market Area as Wycombe District Council as part of a Buckinghamshire Housing Market Area. Based on the December 2016 HEDNA Update and Bucks HEDNA Addendum September 2017 the Objectively Assessed Need for the Bucks Housing Market Area is 45,500 dwellings, of which 19,400 is for Aylesbury Vale and 13,200 is for Wycombe District. Through capacity work we have identified an unmet housing need of 2,275 dwellings that cannot be accommodated within the district due to the land supply constraints that exist. The Memorandum of Understanding agrees that this unmet housing need will be accommodated in Aylesbury Vale. We note there is an error within the VALP which identifies 2,250 dwellings for Wycombe's unmet housing need. We ask that this is corrected to be that set out in the July 2017 Memorandum of Understanding for 2,275 dwellings. We welcome the flexibility built into the VALP housing supply with a 5.2% buffer.

AFFORDABLE HOUSING: The Memorandum of Understanding identifies that affordable housing policies in VALP will secure a proportion of affordable housing as part of delivering unmet housing needs from other plan areas within the Bucks HMA (including Wycombe District). Policy H1 of the VALP sets out residential developments of 11 or more dwellings gross, or sites of 0.3ha or more will be required to provide a minimum of 25% affordable homes on site. Currently it is unclear what this will deliver in terms of potential affordable housing supply and whether sufficient affordable housing will be provided to meet the proportion of unmet housing needs to be accommodated in Aylesbury Vale from Wycombe District. It would be helpful if this could be clarified either in the VALP or the supporting evidence base.

EMPLOYMENT: Aylesbury Vale falls within the same Functional Economic Market (FEMA) area as Wycombe District as part of the Bucks wide FEMA. We support that the VALP identifies there is sufficient employment land available in Aylesbury Vale to meet the overall forecast employment land needs across the FEMA, taking into account undersupply within Wycombe District. The Memorandum of Understanding identifies our plans will adopt a "precautionary and flexible approach to economic development including ensuring allocations are flexible to adjust to changes in the market". In light of this Policy E1 part c identifies that main town centre uses will not be supported on key employment sites, except as ancillary facilities to service a key employment site. The NPPF includes 'offices' as a main town centre use therefore this policy should be amended to take this into consideration. The references to the Bucks HEDNA, throughout the employment land chapter are also incorrect, e.g. para. 4.174 1st sentence should refer to the Bucks HEDNA Update, December 2016 (not 2015). Bucks HEDNA Addendum (para. 4.175) was produced by Atkins and ORS and was published in September 2017. Para. 4.176 refers to a property market review by the LEP. This is included as Appendix A of the HEDNA Addendum (September 2017). References should be checked accordingly.

CONCLUSION: Wycombe District Council is satisfied that the tests of legal compliance and soundness have been met but have identified some comments for consideration as set out above. As part of the Duty to Co-operate we will continue to actively engage until the plan is submitted for examination.

Object

VALP Proposed Submission

H1 Affordable housing

Representation ID: 2487

Received: 12/12/2017

Respondent: Wycombe District Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Policy H1 of the VALP sets out residential developments of 11 or more dwellings gross, or sites of 0.3ha or more will be required to provide a minimum of 25% affordable homes on site. Currently it is unclear what this will deliver in terms of potential affordable housing supply and whether sufficient affordable housing will be provided to meet the proportion of unmet housing needs to be accommodated in Aylesbury Vale from Wycombe District. It would be helpful if this could be clarified either in the VALP or the supporting evidence base.

Full text:

HOUSING: This Memorandum of Understanding identifies that AVDC falls within the same Housing Market Area as Wycombe District Council as part of a Buckinghamshire Housing Market Area. Based on the December 2016 HEDNA Update and Bucks HEDNA Addendum September 2017 the Objectively Assessed Need for the Bucks Housing Market Area is 45,500 dwellings, of which 19,400 is for Aylesbury Vale and 13,200 is for Wycombe District. Through capacity work we have identified an unmet housing need of 2,275 dwellings that cannot be accommodated within the district due to the land supply constraints that exist. The Memorandum of Understanding agrees that this unmet housing need will be accommodated in Aylesbury Vale. We note there is an error within the VALP which identifies 2,250 dwellings for Wycombe's unmet housing need. We ask that this is corrected to be that set out in the July 2017 Memorandum of Understanding for 2,275 dwellings. We welcome the flexibility built into the VALP housing supply with a 5.2% buffer.

AFFORDABLE HOUSING: The Memorandum of Understanding identifies that affordable housing policies in VALP will secure a proportion of affordable housing as part of delivering unmet housing needs from other plan areas within the Bucks HMA (including Wycombe District). Policy H1 of the VALP sets out residential developments of 11 or more dwellings gross, or sites of 0.3ha or more will be required to provide a minimum of 25% affordable homes on site. Currently it is unclear what this will deliver in terms of potential affordable housing supply and whether sufficient affordable housing will be provided to meet the proportion of unmet housing needs to be accommodated in Aylesbury Vale from Wycombe District. It would be helpful if this could be clarified either in the VALP or the supporting evidence base.

EMPLOYMENT: Aylesbury Vale falls within the same Functional Economic Market (FEMA) area as Wycombe District as part of the Bucks wide FEMA. We support that the VALP identifies there is sufficient employment land available in Aylesbury Vale to meet the overall forecast employment land needs across the FEMA, taking into account undersupply within Wycombe District. The Memorandum of Understanding identifies our plans will adopt a "precautionary and flexible approach to economic development including ensuring allocations are flexible to adjust to changes in the market". In light of this Policy E1 part c identifies that main town centre uses will not be supported on key employment sites, except as ancillary facilities to service a key employment site. The NPPF includes 'offices' as a main town centre use therefore this policy should be amended to take this into consideration. The references to the Bucks HEDNA, throughout the employment land chapter are also incorrect, e.g. para. 4.174 1st sentence should refer to the Bucks HEDNA Update, December 2016 (not 2015). Bucks HEDNA Addendum (para. 4.175) was produced by Atkins and ORS and was published in September 2017. Para. 4.176 refers to a property market review by the LEP. This is included as Appendix A of the HEDNA Addendum (September 2017). References should be checked accordingly.

CONCLUSION: Wycombe District Council is satisfied that the tests of legal compliance and soundness have been met but have identified some comments for consideration as set out above. As part of the Duty to Co-operate we will continue to actively engage until the plan is submitted for examination.

Object

VALP Proposed Submission

E1 Protection of key employment sites

Representation ID: 2488

Received: 12/12/2017

Respondent: Wycombe District Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

In light of this Policy E1 part c identifies that main town centre uses will not be supported on
key employment sites, except as ancillary facilities to service a key employment site. The
NPPF includes 'offices' as a main town centre use therefore this policy should be amended
to take this into consideration.

Full text:

HOUSING: This Memorandum of Understanding identifies that AVDC falls within the same Housing Market Area as Wycombe District Council as part of a Buckinghamshire Housing Market Area. Based on the December 2016 HEDNA Update and Bucks HEDNA Addendum September 2017 the Objectively Assessed Need for the Bucks Housing Market Area is 45,500 dwellings, of which 19,400 is for Aylesbury Vale and 13,200 is for Wycombe District. Through capacity work we have identified an unmet housing need of 2,275 dwellings that cannot be accommodated within the district due to the land supply constraints that exist. The Memorandum of Understanding agrees that this unmet housing need will be accommodated in Aylesbury Vale. We note there is an error within the VALP which identifies 2,250 dwellings for Wycombe's unmet housing need. We ask that this is corrected to be that set out in the July 2017 Memorandum of Understanding for 2,275 dwellings. We welcome the flexibility built into the VALP housing supply with a 5.2% buffer.

AFFORDABLE HOUSING: The Memorandum of Understanding identifies that affordable housing policies in VALP will secure a proportion of affordable housing as part of delivering unmet housing needs from other plan areas within the Bucks HMA (including Wycombe District). Policy H1 of the VALP sets out residential developments of 11 or more dwellings gross, or sites of 0.3ha or more will be required to provide a minimum of 25% affordable homes on site. Currently it is unclear what this will deliver in terms of potential affordable housing supply and whether sufficient affordable housing will be provided to meet the proportion of unmet housing needs to be accommodated in Aylesbury Vale from Wycombe District. It would be helpful if this could be clarified either in the VALP or the supporting evidence base.

EMPLOYMENT: Aylesbury Vale falls within the same Functional Economic Market (FEMA) area as Wycombe District as part of the Bucks wide FEMA. We support that the VALP identifies there is sufficient employment land available in Aylesbury Vale to meet the overall forecast employment land needs across the FEMA, taking into account undersupply within Wycombe District. The Memorandum of Understanding identifies our plans will adopt a "precautionary and flexible approach to economic development including ensuring allocations are flexible to adjust to changes in the market". In light of this Policy E1 part c identifies that main town centre uses will not be supported on key employment sites, except as ancillary facilities to service a key employment site. The NPPF includes 'offices' as a main town centre use therefore this policy should be amended to take this into consideration. The references to the Bucks HEDNA, throughout the employment land chapter are also incorrect, e.g. para. 4.174 1st sentence should refer to the Bucks HEDNA Update, December 2016 (not 2015). Bucks HEDNA Addendum (para. 4.175) was produced by Atkins and ORS and was published in September 2017. Para. 4.176 refers to a property market review by the LEP. This is included as Appendix A of the HEDNA Addendum (September 2017). References should be checked accordingly.

CONCLUSION: Wycombe District Council is satisfied that the tests of legal compliance and soundness have been met but have identified some comments for consideration as set out above. As part of the Duty to Co-operate we will continue to actively engage until the plan is submitted for examination.

Object

VALP Proposed Submission

6.1

Representation ID: 2489

Received: 12/12/2017

Respondent: Wycombe District Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

References to the Bucks HEDNA, throughout the employment land chapter are also
incorrect, e.g. para. 4.174 1st sentence should refer to the Bucks HEDNA Update,
December 2016 (not 2015). Bucks HEDNA Addendum (para. 4.175) was produced by
Atkins and ORS and was published in September 2017. Para. 4.176 refers to a property
market review by the LEP. This is included as Appendix A of the HEDNA Addendum
(September 2017). References should be checked accordingly.

Full text:

HOUSING: This Memorandum of Understanding identifies that AVDC falls within the same Housing Market Area as Wycombe District Council as part of a Buckinghamshire Housing Market Area. Based on the December 2016 HEDNA Update and Bucks HEDNA Addendum September 2017 the Objectively Assessed Need for the Bucks Housing Market Area is 45,500 dwellings, of which 19,400 is for Aylesbury Vale and 13,200 is for Wycombe District. Through capacity work we have identified an unmet housing need of 2,275 dwellings that cannot be accommodated within the district due to the land supply constraints that exist. The Memorandum of Understanding agrees that this unmet housing need will be accommodated in Aylesbury Vale. We note there is an error within the VALP which identifies 2,250 dwellings for Wycombe's unmet housing need. We ask that this is corrected to be that set out in the July 2017 Memorandum of Understanding for 2,275 dwellings. We welcome the flexibility built into the VALP housing supply with a 5.2% buffer.

AFFORDABLE HOUSING: The Memorandum of Understanding identifies that affordable housing policies in VALP will secure a proportion of affordable housing as part of delivering unmet housing needs from other plan areas within the Bucks HMA (including Wycombe District). Policy H1 of the VALP sets out residential developments of 11 or more dwellings gross, or sites of 0.3ha or more will be required to provide a minimum of 25% affordable homes on site. Currently it is unclear what this will deliver in terms of potential affordable housing supply and whether sufficient affordable housing will be provided to meet the proportion of unmet housing needs to be accommodated in Aylesbury Vale from Wycombe District. It would be helpful if this could be clarified either in the VALP or the supporting evidence base.

EMPLOYMENT: Aylesbury Vale falls within the same Functional Economic Market (FEMA) area as Wycombe District as part of the Bucks wide FEMA. We support that the VALP identifies there is sufficient employment land available in Aylesbury Vale to meet the overall forecast employment land needs across the FEMA, taking into account undersupply within Wycombe District. The Memorandum of Understanding identifies our plans will adopt a "precautionary and flexible approach to economic development including ensuring allocations are flexible to adjust to changes in the market". In light of this Policy E1 part c identifies that main town centre uses will not be supported on key employment sites, except as ancillary facilities to service a key employment site. The NPPF includes 'offices' as a main town centre use therefore this policy should be amended to take this into consideration. The references to the Bucks HEDNA, throughout the employment land chapter are also incorrect, e.g. para. 4.174 1st sentence should refer to the Bucks HEDNA Update, December 2016 (not 2015). Bucks HEDNA Addendum (para. 4.175) was produced by Atkins and ORS and was published in September 2017. Para. 4.176 refers to a property market review by the LEP. This is included as Appendix A of the HEDNA Addendum (September 2017). References should be checked accordingly.

CONCLUSION: Wycombe District Council is satisfied that the tests of legal compliance and soundness have been met but have identified some comments for consideration as set out above. As part of the Duty to Co-operate we will continue to actively engage until the plan is submitted for examination.

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