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Object

VALP Proposed Submission

Table 1 Spatial strategy for growth in Aylesbury Vale

Representation ID: 1090

Received: 14/12/2017

Respondent: Gleeson Strategic Land

Agent: Nexus Planning Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

That Table 1 should be amended to express housing numbers as a minimum.

Full text:

1. Table 1 of the Local Plan outlines proposed housing delivery across the Plan period by settlement, taking account of commitments, completions and allocations in the Plan. The total number of new dwellings for Aylesbury is specified as 16,398.

2. Consistent with our more detailed representations to Policy S2, Table 1 should be amended to make it clear that the total number of new homes proposed at each identified settlement should be seen as minimum and not a ceiling, in accordance with the presumption in favour of sustainable development at paragraph 14 of the NPPF, and Policy S1 of the Local Plan.

Changes Sought

3. Amend Table 1 to ensure that all housing numbers are expressed as minima.

Object

VALP Proposed Submission

4.40

Representation ID: 1336

Received: 14/12/2017

Respondent: Gleeson Strategic Land

Agent: Nexus Planning Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object, 4.40

That the suggested number of units is not overly specific and is expressed as a minimum.

Full text:

Representations to Paragraph 4.40

1. Nexus Planning is instructed by Gleeson Strategic Land to prepare representations to the Publication Version of the Vale of Aylesbury Local Plan (VALP), in respect of land at South West Aylesbury. These representations should, where relevant, be read in conjunction with our other representations on behalf of Gleeson Strategic Land.

2. Paragraph 4.40 identifies the sites that comprise the 'South West Aylesbury' allocation. Land between Oxford Road, Standalls Farm and Aylesbury is allocated for 'up to' 1,382 dwellings. Land between Marsh Lane, Princes Risborough Railway Line and Aylesbury is allocated for up to 168 dwellings. Land at Lower Road is identified as an existing commitment for 190 dwellings.

3. Whilst supportive of the proposed South West Aylesbury allocation, we consider that the suggested number of units to be provided as set out in this paragraph is overly specific. Furthermore, it should in any event be expressed as a minimum rather than an 'up to' figure, consistent with our representations to Policy S2 and Table 1 and in accordance with the National Planning Policy Framework (2012) and specifically the requirement to 'boost significantly' the supply of housing as set out at paragraph 47 (and reflected in Policy S1 of the Local Plan).

Changes Sought

4. Amend Policy S2, and make associated consequential changes to the supporting text (including paragraph 4.40, to ensure that references to housing numbers generally, and at South West Aylesbury specifically, are not overly specific and, importantly, are expressed as minimum figures not as a ceiling.

Object

VALP Proposed Submission

4.42

Representation ID: 1338

Received: 14/12/2017

Respondent: Gleeson Strategic Land

Agent: Nexus Planning Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object, 4.42: The development on the land at South West Aylesbury will commence in the early / middle part of the plan period and that delivery of the site is not dependent on HS2.

Full text:

Representations to Paragraph 4.42

1. Paragraph 4.42 of the Local Plan states that:
a. 'the majority of the allocation is planned to come forward later in the Plan period especially due to the relationship and dependence on the delivery of HS2''.

2. As set out in our response to Policies D1 and D-AGT2, and as the Council is already aware, a planning application for the South West Aylesbury site is being prepared and is expected to be submitted before the Local Plan examination hearings commence. As such, this site will be capable of starting to deliver new homes in the front / middle of the Plan period (which of course started in 2013).

3. Furthermore, we strongly object to the statement in this paragraph that development of the site is dependent upon the delivery HS2. This is clear when looking briefly at the history of this site.

4. The 'Core Strategy Issues and Options Questionnaire' (June 2006) identified six potential broad areas of growth adjacent to Aylesbury town, three to the north of the town (Sites A, B & C) and three to the south (Sites D, E & F). Land at South West Aylesbury was identified as Site F. The Council acknowledged at that time that it would need to release three or four of these sites to meet its (then) housing requirements.

5. Having considered representations to the Issues and Options consultation, and a suite of technical evidence and a Sustainability Appraisal, the Council identified the allocation of Sites D, E and F as the most technically appropriate option within the Core Strategy Preferred Options version of the Plan in 2007. These sites together formed, and were thereafter referred to as, the Southern Growth Arc ('SGA') - extending from the A41 in the east to the A418 Oxford Road in the west.

6. In the light of objections to the proposed allocation of the SGA (albeit that the level of objections was consistent with any authority identifying any greenfield land for approximately 10,000 homes), the Council decided to review its position as it did not consider that its decision to identify the SGA was absolutely clear cut.

7. Given the Council's desire to deliver an Eastern Link Road adjacent to the town (and the reducing likelihood of Government funding), the Council decided to consult on the comparative merits of the SGA and a potential Eastern Growth Arc ('EGA').

8. Further to the 'Options for Growth Consultation', the Council ultimately proposed to allocate the EGA, going back on its original decision to allocate the SGA. It was evident, however, that this decision was political and was contrary to the Council's own technical evidence which still indicated strongly that the SGA was the most appropriate option. This final version of the Core Strategy was consulted upon and then submitted to The Planning Inspectorate for independent scrutiny by way of an examination.

9. The Core Strategy examination was held between February and April 2010. The Inspector allowed significant time to test each and every technical issue in turn to explore whether the Council's decision to switch from the SGA to the EGA was sound.

10. At the end of the examination hearing sessions, but prior to the Inspector's Report, a series of documents and maps for HS2 were published which, for the first time, brought into the public domain the proposed alignment of HS2. This ran (as it does now) directly north / south through the South West Aylesbury site. The Inspector was clear at the examination sessions that although the information was draft, HS2 was a project of national significance and a substantial amount of technical work had informed it. As such he had no option but to give it very significant weight. At that point the HS2 alignment seemed to preclude any development on the Site i.e. the Site was no longer available.

11. The Core Strategy Interim Inspector's Report was published in 2010. In light of the examination hearing sessions, the Inspector concluded that having regard to the available evidence and the case advanced, he had concerns about the soundness of the Council's proposed EGA allocation which were "...sufficiently serious to justify asking the Council to reconsider its approach before proceeding further".

12. He added that the allocation of the EGA could lead to a finding that the Core Strategy is unsound because the proposals do not represent the most appropriate strategy when compared to reasonable alternatives. As such he asked that the Council investigate alternative options.

13. More specifically with regard to South West Aylesbury (Site F) and the SGA generally, he concluded that:
* it represented a sustainable urban extension with limited landscape, heritage, biodiversity or flooding impacts and that similar comments apply to Sites E and F i.e. the remainder of the proposed SGA (para 7);
* agricultural land quality would not be a determinative factor (para 12);
* unlike Bierton to the east of Aylesbury, the larger settlements to the south of Aylesbury, by their nature, would remain as significant entities if the SGA was developed as they have the critical mass to withstand encroachment (para 14);
* the SGA would meet the sequential test of PPS25 (para 16);
* the SGA is predicted to generate fewer car journeys than the preferred EGA (para 19).
* the Council's concerns about the cost of potential agreements to cross railway lines (Sites E and F), and the impact on viability, was over-stated (para 25).

14. Whilst he did not recommend the allocation of land at South West Aylesbury / the SGA as a direct replacement for the EGA it was clear that in so doing, the Inspector gave considerable weight to the emerging HS2 alignment and its impact.

15. The Core Strategy was formally withdrawn by the Council in October 2010 in the light of the Inspector's Report and the revocation by the Government of Regional Spatial Strategies in July 2010, both of which allowed the Council to re-consider its development strategy.

16. What is clear from this summary of the history of land at South West Aylesbury, is that far from being dependent on the delivery of HS2, the announcement of the HS2 alignment initially played a role in precluding development on land at South West Aylesbury - land that the Council itself had originally identified as one of the most suitable locations for development at Aylesbury. Whilst the line of HS2 would now form the south-west boundary of the Council's proposed allocation, it is evident that the proposed allocation is in no way dependent upon HS2 (it is simply a matter to be considered in the development of the site). Furthermore, as we set out in our response to Policy S2, there is additional land, to the west of the HS2 line that is suitable and available for development in the event that land for additional housing is required.

Changes Sought

17. Amend Paragraph 4.42, and any other associated Plan references, to make it clear that development will commence in the early / middle part of the Plan period.

18. In addition delete the words ''especially due to the relationship to and dependence on the delivery of HS2''.

Object

VALP Proposed Submission

BE4 Density of new development

Representation ID: 1340

Received: 14/12/2017

Respondent: Gleeson Strategic Land

Agent: Nexus Planning Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object, BE4:

That higher density on the edge of the South West Aylesbury site is acceptable and that the policy should be amended to reflect that.

Full text:

Representations to Policy BE4 'Density of New Development'

1. We welcome acknowledgement within Policy BE4 that the density of developments will be determined on a site-by-site basis. However, we object to the generic requirement that higher density development should be situated towards the centre of sites with lower density towards the rural edge.

2. The above approach may be generally accepted design good practice but the Council's proposed allocation on land at South West Aylesbury is unusual in this regard as, rather than having a countryside edge, its edge will in fact be created by theHS2 railway line (when constructed). This means that the site has a hard urban edge both to the east (the existing urban edge of Aylesbury) and to the west (HS2). As a consequence this means that the approach to design and density throughout the site is different to the norm - with a higher density of development appropriate towards the western edge of the allocation (adjacent to HS2). This is a principle that is agreed with the Council but which, as drafted, would conflict with Policy BE4.

3. As a consequence, this policy should be amended to overtly allow for exceptions to the general principle identified.

Changes Sought

4. Amend Policy BE4 to state that higher density areas should "...in normal circumstances" be located towards the centre of the site.

Object

VALP Proposed Submission

D1 Delivering Aylesbury Garden Town

Representation ID: 1343

Received: 14/12/2017

Respondent: Gleeson Strategic Land

Agent: Nexus Planning Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object, D1:
That we support the vision for Aylesbury as part of the garden town concept but that the number of new homes should be referred to as a minimum, that the various SPDs are unnecessary and that community involvement in the treatment of community assets is beyond the control of the Council or developers.

Full text:

Representations to Policy D1 'Delivering Aylesbury Garden Town'

1. These representations relate to land at South West Aylesbury, allocated in the Local Plan as part of the wider Aylesbury Garden Town proposals under draft Policy D-AGT2. We respond separately in connection with that policy.

2. Policy D1 of the Local Plan deals generally with the Aylesbury Garden Town proposals, outlining that it is the focus for the majority of the district's growth - an approach which we support and which is supported by the Council's settlement hierarchy. It identifies a range of sites (both major and smaller sites) which are allocated for development, including land at South West Aylesbury (D-AGT2). We support this allocation specifically.

3. Further, we support the Council's vision for strategic growth at Aylesbury town as part of a 'garden town' concept, with the town being the focus for the majority of the District's development and investment. As the largest town in the district (and the County town for Buckinghamshire), and given its central location and lack of higher order environmental constraints, this is wholly appropriate and indeed necessary in order to ensure a sustainable distribution of development in the district (and the Housing Market Area more widely).

4. However, we make the following more specific comments on Policy D1.

Overall Housing Numbers

5. The policy as drafted suggests that Aylesbury town will deliver 16,398 homes over the Plan period to 2033. Taking account of completions and commitments, it suggests that 7,810 homes are already provided for. It then identifies how it makes provision for the remainder, including the allocation of land at South West Aylesbury. However, consistent with our response to Policy S2 and Table 1, it should be made clear that the number of homes referred to is a minimum and not a ceiling, consistent with the objective to boost significantly the supply of housing as required by the Framework at Paragraph 47, and general good practice in Local Plan production.

Criteria a, b, g and h - Supplementary Planning Documents

6. Criteria a, b, g and h. all make reference to the preparation by the Council of Supplementary Planning Documents (SPDs), including detailed design guidance and site-specific SPDs. We note that none of the documents referred to have yet been prepared. The policy suggests that the emerging Garden Town proposals will have regard to these SPDs, raising the possibility that applications submitted before these documents are produced, applications encouraged by the Council for good planning reasons, could be refused on the basis of prematurity or ultimately a conflict with documents which do not currently exist.

7. We are aware that a number of the strategic sites within the wider Garden Town proposals already benefit from resolutions to grant planning permission - notably the Hampden Fields site (which forms part of the allocated site D-AGT4 'Aylesbury South of A41') and Aylesbury Woodlands site (which forms part of the allocated site D-AGT3 'Aylesbury north of A41').

8. Further, the Local Plan is clear at paragraph 4.44 that an application on the land at South West Aylesbury is due in December 2017 (albeit that this submission date has now pushed back slightly to Q1 2018). A planning application is currently being prepared and extensive preapplication discussions have already taken place with both Aylesbury Vale District Council and Buckinghamshire County Council (with Planning Performance Agreements in place with both).

9. The Council has made it clear that it supports the accelerated delivery of development on land at South West Aylesbury and, indeed, this is a fundamental element / objective of its garden town status.

10. Against this background, we consider that there is no benefit in a number of the SPD's proposed by the Council. The proposals in the Local Plan for each site are already extremely detailed (and could be added to if required) and given the advanced status of many of the key strategic allocations (with two major sites already benefitting from resolutions to grant permission), there would be no real benefit to such SPD's. Indeed, they would serve only to divert Council resources and potential act as a barrier to accelerated housing delivery.

11. As such, the references to these SPDs should be deleted from the policy.

Criterion i - Treatment of Community Assets

12. In outlining the treatment of community assets, criterion i. states that opportunities for sustainable governance and stewardship should be established. It goes on to suggest that arrangements should be funded by developers and should include community representation.

13. Whilst we do not take issue with the broad thrust of this, the policy as worded suggests that community representation in such governance is an obligation. Whilst opportunities for such representation can be provided by the Council and developers, it is clearly beyond the control of either to require communities to be involved. This is a matter for each community to consider. Accordingly, we consider that this criterion should be amended to reflect this

Suggested Changes

Amend Policy D1 to make it clear that:

i. Reference to housing numbers is a minimum and not a ceiling i.e. referring to the delivery of 'at least 16,398 new homes';

ii. Delete all references to subsequent SPDs;

iii. Amend criterion i. to read: '' Establishing opportunities for appropriate and sustainable governance and stewardship arrangement for community assets including green space, public realm, community and other facilities. Such arrangements should be funded by developments and consider the inclusion of community representation''.

Object

VALP Proposed Submission

D-AGT2 South west Aylesbury

Representation ID: 1344

Received: 14/12/2017

Respondent: Gleeson Strategic Land

Agent: Nexus Planning Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object, D-AGT2:
That we support the identification of land at South West Aylesbury for strategic housing growth as part of the wider Aylesbury Garden Town proposals but that:
* the supporting text should be simplified;
* criterion b. (gypsy and traveler pitch provision) should be deleted;
* References to the realigned A4010 and HS2 should be removed from criterion p.
* Under 'implementation Approach' it should be clarified that development will come forward toward the front / middle of the Plan period.

Full text:

Representations to Policy D-AGT2 'South West Aylesbury'

1. Policy D-AGT2 allocates land at South West Aylesbury for development comprising the following key elements:
* Around 1,550 dwellings;
* One primary school;
* Multi-functional green infrastructure (totalling 56.33ha)
* Strategic flood defences and surface water attenuation;
* South West Link Road between Stoke Mandeville A4010 realignment and A418 Oxford Road single carriageway (safeguarded for future dualling) junction improvements and A413 and A418;
* Provision of linear park;
* Buffer zone for HS2 and noise mitigation;
* Cycling and walking links.

2. We support in general terms the provisions of Policy D-AGT2 in identifying land at South West Aylesbury for strategic housing growth as part of the wider Aylesbury Garden Town proposals. However, we have a number of specific comments on the detail of the policy as outlined below.

The Supporting Text

3. The draft policy as worded contains extensive 'Site-Specific Requirements' (criteria a - s) but, in addition, there are a further two pages of supporting text. Amongst other things, this supporting text sets out 'place-shaping principles' and 'the vision and objectives for the site'. As such, this text includes a range of specific issues not referenced in the policy itself. As a result, the requirements against which a future planning application for the site will be assessed by the Council's development management team are unclear. This approach is contrary to paragraph 154 of the NPPF which is clear that 'Only policies that provide a clear indication of how a decision-maker should react to a development proposal should be included in the plan. It is also contrary to the PPG (ID 12-010) which confirms that in drafting policies the local planning authority should avoid undue repetition and that allocations should provide clarity to developers. Against this background, we suggest that the supporting text to the policy is simplified, with any elements that are key but not currently expressed in Policy D-AGT2, included within the policy itself.

Masterplan SPD

4. The policy identifies that a Masterplan SPD will need to be prepared for the site. Paragraph 4.47 of the supporting text adds that the Masterplan SPD will establish more detail with regard to the site layout and disposition of land uses.

5. As set out elsewhere in our representations, we consider that references to this SPD should be deleted. Further, the Local Plan is clear at paragraph 4.44 that an application on the land at South West Aylesbury is due in December 2017 (albeit that this submission date has now pushed back slightly to Q1 2018). A planning application is currently being prepared and extensive pre-application discussions have already taken place with both Aylesbury Vale District Council and Buckinghamshire County Council (with Planning Performance Agreements in place with both).

6. The Council has made it clear that it supports the accelerated delivery of development on land at South West Aylesbury and, indeed, this is a fundamental element / objective of its garden town status.

7. Against this background, we consider that there is no benefit in a number of the SPD's proposed by the Council. The proposals in the Local Plan for each site are already extremely detailed (and could be added to if required) and given the advanced status of many of the key strategic allocations (with two major sites already benefitting from resolutions to grant permission), there would be no real benefit to such SPD's. Indeed, they would serve only to divert Council resources and potential act as a barrier to accelerated housing delivery.

8. As such, the references to these SPDs should be deleted from the policy. The Local Plan is clear at paragraph 4.44 that an application on the land at South West Aylesbury is due in December 2017 (albeit that this submission date has now pushed back slightly to Q1 2018). A planning application is currently being prepared and extensive pre-application discussions have already taken place with both Aylesbury Vale District Council and Buckinghamshire County Council (with Planning Performance Agreements in place with both).

9. The Council has made it clear that it supports the accelerated delivery of development on land at South West Aylesbury and, indeed, this is a fundamental element / objective of its garden town status.

10. Against this background, we consider that there is no benefit in a Masterplanning SPD as proposed by the Council. The proposals in the Local Plan for this (and every strategic) site are already extremely detailed (and could be added to if required), and given the advanced status of many of the key strategic allocations (with two major sites already benefitting from resolutions to grant permission), there would be no real benefit to such an SPD. Indeed, it would serve only to divert Council resources and potentially act as a barrier to accelerated housing delivery.

11. As such, the references to this Masterplanning SPD should be deleted from the policy.

Criterion b. provision of Gypsy and Traveller Pitches

12. We respond separately on this issue in our representations to Policy D1, but we object to the specific requirement, as part of Policy D-AGT2, for the provision for five gypsy and traveller pitches for the reasons set out below.

13. Policy S6 of the Local Plan confirms that there is a requirement for 84 (net) additional pitches for travelling or unknown Gypsies and Travellers, and two (net) additional plots for travelling or unknown Travelling Showpeople.

14. Paragrpah 4 of the NPPF is clear in terms of providing for the needs of Gypsy's and Travellers, stating that 'This Framework should be read in conjunction with the Government's planning policy for traveller sites', and at Footnote 34 that 'The Planning Policy for traveller sites sets out how travellers' accommodation needs should be assessed'.

15. The Government's definition of Gypsy's and Travellers is contained within the document entitled 'Planning Policy for Traveller Sites' (PPTS) (August 2015). As referenced in the supporting text to Policy S6, the Government definition of Gypsy's and Travellers was amended within this document to specifically exclude 'Persons...who have ceased to travel permanently'. The PPTS definition must be the starting point for assessing the need for additional Gypsy and Traveller pitches within the District.

16. ORS were commissioned to produce the Aylesbury Vale, Chiltern, South Bucks and Wycombe 'Gypsy Traveller Accommodation Assessment' (GTAA) in order to provide a robust assessment of current and future need for Gypsy, Traveller and Travelling Showpeople accommodation within those authority areas. The GTAA confirms that of those interviewed for the study, 4 Gypsy and Traveller households met the most up to date planning definition within Aylesbury Vale and on that basis, there is a need for just 8 additional Gypsy and Traveller pitches within the District.

17. The GTAA confirms that a further 20 households did not meet the planning definition, whilst the status of a further 87 households is identified as 'unknown', either because they refused to be interviewed or could not be contacted. There were no identified Travelling Showpeople.

18. The GTAA confirms at paragraph 7.28 that if all of the unknown households were to meet the planning definition, additional need could rise by a further 76 pitches. However, the GTAA also outlines that ORS data has been collected nationally from over 1,800 household interviews since the changes to the PPTS were introduced in 2015. This data confirms that of those interviewed approximately 10% of households met the correct planning definition of Gypsy's and Travellers, whilst in some local authorities (most notably in London), that percentage falls to zero.

19. On that basis it is concluded in the GTAA at paragraph 7.27 that only a small proportion of the 'unknown' households will require new pitches:
''This would suggest that it is likely that only a small proportion of the potential need identified from these households will need new Gypsy and Traveller pitches, and that the needs of the majority will need to be addressed through other means' (emphasis added).

20. The GTAA discusses further the treatment of unknown households at paragraph 1.9 when it states that:
''Councils will need to carefully consider how to address the needs associated with unknown Travellers as it is unlikely that all of this need will need to be addressed through the provision of conditioned Gypsy or Traveller pitches. In terms of Local Plan policies the Councils could consider the use of a specific site allocation/protection policy for those households that do meet the planning definition, together with a criteria-based policy (as suggested in PPTS) for any unknown households that do provide evidence that they meet the planning definition'' (emphasis added).

21. And further at paragraph 1.22 that:
'Only the need from those households who meet the planning definition and from those of the unknown households who subsequently demonstrate that they meet it should be considered as need arising from the GTAA' (emphasis added).

22. The Council's approach to the provision of Gypsy and Traveller pitches is outlined in the supporting text to Policy S6 and at Table 4, which identifies a total of 69 additional pitches for Gypsy's and Travellers. Table 6 identifies 2 additional pitches for Travelling Showpeople. It suggests that the proposed allocations in the Local Plan will meet the needs for all of the unknowns for the first 10 years of the Plan period. A further 8 pitches are planned for later in the Plan period so that, in total, 76 additional pitches would be provided - sufficient to meet, in full, the maximum possible requirement for 'unknown' households. This approach is unsound on the basis that it is contrary to the Council's own evidence base (in the form of the GTAA) and national policy in the NPPF.

23. Based on its own evidence base, the Council has incorrectly and unnecessarily sought to over-provide Gypsy and Traveller pitches to meet the needs of all 'unknown' households. Based on the available evidence, the Council should plan for no more than the 8 pitches known to be required by those meeting the Government's own definition of Gypsy's and Travellers, and for those 'unknown' households that subsequently demonstrate that they meet the definition. ORS evidence suggests that this is likely to be around 10%. This would result in a further 8 pitches for Gypsy's and Travellers and only 1 for Travelling Showpeople i.e. 17 additional pitches in total.

24. In terms of providing these additional pitches, paragraph 1.8 of the GTAA suggests that:
''The need arising from households that meet the planning definition should be addressed through site allocation/intensification/expansion policies. Consideration will also need to be given to the allocation of pitches on public sites''.

25. Table 4 shows clearly that the true number of additional pitches required could comfortably be accommodated by expanding or intensifying provision on a small number of existing sites. Draft Policy D10 sets out a range of criteria that Gypsy and Traveller sites should meet, including safe and convenient vehicular access (criterion b.), access to services (criterion g.), and a maximum size of 15 pitches (criterion h.) A host of the existing sites identified at Table 4 could be expanded without exceeding the maximum suggested figure of 15 pitches. Furthermore, and of fundamental importance, it is clear that these consented sites must already comply with the remaining criteria at Policy D10 including access to services etc.

26. Clearly therefore, the first priority should be the expansion and intensification of existing sites to meet the genuinely identified need as set out in the Council's own evidence base.

Criterion j. Development in the Flood Plain

27. Criterion j. states that, using a sequential approach, 'built development' should be restricted to Flood Zone 1 with Flood Zones 2, 3 and 3a retained as green space.

28. We agree that where better or more sustainable opportunities exist, it is not preferable for residential development to take place in Flood Zones 2 or 3a.

29. However, in terms of land which is within Flood Zones 2 and 3a (a total of approximately 13ha) it should be noted, in accordance with guidance in the NPPF and PPG (ID 7-067), that whilst it is clearly preferable to allocate sites in Flood Zone 1 where suitable and sustainable land is available, the allocation of housing in Flood Zone 2 is considered to be appropriate. Furthermore, development in Flood Zone 3a can also appropriate subject to satisfying the exception test.

30. In any event, and at the very least, the policy should be clarified to state that 'built development' in this context excludes roads and other infrastructure, consistent with national policy on flood risk in the NPPF at paragraphs 100 - 104, as well as the relevant guidance in PPG.

Criterion p. New major transport

31. Criterion p. suggests that the realigned A4010, and HS2, should be designed so that the potential loss of floodplain and change of flow pathways resulting from their implementation do not have an adverse effect on flood risk. It goes on to suggest that their design should ensure that they remain operational and safe for users in times of flood.

32. Whilst we do not object to this in principle, both HS2 and the A4010 are outside of this site and detailed design in this regard is a matter for other parties. As such, this component of the policy, which is specific to the South West Aylesbury site, should be deleted. It may be appropriate for the Council to introduce a separate policy in relation to these other issues.

Implementation Approach

33. Under the heading 'Implementation Approach' the policy goes on to outline that development of this site will come forward 'towards the latter end of the plan period and only once a Masterplan and Delivery SPD for the allocation has been prepared and adopted by the Council''. The policy goes on to suggest that proposals will be expected to demonstrate how they 'positively contribute to the achievement of the SPD and the Aylesbury Garden Town Principles set out in Policy D1'.

34. As highlighted previously and elsewhere in our representations, a planning application for this site is currently being prepared following extensive pre-application discussions and engagement with the Council. It will be submitted in Q1 2018 and as a consequence, it is evident that this site could start to deliver housing towards the front / middle of the Plan period.

35. In addition, and as set out previously and elsewhere in our representations, we do not consider that it is necessary or appropriate to produce a Masterplanning SPD in these circumstances, or to prevent delivery from this site until such a document has been prepared by the Council.

Changes Sought

Amend Policy D-AG2 as follows:
i. Delete criterion b. which relates to gypsy and traveller pitch provision;
ii. Revise criterion j. to make it clear that built development is not limited only to Flood Zone 1 and that such reference does not include development such as roads;
iii. Remove references to the realigned A4010 and HS2 from criterion p.
iv. Amend 'Implementation Approach' to make clear that development will come forward toward the front / middle of the Plan period, and delete reference to the Masterplan and Delivery SPD.

Object

VALP Proposed Submission

H6 Housing Mix

Representation ID: 1345

Received: 14/12/2017

Respondent: Gleeson Strategic Land

Agent: Nexus Planning Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object, H6:
The requirement for Category 3 market and affordable homes should be subject to viability.

Full text:

Representations to Policy H6 'Housing Mix'

1. We support the requirement for new residential developments to deliver a mix of housing types and sizes to meet current and future housing needs, having regard to the most up to date evidence.

2. We also note the requirement that all developments of 100 homes or more in strategic settlements provide an element of self-contained extra care dwellings as part of this overall mix, or an equivalent amount in an alternative location.

3. Specifically we note the requirement that for all new residential development, 10% of market housing and 15% of affordable housing should meet Category 3 of Approved Document M Volume 1. Paragraph 5.62 of the supporting text to this policy confirms that this relates to building regulations categories relating to adaptations and wheelchair accessible homes. Category 3 specifically is identified as wheelchair user dwellings.

4. We do not object to the principle in this regard but clearly in some circumstances, it may not be appropriate or viable to make such provision. This could therefore preclude the delivery of much needed housing and affordable housing generally. Accordingly we consider that this requirement should be subject to the same caveat as extra care provision i.e. subject to it being viable.

Changes Sought

5. Amend Policy H6 to make it clear that the requirement for Category 3 market and affordable homes is subject to viability.

Object

VALP Proposed Submission

H7 Dwelling sizes

Representation ID: 1346

Received: 14/12/2017

Respondent: Gleeson Strategic Land

Agent: Nexus Planning Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object, H7: That policy is unnecessary and as worded is too vague in any event, as such it should be deleted.

Full text:

Representations to Policy H7 'Dwelling Size'

1. Policy H7 of the Local Plan states that new dwellings will be required to provide 'sufficient internal space for normal residential activities commensurate in size with the expected occupancy of the dwelling'. The supporting text to the policy makes it clear, with reference to the Government's national space standards that 'currently there is no evidence that space provision in new dwellings in Aylesbury Vale is below that set out in the standards'. On that evidence, the Council is right to conclude that there is no need for internal space standards in Aylesbury Vale.

2. Against this background, whilst we appreciate the intent of the policy, the policy as worded is so vague as to be meaningless. More worryingly, the supporting text to the policy suggests that further information about the Council's expectations in this regard will be contained within a future Design SPD. However, such an SPD has not been produced and, importantly, would not be the subject of independent examination. The Council cannot seek to include an extremely vague policy in the Local Plan and then introduce meaningful detail through an SPD process that is not independently tested. This would be wholly unfair and inappropriate.

3. Against this background, and given that the issue of dwelling size is, based on the Council's own evidence, not an issue, Policy H7 should simply be deleted.

Changes Sought

4. Policy H7 should be deleted.

Object

VALP Proposed Submission

S2 Spatial Strategy for Growth

Representation ID: 1347

Received: 14/12/2017

Respondent: Gleeson Strategic Land

Agent: Nexus Planning Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object, S2: That we support the spatial distribution but that the number of new homes should be expressed as a minimum. Furthermore, in the event that FOAN for the district is found to be materially higher than set out in the Local Plan, that land to the west of HS2 is available for development.

Full text:

Representations to Policy S2
'Spatial Strategy for Growth'

1. Policy S2 of the Local Plan identifies that in the period to 2033, the Council proposes to make provision for a total of 27,400 new homes, comprised of 19,400 homes to meet the needs of Aylesbury Vale District, 2,250 homes to meet the needs of Wycombe District and 5,750 homes to meet the needs of Chiltern / South Bucks Districts. It then moves on to clarify the spatial strategy for the District, which focusses development at the strategic settlements (criteria a-e), most notably Aylesbury town.

2. We support the clarity provided by Policy S2 in terms of the proposed spatial distribution of development within the district and specifically, the statement that the primary focus of development will be Aylesbury town. Having regard to the Council's identified settlement hierarchy, and the fact that Aylesbury is the largest and most sustainable town in the District, this is wholly appropriate.

3. However, we object to the expression of the housing requirement for the district, and at Aylesbury (16,398 new homes) as a fixed figure or ceiling. This approach is not consistent with the presumption in favour of sustainable development as set out in the NPPF, or Policy S1 of the Local Plan, or the requirement to 'boost significantly' the supply of housing set out at paragraph 47 of the NPPF.

Land to the West of HS2

4. In the event that the Inspector finds that the FOAN for the District is, as some other parties suggest, materially higher than that identified in the HEDNA and the Local Plan, such that additional land is required for housing, we would like to confirm that additional land to the west of the strategic allocation at South West Aylesbury, to the west of HS2, available for development (as shown indicatively on the Development Plan at (Appendix 1).

5. This additional land comprises approximately 140ha. It is located at Aylesbury (the largest settlement in the District) and benefits from the majority of the sustainability benefits that apply to the Council's allocation at South West Aylesbury. In accordance with the Garden Town principles, around 50% of the land could be given over to green infrastructure and the site could realistically accommodate approximately 1,600 units. It would be able to rely upon much of the infrastructure being delivered by the allocation at South West Aylesbury, including the new primary school for example, utilising links across HS2 that are already proposed. Furthermore, it would allow the delivery of development that reduces in density as it moves towards the rural edge, feathering out in to the countryside to create a soft edge to Aylesbury.

6. Access to this additional land could be achieved from the A418 Oxford Road

7. The Council's HEDNA (May 2016) considers the merits of this additional land, to the west of HS2, as part of the larger site ref. STO016. It concludes (with the exception of areas in Flood Zones 2 and 3a which may be suitable for employment uses) that it is suitable for housing.

Changes Sought

Amend Policy S2 to:
i. Ensure that the housing requirement for the district, and the proportion of growth identified
to Aylesbury (and indeed the other identified strategic settlements), is expressed as a
minimum such that sustainable development in excess of these figures could be provided
and should be encouraged;
ii. In the event that the Inspector finds that FOAN for the district is materially higher than set
out in the Local Plan, as advocated by some parties, to note the availability and merits of
additional land west of the Council's proposed allocation at South West Aylesbury.

Object

VALP Proposed Submission

S3 Settlement hierarchy and cohesive development

Representation ID: 1348

Received: 14/12/2017

Respondent: Gleeson Strategic Land

Agent: Nexus Planning Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object, S3: That the policy should not seek to protect the countryside for its own sake but should instead take account of the different roles and character of different areas recognizing the intrinsic beauty of the countryside.

Full text:

Representations to Policy S3 'Settlement Hierarchy and Cohesive Development'

1. Policy S3 of the Local Plan identifies that the scale and distribution of development in the district should accord with the settlement hierarchy (as set out in Table 2).

2. At the top of the settlement hierarchy are the 'Strategic Settlements' of Aylesbury, Buckingham, Haddenham, Wendover and Winslow. As set out in our representations to Policy S2, we agree that this settlement hierarchy should guide growth in the district, with a focus on these strategic settlements, most notably Aylesbury.

3. However, consistent with our response to Policy S2 and Table 1, Table 2 and Policy S3 should make it clear that the housing numbers referred to should be regarded as minima in all cases.

4. Policy S3 goes on to outline that 'new development in the countryside should be avoided'. Whilst we do not object to the general thrust of the policy, the protection of the countryside should be seen in the context that the housing numbers in the Local Plan are minima. Furthermore, the NPPF is clear that there is protection for land which is subject to national level constraints (for example Green Belt or Areas of Outstanding Natural Beauty) but that theprotection of the countryside i.e. land outside settlements, purely for its own sake, is inappropriate. Instead, as set out at paragraph 7 of the NPPF, the Council should take account of the different roles and character of different areas, recognising the intrinsic beauty of the countryside.

Changes Sought

5. Amend Policy S3 to delete reference to the protection of the countryside for its own sake, and to instead reflect guidance in the NPPF i.e. that the Council will take account of the different roles and character of different areas, recognising the intrinsic beauty of the countryside.

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