Aylesbury Vale Area

VALP Proposed Submission

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Object

VALP Proposed Submission

S1 Sustainable development for Aylesbury Vale

Representation ID: 1091

Received: 14/12/2017

Respondent: Persimmon Homes Midlands

Agent: Bidwells

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Overall, we are supportive of Policy S1 as this sets out the Council's aspiration to deliver sustainable development which is in accordance with national planning policy and the NPPF's requirement (paragraph 6) for the planning system to contribute towards achieving sustainable development. We are also supportive of the prioritisation of the redevelopment of brownfield sites under limb 'd' of Policy S1 and Objective 1 of the VALP.

Full text:

As it stands, the VALP is not sound and hence there are a number of changes required to the plan including a number of strategic and development management policies as identified in the submitted representation letter. In summary, we consider that the following policies are unsound and for reasons stated above, do not meet the test of soundness: Policy S2 'Spatial Strategy for Growth'; Policy S3 'Settlement Hierarchy and Cohesive Development'; Policy H1 'Affordable Housing'; Policy H5 'Self/Custom Build Housing'; Policy H6 'Housing Mix'; Policy H7 'Dwelling Sizes'; Policy T5 'Vehicle Parking'; and Policy T7 'Electric Vehicle Infrastructure'. My client's site at Calvert Green represents an achievable, suitable and deliverable allocation that is part brownfield to support the necessary housing growth for Aylesbury Vale.

Object

VALP Proposed Submission

S2 Spatial Strategy for Growth

Representation ID: 1967

Received: 14/12/2017

Respondent: Persimmon Homes Midlands

Agent: Bidwells

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The proposed housing target is not considered to be consistent with the requirements of the NPPF and is not justified by a robust evidence base. The VALP does not allocate sites sufficiently, hence it doesn't comply with the NPPF and the target fails to plan positively for the housing need in Aylesbury Vale over the plan period. The current approach would constrain growth and exacerbate housing availability and affordability issues. The housing target proposed in the Local Plan is unsound. My client wishes to promote their land at Calvert Green for residential development through a site allocation in VALP.

Full text:

As it stands, the VALP is not sound and hence there are a number of changes required to the plan including a number of strategic and development management policies as identified in the submitted representation letter. In summary, we consider that the following policies are unsound and for reasons stated above, do not meet the test of soundness: Policy S2 'Spatial Strategy for Growth'; Policy S3 'Settlement Hierarchy and Cohesive Development'; Policy H1 'Affordable Housing'; Policy H5 'Self/Custom Build Housing'; Policy H6 'Housing Mix'; Policy H7 'Dwelling Sizes'; Policy T5 'Vehicle Parking'; and Policy T7 'Electric Vehicle Infrastructure'. My client's site at Calvert Green represents an achievable, suitable and deliverable allocation that is part brownfield to support the necessary housing growth for Aylesbury Vale.

Object

VALP Proposed Submission

S3 Settlement hierarchy and cohesive development

Representation ID: 1968

Received: 14/12/2017

Respondent: Persimmon Homes Midlands

Agent: Bidwells

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Policy S3 should recognise Calvert Green as an area for major future growth beyond the plan period of the VALP but also
to support short to medium-term growth. Brownfield sites should be prioritised in accordance with Policy
S1 and Objective 1 as discussed previously.

Full text:

As it stands, the VALP is not sound and hence there are a number of changes required to the plan including a number of strategic and development management policies as identified in the submitted representation letter. In summary, we consider that the following policies are unsound and for reasons stated above, do not meet the test of soundness: Policy S2 'Spatial Strategy for Growth'; Policy S3 'Settlement Hierarchy and Cohesive Development'; Policy H1 'Affordable Housing'; Policy H5 'Self/Custom Build Housing'; Policy H6 'Housing Mix'; Policy H7 'Dwelling Sizes'; Policy T5 'Vehicle Parking'; and Policy T7 'Electric Vehicle Infrastructure'. My client's site at Calvert Green represents an achievable, suitable and deliverable allocation that is part brownfield to support the necessary housing growth for Aylesbury Vale.

Object

VALP Proposed Submission

S8 Neighbourhood plans

Representation ID: 1972

Received: 14/12/2017

Respondent: Persimmon Homes Midlands

Agent: Bidwells

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Whilst we recognise the importance of Neighbourhood Plans, we consider that where a Neighbourhood Plan has already been 'made' within the Vale, these will need to be reviewed to ensure that they contribute towards and are in general conformity with the strategic policies and approach of the VALP once adopted. This requirement should be explicitly set out under the policy.

Full text:

As it stands, the VALP is not sound and hence there are a number of changes required to the plan including a number of strategic and development management policies as identified in the submitted representation letter. In summary, we consider that the following policies are unsound and for reasons stated above, do not meet the test of soundness: Policy S2 'Spatial Strategy for Growth'; Policy S3 'Settlement Hierarchy and Cohesive Development'; Policy H1 'Affordable Housing'; Policy H5 'Self/Custom Build Housing'; Policy H6 'Housing Mix'; Policy H7 'Dwelling Sizes'; Policy T5 'Vehicle Parking'; and Policy T7 'Electric Vehicle Infrastructure'. My client's site at Calvert Green represents an achievable, suitable and deliverable allocation that is part brownfield to support the necessary housing growth for Aylesbury Vale.

Object

VALP Proposed Submission

S9 Monitoring and review

Representation ID: 1973

Received: 14/12/2017

Respondent: Persimmon Homes Midlands

Agent: Bidwells

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Considering that the VALP does not adequately meet the OAN (refer to comments under Policy S2). As
currently drafted, an early review of the VALP is essential given the uncertainty of housing numbers within
the HMA and pending changes to Government guidance on calculating housing requirements and changes
to the NPPF. It is however necessary to provide greater clarity and certainty on the timing for a review of
the VALP. The policy should explicitly state when the replacement VALP will be adopted following a review.

Full text:

As it stands, the VALP is not sound and hence there are a number of changes required to the plan including a number of strategic and development management policies as identified in the submitted representation letter. In summary, we consider that the following policies are unsound and for reasons stated above, do not meet the test of soundness: Policy S2 'Spatial Strategy for Growth'; Policy S3 'Settlement Hierarchy and Cohesive Development'; Policy H1 'Affordable Housing'; Policy H5 'Self/Custom Build Housing'; Policy H6 'Housing Mix'; Policy H7 'Dwelling Sizes'; Policy T5 'Vehicle Parking'; and Policy T7 'Electric Vehicle Infrastructure'. My client's site at Calvert Green represents an achievable, suitable and deliverable allocation that is part brownfield to support the necessary housing growth for Aylesbury Vale.

Object

VALP Proposed Submission

D3 Housing development at smaller villages

Representation ID: 1974

Received: 14/12/2017

Respondent: Persimmon Homes Midlands

Agent: Bidwells

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Whilst we do not have any specific comments on Policy D3, I would like to reiterate that Calvert Green
should not be identified as a smaller village under Policy S3 and we consider that proposed development
of my client's site has the potential to deliver the short-medium term growth required throughout the lifetime
of the VALP to support the delivery the Calvert Infrastructure Maintenance Depot for HS2 and could form
part of a wider consideration to deliver in the long-term a major new town or settlement.

Full text:

As it stands, the VALP is not sound and hence there are a number of changes required to the plan including a number of strategic and development management policies as identified in the submitted representation letter. In summary, we consider that the following policies are unsound and for reasons stated above, do not meet the test of soundness: Policy S2 'Spatial Strategy for Growth'; Policy S3 'Settlement Hierarchy and Cohesive Development'; Policy H1 'Affordable Housing'; Policy H5 'Self/Custom Build Housing'; Policy H6 'Housing Mix'; Policy H7 'Dwelling Sizes'; Policy T5 'Vehicle Parking'; and Policy T7 'Electric Vehicle Infrastructure'. My client's site at Calvert Green represents an achievable, suitable and deliverable allocation that is part brownfield to support the necessary housing growth for Aylesbury Vale.

Object

VALP Proposed Submission

H1 Affordable housing

Representation ID: 1975

Received: 14/12/2017

Respondent: Persimmon Homes Midlands

Agent: Bidwells

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

There is scope for the Council to consider a lower percentage of affordable housing provision. Viability testing will need to be considered on a case by case basis. The Council should strongly consdier incorporating reference to Starter Homes as part of the affordable housing requirement. This would allow for a wider range of people to access affordable housing and be in accordance with the evidence base of the Viability Assessment and national objectives under the HWP. We consider that Policy H1 is unsound as the policy is unjustified in terms of its evidence base and inconsistent with national policy.

Full text:

As it stands, the VALP is not sound and hence there are a number of changes required to the plan including a number of strategic and development management policies as identified in the submitted representation letter. In summary, we consider that the following policies are unsound and for reasons stated above, do not meet the test of soundness: Policy S2 'Spatial Strategy for Growth'; Policy S3 'Settlement Hierarchy and Cohesive Development'; Policy H1 'Affordable Housing'; Policy H5 'Self/Custom Build Housing'; Policy H6 'Housing Mix'; Policy H7 'Dwelling Sizes'; Policy T5 'Vehicle Parking'; and Policy T7 'Electric Vehicle Infrastructure'. My client's site at Calvert Green represents an achievable, suitable and deliverable allocation that is part brownfield to support the necessary housing growth for Aylesbury Vale.

Object

VALP Proposed Submission

H5 Self/custom build housing

Representation ID: 1976

Received: 14/12/2017

Respondent: Persimmon Homes Midlands

Agent: Bidwells

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Reference should be made to Section 9 of the Housing and Planning Act 2016 and the update to the NPPF, acknowledging this guidance is emerging and further consultation required. My client questions there is evidence of demand for custom/ self-build housing in this part of Aylesbury Vale and its requirement for the Council to have evidence before setting out a policy. Consider the viability of providing serviced land plots; whole sites would likely be more suitable. Smaller sites/ sites with a wide design approach may not be. Policy H1 [sic] is unsound: the policy is unjustified in its evidence base.

Full text:

As it stands, the VALP is not sound and hence there are a number of changes required to the plan including a number of strategic and development management policies as identified in the submitted representation letter. In summary, we consider that the following policies are unsound and for reasons stated above, do not meet the test of soundness: Policy S2 'Spatial Strategy for Growth'; Policy S3 'Settlement Hierarchy and Cohesive Development'; Policy H1 'Affordable Housing'; Policy H5 'Self/Custom Build Housing'; Policy H6 'Housing Mix'; Policy H7 'Dwelling Sizes'; Policy T5 'Vehicle Parking'; and Policy T7 'Electric Vehicle Infrastructure'. My client's site at Calvert Green represents an achievable, suitable and deliverable allocation that is part brownfield to support the necessary housing growth for Aylesbury Vale.

Object

VALP Proposed Submission

H6 Housing Mix

Representation ID: 1977

Received: 14/12/2017

Respondent: Persimmon Homes Midlands

Agent: Bidwells

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The reference to Building Regulations is too prescriptive. The policy must be sufficiently flexible to adapt to changing circumstances as required by the NPPF. It is too rigid to specify percentages of dwellings to meet Building Regulations and this should relate to the identified need. Viability testing will be considered on a case by case basis. In any event, it is not necessary to require adherence to Building Regulations within a development plan policy and this reference should be omitted. Policy H6 is unsound as the policy is unjustified in terms of its evidence base and inconsistent with national policy.

Full text:

As it stands, the VALP is not sound and hence there are a number of changes required to the plan including a number of strategic and development management policies as identified in the submitted representation letter. In summary, we consider that the following policies are unsound and for reasons stated above, do not meet the test of soundness: Policy S2 'Spatial Strategy for Growth'; Policy S3 'Settlement Hierarchy and Cohesive Development'; Policy H1 'Affordable Housing'; Policy H5 'Self/Custom Build Housing'; Policy H6 'Housing Mix'; Policy H7 'Dwelling Sizes'; Policy T5 'Vehicle Parking'; and Policy T7 'Electric Vehicle Infrastructure'. My client's site at Calvert Green represents an achievable, suitable and deliverable allocation that is part brownfield to support the necessary housing growth for Aylesbury Vale.

Object

VALP Proposed Submission

H7 Dwelling sizes

Representation ID: 1978

Received: 14/12/2017

Respondent: Persimmon Homes Midlands

Agent: Bidwells

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

We object strongly on the grounds that insufficient evidence has been presented to justify or consider the policy as drafted and that more work is needed to demonstrate any need and implication of adoption. Only after justification of need has been established can the consideration of Viability and timings be truly considered.

Full text:

As it stands, the VALP is not sound and hence there are a number of changes required to the plan including a number of strategic and development management policies as identified in the submitted representation letter. In summary, we consider that the following policies are unsound and for reasons stated above, do not meet the test of soundness: Policy S2 'Spatial Strategy for Growth'; Policy S3 'Settlement Hierarchy and Cohesive Development'; Policy H1 'Affordable Housing'; Policy H5 'Self/Custom Build Housing'; Policy H6 'Housing Mix'; Policy H7 'Dwelling Sizes'; Policy T5 'Vehicle Parking'; and Policy T7 'Electric Vehicle Infrastructure'. My client's site at Calvert Green represents an achievable, suitable and deliverable allocation that is part brownfield to support the necessary housing growth for Aylesbury Vale.

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