Aylesbury Vale Area

VALP Proposed Submission

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Object

VALP Proposed Submission

S2 Spatial Strategy for Growth

Representation ID: 1107

Received: 14/12/2017

Respondent: Richborough Estates

Agent: RPS Planning & Development

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Concern over the level of housing growth, both in the OAN and the unmet needs. A housing need technical review document is at appendix 1 which highlights flaws in the HEDNA. This document shows the OAN at 30,350 for Aylesbury Vale and 60,600-62,200 across the HMA.
Unmet needs from Luton - their inspector said 400 dwellings should be in AV.
Emerging standardised methodology shows 1,499 for AV. AV is not a constrained authority.
Concern over the distribution of growth, it doesn't respect the capacity of certain settlements. Query the realism of delivery in Aylesbury. There should be more growth at Haddenham.
Need for a new settlement remains and shouldn't be delegated to a review of VALP. Haddenham could facilitate greater amounts of growth.
Promotes alternative site at Haddenham HAD002, has little confidence in HELAA as the boundaries for this site havent been amended after requesting it.

Full text:

Attached report makes comments to the Proposed Submission VALP, by RPS on behalf of our client Richborough Estates, contains full comments on the policies and includes at appendix 1 a Housing Need Technical Review by Barton Willmore (November 2017).

Object

VALP Proposed Submission

S3 Settlement hierarchy and cohesive development

Representation ID: 1690

Received: 14/12/2017

Respondent: Richborough Estates

Agent: RPS Planning & Development

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

The purpose of this policy is to curtail development beyond those sites allocated, unless proposals demonstrate that there will be no negative impact on settlements in the spatial hierarchy. In light of the shortcomings in the Council's assessment of OAHN, RPS does not consider that the Council can take such an inflexible approach towards development.
As currently drafted the thrust of this policy seeks to restrict development, rather than enable development that is sustainable. The general principles of this policy do not conform to the principles of the NPPF which seek to promote sustainable development.

Full text:

Attached report makes comments to the Proposed Submission VALP, by RPS on behalf of our client Richborough Estates, contains full comments on the policies and includes at appendix 1 a Housing Need Technical Review by Barton Willmore (November 2017).

Object

VALP Proposed Submission

S4 Green Belt

Representation ID: 1691

Received: 14/12/2017

Respondent: Richborough Estates

Agent: RPS Planning & Development

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

It is noted that some 800 dwellings are proposed to be placed in land which is currently occupied by the Green Belt. Given the Spatial Vision (Criterion a) is to 'strongly protect the Green Belt', RPS would suggest there exists the potential for conflict within the Plan.

Given this potential conflict RPS would suggest the Council give greater consideration to the positive allocation of additional land on land outside the Green Belt in settlements in the south of the District, including Haddenham

Full text:

Attached report makes comments to the Proposed Submission VALP, by RPS on behalf of our client Richborough Estates, contains full comments on the policies and includes at appendix 1 a Housing Need Technical Review by Barton Willmore (November 2017).

Object

VALP Proposed Submission

S5 Infrastructure

Representation ID: 1692

Received: 14/12/2017

Respondent: Richborough Estates

Agent: RPS Planning & Development

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Whilst the provision of infrastructure is supported along with phasing of provision, the policy should not inhibit development coming forward in different timescales. The Council should acknowledge that on many sites, and in particular areas around Aylesbury, due to different ownerships, land will come forward in an independent manner. This is not unusual at all, but the Council needs to ensure, through either S106 or CIL and via its intended SPD, it has mechanisms in place to coordinate the funding of infrastructure and ensure that independent development sites do not prejudice delivery of wider land parcels.

Full text:

Attached report makes comments to the Proposed Submission VALP, by RPS on behalf of our client Richborough Estates, contains full comments on the policies and includes at appendix 1 a Housing Need Technical Review by Barton Willmore (November 2017).

Object

VALP Proposed Submission

T2 Protected Transport Schemes

Representation ID: 1693

Received: 14/12/2017

Respondent: Richborough Estates

Agent: RPS Planning & Development

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

It is noted that the Local Plan seeks to protect transport schemes including HS2 and East West Rail. Whilst the route of HS2 should be indicated on the Proposals Map, the implications of proposals on or near to the route is, essentially, a development control issue, which by its very nature is site specific. The policy should therefore be flexible and ensure public consultation on applications relating to the specific HS2 lines that affect the District. It should be noted that Richborough Estates proposals to the south of Aylesbury do not affect HS2.

Full text:

Attached report makes comments to the Proposed Submission VALP, by RPS on behalf of our client Richborough Estates, contains full comments on the policies and includes at appendix 1 a Housing Need Technical Review by Barton Willmore (November 2017).

Object

VALP Proposed Submission

S9 Monitoring and review

Representation ID: 1694

Received: 14/12/2017

Respondent: Richborough Estates

Agent: RPS Planning & Development

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Although RPS agrees that a strong monitoring policy is needed, the scale of the shortfall is already significant and would trigger this policy. The Council already recognises through this policy that the future housing need will increase, however the Council makes no provision through the VALP to meet this.

Were the Council to bring forward a monitoring policy, RPS consider that this should be clearer in the triggers for review. As currently stated a plan review would commence if site allocations fail to be delivered at the rate expected in the plan. At which year would this occur?

Full text:

Attached report makes comments to the Proposed Submission VALP, by RPS on behalf of our client Richborough Estates, contains full comments on the policies and includes at appendix 1 a Housing Need Technical Review by Barton Willmore (November 2017).

Object

VALP Proposed Submission

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

Representation ID: 1695

Received: 14/12/2017

Respondent: Richborough Estates

Agent: RPS Planning & Development

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

The new policy bears no relation to a potential new settlement. This new policy takes a very conservative view of facilitating development, indicating that only small scale development will be permitted, unless the Council's monitoring of housing land indicates dips in delivery that would leave the Plan-led approach vulnerable.

As indicated elsewhere in this report, RPS would urge caution in taking such a restrictive view in the Local Plan, particularly in light of a potential discrepancy in the calculation of housing need. RPS considers that this policy should be rewritten in a more flexible way.

Full text:

Attached report makes comments to the Proposed Submission VALP, by RPS on behalf of our client Richborough Estates, contains full comments on the policies and includes at appendix 1 a Housing Need Technical Review by Barton Willmore (November 2017).

Object

VALP Proposed Submission

D-HAD007 Land north of Rosemary Lane

Representation ID: 1696

Received: 14/12/2017

Respondent: Richborough Estates

Agent: RPS Planning & Development

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

HAD007 had been increased northwards and the yield increased by 200 dwellings, concerned about this increase, this doesn't appear to be justified and contradicts previous conclusions in the 2016 HELAA. This extended boundary does not utilise existing field boundaries and there is presently no certainty over how the site will fit into the setting of the village. The northern boundary of the village was something that featured in the application of Richborough Estates land at Haddenham, which recognised the need for appropriate landscape buffering, however RPS remains unconvinced that this has been factored into the Council's considerations.

Full text:

Attached report makes comments to the Proposed Submission VALP, by RPS on behalf of our client Richborough Estates, contains full comments on the policies and includes at appendix 1 a Housing Need Technical Review by Barton Willmore (November 2017).

Object

VALP Proposed Submission

D-HAL003 RAF Halton

Representation ID: 1697

Received: 14/12/2017

Respondent: Richborough Estates

Agent: RPS Planning & Development

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Notwithstanding suitability considerations identified by the Council, including reference to a number of identified designations, RPS considers that the Council is being overly optimistic over the delivery of the proposed allocation which would require all barriers to planning overcome and sustained delivery across the plan period from 2022 onwards.

Of additional concern, RPS is also aware that the assurances from the Defence Infrastructure Organisation (DIO) remain fragile for the purposes of plan making.

RPS therefore recommends that the proposed allocation at RAF Halton remains as part of the Plan, but an additional aspiration.

Full text:

Attached report makes comments to the Proposed Submission VALP, by RPS on behalf of our client Richborough Estates, contains full comments on the policies and includes at appendix 1 a Housing Need Technical Review by Barton Willmore (November 2017).

Object

VALP Proposed Submission

H1 Affordable housing

Representation ID: 1700

Received: 14/12/2017

Respondent: Richborough Estates

Agent: RPS Planning & Development

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

The policy requires a 'minimum of 25%' affordable homes. This is a reduction from the figure of 31% in the Draft VALP however again, there appears to be limited justification for the new figure and also its treatment as a minimum requirement, therefore until this is appropriately evidenced based, this element of the policy is not considered to be justified.
The independent consultant cannot be independent if chosen solely by the Council; it must be chosen by the Council and Applicant, from a selected shortlist.

Full text:

Attached report makes comments to the Proposed Submission VALP, by RPS on behalf of our client Richborough Estates, contains full comments on the policies and includes at appendix 1 a Housing Need Technical Review by Barton Willmore (November 2017).

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