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Representations on VALP Proposed Submission - S2 Spatial Strategy for Growth

Representation ID: 2720

OBJECT Kier Property represented by Planning Potential (Nona Jones)

Summary:

Land between Manor Farm and Railway Line is not identified as a site allocation for residential development within Newton Longville. As such, we consider that the Local Plan is not positively prepared by not acknowledging this much-needed, suitable, available and achievable site to deliver up to 300 new homes. Especially in light of the unmet housing need in the LPA and the HMA. The VALP is therefore considered unsound and we suggest that S2 is amended to "the plan will make the provision for the delivery of a minimum of 27,400 new homes" to deliver beyond the established housing targets.

More details about Rep ID: 2720

Representation ID: 2700

OBJECT Hallam Land Management represented by David Lock Associates (N Freer)

Summary:

Hallam Land Management has substantial concerns regarding the scale of development proposed in in Policy S2 - which does not accord with OAN of the District or make adequate allowance for the unmet needs of other districts in accordance with the Duty to Co-operate. Moreover HLM is concerned that the provision made for Buckingham in particular but also potentially Aylesbury is not positively prepared or effective in terms of meeting the aspirations of the Plan. The provision should be increased.

More details about Rep ID: 2700

Representation ID: 2682

OBJECT Amarillo Ltd & Scandale Ltd represented by Planning Prospects (Mr Chris Dodds)

Summary:

The current draft of the VALP makes provision for 27,400 homes to be delivered in Aylesbury Vale over the Plan Period. This is based on an OAN of 965 dwellings per annum as set out in the December 2016 Buckinghamshire HEDNA. Evidence suggests that Aylesbury Vale's true Objectively Assessed Need (OAN) is significantly higher than the HEDNA's suggested figure. With this in mind, we do not consider that the VALP as currently drafted will deliver the homes required in Aylesbury Vale over the Plan Period, or those required of its neighbouring authorities, including in the identified Housing Market Area (HMA).

More details about Rep ID: 2682

Representation ID: 2677

SUPPORT Oxfordshire County Council (John Disley)

Summary:

OCC supports the draft VALP in seeking to accommodate the district's own identified housing needs in full and make provision for unmet needs from other Buckinghamshire districts.

We also have no objection in principle to the significant scale of employment land supply identified within the district.

We support in principle the spatial strategy.

More details about Rep ID: 2677

Representation ID: 2669

OBJECT Barwood LaSalle Land Limited Partnership represented by WYG (Mr Keith Fenwick)

Summary:

This approach fails to have regard to the DCLG's proposed new methodology, which if adopted would likely result in a further increase in the numbers of dwellings required per annum in Aylesbury Vale.

More details about Rep ID: 2669

Representation ID: 2652

OBJECT FCC Environment represented by Sirius Yorkshire (Joanna Berlyn)

Summary:

Whilst the SA Report refers to the Council adopting a capacity led approach for smaller settlements based on suitable sites in sustainable locations, this does not appear to have been translated into the policy within the Proposed Submission VALP. Further consideration should also be given to planning growth and allocations in locations where there are existing prospects and opportunities to reduce greenhouse gas emissions. CAL003 should have been considered 'suitable' to improve the sustainability of the existing village and provide AVDC an opportunity to increase their housing numbers to compensate for the underestimated OAN and uncertainty over the plan period.

More details about Rep ID: 2652

Representation ID: 2646

OBJECT O&H Properties Ltd. represented by David Lock Associates (Heather Pugh)

Summary:

The overall level of growth is too given the Oxford-Cambridge arc; the HEDNA identifies the starting point is 21,028 homes; it does not make adequate provision for unmet need; and the draft housing need methodology gives an annual figure of 1,499 homes placing doubt on the validity of the Bucks HEDNA. Policy S2 should contain a commitment to an early review of the scale of proposed growth and the spatial distribution. Joint working on a cross-boundary growth strategy for the north of the district should be part of the review. A 20% buffer should apply for the whole plan period.

More details about Rep ID: 2646

Representation ID: 2634

OBJECT Buckingham Town Council (Councillor Robin Stuchbury)

Summary:

Why is Buckingham is allocated such a high proportion of new housing, while such serious constraints with sewerage system remain an issue. The phasing of sites doesn't seem to accord with the information regarding the Water Cycle Study.
If Buckingham is to remain a strategic settlement, a clearer policy as to how to upgrade WwTw needs to be provided if deliverability and viability issues are to be met, and to justify the additional allocation within the deliverability timescale set out.

More details about Rep ID: 2634

Representation ID: 2624

OBJECT Buckingham Town Council (Mr Christopher Wayman)

Summary:

There is internal in consistency within the VALP. The allocation of two new sites in Buckingham is inconsistent with other strategic policies within VALP. It is submitted that the inconsistency makes it unsound, as the lack of apparent consideration as to whether there are other suitable sites consistent with the Plan. This might question why Buckingham is allocated such a high proportion of new housing, while such serious constraints with sewerage system remain an issue. The phasing of sites doesn't seem to accord with the information regarding the Water Cycle Study.

More details about Rep ID: 2624

Representation ID: 2568

OBJECT Mareen Growly

Summary:

It would be far more sensible to allocate housing close to Milton Keynes, for example on the site to the south west which seems to have come out of this version of the plan. As it can accommodate 2000 houses, this would substantially reduce the burden on Buckingham residents and renew our confidence that the council respects our views.

More details about Rep ID: 2568

Representation ID: 2563

OBJECT Hallam Land Management represented by David Lock Associates (N Freer)

Summary:

Hallam Land Management has substantial concerns regarding the scale of development proposed in in Policy S2 - which does not accord with OAN of the District or make adequate allowance for the unmet needs of other districts in accordance with the Duty to Co-operate.

Moreover HLM is concerned that the provision made for Buckingham in particular but also potentially Aylesbury is not positively prepared or effective in terms of meeting the aspirations of the Plan. The provision should be increased.

More details about Rep ID: 2563

Representation ID: 2550

OBJECT Buckinghamshire County Council (SA Sharp)

Summary:

Suggested amendments to site specific policies - Highways Development Management,
Flooding and Public Rights of Way have set out a number of suggested amendments to ensure
consistency throughout and to provide greater opportunities for improving connectivity via
sustainable modes of travel and strategic flood risk management.

More details about Rep ID: 2550

Representation ID: 2496

OBJECT Sir/ Madam

Summary:

.
I believe local residents would be better served if the Council were to respect our adopted Neighbourhood Plan and consider re-allocating the site close to Milton Keynes for 2000 homes, instead of burdening us with all this development.

More details about Rep ID: 2496

Representation ID: 2495

OBJECT Mr David Flegg

Summary:

I gather that the Council has planned to put 2,000 houses to the south west of Milton Keynes, but then changed its mind. This idea should be reconsidered to reduce the burden on our small village.

More details about Rep ID: 2495

Representation ID: 2494

OBJECT Mrs L Bartlett

Summary:


I am also alarmed to hear that the Council decided to remove a large site near Milton Keynes from the VALP, while keeping our two allocations in Buckingham. Most local people commute in that direction anyway, so I believe it would make far more sense to have that development instead of these unwanted ones.

More details about Rep ID: 2494

Representation ID: 2421

OBJECT The Environment Agency (Michelle Kidd)

Summary:

Without up-to-date modelling for the following sites: WTV018 'Woodlands', BIE022
'Land at Manor Farm' and STO016 'Land South West of Aylesbury, we can't be
satisfied that there is sufficient land available in Flood Zone 1 to accommodate the
level/quantum of development proposed.
Therefore we can't see how the conclusion has been reached that the second part of
the exception test has been passed for this site

More details about Rep ID: 2421

Representation ID: 2416

OBJECT Wendover Neighbourhood Plan Steering Group (Mr Jonathan Clover)

Summary:

We seek clarification of the phrase "around 1128". If 128 are already approved, and
1000 are to go to RAF Halton, then the figure should simply be 1128, and the word
"around" deleted. It is also stated in text and in the FAQs produced by AVDC that the
figure of 1000 is a conservative estimate. This adds to the confusion

More details about Rep ID: 2416

Representation ID: 2404

SUPPORT Wendover Neighbourhood Plan Steering Group (Mr Jonathan Clover)

Summary:

We welcome the adjustment to the draft Green Belt proposals and the
limitation of development within the Town which accords with the great
majority of views expressed by the public.

More details about Rep ID: 2404

Representation ID: 2393

OBJECT Mr David Vowles

Summary:

agree with methodology used, except the settlement hierarchy approach is now meaningless regarding policy differentiation among larger and medium villages.

plan is also unsound with regards to housing provision. approval of plan should be subject to immediate review.

More details about Rep ID: 2393

Representation ID: 2342

OBJECT The Environment Agency (Michelle Kidd)

Summary:

HS2 and ecological mitigation

The local planning authority needs to confirm that none of the allocated sites conflict
with sites allocated by HS2 for ecological mitigation proposals.

More details about Rep ID: 2342

Representation ID: 2333

OBJECT South West Milton Keynes Consortium represented by Carter Jonas - Associate SWMK Consortium (Mr Brian Flynn)

Summary:

We consider that the HEDNA is not robust and the objectively assessed housing need figure should be higher than currently proposed in PSVALP. As such, we consider that additional land needs to be allocated in sustainable locations to meet the higher housing requirement.

The DLP Report, submitted with these representations, concludes the HEDNA requirement too low both when compared to the official projections and other economic forecasts. The DLP Report demonstrates that depending on the Memorandum of Agreement the housing requirement for VALP is between 1,677 dpa and 1,780 dpa or between 33,459 and 35,600 for the plan period.

More details about Rep ID: 2333

Representation ID: 2271

OBJECT IM Land represented by Turley Associates (Ms. Hannah Bowler)

Summary:

On the basis that questions are being raised over whether there is a demonstrable requirement for AVDC ,to plan and deliver for such a significant number of new homes above its own OAN, we consider that the southern authorities should be requested to demonstrate robustly that it has exhausted all opportunities for accommodating development with their own boundaries especially given there is considerable evidence (both our Client's and the Council's own evidence in some cases) to demonstrate that there are additional sites that could be allocated to reduce the quantum of unmet need.

More details about Rep ID: 2271

Representation ID: 2268

OBJECT DIO represented by Jones Lang LaSalle (Mr Tim Byrne)

Summary:

RAF Halton can play a far greater role in housing delivery by providing the right homes in the right places and building homes faster. Policy S2 should be amended to recognise the potential to realise the full residential development potential of the site through the development of a masterplan SPD.

More details about Rep ID: 2268

Representation ID: 2238

OBJECT Mrs Jane Chilman

Summary:

The amount of housing proposed to the south of Aylesbury is far too high. The plan will lead to more local traffic particularly at peak times. The location of large housing development which do not have sufficient public transport links will ensure very high car usage and make the problem worse. The expected jobs are no more than allocations on a drawing.

More details about Rep ID: 2238

Representation ID: 2219

OBJECT The Environment Agency (Michelle Kidd)

Summary:

Please be aware that in order for all site allocations to be deliverable, any sites with
watercourses will need to comply with the emerging local plan policy BE3 River and
stream corridors. This policy incudes a 10m ecological buffer to be in place from the top
of the river bank. This ecological buffer zone should be free from development.

More details about Rep ID: 2219

Representation ID: 2204

OBJECT North Bucks Parishes Planning Consortium (Mr Geoff Culverhouse)

Summary:

Given that 30% pf the housing growth proposed in the submission VALP is a requirement of the need to meet neighbouring authorities' unmet need it is logical that this should be delivered in areas closest to where that need arises.. Of the strategic settlements Haddenham and Wendover are closest to the areas with unmet need whilst Winslow and Buckingham are farthest away.

More details about Rep ID: 2204

Representation ID: 2202

OBJECT The Environment Agency (Michelle Kidd)

Summary:

We are pleased to see that many allocation descriptions that are at risk of flooding in
the local plan refer the reader to the SFRA level 2 for more detailed advice. Please can
you ensure that all the allocation descriptions refer to the SFRA level 2 if they are at riskof flooding.

More details about Rep ID: 2202

Representation ID: 2085

SUPPORT Historic England (Mr Martin Small)

Summary:

we welcome the statements in clauses g. and h. of Policy S2 that housing growth will be at a scale in keeping with local character, and the explanation in paragraph 3.20 that the allocations for each settlement are based on the capacity of the settlement to accommodate housing growth rather than a blanket percentage increase on housing stock as was previously proposed in the draft Plan and which we queried.

More details about Rep ID: 2085

Representation ID: 2082

OBJECT CEG represented by Nexus Planning Ltd (Mr Steven Doel)

Summary:

That the FOAN for the district contained within the Local Plan is fundamentally too low. Further that the housing requirement for the district should be expressed as a minimum and that land north of Aylesbury Road, Wendover must be allocated for housing.

More details about Rep ID: 2082

Representation ID: 2060

OBJECT Persimmon Homes North London represented by Woolf Bond Planning (Mr Steven Brown)

Summary:

cannot be said to be sound on the basis of its over-reliance in
strategic delivery at Aylesbury Town which fails to represent the most appropriate
strategy in the circumstances. This includes potential constraints to delivery at
the strategic sites from key milestones in the identified schemes, such as the
timing for the delivery of key elements of infrastructure such as roads, utilities and
schools etc. This leads to uncertainty in delivery and the strategy should be
revised in order to provide for additional housing allocations at a smaller to
medium size housing sites both within Aylesbury itself and surrounding
settlements.

More details about Rep ID: 2060

Representation ID: 2043

OBJECT Manlet Group Holdings represented by Barton Willmore LLP (Ms Jane Harrison)

Summary:

Plan does not provide growth to match Government housing figure.
No land is allocated in Wendover Parish so plan does not reflect strategy in S"
Halton Camp is not in Wendover Parish.
Like land being removed from the Green Belt elsewhere the same should happen for our site west of the canal and south of Halton Lane.
The Halton Camp site is not deliverable.


More details about Rep ID: 2043

Representation ID: 2042

OBJECT Crest Strategic Projects represented by Savills Southampton (Mr Jon Gateley)

Summary:

In the previous draft of the VALP, Shenley Park had been put forward as an allocation for up to 2,000 dwellings, recognising its sustainable location, the capacity of the site and its environment and surrounding landscapes to accommodate development sensitively, and its ability to consistently deliver housing through the plan period in tandem with infrastructure.

As set out in the supporting Technical Appendices, the basis for the omission of the site in the Submission Draft VALP is confused and contradictory, and is not justified by a rational and reasoned understanding of evidence, as is required by the NPPF.

More details about Rep ID: 2042

Representation ID: 2021

OBJECT Crest Strategic Projects represented by Savills Southampton (Mr Jon Gateley)

Summary:

we do not consider that it is appropriate to introduce site-specific allocation policies for additional growth at Buckingham, Winslow and Wendover. Rather, these should be addressed by means of Neighbourhood Plan reviews which take account of the overall higher development requirement.

More details about Rep ID: 2021

Representation ID: 2020

OBJECT Crest Strategic Projects represented by Savills Southampton (Mr Jon Gateley)

Summary:

CSP objects to this policy on the basis that it derives from a calculated level of Objectively Assessed Need ('OAN') for the District itself, of only 19,400 dwellings (970 per annum), plus 8,000 unmet need from other districts to the south. According to paragraph 1.48 of the draft VALP, completions over the past 5 years have averaged 1,127 dwellings per annum. Therefore, in effect the VALP is planning for a reduction in development, rather than the significant 'boost' that is necessary, pursuant to NPPF Paragraph 47.

More details about Rep ID: 2020

Representation ID: 1998

OBJECT Society of Merchant Ventures represented by Savills Reading (Mrs Rebecca McAllister)

Summary:

The Government's proposed new formula for calculating OAN demonstrates that Aylesbury's housing need is 1,499 dpa, a 55% increase from that currently assessed. We recommend that it would be more appropriate to re-assess and provide for the full OAN in this Plan as a number of these 'elements' are already known and reveal a significant increase in the housing requirement. Accordingly, the Plan in its current form fails to assist in accommodating the expected housing need for Aylesbury Vale and is therefore unsound.
See further details in the attached covering letter.

More details about Rep ID: 1998

Representation ID: 1984

OBJECT Edward Ware Homes represented by Pegasus Group (Robert Taylor)

Summary:

The policy should be amended to require the delivery of 33,350 homes over the plan period.
The plan should facilitate more housing growth at medium villages and the requirement at medium villages should therefore be presented as a minimum, and not a ceiling.

More details about Rep ID: 1984

Representation ID: 1969

OBJECT Ms F. Mari

Summary:

Neighbouring places need some neighbourliness between neighbours in lived reality. Not only are the VALP housing allocations for Buckingham and Maids Moreton distinctly UNneighbourly in their excessiveness (in relation to other, similarly sized, communities), but these plans are already fostering divisions between both individual neighbours and between communities. It is also unneighbourly to skew housing matters in favour of landowners and developers rather than, more properly, in favour of local tax-paying residents. Therefore, I also strongly object to the VALP on the grounds of unneighbourliness.

More details about Rep ID: 1969

Representation ID: 1967

OBJECT Persimmon Homes Midlands represented by Bidwells (Mr Robert Love)

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.

More details about Rep ID: 1967

Representation ID: 1953

OBJECT Careys New Homes represented by Bidwells (Mr Robert Love)

Summary:

My client wishes to promote their land interest at Land at Winslow Road, Wingrave for residential
development through a site allocation in the VALP. the site represents an achievable, suitable and deliverable allocation to support the
necessary housing growth for Aylesbury Vale. The proposed development will contribute towards the
Council's housing requirements and potential unmet need from adjacent authorities. site can be
developed within the forthcoming five-year period, which will contribute significantly towards maintaining a
rolling 5-year supply of suitable housing sites throughout the lifetime of the plan.

More details about Rep ID: 1953

Representation ID: 1952

OBJECT Careys New Homes represented by Bidwells (Mr Robert Love)

Summary:

significant concerns that the approach to considering housing need is flawed and that
there is significantly less capacity in Aylesbury Vale than is being suggested.

The proposed housing target is not considered to be consistent
with NPPF requirements and is not justified by a robust evidence base. Furthermore, the
identified target fails to plan positively for the full extent of housing need in Aylesbury Vale over plan
period. the current approach would artificially constrain growth and doing so exacerbate already
acute housing availability and affordability issues. The housing target proposed in the Local Plan is
therefore considered to be unsound.

More details about Rep ID: 1952

Representation ID: 1935

OBJECT CALA Homes represented by Pegasus Group (Ms Laura Humphries)

Summary:

The HEDNA adopts inconsistent assumptions to reduce the OAN. This is not consistent with the national policy justified, effective or positive. Once the OAN is consistently calculated the VALP will nee to make provision for additional supply (including the new settlement/s).
The proposed distribution has also not been agreed with Milton Keynes and is likely to be prejudicial to future delivery at Milton Keynes. Until the distribution has been agreed between the Councils, the duty to co-operate has not been met.

More details about Rep ID: 1935

Representation ID: 1934

OBJECT Revera Limited (Mr Renshaw Watts) represented by Pegasus Group (Mr Rob Riding)

Summary:

The policy provision is significantly below the minimum OAN and therefore additional mechanisms will
need to be identified to address the resultant shortfall.
Growth at medium villages is supported.

More details about Rep ID: 1934

Representation ID: 1911

OBJECT Home Builders Federation Ltd (Mr Mark Behrendt)

Summary:

The policy is unsound as the delivery expectations to support the other authorities in the HMA are unjustified

we welcome the approach taken by AVDC to set a housing requirement of 27,400 new homes we do not consider the level of growth to be sufficient to support the other authorities in the HMA to the degree stated.

More details about Rep ID: 1911

Representation ID: 1896

OBJECT Thornborough Parish Council (Maggie Beach)

Summary:

The Government emphasis on denser housing stock will inevitably lead to smaller and smaller amenity space which will impact on health and well-being, this should be addressed. It will also put pressure on smaller sites to take houses in backyards and gardens. This could have an adverse impact on the nature of the historic environment, the local ecology (gardens are often refuges for wildlife and their loss would be detrimental, and the loss of hedgerows which are ecologically significant as highways, a food source and protection. The natural and historic environment also need protection with robust policies.

More details about Rep ID: 1896

Representation ID: 1894

OBJECT Thornborough Parish Council (Maggie Beach)

Summary:

* Thornborough Parish Council supports allocating development to settlements on a "case by case basis", rather than as generic percentages based on hierarchy classification, but thinks that not enough evidence is presented in the Plan to explain how the actual numbers have been derived.

More details about Rep ID: 1894

Representation ID: 1887

OBJECT Granborough Parish Council (Victoria Firth)

Summary:

The GPC does have some concerns about the cumulative impact of such development where smaller villages share limited infrastructure, in particular schools.

The GPC is still concerned as to the overall impact on the plan of meeting the unmet need from the other Buckinghamshire Districts. This has meant that AVDC has had to identify sites which are, at the very least, unpopular with local communities and in some circumstances contrary to the declared wishes of local communities as contained in their approved neighbourhood plans.

One of the reasons why other authorities are claiming that they cannot meet their identified housing need is by proposing low housing densities, and thus not maximising the sites available, hence GPC believes that AVDC has at this time made over-provision.

More details about Rep ID: 1887

Representation ID: 1867

OBJECT Halton Parish Council (Fiona Lippmann)

Summary:

In both Tables 1 and 2 of S2 Spatial strategy for growth, the single line entry combining Wendover with Halton (Halton Camp) should be separated into distinct rows and Halton should have a distinct entry in the tables with the correct demarcation (a "smaller village") and its housing allocation (1,000 houses). In Table 2 the entry for Halton needs to have a description in column 2 highlighting why it has been selected for the 1,000 houses and how that fits within the settlement hierarchy.

More details about Rep ID: 1867

Representation ID: 1864

OBJECT Manor Oak Homes - Director (Mr William Main) represented by Strutt & Parker (Sophie Horsley)

Summary:

Strutt & Parker considers that Policy S2 is unsound on the basis that the quantum of homes proposed at Aylesbury is undeliverable during the Plan period, rendering the policy ineffective in respect of the tests of soundness set out in paragraph 182 of the NPPF. The emphasis on Aylesbury has been at the expense of other sustainable locations, such as at Stoke Mandeville.

More details about Rep ID: 1864

Representation ID: 1844

OBJECT CALA Homes Limited represented by Hunter Page Planning (Guy Wakefield)

Summary:

We fully endorse the findings of the Turley report (Housing Needs in Aylesbury Vale - Review and Critique of the Evidence Base dated December 2017) which concludes that there is requirement to increase the OAN figure to fulfil the economic and social objectives for the HMA.

This representation fully supports the Plan's recognition of the importance of medium sized villages in its Strategy for Growth (Policy SP2) for which both proposed allocation sites lie within.


The reasoning behind Bierton's lack of allocations is due to its close proximity to the proposed growth at Aylesbury Garden Town however, this is not considered a suitable justification.

The proposed sites (BIE027 and GUW008) are considered to be located in settlements where future development is supported, are relatively unconstrained and have the capacity to deliver further housing units.

More details about Rep ID: 1844

Representation ID: 1832

OBJECT Paul Newman New Homes. represented by Development Planning and Design Services Ltd (Mr Neil Arbon)

Summary:

Unmet need should also be considered from Bedfordshire, in particular Luton. Uncertainty remains as to whether authorities such as Central Bedfordshire can accommodate Lutons's unmet need with in the Luton HMA. VALP doesn't meet para 182 of NPPF. Therefore the most sensible location for allocating a site would be in a sustainable location on the CBC/AVDC boundary at Leighton-Linslade.

More details about Rep ID: 1832

Representation ID: 1827

OBJECT Rectory Homes Limited (Mr Tim Northey)

Summary:

as drafted is too reliant on delivery of small large strategic urban extension sites. strategy offers insufficient opportunities to small/medium sized House builders. a re-balanced spatial strategy is required which increases the proportion of housing delivery at sustainable rural settlements such as Haddenham. offering chance to enhance local services, reduce risk of delays with housing delivery and potential future housing land supply shortfall.

More details about Rep ID: 1827

Representation ID: 1814

OBJECT Mrs Alina Neagoe

Summary:

total number of dwellings will only need to be determined after the Local Plans for Wycombe/Chiltern/South Bucks are validated by the Planning Inspectors (if not, there will be a huge risk that part of the un-met need from Wycombe/Chiltern/South Bucks will be fulfilled in two locations, e.g. Wycombe District and Aylesbury Vale - and will be built more homes than necessary in Buckinghamshire). This is the effect that Aylesbury Vale District Council has not put enough pressure on the other Councils to do their job in a professional manner and to create Local Plans that reflect reality.

More details about Rep ID: 1814

Representation ID: 1787

OBJECT Mr & Mrs Peter & Jane Chilman

Summary:

The amount of housing proposed to the south of Aylesbury is far too high. The plan will lead to more local traffic particularly at peak times. The location of large housing development which do not have sufficient public transport links will ensure very high car usage and make the problem worse. The expected jobs are no more than allocations on a drawing.

More details about Rep ID: 1787

Representation ID: 1778

OBJECT Cerda Planning Limited (Tina Pearsall)

Summary:

The Council should also be aware that as drafted, Policy S2 is clearly a housing land supply policy the purposes of Paragraph 49 of the NPPF in terms of the scale and distribution requirements of the policy.

More details about Rep ID: 1778

Representation ID: 1758

OBJECT Ainscough Strategic Land represented by Turley Associates (Taylor Cherrett)

Summary:

It is essential that the Council's in the HMA provide a clear justification as to the reason
for this significant reduction in the demographic starting point.
ASL would also request that the figures outlined in Policy S2 are expressed as a
minimum, through the inclusion of the wording "at least".
This ensures that the plan is flexible enough to be able to respond to changing needs
over the plan period (i.e. without the need for a major review if housing total
exceeds the provision made), as well as ensure that the
proposals meet the requirements of the NPPF

More details about Rep ID: 1758

Representation ID: 1733

OBJECT Persimmon Homes Ltd., and CALA homes Ltd represented by Turley Associates (Mr Christopher Roberts)

Summary:

Our principle concern with the Proposed Submission Local Plan is that the spatial
strategy and housing delivery strategies articulated at Proposed Policies S2 and D1 lead
to an overconcentration of allocations at Aylesbury. In turn, this leads to resultant
concerns regarding the deliverability of these allocations and market saturation an

More details about Rep ID: 1733

Representation ID: 1731

OBJECT Persimmon Homes Ltd., and CALA homes Ltd represented by Turley Associates (Mr Christopher Roberts)

Summary:

our primary concern is that the strategy of concentrating 16,389 dwellings at
Aylesbury (i.e. approximately 60 per cent of the total planned requirement) overstates
'capacity', as understood in terms of the market's capacity to deliver this quantum of
development, at that location, over the Plan period. This is explored further in Section 4
of these representations.

More details about Rep ID: 1731

Representation ID: 1725

OBJECT Persimmon Homes Ltd., and CALA homes Ltd represented by Turley Associates (Mr Christopher Roberts)

Summary:

Turley raises a number of concerns regarding the housing delivery strategy, as
described in proposed Policy S2 and its supporting text. Table 1 (at page 35 of the
Proposed Submission Local Plan) identifies a District-wide 'housing requirement' of
27,400, with a residual requirement of 12,529 still to be met. The Plan proposes to
allocate land for 12,997 additional dwellings, with a further 962 units being anticipated to
be provided via windfall development.

More details about Rep ID: 1725

Representation ID: 1717

OBJECT Wates Developments Ltd. represented by Boyer Planning Ltd (Jonathan Liberman)

Summary:

This strategy is supported on the basis that these are the most appropriate locations with significant levels of existing infrastructure to accommodate new growth. We would recommend nevertheless that the housing requirement set out in Policy S2 (and Table 1) is expressed as a 'minimum'.

More details about Rep ID: 1717

Representation ID: 1673

OBJECT Aviva Life & Pensions UK Limited represented by GL Hearn (Mr David Maxwell)

Summary:

Policy S2 is overly reliant on release of greenfield land to meet housing needs for Aylesbury Vale and for neighbouring districts. An updated assessment should be carried out to assess existing vacant and previously developed land, particularly historic employment land at the Gatehouse Industrial Estate, for alternative land uses, including residential.

More details about Rep ID: 1673

Representation ID: 1616

OBJECT September Properties represented by DLP Planning Limited (Ed Norris)

Summary:

For the reasons outlined above, DLP submit that the housing strategy and
requirement as set out in Policy S2 is not sound in its current format. The VALP:
PS is not using the most up do date population figures to establish net migration
in Aylesbury and is not preparing for an appropriate level of market uplift. The
HEDNA is treating Aylesbury Vale differently to the rest of the HMA whereas it
should be subject to at least a similar 20% uplift.

More details about Rep ID: 1616

Representation ID: 1614

OBJECT Gladman Developments Ltd (Ms Nicole Penfold)

Summary:

Objections to both the housing requirments and the spatial strategy. The plan needs greater flexibility/contingency.

More details about Rep ID: 1614

Representation ID: 1604

OBJECT Waldridge Garden Village Consortium represented by Pegasus Group (on behalf of Jeremy Elgin) (Mr Neil Tiley)

Summary:

The HEDNA adopts inconsistent assumptions to reduce the OAN.
The proposed distribution has also not been agreed with Milton Keynes and is likely to be prejudicial to future delivery at Milton Keynes. Until the distribution has been agreed between the Councils, the duty to co-operate has not been met.
The proposed distribution which takes no account of the need for the new settlement/s will be prejudicial to the location of the new settlement/s. It will also result in either (or both) Winslow and Haddenham being required to accommodate significant development in addition to the new settlement/s.

More details about Rep ID: 1604

Representation ID: 1556

OBJECT Barwood Land and Estates represented by Chilmark Consulting Ltd (Mike Taylor)

Summary:

Fleet Marston (FLM-001) should be included within the Proposed Submission VALP's housing
allocations for Aylesbury and has been omitted on the basis of deficient and flawed evidence.

The VALP's failure to properly appraise FLM-001 and the site's omission from the VALP's proposed
housing development allocations result in a Plan that does represent the most effective or sustainable
use of land or the optimal choice of sites for future development.

More details about Rep ID: 1556

Representation ID: 1550

OBJECT Barwood Land and Estates represented by Chilmark Consulting Ltd (Mike Taylor)

Summary:

The proposed housing requirement includes significant flaws as set out in detail in BLEL's
representation. The OAN and housing requirement has been cynically and adversely manipulated
and fails to represent a full OAN figure for the District as presented.
The policy is underpinned by housing evidence that contains significant and material deficiencies.
The approach and resulting policy is therefore unsound and inconsistent with national policy

There is no housing trajectory and that this is a significant omission undermining
the Plan and a failure to ensure that the supply of housing is significantly boosted in accordance with
NPPF paragraph 47.

More details about Rep ID: 1550

Representation ID: 1538

OBJECT Halsbury Homes Ltd represented by RPS Planning and Development (Camilla Fisher)

Summary:

Aylesbury Vale plan cannot include a commitment within policy S2 to provide for
2,250 homes to meet the needs from Wycombe District until this exercise has been undertaken or the
Wycombe Plan has been found to be sound as drafted. The presumption has to be that an authority
proposing to "transfer" housing need in this way has exhausted all possible options in the context of its
own plan making exercise before another authority can accept it in an equivalent exercise.

More details about Rep ID: 1538

Representation ID: 1537

OBJECT Halsbury Homes Ltd represented by RPS Planning and Development (Camilla Fisher)

Summary:

Given that the DCLG figure of 30,000 dwellings representing local OAN in AVDC, is actually higher
than the current draft figure of 27,400 dwellings contained in the Local Plan, the question must be
asked as to whether:-
1) AVDC is content to accept a minimum of 8,000 additional dwellings in addition to the 30,000
local need - giving an adjusted total of 35,400 dwellings in 2 years time; or
2) Whether it will have to review the MOU to see if it considers the current allocations should
provide for its own local need rather than the needs of adjoining authorities.

More details about Rep ID: 1537

Representation ID: 1524

OBJECT Bellway Homes represented by Turley Associates (Mr Christopher Roberts)

Summary:

However, it is clear that the figures outlined in proposed Policy S2 should be expressed as a 'minimum', with the policy being reworded to include the wording "at least". This is to ensure that the Plan is flexible enough to be able to respond to changing needs over the plan period. This adjustment will assist in ensuring the Proposed Submission Local Plan accords with the requirements of the NPPF which direct Local Planning Authorities to "boost significantly" the supply of housing and to plan positively at paragraph 47 and 157 respectively.

More details about Rep ID: 1524

Representation ID: 1517

OBJECT Lands Improvement Holdings (LIH) represented by Savills Oxford (Reece Lemon)

Summary:

LIH objects to the low level of growth proposed at Haddenham. The settlement has capacity to accommodate
significantly more development (both residential and employment). This would have the effect of directing
growth away from the lower order/less sustainable villages in the District. This approach underpins plan making
as set out in the NPPF. Indeed, the NPPF states at paragraph 151

More details about Rep ID: 1517

Representation ID: 1516

OBJECT Lands Improvement Holdings (LIH) represented by Savills Oxford (Reece Lemon)

Summary:

*Failure in its Duty to Cooperate
*It does not full take account of the unmet housing needs within the Housing Market Area
*Does not plan for the expected increase in OAN over the plan period
*Fragile Housing Land Supply Position
*Plan does not take account of the Cambridge, Milton Keynes, Oxford Express Way

remains a known OAN from Luton, alongside an unknown but foreseeable
further OAN from London, and Chiltern & South Bucks. If the Council continues with this approach, there are
significant risks regarding Duty to Co-operate as well as compliance with national policy for identifying and
meeting OAN

More details about Rep ID: 1516

Representation ID: 1495

OBJECT Corbally (Finmere) Group and Mrs Vanessa Tait represented by WYG (Sarah Butterfield)

Summary:

The Local Plan should take into account now the Government's standard methodology, and incorporate these figures into the housing need planned for and identify additional sites and land for housing to meet that need.
My client's land at Finmere Airfield is suitable to meet such additional need, its credentials are set out at Section 1 of these representations.

More details about Rep ID: 1495

Representation ID: 1482

OBJECT Weston Mead Farm Limited represented by Nexus Planning Ltd (Mr Oliver Bell)

Summary:

The total number of homes to meet the needs of the District should increase to 27,300 dwellings over the plan period, excluding any allowance for unmet needs within the housing market area. The housing requirement should also be expressed as a minimum.

More details about Rep ID: 1482

Representation ID: 1468

OBJECT Sport England (South East Region) (Office Manager

Summary:

The Council will need to review through a Playing Pitch Strategy and Built Sports Facilities Strategy what will be required to support the new homes within these allocations, particularly for the larger sites including; DAGT1, D-AGT2, DAGT3 (which includes a sports village and pitches) and D-GT4. The allocations for new sports facilities are welcomed by Sport England but the Council will need to justify these allocations using its evidence base.

More details about Rep ID: 1468

Representation ID: 1451

SUPPORT Chiltern and South Bucks District Council (Ms Shereen Ansari)

Summary:

Our Councils welcome the approach to employment land as set out in the Draft VALP. Paragraph 1.14 , and Policy S2 (Spatial Strategy for Growth) recognise that surplus employment land in Aylesbury Vale will play a crucial role in helping to make up for the shortfall in neighbouring authorities within the wider FEMA. The Draft VALP seeks the safeguarding of suitable key employment sites, and supports employment development in sustainable locations. This approach provides flexibility for changes/uncertainties in future economic growth both within Aylesbury Vale and within the wider economic area.

More details about Rep ID: 1451

Representation ID: 1438

OBJECT Hertfordshire County Council (Mr Lewis Claridge)

Summary:

We note the Cumulative Impact Assessment that has been undertaken and considers all of the development sites around Aylesbury. However, we are concerned that it does not appear to consider impacts that may result outside of the border of the Vale of Aylesbury Local Plan. We also note the Aylesbury Transport Strategy commissioned by Bucks County Council and that transport modelling work has been undertaken - again, we have some concerns about how cross boundary impacts and cumulative growth is factored in.

More details about Rep ID: 1438

Representation ID: 1431

OBJECT Winslow Town Council (Dr Sean Carolan)

Summary:

The Memorandum of Understanding between AVDC, Wycombe DC, Chiltern DC, South Bucks DC and Bucks Thames Valley LEP is flawed.

More details about Rep ID: 1431

Representation ID: 1398

OBJECT Edward Ware Homes represented by Pegasus Group (Robert Taylor)

Summary:

object to Policy S2, para 3.16 and 3.17. The policy should be amended to require the delivery of 33,350 homes over the plan period.
The plan should facilitate more housing growth at medium villages and the requirement at medium villages should therefore be presented as a minimum, and not a ceiling.

More details about Rep ID: 1398

Representation ID: 1347

OBJECT Gleeson Strategic Land represented by Nexus Planning Ltd (Mr Steven Doel)

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.

More details about Rep ID: 1347

Representation ID: 1341

OBJECT High Barrow Holdings (Mr. Ikram Haq) represented by Ingleton Wood LLP (Rebecca Howard)

Summary:

1370 dwellings per year is unrealistic. It would need a step change
in approach that is not evidenced in the Local Plan. VALP fails to consider such involvement basing its delivery rate on aspirational targets rather than sound evidence and as such the Local Plan does not realistically demonstrate that it is deliverable. 16,398 houses within Aylesbury will be challenging in terms of whether the market can supply such demand. An alternative strategy is required.

More details about Rep ID: 1341

Representation ID: 1337

OBJECT High Barrow Holdings (Mr. Ikram Haq) represented by Ingleton Wood LLP (Rebecca Howard)

Summary:

The preferred strategy is not considered to distribute growth across the entire district thus starving communities of the opportunities to grow and provide the infrastructure and facilities needed. The Sustainability Appraisal of the VALP, states that a more dispersed approach was examined. This approach was not considered a 'reasonable alternative' given it would require 'further detailed work'. No further
detail is provided within the SA of such work. It is therefore questioned whether such work has been carried out. If this reasonable alternative has indeed not been properly considered, then the VALP is considered to fail this test of soundness.

More details about Rep ID: 1337

Representation ID: 1233

OBJECT Thakeham (Ms Judith Onuh)

Summary:

It is essential that the Local Plan acknowledges the Government's ambitions to significantly boost the supply of housing and seek to deliver the full housing requirement of the district to comply with national policy, particularly paragraph 47 of the NPPF.

More details about Rep ID: 1233

Representation ID: 1230

OBJECT Berkshire, Buckinghamshire & Oxfordshire Wildlife Trust (Mr Neil Rowntree)

Summary:

We are generally concerned about the quantum of development proposed, which will inevitably impact on wildlife even if the most ecologically-rich areas are avoided.

We are concerned that housing numbers might not be informed by necessary masterplanning and as a result might not allow for sufficient space for green infrastructure.

Related to this we could not find any information that suggests that the allocations have been informed by baseline ecological surveys.

There is also considerable discrepancy between the way biodiversity is dealt with between different site allocations.

List of sites provided which appear to have areas of significant wildlife value.

More details about Rep ID: 1230

Representation ID: 1193

OBJECT Newton Longville Parish Council (Mr Mike Galloway)

Summary:

The provision for employment seems low given the amount of housing proposed. A table should be included which details all existing and proposed employment areas and size of each. Retail is mentioned within the policy but not in the supporting text. A far greater allocation should be made in the greater Aylesbury area as that is where most of the need is and is where there are better transport connections. The villages surrounding Aylesbury clearly operate as part of Aylesbury even though there are small gaps between them and Aylesbury.

More details about Rep ID: 1193

Representation ID: 1178

OBJECT Lands Improvement Holdings Plc represented by Indigo Planning Limited (Mr Michael Wood)

Summary:

We note that the policy references the implementation of a Community Infrastructure Levy
(CIL) Charging Schedule to secure infrastructure obligations from developments.
Preparation of the Charging Schedule should be undertaken alongside the VALP as the two documents will directly influence the deliverability and sustainability of one-another.

Whilst it is appreciated that the CIL Charging Schedule will be assessed through
Examination, the Council cannot guarantee that CIL will deliver the infrastructure required without impacting the viability of delivering the VALP.

More details about Rep ID: 1178

Representation ID: 1137

OBJECT Gallagher Estates Ltd represented by Barton Willmore (Mr Michael Knott)

Summary:

2.7 Barton Willmore has undertaken a
Housing Needs Technical Review for the
Buckinghamshire HMA. A copy of this
report is submitted in support of these
representations. In summary, the Technical
Review concludes that:
* The FOAHN for Aylesbury Vale
District is 1,520 dpa (30,350 homes
2013-2033)
* The FOAHN for the Buckinghamshire
HMA (including Aylesbury Vale
District) is 3,030 - 3,100 dpa (62,200
homes 2013-2033)

More details about Rep ID: 1137

Representation ID: 1135

OBJECT Mr Malcom Brown

Summary:

opposed to development in stoke hammond

More details about Rep ID: 1135

Representation ID: 1132

OBJECT Taylor Wimpey South Midlands represented by Armstrong Rigg Planning (Mr Geoff Armstrong)

Summary:

Objects to S2, concerned the housing target is not sufficiently ambitious or positively prepared with regard to future need (Governments OAN methodology and the 2015 HEDNA mentioned). Spatial strategy is crucial to achieving the delivery rates required. Pleased percentage approach isn't used now but consider there is a over reliance on large strategic sites. This can be addressed by further allocation of sites at across the other strategic settlements, with more at larger and medium villages. These could be reserve sites to future proof the plan. This should include allocation of sites like our clients (GHW013) which could be delivered within 5 years. This would be a positive response to the housing delivery test. It would be prudent for a contingency of 10-15% (2,740-4,110 homes) of the total housing requirement to be added to the supply in additional allocated sites or reserve sites, rather than the 5.2%.

Target figures should be a expressed as a minimum.

More details about Rep ID: 1132

Representation ID: 1130

OBJECT Landseer Properties Ltd represented by BB Architecture and Planning (Dan Stiff)

Summary:

We consider the specific strategic policies and delivery policies; and the approach to distribution
through the HELAA and settlement hierarchy are intrinsically flawed and therefore not sound or
Framework compliant.
Overall the housing policies proposed seek to restrict the significant boost in housing required by
Framework para. 47, and seemingly offer no room for manoeuvre for new development, particularly
in the rural areas that is over and above the commitments and allocations of housing proposed in the
plan.

More details about Rep ID: 1130

Representation ID: 1129

OBJECT Persimmon Homes Ltd., and CALA homes Ltd represented by Turley Associates (Mr Christopher Roberts)

Summary:

it is clear that the figures outlined in proposed Policy S2 should be expressed
as a 'minimum', with the policy being reworded to include the wording "at least". This is
to ensure that the Plan is flexible enough to be able to respond to changing needs over
the plan period. This adjustment will assist in ensuring the Proposed Submission Local
Plan accords with the requirements of the NPPF which direct Local Planning Authorities
to "boost significantly" the supply of housing and to plan positively at paragraph 47 and
157 respectively.

More details about Rep ID: 1129

Representation ID: 1126

OBJECT Inspire Villages Group represented by BB Architecture and Planning (Mr Andrew Boughton)

Summary:

The representation of Inspired Villages Group is set out in The Inspire Villages
supporting statement which is to be read with reports also attached to the email
submission.
Documents forming part of this representation are:
(separate attachments):
* Inspire Villages supporting statement
* Housing LIN doc: More Choice Greater Voice
* JLL report Retirement living
* The Market Opportunity (ECV report)
* Economic, social and environmental impacts of a typical care village
* Knight Frank report

More details about Rep ID: 1126

Representation ID: 1122

OBJECT Catesby Estates Limited represented by Barton Willmore (Alastair Bird)

Summary:

The note explains that the HEDNA Update contains a number of fundamental flaws which mean that
it does not form a sound, robust evidence base suitable for underpinning the emerging VALP.

More details about Rep ID: 1122

Representation ID: 1120

OBJECT Trustees of FJ Wallis represented by Kirkby Diamond (on behalf of Trustees of FJ Wallis) (Chris Green)

Summary:

the combined effect of Policy S2 'Spatial Strategy for Growth' and Policy D4 'Housing at Other
Settlements' is to treat Stoke Hammond (and other such settlements) as 'open countryside'. It places an
unnecessarily restrictive approach on new development: not only must there be exceptional circumstances
where allocated sites are not coming forward at a sufficient rate; but even in such circumstances, proposals
may only be for either affordable housing, or small infilling.

More details about Rep ID: 1120

Representation ID: 1110

OBJECT Bellway Homes Ltd, Bellcross Co. Ltd and Fosbern Manufacturing Ltd represented by Armstrong Rigg Planning (Mr Geoff Armstrong)

Summary:

Objects to S2, concerned the housing target is not sufficiently ambitious or positively prepared with regard to future need (Governments OAN methodology and the 2015 HEDNA mentioned). Spatial strategy is crucial to achieving the delivery rates required. Pleased percentage approach isn't used now but consider there is a over reliance on large strategic sites. This can be addressed by further allocation of sites at across the other strategic settlements, with more at larger and medium villages. These could be reserve sites to future proof the plan.

More details about Rep ID: 1110

Representation ID: 1109

OBJECT Inland Homes and Western Mead Farms Ltd represented by Nexus Planning Ltd (D Veasey)

Summary:

The evidence base underpinning the Policy S2 housing figure fundamentally under assesses FOAN for Aylesbury Vale and the wider HMA. As set out in detail within our supporting report, consequently, Policy S2 fails all of the NPPF paragraph 182 soundness tests. Our recommended approach to rectify the soundness failings are set out within paragraph 86 of our supporting report.

More details about Rep ID: 1109

Representation ID: 1107

OBJECT Richborough Estates represented by RPS Planning & Development (Mr Cameron Austin-Fell)

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.

More details about Rep ID: 1107

Representation ID: 1106

OBJECT Berryfields Consortium represented by Savills (on behalf of Berryfields Developers) (Mr Matthew Dawber)

Summary:

The reapportionment of employment need from Wycombe, South Buck and Chiltern to Aylesbury Vale is not appropriate given the location and site specific requirements for employment land. E.g at Berryfields, no B use class development has been delivered in 10 years since outline consent

Given the lack of proximity to the M40 of much of Aylesbury Vale does not meet
the same criteria as locations in South Buck and Wycombe

The spatial allocation of employment at levels of need well above that of Aylesbury District itself will not be an effective way of meeting requirements over the FEMA. its doesnt accord with Para 22 of NPPF.

More details about Rep ID: 1106

Representation ID: 1101

OBJECT September Properties represented by DLP Planning Limited (Ed Norris)

Summary:

on the overall strategy for housing and the soundness of the VALP. It highlights the view that the VALP fails to give adequate regard to the housing market areas and unmet need that is identified in this area as well as the surrounding areas. The VALP has not allocated an adequate level of growth to allow it to meet the unmet need that it will need to accommodate from surrounding districts, as well as its own housing requirement. As such, additional sites must be allocated to this area of the VALP to ensure that local and strategic needs are met.

More details about Rep ID: 1101

Representation ID: 1100

OBJECT The Fingask Association represented by Rural Solutions (Ms Kate Girling)

Summary:

council should consider allocating more sites to ensure that the increased housing need can be met, in light of changes to the methodology for calculating objectively assessed housing needs.

More details about Rep ID: 1100

Representation ID: 1097

OBJECT Vanderbilt Strategic represented by Wessex Environmental Planning (Andrew Blackwell)

Summary:

The SA has not looked at Aston Clinton fairly. The evidence base does not point to a finite environmental, school or other infrastructure capacity for Aston Clinton having been reached. Policy S 2 plus supporting tables and text references should therefore be amended to allow a further allocation at Aston Clinton and with the suggestion of 89 homes on land adjacent to College Road South.

More details about Rep ID: 1097

Representation ID: 1092

OBJECT FCC Environment represented by West Waddy ADP (Mr. Ashley Maltman)

Summary:

Our client, FCC, has significant concerns that the VALP, in its current form, is not positively prepared insofar as Policy S2 (Spatial Strategy for Growth) fails to set out a strategy which seeks to meet the objectively assessed development and infrastructure need over the plan period. The failure to set out a positively prepared strategy for meeting the objectively assessed development and infrastructure needs of the District will have a detrimental impact upon the local and wider economy. The delivery of homes and infrastructure cannot be viewed in isolation. My client's site NLV029 assessed in the HELAA should be allocated.

More details about Rep ID: 1092

Representation ID: 1087

OBJECT GRE Assets represented by Lichfields (Mr. Myles Smith)

Summary:

The HEDNA Update contains a number of fundamental flaws which mean it does not form a sound robust evidence base suitable for underpinning the VALP. In particular, its justifications for amending the official population figures which result in a significant downward adjustment are not based on established sources of robust evidence and are contrary to a range of guidance and methodology documents published by ONS itself. An appropriate and robust assessment in line with the PPG suggest the demographic-led need figure should be 1,137 dpa.
The HEDNA Update has also failed to demonstrate that a 10% uplift could improve affordability.

More details about Rep ID: 1087

Representation ID: 1085

OBJECT SEGRO Plc represented by Turley Associates (Mr Tim Burden)

Summary:

There is clear lack of substance to justify Aylesbury Vale District meeting the purported 'unmet needs' of the southern Buckinghamshire authorities with respect to employment land provision. More specifically it is evident that AVDC is unlikely to meet the B8 requirements of the FEMA on account of its poor strategic connectivity and with explicit reference to the District being unlikely to meet warehousing requirements over the plan period. The portfolio of sites available are limited and as set out in the Turley representation for SEGRO Plc, are unlikely to be deliverable. The site selection and sustainability appraisal process is flawed.

More details about Rep ID: 1085

Representation ID: 1083

OBJECT The Guinness Partnership represented by Woolf Bond Planning (Mr Douglas Bond)

Summary:

We object to the significant concentration of the strategic sites within Aylesbury
and the failure to allocate larger and also more medium size sites at the other
sustainable locations at settlements as being identified in the hierarchy in Table 2,
in particular at Milton Keynes.

Such a significant concentration of new houses in one settlement is a high risk strategy that either needs to contingences or alternative, replacement allocations away from Aylesbury.

More details about Rep ID: 1083

Representation ID: 1070

SUPPORT Central Bedfordshire Council (Ms. Sally Hicks)

Summary:

Central Bedfordshire Council agrees with the extent of the HMA, methodology and conclusions of the HEDNA. We commend the Councils aspirations to deliver 27,400 homes, including the provision of 8,000 to meet unmet needs from Wycombe, Chiltern and South Bucks. CBC supports the spatial distribution of growth.

It is surprising that work undertaken in respect to the Luton HMA growth options study is not reference, as a minimum to confirm the conclusion that Aylesbury does not at the current time need to meet any unmet needs arising within the Luton HMA.

In relation to employment, we note that there is a current over supply within Aylesbury of over 100 ha, we would advise that given the likely growth pressures, it may be prudent to seek to ensure good quality employment land is retained.

More details about Rep ID: 1070

Representation ID: 1061

OBJECT RPS Group (Conor Doyle)

Summary:

DCLG published the 'Planning for the right homes in the right places' consultation paper in October 2017 which proposes an increase in housing need Aylesbury Vale, from 965 to 1,499 units per annum, which is an increase of circa 50%.
As such, the local authority will likely require to allocate further housing growth in the future and NMA002 is well placed to accommodate residential development.

We propose that AVDC brings the site forward for residential use (C3) or if not included within the VALP, that AVDC brings the residential use (C3) in the early review of the Local Plan.

More details about Rep ID: 1061

Representation ID: 1060

SUPPORT Mr B Robson

Summary:

BwB PC supports policies S2 and S3 for not making housing allocations for Bierton (including Broughton), in view of the very significant development already approved for the Parish, the need to prevent coalescence and the need to reinforce the identity and setting of the village (as stated in Para 4.94).
BwB PC considers the Policies to be legally compliant and to comply with the duty to co-operate and are sound

More details about Rep ID: 1060

Representation ID: 1036

OBJECT North Bucks Parishes Planning Consortium (Mr Geoff Culverhouse)

Summary:


* The need to rationally and objectively identify those existing communities and other areas of the Vale which are best suited to deliver major housing growth to 2033.
* The fact that with 30% of the housing growth during the Plan period accommodating unmet need for districts bordering the south of the Vale, there does not appear to be a recognition that logic demands these homes should be located reasonably close to those districts.
* The failure of the Sustainability Assessment (SA) to make a valid and justified comparative analysis of sustainability between the proposed strategic settlements.

More details about Rep ID: 1036

Representation ID: 1034

OBJECT Ms Martha Ortegon

Summary:

I object the referred draft for not including as suitable for residential purposes the Site SHLBUC054 as I proposed. In contrast the draft includes the site SHLBUC051 which is just in the opposite side just in front of our site.

More details about Rep ID: 1034

Representation ID: 1017

OBJECT Barwood Development Securities Limited represented by WYG (Mr Keith Fenwick)

Summary:

This approach fails to have regard to the DCLG's proposed new methodology, which if adopted would likely result in a further increase in the numbers of dwellings required per annum in Aylesbury Vale.

More details about Rep ID: 1017

Representation ID: 1014

OBJECT Berkeley Strategic Land Limited (Ms Eleanor Fritton)

Summary:

Berkeley is of the view that the level of housing proposed in the Local Plan will not be delivered and, as a consequence, the housing need in the HMA will not be met in full.

More details about Rep ID: 1014

Representation ID: 1005

OBJECT Land and Partners Limited (Mr Jonathan Harbottle)

Summary:

The methodology for calculating the OAN is not aligned with the evidence on household formation
rates. This requires justification for the plan to be found sound.
The starting point should be to meet needs where they arise in each district within the HMA, but this
appears not to be the case. L&P has detailed knowledge of sites in other Bucks districts which have
capacity for additional sustainable development.

More details about Rep ID: 1005

Representation ID: 1004

OBJECT Newton Longville Parish Council (Mr Mike Galloway)

Summary:

Starting the plan period from 2013 is misleading, leads to public confusion and is not effective. Around 50% of the housing in the plan has already delivered or committed. It should be modified to run from 2017 or 2018.
Consideration should be given to splitting the Local Plan into two or three parts which can potentially be adopted even if more work is required on others.
Consideration should be given to deferring meeting unmet need from elsewhere until later. Exemplar cases have been accepted with a clear policy commitment as to how any such unmet need would be dealt with.

More details about Rep ID: 1004

Representation ID: 1003

OBJECT Lands Improvement Holdings Plc represented by Indigo Planning Limited (Mr Michael Wood)

Summary:

The needs of Aylesbury District: consider that the adjustments made to the December 2016 HEDNA mean that it does not reflect AVDC's true FOAN.

Unmet needs: assumptions now made are, not justified.

Government standard methodology: gap between the Council's assessment of need and an approach which factors in housing stress and confirms that our assessment of FOAN is itself conservative.

FOAN scenarios: current housing target not meeting true FOAN

Housing supply shortfall: VALP is not sound as it does not deliver a robust five year housing land supply against either the artificially depressed current VALP target, or the realistic target.

More details about Rep ID: 1003

Representation ID: 989

OBJECT Hertfordshire County Council (Mr Lewis Claridge)

Summary:

We appreciate that following this settlement hierarchy and concentrating growth in the largest town is intended for reasons of sustainability and being able to provide needed infrastructure and access to jobs for the growing population. However, the location of Aylesbury close to the boundaries of Hertfordshire, the direct road links, and the close cross-boundary connections and commuter flows between Aylesbury, south west Hertfordshire and Luton / Dunstable for instance, means that there needs to be an understanding of the likely cross boundary, cumulative impacts on the highway and transport networks of planned growth in all of these areas.

More details about Rep ID: 989

Representation ID: 978

OBJECT DJ Kimble

Summary:

3.3 AND POLICY SI SUSTAINABLE DEVELOPMENT

I OBJECT TO THE VALP BECAUSE

PLACING TOO MANY HOUSES IN TOO SMALL AN AREA ULTIMATELY LEAD TO TRAFFIC PROBLEMS THAT WILL LEAD TO ECONOMIC STAGNATION. THIS IS NEITHER A JUSTIFIED NOR AN EFFECTIVE STRATEGY.

ALL IN ALL, I FEEL THE IMPACT ON THE ROADS AND TRAFFIC SYSTEM NORTH AND SOUTH OF AYLESBURY WILL CAUSE CHAOS AND DESTROY VILLAGE LIFE .

More details about Rep ID: 978

Representation ID: 974

OBJECT Louisa Macey

Summary:

I object to the VALP for the following reasons:
VALP proposes a 61% increase in population in the population of Maids Moreton, whereas the average for all medium sized villages is 14%.
There is little employment here, the nearest being Milton Keynes or in the south of the country. Maids Moreton has been singled out to accommodate the housing needs of the south of the country.
VALP proposals will destroy the natural environment and reduce open vistas, and destroy the specific feeling of a village community.
VALP will damage the visual aspect on entering the village.
VALP proposals are to use pasture and farmland, not using brown field sites.
VALP will destroy the clearly defined boundary and individual character of the village.
VALP will further worsen existing traffic problems and will remove existing householder and business parking.
VALP will increase the demand for medical and social services in the area which are already over-stretched.
VALP will destroy the district identity of Maids Moreton, allowing it to just become a dormitory village that will affect the community spirit of its residents.
Overall, this proposal does not meet the widely accepted definition of sustainable development.

More details about Rep ID: 974

Representation ID: 973

OBJECT Mrs Lydia Macey

Summary:

I object to VALP for the following reasons:
VALP proposes a 61% increase in population in the population of Maids Moreton, whereas the average for all medium sized villages is 14%.
There is little employment here, the nearest being Milton Keynes or in the south of the country. Maids Moreton has been singled out to accommodate the housing needs of the south of the country.
VALP proposals will destroy the natural environment and reduce open vistas, and destroy the specific feeling of a village community.
VALP will damage the visual aspect on entering the village.
VALP proposals are to use pasture and farmland, not using brown field sites.
VALP will destroy the clearly defined boundary and individual character of the village.
VALP will further worsen existing traffic problems and will remove existing householder and business parking.
VALP will increase the demand for medical and social services in the area which are already over-stretched.
VALP will destroy the district identity of Maids Moreton, allowing it to just become a dormitory village that will affect the community spirit of its residents.
Overall, this proposal does not meet the widely accepted definition of sustainable development.

More details about Rep ID: 973

Representation ID: 969

OBJECT R Wills

Summary:

Objects to the allocation of sites in Buckingham not allocated in the Neighbourhood Plan. The Council should uphold the wishes of residents where there is a neighbourhood plan in place. Shenley Park would be a preferable site as it is close to a large town and would not undermine the neighbourhood planning process.

More details about Rep ID: 969

Representation ID: 958

OBJECT Village Foundations (Mr Nick Wyke)

Summary:

The strategy aims to accommodate the unmet needs of needs of the other Buckinghamshire authority areas. Whilst the aim to protect the Green Belt is supported, it is considered that there is additional capacity within Wycombe, South Buckinghamshire and Chiltern Districts for sustainable development.

More details about Rep ID: 958

Representation ID: 922

OBJECT Jake Collinge Planning Consultancy Ltd (Mr Jake Collinge)

Summary:

The housing requirements set out in Policy S2 should be increased to take account of the new methodology in connection with the calculation of the Objectively Assessed Need for Housing, whilst also taking account of the effects of the Oxford to Cambridge Expressway. The consequences of such should 'drop-down' the existing strategy but include provision for a new settlement.

More details about Rep ID: 922

Representation ID: 883

SUPPORT Chiltern Area of Outstanding Natural Beauty Conservation Board (Dr Lucy Murfett)

Summary:

The Chilterns Conservation Board supports and welcomes the Council's approach of accommodating some unmet needs of the local authorities in southern Buckinghamshire, which are highly constrained by the Chilterns AONB. In this important way, the Council is demonstrating good practice under the Duty to Cooperate, and its Duty of Regard to conserving and enhancing the natural beauty of the AONB under the Countryside and Rights of Way Act 2000 (section 85).

More details about Rep ID: 883

Representation ID: 872

OBJECT Great & Little Kimble cum Marsh Parish Council represented by Mr Neil Homer

Summary:

We welcome the VALP seeking to accommodate unmet housing need from Wycombe District. We also welcome the constraints on development at smaller villages and in the countryside. However, we are concerned that the cumulative transport effects of the Aylesbury Garden Town (especially its South and South West proposals) have not taken into account the scale of developments planned at Wendover and at Princes Risborough. We doubt public transport improvements will be enough to mitigate those effects. We are also concerned that a failure to deliver supporting infrastructure in a timely fashion, will have major adverse consequences for our Parish.

More details about Rep ID: 872

Representation ID: 847

OBJECT Mr Connolly represented by WYG (Mr Keith Fenwick)

Summary:

Object to S2, the housing need has reduced since the draft plan, this is not sound in the context of the housing crisis and the NPPF requirement to significantly boost housing supply. VALP fails to have regard to DCLG's proposed new methodology, which identifies 1,499dpa need. It fails to adequately consider the role of Aylesbury Vale District in the development of the East-West Rail link, and its position within the Cambridge-Milton Keynes-Oxford Corridor, particularly with its proximity to the growth hub of Milton Keynes.

More details about Rep ID: 847

Representation ID: 846

OBJECT Mrs Claire Woodward represented by WYG (Mr Keith Fenwick)

Summary:

Object to S2, the housing need has reduced since the draft plan, this is not sound in the context of the housing crisis and the NPPF requirement to significantly boost housing supply. VALP fails to have regard to DCLG's proposed new methodology, which identifies 1,499dpa need. It fails to adequately consider the role of Aylesbury Vale District in the development of the East-West Rail link, and its position within the Cambridge-Milton Keynes-Oxford Corridor, particularly with its proximity to the growth hub of Milton Keynes.

More details about Rep ID: 846

Representation ID: 844

OBJECT AB Planning & Development Ltd (Mr Andrew Bateson)

Summary:

Increase District housing numbers by 5,000-6,000.
Reduce an over-concentration of development planned at Aylesbury and increase commensurately the development totals planned elsewhere to help facilitate deliverability.
Provide a full outer ring road for Aylesbury, if the scale of development currently planned at Aylesbury is maintained.
More development allocations and/or targets ought to be set for the named larger and medium-sized villages.

More details about Rep ID: 844

Representation ID: 843

OBJECT Slough Borough Council (Mr Paul Paul Stimpson)

Summary:

The Council objects to the submission version of the Vale of Aylesbury Local Plan on the grounds that it is not reasonable or sustainable to plan to import housing into Aylesbury from the part of South Bucks District that is not within the same functional Housing Market Area.

More details about Rep ID: 843

Representation ID: 786

OBJECT Define (on behalf of Bovis Homes) (Mr Mark Rose) represented by Define (on behalf of Bovis Homes) (Mr Mark Rose)

Summary:

Considered unsound as it is:
-not positively prepared as it is not based on a strategy that will ensure that the OAN will be met within the plan period;
-not justified in that it is not the most appropriate strategy and has not properly considered reasonable alternative strategies;
-not effective in that some allocation sites will not deliver the scale of development the Submission Plan currently assumes, and the identified needs will not be met;&
-inconsistent with national policy in that it doesn't fully reflect the Government's priorities/policies in terms of enabling sustainable development and boosting the supply of housing.

More details about Rep ID: 786

Representation ID: 755

SUPPORT Peter Brett Associates LLP (Mr Tim Coleby)

Summary:

BA supports Policies S1 and S2 in respect of sustainable development and the spatial strategy for growth, especially now the earlier draft VALP's reference in S2 to no more than 27ha of new employment land being required has been tempered with "and additional provision of employment land to contribute to the employment needs of the wider economic market area". This is particularly relevant to the employment provision envisaged within the Woodlands development.

More details about Rep ID: 755

Representation ID: 734

OBJECT Sue Barber

Summary:

Halton is a separate parish and NOT part of Wendover. Why has the housing allocation for Wendover now been moved to Halton? There is no evidence provided to demonstrate that Halton can accommodate 1,000 houses. Wendover is stated as a sustainable settlement suitable for development. Wendover is not Halton. Halton is a rural settlement with agriculture at its core and not a sustainable settlement. There is insufficient evidence about how Halton will become a sustainable community.

More details about Rep ID: 734

Representation ID: 728

OBJECT Aldbury Parish Council (Mrs Lucy Bancroft)

Summary:

Aldbury Parish Council wishes to draw attention therefore to the serious omission of consideration of the impact on the infrastructure of a Parish in the neighbouring
county of Hertfordshire (and indeed the other Town and Parish Councils of West Dacorum).

More details about Rep ID: 728

Representation ID: 724

SUPPORT Mr Andrew Docherty

Summary:

The proposed hierarchy and general approach is considered the appropriate way to deliver the required housing

More details about Rep ID: 724

Representation ID: 711

SUPPORT Rockspring Hanover Property Unit Trust represented by Castle Planning (Mrs Julia Riddle)

Summary:

The sites identified in the HELA, which may form the growth at Westcott Village are not the most appropriate locations and all sites should be subject of more rigorous testing.

More details about Rep ID: 711

Representation ID: 677

SUPPORT Whaddon Parish Council (Ms Suzanne Lindsey)

Summary:

Whilst supporting this policy, WPC reiterates that whilst 'The strategy also allocates growth at a site adjacent to Milton Keynes which reflects its status as a strategic settlement immediately adjacent to Aylesbury Vale District' , these 2212 houses, of which 1855 are on two main proposed sites do nothing, or very little, to help the economy or well being of the Vale of Aylesbury, - which should surely be the focus of this plan.
Had the two sites adjoining Milton Keynes not been granted planning consent already, then WPC would have been objecting to this element of the S2 policy.

More details about Rep ID: 677

Representation ID: 661

OBJECT Claydon Estate represented by Strutt and Parker (Mr Craig Noel)

Summary:

VALP will be out of date soon after it is adopted due to it being blind to progress in bringing forward significant strategic infrastructure, the new method for calculating
housing need, progress in relation to cross boundary planning and the potential of the O2C Corridor.

More details about Rep ID: 661

Representation ID: 593

OBJECT Mr Peter Hoare

Summary:

3.3, 4.16, 4.17, D-AGTI, D-AGT3, and Policy H1 do not provide effective solutions or are totally inadequate for the development proposals.

More details about Rep ID: 593

Representation ID: 578

OBJECT Ms F. Mari

Summary:

I have recently tried to consider as many documents as possible relating to the VALP but to have to read the equivalent of a number of academic texts in less than six weeks is an impossibly tall order. In addition to the VALP itself, in its assorted incarnations, the other significant document in this matter has been Buckingham Town Council's response to the VALP. (As summarised in the document at (09/12/2017) https://www.buckingham-tc.gov.uk/wp-content/uploads/2017/02/171211-ExFC-Appendix-A-1.pdf ) I here endorse all the objections made in that document, noting that these objections predominantly focus on a general unsoundness in the VALP.

More details about Rep ID: 578

Representation ID: 574

OBJECT Marrons Planning (Jane Gardner)

Summary:

It is inappropriate to specify "2,212" homes and to attempt to inject this degree of precision into a strategic planning policy. In any event, there is greater scope for further development to the south west of Milton Keynes which would enable the provision of a greater number of dwellings.

Flexibility will be essential to ensure that changing circumstances and requirements can be accommodated during the application process.

The final sentence is too dogmatic in its approach to development proposals which will contravene the presumption in favour of sustainable development as set out in Policy S1.


More details about Rep ID: 574

Representation ID: 571

OBJECT Valerie Jones

Summary:

Object, S2:
4.16 Aylesbury Transport Strategy - ATS, 4.17 Interventions including Outer Link Roads, D-AGT1 South Aylesbury, 3.3 and Policy S1 Sustainable Development, New Settlement, 3.22 Preserving character and identities of neighbouring settlements and resisting development compromising open countryside between settlements, Aylesbury Town Centre, D-AGT4 Aylesbury south of A41 Hampden Fields, RAF Halton, Policy H1 : Affordable Housing, East-West Rail, Oxford-Cambridge Expressway, Air Quality Requirement on Developers

More details about Rep ID: 571

Representation ID: 564

OBJECT Mr Stephen Richards

Summary:

Object to new homes being built because of the issues with traffic and congestion and the impact this will have on the AONB. Homes should be built in the north instead.

More details about Rep ID: 564

Representation ID: 561

SUPPORT Wokingham Borough Council (Mr James McCabe)

Summary:

The plan outlines that Aylesbury Vale is able to meet their own housing need as well as the unmet need of Wycombe District as well as Chiltern/South Bucks Districts.

Wokingham Borough Council is therefore satisfied that on the basis of available information that AVDC are planning to meet the need for the District within the Buckinghamshire HMA, but would welcome further understanding of pressure regarding the meeting of the housing need as an HMA as well as impact on the East Berkshire HMA.

More details about Rep ID: 561

Representation ID: 557

OBJECT Mrs Claudia Belardo

Summary:

The number of houses that AVDC is proposing directly contradicts that being required in the Housing Need Consultation Data (Published 14th September 2017) (attached)

Higher number: "based on proposed formula, 2016 to 2026 " = 1,499 per annum = maximum of 14,990 houses in this time period.

Actual Number "Current local assessment of housing need, based on most recent publicly available document" = 965 per annum = maximum of 9,650 houses in this time period.

However, these latest proposals would see nearer 23,000 new homes being built which far outstrips what has been ruled as Sustainable for the area.

More details about Rep ID: 557

Representation ID: 514

SUPPORT Mrs Roz Green

Summary:

I am pleased there will not be any further building in Wendover as the Halton Camp development of 1000 houses plus the 128 houses already built or planned will cover the required 1280 required in the Plan. I am, however, concerned about future development which would effect the coalescence between Wendover and Halton.

More details about Rep ID: 514

Representation ID: 503

SUPPORT Mrs Nicky Gregory

Summary:

e. I am pleased to note there will be no further building development in Wendover as the Halton Camp development will provide 1000 homes, the remaining 128 are already covered by completions and commitments. Especially as I have a concerns about coalescence between Wendover and Halton.

More details about Rep ID: 503

Representation ID: 471

OBJECT Mr and Mrs J L Wickson and S G Raven represented by JMI Planning Ltd (Mr Jim Malkin)

Summary:

We believe this strategy to be ineffective, significant concerns are raised with the
deliverability of the larger allocations. We are therefore of the view that the Proposed Submission Local Plan places too
much reliance on the new settlement, and also on development on unspecified sites
around Milton Keynes and within strategic settlements.

The failure of the Proposed Submission Local Plan to allocate organic and sustainable
growth to smaller villages including Nash is inconsistent with National Planning

More details about Rep ID: 471

Representation ID: 468

OBJECT Arnold White Estates (Bob Williams) represented by Gardner Planning Ltd (Mr Geoff Gardner)

Summary:

ORS District number is flawed at 970 homes p.a., well below other sources - ONS (1,092), GL Hearn 2015 (1,326), DCLG (1,499). CMKOx figures will be even higher. Household figures rose in the 2014 based projections (from 18,404 to 21,028), but ORS figures fell (from 21,289 to 19,385). ORS uses 10-year migration but ONS is 5-year. ORS have raised this point many times but ONS has not agreed. ORS numbers are so different complete re-assessment is required.
5YHLS is wrongly calculated and cannot be demonstrated - inadequate provision is made for 'persistent under-performance'.

More details about Rep ID: 468

Representation ID: 426

OBJECT Hampden Fields Action Group (Dr Glynn White)

Summary:

The allocation of housing is too great for the areato the South of Aylesbury. The plan will lead to more local traffic in the peak times as people commute out of the town. The placement of large housing developments which do not have sufficient public transport links will result in very high car usage and exacerbate the problem. The expected jobs are no more than allocations on map. AVDC has a particularly bad track record of delivering jobs. Aylesbury is no more than a dormitory town for London, Milton Keynes and Oxford commuters.

More details about Rep ID: 426

Representation ID: 368

SUPPORT Milton Keynes Council (Mr Jon Wellstead)

Summary:

Policy S2 (Spatial strategy for growth) of the Proposed Submission Local Plan provides for about 1,855 new homes adjacent to Milton Keynes. We have no objections in principle to the inclusion of Salden Chase (SWMK), provided that the infrastructure requirements for Salden Chase outlined in the VALP are retained in the final plan and are delivered in the manner set out in the attached Memorandum of Understanding.

More details about Rep ID: 368

Representation ID: 362

OBJECT Joyce Graham

Summary:

You do not provide schools, doctor's surgeries, sufficient roads to cope with all the countryside you will ruin, all the wildlife you will kill putting up housing to turn Aylesbury into a borough of London.

Aylesbury is loosing it's character each time you agree to plans that turn our road system into one long traffic jam. If you believe that builders care about Aylesbury other than to make money and run straight to the bank, you are fooling yourselves. They will not be living with the results of the crowding and lack of facilities. I would like to think that those of the council that are pushing these plans will be around to be accountable for the mess they are making.

More details about Rep ID: 362

Representation ID: 275

SUPPORT Paradigm Housing (Mr Steve Brown)

Summary:

The only query I have as I do agree you have followed the correct procedure for Duty to Cooperate in the Housing market area is the fact Lutons unmet need locations is still undetermined. It looks like they were looking to AVDC to see whether they would accept an allocation. As far as I am concerned as AVDC have already taken 8,000 unmet need from three other LAs it would be unreasonable to expect AVDC to accept a higher figure.

Please be aware it would be wise to consider Chiltern/ South Bucks unmet need number could well rise as they will be submitting their local plan after March 2018 when the new methodology will kick in. As they feel they have exhausted all suitable sites for development it may be AVDC will have to accept a higher figure. (Slough will also have a large unmet need as this has not been determined either)

More details about Rep ID: 275

Representation ID: 207

OBJECT The University of Buckingham represented by Delta Planning (Maria Sheridan)

Summary:

Objection is raised to the level of housing numbers identified in this version of the Plan on the basis that it is not positively prepared.

More details about Rep ID: 207

Representation ID: 206

OBJECT Crevichon Properties Ltd represented by Delta Planning (Maria Sheridan)

Summary:

It is considered that the development strategy and proposed level of housing provision set out in Policy S2 will not provide for sufficient levels of sustainable development to meet the OAN of the District and HMAs and therefore does not meet the test of soundness as it fails to accord with NPPF.

More details about Rep ID: 206

Representation ID: 190

OBJECT Mr Tim Jones

Summary:

The document appears to assume as a given, that we have to adopt the additional homes that are not to be built in South Bucks, this is unreasonable. Where does this passing of responsibility end? Can we expect to absorb the shortcoming of Northants, Beds and Milton Keynes as well?

Once this 'process' is established there will be boundary or control that can be fairly reasoned for or against. We must address the needs of North Bucks and North Bucks only. The environmental impact of this diktat will be enormous.

More details about Rep ID: 190

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