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Representations on VALP Proposed Submission - S7 Previously developed land
SUPPORT Persimmon Homes Midlands represented by Bidwells (Mr Robert Love)
We are supportive of Policy S7 and would actively encourage the Council to identify appropriate sites on their Brownfield Land Register. Policy S7 should be consistent with the proposed allocations in the VALP by prioritising the redevelopment of previously developed land in line with Policy S1 and Objective 1 of the VALP.
SUPPORT Wendover Neighbourhood Plan Steering Group (Mr Jonathan Clover)
The policy is acceptable in principle, subject to the need to develop a suitable
Masterplan for the RAF Halton site.
OBJECT Historic England (Mr Martin Small)
whilst we support the principle of the re-use of previously-developed land, occasionally such land or sites can have historical interest. We therefore welcome the caveat in the policy regarding environmental value, in addition to the caveat regarding impact on local character, as part of the positive strategy for the conservation and enjoyment of, and the clear strategy for enhancing, the historic environment required by paragraphs 126 and 157 of the National Planning Policy Framework.
OBJECT Crest Strategic Projects represented by Savills Southampton (Mr Jon Gateley)
CSP does not object to this policy, which closely reflects the NPPF's prioritisation of previously developed land. However, we observe that the VALP's proposed approach to RAF Halton, in terms of retaining the site within the Green Belt, potentially risks failing to make the most efficient use of that site. As such, the policies for RAF Halton are ineffective and unjustified, as set out later in this document under the specific allocation policy for that site, and in accompanying technical appendices.
OBJECT Wheeldon Estates represented by Savills (Mr Geraint Jones)
The representations set out our support for the recognition of Buckingham as a 'strategic settlement' (Policy S3), the Council's approach to re-use of previously developed land (Policy S7), and confirm the flexibility in terms of appropriate uses within town centres (Policy D6). In addition, the representations confirm our broad support for allocation BUC040 in Buckingham, but with the caveat that greater clarity is required regarding the distribution of uses.
OBJECT Rectory Homes Limited (Mr Tim Northey)
Whilst we support the policy's encouragement of re-use of previously developed land (PDL), it needs to be recognised within the policy that Aylesbury Vale maintains very limited PDL resource and therefore the majority of development will have to take place on greenfield sites to deliver the identified housing requirement.
OBJECT Cerda Planning Limited (Tina Pearsall)
No specific objections are lodged to the provisions of Policy S7, however, it is important that as applied it should not be read as providing some sort of sequential approach seeking to utilise previously developed land in favour of greenfield land. If the policy were to be applied in that manner, it would be inconsistent with the NPPF which does not contain any such sequential approach.
OBJECT Ainscough Strategic Land represented by Turley Associates (Taylor Cherrett)
However, ASL do consider that the policy in its current form is to narrow and restrictive
and would request that the Policy is amended with the following revisions identified in
OBJECT Aviva Life & Pensions UK Limited represented by GL Hearn (Mr David Maxwell)
Aylesbury Vale District should provide commitment to preparation of a brownfield land register, to include appropriate previously developed sites that are suitable, available and deliverable for residential developments.
SUPPORT Gladman Developments Ltd (Ms Nicole Penfold)
Support this policy, however note that Policy S1 (d) seeks to prioritise brownfield land and is not consistent with this policy.
OBJECT Corbally (Finmere) Group and Mrs Vanessa Tait represented by WYG (Sarah Butterfield)
Objection is raised to Draft Policy S7 as it goes beyond the scope of national policy and
is therefore not consistent with the national policy.
SUPPORT Chiltern Area of Outstanding Natural Beauty Conservation Board (Dr Lucy Murfett)
The Chilterns Conservation Board supports the policy which encourages the re-use of previously developed land in sustainable locations
OBJECT AB Planning & Development Ltd (Mr Andrew Bateson)
The general support offered towards redevelopment of previously developed (brownfield) land, which is broadly consistent with national guidance, is overly constrained by caveats within the policy that could be used later to attempt to thwart development. To some degree, the suggested caveats to brownfield land redevelopment is already reflected in a plan that is currently highly reliant on greenfield site developments in order to accommodate new needs.
SUPPORT Whaddon Parish Council (Ms Suzanne Lindsey)
Policy S7 Whaddon PC Support.
OBJECT Mr Terry Benwell
There can be no consistency in site selection using the wording in S7, because the ambiguity can give rise to a subjective interpretation of previously developed land, this is not the intention of the NPPF. Also the word SUSTAINABLE is not used in the NPPF.