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Representations on VALP Proposed Submission - S9 Monitoring and review
OBJECT Mr David Vowles
Policies S9 and D2 contain ambiguities in respect of the actin to be taken in the event that housing delivery falls short of what is required and, indeed, in respect of what those requirements are.
OBJECT FCC Environment represented by Sirius Yorkshire (Joanna Berlyn)
The Buckinghamshire Growth Strategy (BGS) sets the economic development strategy and vision for the County of Buckinghamshire to 2050. The BGS proposes a Joint Spatial Strategy for the County that will set the growth framework for the delivery of the 105,000 new homes identified up to 2050. The objectives for a Joint Buckinghamshire Spatial Plan are supported and must be fully recognised and set out within the emerging VALP in order to plan coherently and comprehensively the next phase (and phases) of development that will be required beyond the early review of the Local Plan.
OBJECT The Guinness Partnership represented by Woolf Bond Planning (Mr Douglas Bond)
We support the inclusion of a monitoring and review policy but object to the proposed wording.
3.30. As drafted, the policy relies upon a review of the Plan to allocate sites for development in the event the site allocations in the VALP are not coming forward at the rate expected in the Plan. This fails to provide for a justified and/or effective Plan.
OBJECT Persimmon Homes North London represented by Woolf Bond Planning (Mr Steven Brown)
As drafted, the policy relies upon a review of the Plan to allocate sites for
development in the event the site allocations in the VALP are not coming forward
at the rate expected in the Plan. This fails to provide for a justified and/or
OBJECT Crest Strategic Projects represented by Savills Southampton (Mr Jon Gateley)
should provide some degree of flexibility and positive supply, to defend against any unavoidable delay to plan review. As part of this, an automatic trigger for an uplift of the housing requirement, applicable from two years from plan adoption should be considered, dependent on available land supply.
Both Policy S9 and Policy D2 should be amended as shown below, with the former being clearer as to the review mechanism, and the latter enabling sustainable and well-located sites adjacent at Strategic Settlements to come forward. This would be a criteria-based policy enabled should there be no sufficient 5-year housing land supply.
OBJECT Society of Merchant Ventures represented by Savills Reading (Mrs Rebecca McAllister)
Policy S9 states that the VALP will be reviewed, or proposals for alternative sustainable sites considered favourably (subject to compliance with other policies) in certain circumstances.
If the need for a review of the District's housing requirement is not accepted to provide for the full OAN in this Plan, this policy needs to be more robust.
See further details in the attached covering letter.
OBJECT Persimmon Homes Midlands represented by Bidwells (Mr Robert Love)
Considering that the VALP does not adequately meet the OAN (refer to comments under Policy S2). As
currently drafted, an early review of the VALP is essential given the uncertainty of housing numbers within
the HMA and pending changes to Government guidance on calculating housing requirements and changes
to the NPPF. It is however necessary to provide greater clarity and certainty on the timing for a review of
the VALP. The policy should explicitly state when the replacement VALP will be adopted following a review.
OBJECT Careys New Homes represented by Bidwells (Mr Robert Love)
An early review of the VALP is essential given the uncertainty of housing numbers within the HMA and
pending changes to Government guidance on calculating housing requirements and changes to the NPPF.
It is however necessary to provide greater clarity and certainty on the timing for a review of the VALP. The
policy should explicitly state when the VALP will be re-adopted following a review.
SUPPORT Central Bedfordshire Council (Ms. Sally Hicks)
CBC further supports the identification of the need for an early review of the Vale of Aylesbury Local Plan to consider the potential for new housing at RAF Halton once it closes as well as the potential for a new settlement to help meet future growth requirements. This would need to be considered within the contest of the Cambridge Milton Keynes-Oxford Corridor and the government aspirations for significant growth to meet housing demand.
OBJECT Granborough Parish Council (Victoria Firth)
The GPC is extremely concerned about the need to review the VALP within a very short time of its adoption to accommodate further government requirements for housing. If the proposed unmet need figures from the other DC's are accepted, this could be taken as an acceptance that these authorities are "full" and will look for yet further development in AVDC to meet identified need in their areas which are in the main serving London and the Thames corridor. The GPC's concerns are further exacerbated by the proposals for the Oxford - Cambridge Express way which will generate the demand from Government for even more housing and commercial sites to be identified in the centre/north of AVDC on a scale which will potentially dwarf those required so far. Implicit in this is the prospect that AVDC could be seen as a prime area for massive scale development simply because it is currently rural and does not have the benefit of statutory protection.
OBJECT GRE Assets represented by Lichfields (Mr. Myles Smith)
The assessment and reasonable alternatives set out in the SA Technical Annex for Aston Clinton in support of the SA , is underpinned by a point in time assessment of need s, does not consider how population and new development within the district (including the provision of new schools) may affect the District needs and provision, and does not consider a smaller scale growth alternative for Aston Clinton. As such, the VALPs proposed spatial strategy, set out in Policy S2 has not been informed by robust evidence or an objective view on the reasonable alternatives, and is therefore not justified.
OBJECT Richborough Estates represented by RPS Planning & Development (Mr Cameron Austin-Fell)
Although RPS agrees that a strong monitoring policy is needed, the scale of the shortfall is already significant and would trigger this policy. The Council already recognises through this policy that the future housing need will increase, however the Council makes no provision through the VALP to meet this.
Were the Council to bring forward a monitoring policy, RPS consider that this should be clearer in the triggers for review. As currently stated a plan review would commence if site allocations fail to be delivered at the rate expected in the plan. At which year would this occur?
OBJECT Gladman Developments Ltd (Ms Nicole Penfold)
The policy lacks the necessary detail and triggers to ensure it is effective.
OBJECT Waldridge Garden Village Consortium represented by Pegasus Group (on behalf of Jeremy Elgin) (Mr Neil Tiley)
The trigger mechanisms are not sufficiently precise to ensure that housing is delivered as intended.
OBJECT Lands Improvement Holdings (LIH) represented by Savills Oxford (Reece Lemon)
LIH has set out above the need to take on board a number of strategic issues in the VALP rather than rely on
an early review. The evidence is clear now that such a review will be required. As has been demonstrated at
other local plan examinations, where there is such clear evidence of strategic issues and/or deficiencies these
should be taken in to account within the emerging plan and not 'kicked along the road' for some date in the
OBJECT Lands Improvement Holdings Plc represented by Indigo Planning Limited (Mr Michael Wood)
Given the substantial shortfall against FOAN identified in Section 2, it is vitally important that
Policy S9 is amended to ensure that it contains a robust and definitive review mechanism to
ensure it is effective, justified and positively prepared. The Council must plan to respond to
key changing circumstances which will significantly impact its housing and economic needs
which include the Government's standard methodology for calculating housing needs and
the Oxford to Cambridge Expressway.
OBJECT Jackson Planning (Planning Manager
As set out elsewhere in representations the plan completely fails to recognise the on-going work by the National
Infrastructure Commission (NIC) to accommodate over a million new homes in the Cambridge-Milton Keynes-Oxford arc.
There needs to be greater acknowledgement about the role Aylesbury Vale District Council (AVDC) must play in shaping
the future of the city as part of the 2050 spatial vision and the plan needs a specific policy that deals with how this will be
accommodated until 2033 which is the time period for the plan.
OBJECT Revera Limited (Mr Renshaw Watts) represented by Pegasus Group (Mr Rob Riding)
upon adoption of VALP (even assuming housing requirement remains as proposed) there will have been under-delivery in almost every year since 2013/14 with needs across the HMA falling to Aylesbury Vale but not having been met. Upon adoption they will need to apply a 20% buffer to afford the appropriate weight to housing proposals due to significant shortfall in provision across the HMA since 2013.
Effect of the application of necessary 20% buffer on adoption would result in a five-year land supply shortfall of circa 600 dwellings. This needs to be addressed within VALP through identification of additional deliverable allocations.
OBJECT Chiltern Area of Outstanding Natural Beauty Conservation Board (Dr Lucy Murfett)
The Chilterns Conservation Board is concerned that this policy provides so readily for the undermining of the development plan. Development should be plan-led. It should not be the case that a single policy becoming out of date because of a national policy change, or a single indicator shown not to be not achieving the Plan's objectives, or the slow delivery of a single site in the trajectory, bins the whole plan.
OBJECT Define (on behalf of Bovis Homes) (Mr Mark Rose) represented by Define (on behalf of Bovis Homes) (Mr Mark Rose)
Bovis Homes object to Policy S9, which is considered unsound on the basis that it:
- has not been positively prepared as it is not based on a strategy that will ensure that the objectively assessed housing needs will be met within the plan period;
- is inconsistent with national policy in that it does not fully reflect the Government's priorities and policies in terms of enabling sustainable development.