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Representations on VALP Proposed Submission - D2 Proposals for non-allocated sites at strategic settlements, larger villages and medium villages

Representation ID: 2727

OBJECT Shanly Homes Limited (Mr David Howells)

Summary:

Shanly Homes has reservations about whether the level of housing supply is sufficient to meet Government targets and about how these needs are going to be met.

Policy D2 as a whole seems to put substantial pressure on the allocation sites coming forward over a particular time period.

By considering alternative options now, the Council could exceed their housing supply figures and not be solely reliant on the allocated sites. Therefore, it is the opinion of Shanly Homes that the wording of Policy D2 should not restrict non-allocated sites coming forward only when allocated sites can't be delivered.

More details about Rep ID: 2727

Representation ID: 2722

OBJECT Kier Property represented by Planning Potential (Nona Jones)

Summary:

Whilst we agree with the principle of development within villages as set out in Policy D2, we consider a greater level of flexibility within the wording should be considered. It is well recognised that rural settlements inherently have more constrained footprints and natural and physical constraints than brownfield sites, consequently this wording precludes many sites with appropriate attributes to meet both the district and Newton Longville's housing needs. We urge the Council to reassess the wording of Policy D2 to plan more positively within the village context, and to do this now, to ensure the plan is effective.

More details about Rep ID: 2722

Representation ID: 2717

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

Summary:

O&H object to the change to Policy D2; its addition renders the policy unsound, ineffective and contrary to national policy.

* The addition to part c undermines housing delivery should allocations not come forward as intended, jeopardising the strategic objectives and the ability to meet increasing need;

*The amendment enables Neighbourhood Plans to determine settlement boundaries without taking account of local plan housing targets;

* Clarification is required on the compatibility with national policy and existing or emerging local plan policy;

* The amendment should be reviewed prior to and during the Examination, and after the updated NPPF's publication.

More details about Rep ID: 2717

Representation ID: 2710

OBJECT Mr David Vowles

Summary:

Policies S9 and D2 contain ambiguities in respect of the action to be taken in the event that housing delivery falls short of what is required and, indeed, in respect of what those requirements are.

More details about Rep ID: 2710

Representation ID: 2647

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

Summary:

Whilst O&H does not object to the principle of this policy and recognises that it has the potential to deliver additional development beyond that allocated and could support the delivery of small to medium sized sites in sustainable settlements, the following improvements could be made to this policy to enhance its effectiveness and more closely align with the Government's position set out within the Housing White Paper:

Add a new criteria c)... "development which can facilitate the delivery of necessary local infrastructure by providing sustainable growth (when considered against all other planning policies and meeting the criteria for sustainable development)."

More details about Rep ID: 2647

Representation ID: 2546

OBJECT Coda Planning (Mr Adam Murray)

Summary:

the proposed retreat from the level of
residential development that the settlement can support is inappropriate. The
Framework sets out that for a Local Plan to be sound it must deliver sustainable
development commensurate with what can be sustainably accommodated,
and with the OAN. In this case that means allocating a greater level of
development within Ickford and in light of the above the Proposed Submission
version of the VALP represents a step backwards away from 'soundness'

More details about Rep ID: 2546

Representation ID: 2491

OBJECT Gillian Mather

Summary:

In addition to this, I understand that there were plans to build 2000 houses near to Milton Keynes which were dropped by the Council. I believe this site should be reconsidered and the views of our local community taken into account.
For the reasons above I hope you reject the allocations.

More details about Rep ID: 2491

Representation ID: 2490

OBJECT John Mather

Summary:

I was also concerned to learn that the council rejected plans to allocate a large site near to Milton Keynes in the VALP. I do not believe that towns and villages should be burdened with housing when this is a reasonable alternative.

More details about Rep ID: 2490

Representation ID: 2422

OBJECT Wendover Neighbourhood Plan Steering Group (Mr Jonathan Clover)

Summary:

The above Policy is entirely sensible as a principle, but the WNP will need to
contribute to the development of practical criteria, so that the Policy is effective and
meets public concerns that in appropriate development
is not permitted.

More details about Rep ID: 2422

Representation ID: 2397

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: 2397

Representation ID: 2223

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

Summary:

object to the Plan as drafted and identify a need for the VALP to identify additional housing site allocations.
4.3. We object to the omission of two sites controlled by our client:
I. Land south of Lavante Gate and east of A4146; and
II. Land south of Eaton Leys and A4146 and west of Galley Lane.
4.4. The first site is deliverable in meeting the identified need for housing within the first five years of the Plan while the second forms part of a larger, longer term development within the plan period.

More details about Rep ID: 2223

Representation ID: 2122

SUPPORT Historic England (Mr Martin Small)

Summary:

we welcome criteria e and g of Policy D2, 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.

More details about Rep ID: 2122

Representation ID: 2066

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

Summary:

Land North of Broughton Lane, Bierton

We do not consider that the Council's assessment is correct. As such, we have
reassessed the site in accordance with the Stage 1 and Stage 2 methodologies
used in preparation of the HELAA.

More details about Rep ID: 2066

Representation ID: 2064

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

Summary:

Land South of Buckland Road, Aston Clinton.

Contrary to the LPA's assertions in the HELAA, the advice from the consultant
disciplines who have appraised the merits of the site as a housing allocation in
some considerable detail have confirmed the acceptability of developing the site
for housing.

More details about Rep ID: 2064

Representation ID: 2063

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

Summary:

For the reasons set out in response to policies S2, S9 and D1 above, we object to
the Plan as drafted and identify a need for the VALP to identify additional housing
site allocations.

We object to the omission of land controlled by our client as Aston Clinton and
Bierton which sites are deliverable in meeting the identified need for housing
within the first five years of the Plan.

More details about Rep ID: 2063

Representation ID: 2046

OBJECT Pitstone Parish Charity and the Hawkins family represented by Bidwells (Mr Derek Bromley)

Summary:

We act on behalf of landowners who have interests in the policy allocation PIT001.
The land is jointly owned by the Pitstone Parish Charity and the Hawkins family who both support the residential allocation of this site.

More details about Rep ID: 2046

Representation ID: 2028

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

Summary:

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.

More details about Rep ID: 2028

Representation ID: 1993

OBJECT Aylesbury Vale Estates LLP represented by Savills Reading (Mrs Rebecca McAllister)

Summary:

this policy is unduly restrictive and onerous. The Policy seeks to restrict proposals for non-allocated residential development within the built up areas of the strategic settlements, larger and medium villages to small-scale areas of land via infill and development that consolidates existing settlement patterns. The Policy will only support additional (i.e. large-scale) development on brownfield land (and land adjacent to the existing developed footprint of the settlement) in the circumstances where the Council's monitoring of delivery across the district shows that the allocated sites are not being delivered at the anticipated rate and subject to a number of criteria.

More details about Rep ID: 1993

Representation ID: 1966

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

Summary:

Policy D2 is too restrictive. There is no definition of 'small scale' trying to establish a definition would be fruitless as one would expect different definitions depending upon whether a site is in a village or one of the strategic settlements.

The supporting text at paragraph 4.122 says that unallocated sites will not normally be permitted. The housing requirement should be expressed as a minimum figure. It is likely to restrict development that constitutes sustainable development.

It does not allow for a proper balancing exercise to be undertaken.

Specific comments made on criteria e, f and g.

More details about Rep ID: 1966

Representation ID: 1957

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

Summary:

Whilst we do not object specifically to Policy D2, I would like to reiterate that we consider that proposed
development of my client's site at Wingrave represents an achievable, suitable and deliverable site to
support the necessary housing growth for Aylesbury Vale as detailed under our response to Policy S2 and
we request the request the allocation of the site for housing.

More details about Rep ID: 1957

Representation ID: 1933

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

Summary:

An objection remains in respect of the lack of any allocation to Bierton (which continues to be "downgraded" to a Medium Settlement), which has been subsumed into the housing requirement of Aylesbury. Our objection to the reclassification of Bierton from a Larger Village to a Medium Village still remain valid.
The principle of the approach in Policy D2 is to be welcomed as this provides sufficient flexibility to respond to housing shortfalls as they arise.

More details about Rep ID: 1933

Representation ID: 1834

OBJECT Rectory Homes Limited (Mr Tim Northey)

Summary:

he policy states that in the event of allocated sites not being delivered at the anticipated rate, then the policy will not be applied. Further clarity in the policy is required as to the circumstances that would trigger this event, for instance if the Council's Housing Land Supply Statement identifies a shortfall in housing land supply with a need to release additional land resources.

More details about Rep ID: 1834

Representation ID: 1752

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: 1752

Representation ID: 1722

OBJECT Mr Roger Williams

Summary:

The plan is unsound because it applies different environmental protection policies to villages not according to the environmental circumstances but to their size category.

This is of particular importance to the hilltop village Brill the special character of which would be threatened by the policy D2 which allows for development outside the village footprint.

More details about Rep ID: 1722

Representation ID: 1720

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

Summary:

The allocation of the site BUC046 in the VALP is fully supported. The technical work undertaken to date confirms that a scheme of 420 dwellings could be successfully achieved on the site. Wates full endorses the allocation and the number of dwellings proposed and makes a separate representation on the site allocation policy criteria.

More details about Rep ID: 1720

Representation ID: 1695

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

Summary:

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

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

More details about Rep ID: 1695

Representation ID: 1622

OBJECT Gladman Developments Ltd (Ms Nicole Penfold)

Summary:

Policy as drafted is too restrictive. Needs to provide greater flexibility for delivery outside of the allocations.

More details about Rep ID: 1622

Representation ID: 1530

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

Summary:

This approach is not however considered to accord with the requirements of the NPPF for a Local Plan
to be 'positively prepared' and should be considered unsound. Indeed, as currently drafted, Policy D2
would restrict housing insofar that it does not allow for a balanced judgement to be made when
assessing the suitability of individual development proposals. Instead, draft Policy D2 simply aligns
itself to the delivery of allocated sites within the emerging VALP.

No definition or guidance is
provided by the Council as to what will be regarded as a 'timely manner'.

More details about Rep ID: 1530

Representation ID: 1521

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

Summary:

Policy D2 is a restrictive policy that is not in accordance with the permissive approach set out in the NPPF.

More details about Rep ID: 1521

Representation ID: 1487

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

Summary:

Criteria a) and b) are overly restrictive. In accordance with the NPPF, the location of development should be assessed on its sustainable development merits and allow for sustainable development to be brought forward. This draft policy has the effect of restricting sustainable development from coming forward. All applications should be considered on their own merits.
On the above basis this policy is not effective or in accordance with national policy.

More details about Rep ID: 1487

Representation ID: 1453

OBJECT Mr David Vowles

Summary:

Policy D2 should be clarified and reference to medium villages deleted to take Account of the Rural Exceptions Policy (H2) and my suggestedd changes to Policies S2, S3 and Table 2

More details about Rep ID: 1453

Representation ID: 1396

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

Summary:

Policy D2 is too restrictive. There is no definition of 'small scale' trying to establish a definition would be fruitless as one would expect different definitions depending upon whether a site is in a village or one of the strategic settlements.

The supporting text at paragraph 4.122 says that unallocated sites will not normally be permitted. The housing requirement should be expressed as a minimum figure. It is likely to restrict development that constitutes sustainable development.

It does not allow for a proper balancing exercise to be undertaken.

Specific comments made on criteria e, f and g.

More details about Rep ID: 1396

Representation ID: 1356

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

Summary:

This policy anticipates a situation where housing delivery drops below expected rates. A flexible and positive policy response to this should be adopted.
Our suggestion of including deliverable housing sites as reserve sites, could be included at criteria C of the policy. In the circumstances described the need to restrict development within neighbourhood plan settlement boundaries is considered unduly restrictive and could favour otherwise more constrained, less suitable sites in settlements where no neighbourhood plan is in place.
As noted at paragraph 1.20 of the VALP existing neighbourhood plans which have been made are not based on this Local Plan.

More details about Rep ID: 1356

Representation ID: 1350

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

Summary:

The wording of criteria c from this policy should be amended as follows, to more closely reflect the wording of relevant policies within the relevant neighbourhood plan, as follows:
c. be located within or adjacent to the existing developed footprint of the settlement or, where there is a made neighbourhood plan, whose policies expressly restrict development beyond settlement boundary limits, the site is located entirely within that settlement boundary.

More details about Rep ID: 1350

Representation ID: 1117

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

Summary:

Land set out in the accompanying letter at Bierton and Grendon Underwood be allocated for housing.

More details about Rep ID: 1117

Representation ID: 1102

OBJECT Trustees of the Pitstone Townlands Charity represented by Bidwells (Mr Derek Bromley)

Summary:

The VALP contains no site-specific policies for existing commitments.
There is a need for a new Doctors Surgery to serve the village and outlying areas. The Practice Manager of the Rothchild Surgery has confirmed the need. There is no provision either within VALP or NP for this facility. It is a use which falls with a general D1 use.
For the reasons stated in the HBF submissions there is no justification for the reduced housing numbers and the identification of this site to provide for the part of the unmet need will contribute to the shortfall in housing numbers.

More details about Rep ID: 1102

Representation ID: 1078

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

Summary:

Our clients have a controlling interest in land at Buckland Road, Aston Clinton
and Broughton Lane, Bierton, and object to the omission of the sites as housing
allocations in Policy D2.

More details about Rep ID: 1078

Representation ID: 1075

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

Summary:

Policy D2 only supports additional development (i.e. non-allocated sites) on land adjacent to the existing developed footprint of the settlement in the circumstances where the Council's monitoring of delivery across the district shows that the allocated sites are not being delivered at the anticipated rate and subject to a number of criteria.
This Policy will not deliver sufficient flexibility in the Plan to respond to changes in circumstances i.e. Government's changed methodology to calculating housing need.
See further details in the attached covering letter.

More details about Rep ID: 1075

Representation ID: 1054

OBJECT Mr Cameron Branston

Summary:

Objects to D2.
Recognises the significance of the document and welcomes the new capacity-based approach to housing targets. There is concern from residents, Grendon Underwood Parish Council, Brill Society and Brill Parish Council that despite the pre-existing planning policy, that developers may try to build in and around the villages in unsuitable locations. Infrastructure is required to support new development.

More details about Rep ID: 1054

Representation ID: 939

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

Summary:

The 'within or adjacent to the existing developed footprint of the settlement' is particularly problematic, suggest delete 'or adjacent'. Otherwise once a greenfield development has been allowed, can another one take place on the greenfield land beyond that? What control is there over incremental creep outwards of villages, and how will cumulative effects be taken into account? How will rural exceptions sites ever be delivered if land adjacent to villages is allowed for market housing? If there is slow delivery of an allocation there should be no expectation that a site in the AONB or its setting is released.

More details about Rep ID: 939

Representation ID: 884

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

Summary:

We support the strategy for limiting housing development in rural areas beyond the strategic site allocations and the built up areas of identified settlements.

More details about Rep ID: 884

Representation ID: 867

OBJECT AB Planning & Development Ltd (Mr Andrew Bateson)

Summary:

It is inappropriate in the policy and in criterion (a) to include the word "small" as it is too restrictive and takes no account of local circumstance.

More details about Rep ID: 867

Representation ID: 811

OBJECT Cheddington Parish Council (Mrs Margret Smith)

Summary:

Cheddington Parish Council (CPC) would like to make the following points:
a) CPC is concerned that the general rate of 25% affordable housing undermines their own figure of 35% included in its adopted Neighbourhood Plan.
b) CPC is concerned in respect of Paragraph 4.159 that any additional development in Cheddington should be returned to the Parish Council for agreement in a further referendum within the updating process of the Cheddington Neighbourhood Plan.

More details about Rep ID: 811

Representation ID: 791

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

Summary:

Bovis Homes object to Policy D2, 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 OAN will be met within the plan period;
-is not justified in that it is not the most appropriate strategy and has not properly considered reasonable alternative strategies;
-is not effective in that the policy is unduly restrictive; and
-is inconsistent with national policy in that it does not fully reflect the Government's priorities and policies in terms of enabling sustainable development and supporting rural communities.

More details about Rep ID: 791

Representation ID: 590

OBJECT Dr Geoffrey Harris and 21 others

Summary:

The terms and approach of Policy D2, applied to Edlesborough, produce a situation which is inconsistent and perverse; and where the Neighbourhood Plan subverts the authority of the Local Plan to set policy and strategic direction.

Allocation EDL021 contravenes or is inconsistent with 7 of the 8 key criteria of Policy D2; most significantly, that proposals for development should not 'comprise partial development of a larger site'. This is explicitly the case for EDL021.

If the level of housing provision must be maintained, an alternative site is available which infringes the criteria of Policy D2 to a substantially lesser degree.

More details about Rep ID: 590

Representation ID: 500

OBJECT Mr Andrew Docherty

Summary:

There should be consideration of de-allocation of sites in certain circumstances.
There should be a sustainable hierarchy of release of any non-allocated sites.
Where there is a made Neighbourhood Plan (NP), non- allocated sites should not be released without a prior review of the NP.
Add 'important views' to para g.
Support for para c restrictions at made NP settlements.

More details about Rep ID: 500

Representation ID: 313

OBJECT Cllr Warren Whyte

Summary:

To allow for organic natural growth of rural villages, carefully situated buildings should be considered in areas that are supported by residents or the parish council, such as infilling between former agricultural buildings and village edges that do not form a strong edge. By there nature, many villages "bleed" into the countryside, and flexibility should be permitted. A recent example in Akeley which has been refused several times is seen as an absurdity to the village, especially when the occasional windfall site would enhance the slow natural growth of villages.

More details about Rep ID: 313

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