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Representations on VALP Proposed Submission - H6 Housing Mix

Representation ID: 2633

OBJECT Buckingham Town Council (Councillor Robin Stuchbury)

Summary:

There is inconsistency in the policy explanation at 5.61 which refers to "larger developments" as being more than 300; yet in the actual policy H6 larger development is taken to be 100 or more. Distance from facilities such as GP surgeries; convenience retail and public transport does not seem to have been considered in the allocation/suitability of these sites. Lifetime homes mechanism is needed to ensure small houses are replaced if extended. Childcare facilities is an additional example of where VALP has vision statements regarding education but does not indicate how it will be delivered.

More details about Rep ID: 2633

Representation ID: 2623

OBJECT Buckingham Town Council (Mr Christopher Wayman)

Summary:

There is inconsistency in the policy explanation at 5.61 which refers to "larger developments" as being more than 300; yet in the actual policy H6 larger development is taken to be 100 or more. Distance from facilities such as GP surgeries; convenience retail and public transport does not seem to have been considered in the allocation/suitability of these sites. Lifetime homes mechanism is needed to ensure small houses are replaced if extended. Childcare facilities is an additional example of where VALP has vision statements regarding education but does not indicate how it will be delivered.

More details about Rep ID: 2623

Representation ID: 2553

OBJECT Buckinghamshire County Council (SA Sharp)

Summary:

Suggested amendments to h6

More details about Rep ID: 2553

Representation ID: 2433

OBJECT Wendover Neighbourhood Plan Steering Group (Mr Jonathan Clover)

Summary:

This is unexceptionable, but the local views on the mix will need to be explored
further when developing the WNP.

More details about Rep ID: 2433

Representation ID: 2073

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

Summary:

The requirement to provide Category 3 market and affordable homes should be subject to viability.

More details about Rep ID: 2073

Representation ID: 2068

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

Summary:

The proposed policy affords no consideration to development viability and the
subsequent impact that the provision of extra care dwellings may have on the
overall deliverability of a scheme or the provision of affordable homes.

On the basis of the foregoing, including the lack of a detailed viability assessment
to assess the commercial impact of such a blanket requirement, we are of the
view that Policy H6 is not justified nor effective and has the potential to impede
the delivery of sites of in excess of 100 dwellings.

More details about Rep ID: 2068

Representation ID: 2056

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

Summary:

Requirement for self contained extra care housing may make development unviable

More details about Rep ID: 2056

Representation ID: 1997

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

Summary:

The Policy states that "larger residential development schemes proposing 100 dwellings and above in strategic settlements will be expected to provide an element of self-contained extra care dwellings as part of the overall mix, or an equivalent amount in an alternative location if this is agreed to be more appropriate".
The contribution of any amount of self-contained extra care dwellings must be considered on a site by site basis and subject to viability and demand.

More details about Rep ID: 1997

Representation ID: 1977

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

Summary:

The reference to Building Regulations is too prescriptive. The policy must be sufficiently flexible to adapt to changing circumstances as required by the NPPF. It is too rigid to specify percentages of dwellings to meet Building Regulations and this should relate to the identified need. Viability testing will be considered on a case by case basis. In any event, it is not necessary to require adherence to Building Regulations within a development plan policy and this reference should be omitted. Policy H6 is unsound as the policy is unjustified in terms of its evidence base and inconsistent with national policy.

More details about Rep ID: 1977

Representation ID: 1970

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

Summary:

Policy H6 is not justified and is not sufficiently flexible to respond to the circumstances of individual sites. It also requires and inefficient and ineffective provision of extra care accommodation.

More details about Rep ID: 1970

Representation ID: 1960

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

Summary:

Based on the above, we consider that Policy H6 is unsound as the policy is unjustified in terms of its
evidence base and inconsistent with national policy.

More details about Rep ID: 1960

Representation ID: 1940

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

Summary:

Policy H6 is not justified and is not sufficiently flexible to respond to the circumstances of individual sites.

More details about Rep ID: 1940

Representation ID: 1918

OBJECT Home Builders Federation Ltd (Mr Mark Behrendt)

Summary:

not justified the requirement for all homes to be built to part M4(2) and for 10% of market homes and 15% of affordable homes to be built to part M4(3). With regard to Part M4(2), the evidence in the HEDNA suggests that as the population is ageing then all new homes should be made accessible . However, the HEDNA itself outlines that many of the existing older people are unlikely to move from their current homes and as such there is likely to be significantly less need for new homes to be built to part M4(2).

More details about Rep ID: 1918

Representation ID: 1853

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

Summary:

It also seeks to remove or for greater justification to be provided for the blanket requirement for 15% of affordable housing to meet category 3 requirements - M4(3) (wheelchair user dwellings), of the Building Regulations.

More details about Rep ID: 1853

Representation ID: 1840

OBJECT Rectory Homes Limited (Mr Tim Northey)

Summary:

The policy as drafted contains very limited detail to guide both decision makers and applicants in terms of agreeing an appropriate housing mix on a potential development site. This lack of detail introduces uncertainty and ambiguity with the policy. consider the policy to be contrary to advice in paragraph 17 of the NPPF

More details about Rep ID: 1840

Representation ID: 1803

OBJECT Minton Health Care (Buckingham) Ltd represented by Alder King (Portia Banwell)

Summary:

consequences of the policy, is that the OAN may not be met due to C2 development wrongly being assumed as forming part of the supply. Conversely, it will be unclear to what extent institutional need is being met if the development being delivered is assumed to be specialist mainstream housing. Of these two issues, of greatest concern to Minton is the risk that institutional need is not appropriately planned for, something that it considers to be a credible issue given that there is no commitment within the plan to meet the need for this type of development.

More details about Rep ID: 1803

Representation ID: 1802

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

Summary:

The housing mix may need to vary depending on the specific circumstances. We object to the requirement for self-contained extra care dwellings on the site. There is no evidence to justify the provision or assess the impact on scheme viability. the policy should be deleted.

More details about Rep ID: 1802

Representation ID: 1777

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

Summary:

The 'blanket' requirement to provide extra care dwellings
discourages effective consideration of the specific needs of the locality, and has no
regard to the suitability of a particular site or its capacity to accommodate extra care
units or indeed the viability of such proposals. We advise that extra care developments
often require a large building footprint and introduce large blocks of apartments. Such
developments are unlikely to be suitable in locations where this would (for example)
contrast with development density in the surrounding locality.

More details about Rep ID: 1777

Representation ID: 1728

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

Summary:

larger residential developments, in Strategic
Settlements, will be expected to provide an element of self-contained extra care
dwellings, noting that delivery of such units at an 'alternative location' may be
acceptable if this is agreed to be more appropriate. We submit that this aspect of the
proposed policy is all-encompassing and inflexible, in both its wording and conception.
The 'blanket' requirement to provide extra care dwellings discourages effective
consideration of the specific needs of the locality. Furthermore, even though there is
some allowance for delivery at alternative locations, the proposed policy assumes that
land will be available (in suitable locations).

More details about Rep ID: 1728

Representation ID: 1701

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

Summary:

This policy expects that all larger developments should provide an element of self-contained extra care dwellings as part of the over mix. Whilst this might be possible on very large sites (500+), this would/may not be possible or appropriate on sites below this general level of site and should either therefore be clarified or omitted from the plan.
Concern is raised in relation to the requirement for all residential developments to meet Category 2 standards for adapted homes with 10% of market homes meeting Category 3 standards. The evidence base for such specific requirements appear limited and the justification appears lacking, particularly the viability implications of imposing such stringent requirements

More details about Rep ID: 1701

Representation ID: 1687

OBJECT Buckinghamshire Fire & Rescue Service (Mr Staurt Gowanlock)

Summary:

We recommend that a requirement for the installation of automatic fire suppression systems be included for Category 2 (accessible and adaptable) and Category 3 (wheelchair user) dwellings as occupants will face greater risk to life in the event of fire.

More details about Rep ID: 1687

Representation ID: 1629

OBJECT Gladman Developments Ltd (Ms Nicole Penfold)

Summary:

Object to the percentage requirement in relation to Building Regulations Part M4(3) (wheelchair user dwellings). Not properly considered the viability implications of proposed policy requirements.

More details about Rep ID: 1629

Representation ID: 1602

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

Summary:

Policy H6 is not justified and is not sufficiently flexible to respond to the circumstances of individual sites. It also requires and inefficient and ineffective provision of extra care accommodation.

More details about Rep ID: 1602

Representation ID: 1563

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: 1563

Representation ID: 1541

OBJECT FI Real Estate Management represented by DPP Planning (Richard Purser)

Summary:


Policy H6 incorrectly translates the 300 houses large site threshold in justification paragraph 5.61 in to the policy as 100 dwellings. This sets up an unnecessary and unacceptable prospect of smaller scale schemes, including apartment buildings, needing to justify why extra care cannot be provided, adding costs and delay to provision of housing development. Additionally, it is unclear how provision of extra care will be furthered by such a policy as it takes little consideration of the specific support facilities required, including on-site staff availability. Extra care housing should be promoted in a standalone, positive policy

More details about Rep ID: 1541

Representation ID: 1533

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

Summary:

However, it is considered that the first paragraph to draft Policy H6 is inflexible as it does not take
into account viability or site specific circumstances.

More details about Rep ID: 1533

Representation ID: 1499

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

Summary:

Draft Policy H6 is not positively prepared and will not be effective. This is because it
doesn't deliver enough flexibility to allow housing mix to be considered on a site by site
basis, to ensure local housing need is met and without the applicability of any blanket
requirements, for example on extra care provision.

More details about Rep ID: 1499

Representation ID: 1397

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

Summary:

Policy H6 is not justified and is not sufficiently flexible to respond to the circumstances of individual sites. It also requires and inefficient and ineffective provision of extra care accommodation.

More details about Rep ID: 1397

Representation ID: 1354

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

Summary:

The requirement to deliver a mix of housing types and sizes in line with an assessment of requirements across the whole HMA is considered unreasonable and unjustified.
Developers are well placed to understand market demand for the type of housing needed in a particular location.

The requirement expressed in the second paragraph of the policy for self-contained extra care dwellings is considered unduly onerous, in conflict with paragraph 5.61 of the VALP and not justified by reference to express evidence of need of the amount of this type of accommodation required. In the event the policy requirement is warranted it should be justified by direct evidence of need on a case by case basis.

More details about Rep ID: 1354

Representation ID: 1345

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

Summary:

Object, H6:
The requirement for Category 3 market and affordable homes should be subject to viability.

More details about Rep ID: 1345

Representation ID: 1331

OBJECT Dandara Ltd (J Richards)

Summary:

Object, H6: supportive of wording regarding housing mix in HEDNA being a guide rather than a requirement. Should apply flexibility to individual sites and include site specific considerations.

Provision of extra care dwellings should be fully taken into account within viability assessments for individual sites. Definition of 'larger residential development schemes' as over 300 homes should be retained in paragraph 5.61.

Supports objective of requiring a proportion of new homes in developments to achieve Categories 2 & 3 in Approved Doc M: Vol 1. Should consider viability implications of standards and be in accordance with Planning Policy Guidance.

More details about Rep ID: 1331

Representation ID: 1183

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

Summary:

The policy states that all housing should be delivered to meet building regulation standard
Category 2 or above (10% of market housing and 15% of affordable housing should meet Category 3). This is unduly onerous. If the Government wanted all housing to meet
Category 2 as a minimum, the building regulations would be amended accordingly, except
for 10% to be delivered to M4(3) standards (i.e. all new dwellings will need to exceed
building regulations category 1). This is an onerous requirement which exceeds building
regulation requirements and which could adversely impact the deliverability and viability of
housing coming forward across the District.

More details about Rep ID: 1183

Representation ID: 794

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

Summary:

For the reasons set out above, Bovis Homes object to Policy H6, which is considered unsound on the basis that it:
- is not justified in that it is not the most appropriate strategy and has not properly considered reasonable alternative strategies; and
- is inconsistent with national guidance in that it does not fully reflect the Government's objective to ensure the housing requirements are not prohibitive to the delivery of development.

More details about Rep ID: 794

Representation ID: 699

OBJECT Mr Alan Sherwell

Summary:

Whilst I agree with what is in this section, th opportunity should be taken to re-enforce the need for rented social housing

More details about Rep ID: 699

Representation ID: 597

OBJECT The Buckingham Society (Carolyn Cumming)

Summary:

BUT Policy needs clarification.
Paragraph 5.61 states that an element of self-contained extra care dwellings are required in "larger" residential schemes in strategic settlements. But H6 refers to 100 dwellings as the threshold.
H7 There is no mention of Houses in Multiple Occupation (HMOs), which, as well as limiting square footage space per person, add a further strain on adjacent community facilities; e.g. parking.

Officer Note: changed from support to Object - due to criticism

More details about Rep ID: 597

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