Aston Clinton MDA Representations to the Vale Of

Representations to the Vale of Aylesbury Local Plan on behalf of Aston Clinton Sarl September 2016

Representations to the VALP for Aston Clinton Sarl

Contents

Executive Summary ...... 4 1.0 Introduction ...... 5 2.0 Allocation and Site History ...... 5 3.0 Comments on the draft VALP ...... 6 3.0 WTV016 “Aston Clinton MDA” – Site Specific Comments ...... 10 4.0 Summary ...... 14

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Executive Summary

Aston Clinton Sarl control land north of Aston Clinton Road, Aylesbury and can confirm that the site is available for a residential-led mixed use development. The Vale of Aylesbury Plan (“VALP”) identifies the site (WTV016) as an existing commitment, which is expected to deliver 150 dwellings and 30,060sqm of economic development related floorspace. No timescales are provided for delivery.

The site is located within the Aylesbury Strategic Settlement and therefore one of the most sustainable locations in the District. The site also comprises a large part of the Aston Clinton MDA, which is allocated for a mixed use development in current Local Plan.

The Council’s Objectively Assessed Housing Need (“OAN”) is considered to be too low and the Council cannot at present identify a five-year housing land supply, as required by the National Planning Policy Framework (“NPPF”). Furthermore, it remains a significant challenge for the Council to identify such a housing land supply as part of the VALP, despite making a number of new housing allocations.

Whilst Aston Clinton Sarl welcome the identification of the site as an existing commitment, the level of development envisaged by the Council is not considered to make the most effective use of land, nor it is considered to respond to the latest evidence base prepared in support of the VALP i.e. an increase in housing needs and a surplus of employment land (particularly in the vicinity of Aylesbury).

Extensive technical work has been prepared in support of planning application 15/03806/OUT, which was submitted on the site for a residential-led mixed use development. The application is significantly progressed, with all statutory consultee comments received to date raising no objection. The only outstanding statutory consultee comments relate to BCC Highways, which Aston Clinton Sarl expect to resolve very soon.

It is clear that site WTV016 can accommodate a residential-led mixed use development comprising 400 dwellings and 5,000sqm of employment floorspace. Subject to receiving an approval of the current application soon, Aston Clinton Sarl consider that the majority of the proposed 400 dwellings could be delivered within the first five years of the Plan period, boosting the Council’s housing land supply position and demonstrating that the site is deliverable, having regard to footnote 11 of the NPPF. The Council’s HELAA should therefore be updated accordingly.

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1.0 Introduction

1.1 These representations have been prepared by Nexus Planning, on behalf of Aston Clinton Sarl (“the applicant”), in response to the current consultation on the draft Vale of Aylesbury Local Plan (“VALP”) and in respect of the Aston Clinton Major Development Area (MDA) site (“the site”).

1.2 Within the Draft VALP, we note that the site is identified as WTV016 and as a ‘existing commitment’. The Aylesbury Housing and Economic Land Availability Assessment May 2016 (“HELAA”) identifies that site WTV016 is expected to deliver 150 dwellings and 30,060sqm of economic development related floorspace. No timescales are provided for delivery.

1.3 Aston Clinton Sarl welcome the Council’s acknowledgement that the site can deliver a mixed use development, but consider that the mix of uses should be more residential-led, as demonstrated in outline planning application 15/03806/OUT, which is currently under consideration. Evidence to support this approach is detailed throughout our representations.

2.0 Allocation and Site History

2.1 The site is currently allocated within the Aylesbury Vale District Local Plan 2004 (AVDLP) under Policy AY15 and remains the only MDA not to be built out to date.

2.2 An outline application was submitted to Aylesbury Vale District Council (“AVDC”) in October 2007 (Ref. 07/02923/AOP) for a mixed use development comprising a business park, including B1 office buildings, 125 dwellings, hotel and gym, mixed use core comprising B1 use, retail, café, and up to 25 dwellings, public open space, new accesses, roads and services. A resolution to grant was secured at Planning Committee subject to a signed Section 106 agreement, although the Section 106 was never signed.

2.3 In November 2015, an outline planning application was submitted on the site for the construction of up to 400 dwellings (C3 use class), a Hotel, Pub and/or Restaurant (C1/A3 use class), extra care housing (C2/C3 use class) (80 bed), 5,000 square metres of employment floorspace (B1 use class) and a local centre (A1/A2/A3 use class). Public open space, play areas, a water meadow and associated infrastructure including roads was also proposed. This planning application is currently under consideration but well advanced, with a Planning Committee date expected in September / October. Further details regarding this application are set out later on in our representations.

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3.0 Comments on the draft VALP

Policy S2 “Spatial Strategy for Growth”

2.4 Aston Clinton Sarl support Policy S2, which sets out that the primary focus for strategic levels of growth and investment will be at Aylesbury. Aylesbury is the largest town within the area and therefore in order to provide sustainable growth, development should be located here both within the existing settlement and on greenfield land adjoining the settlement, where appropriate.

2.5 However, the housing requirement as identified within the policy as 33,300 dwellings over the Plan period is not considered to reflect Objectively Assessed Need (“OAN”), as the figure identified for Aylesbury District is demonstrably too low and the figures used for the unmet need elsewhere in the housing market area (“HMA”) may identify a higher need than the currently identified 12,000 homes.

2.6 Furthermore, we note that the Buckinghamshire Housing and Economic Needs Assessment January 2016 (“HEDNA”), upon which OAN has been calculated, is based upon the 2012- based household projections. However, the recently published 2014-based household projections identify a significant increase in housing pressures within Aylesbury Vale and an overall increase in housing needs in the HMA as a whole. The National Planning Practice Guidance (“NPPG”) is clear that household projections are the starting point for estimating OAN and therefore changes in population and household projections are a material consideration in calculating OAN. The Council’s OAN should therefore be revised (most likely upwards) for this reason as well.

Paragraph 3.17- 3.18 Housing Land Supply

2.7 We note that Council cannot currently demonstrate a five-year housing land supply, as required by the NPPF, with paragraph 3.17 of the VALP detailing that it is currently at 3.9 years. This figure may however be even lower, given our above comments on OAN.

2.8 The Council’s highlight the difficulties they face in achieving a five-year housing land supply within the VALP due to the significant housing needs emanating from the area and as a result, the Council should seek to maximise development opportunities in sustainable locations and approve application at the earliest opportunity. Indeed, we note that Policy S1 ‘Sustainable Development for Aylesbury Vale’ states that proposals that are in accordance with the development plan will be approved without delay.

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2.9 Site WTV016 is in a highly sustainable location, falling within the Aylesbury Strategic Settlement, one of the most sustainable locations in the District, as acknowledged by the VALP. The Council’s HELAA sets out that the site is only expected to deliver 150 dwellings and 30,030sqm of economic floorspace. However, given the significant housing needs for the Vale and reduced employments needs within the Aylesbury sub-FEMA (as detailed within supporting material for planning application 15/03806/OUT and the VALP) Aston Clinton Sarl consider that the HELAA should be amended to expect that the site delivers 400 dwellings plus commensurate economic floorspace (circa 5,000sqm). Subject to receiving an approval of our planning application 15/03806/OUT within the coming weeks, Aston Clinton Sarl consider that the site could deliver a significant quantum of the proposed housing within the first five years of the Plan period, boosting the Council’s housing land supply position.

Changes Sought:

2.10 The Council’s HELAA is amended to identify that site WTV016 will deliver 400 dwellings and 5,000sqm of employment floorspace.

Table 3 “Proposed Settlement Hierarchy and housing development”

2.11 Given the sustainable location of Weston Turville we wholly support its inclusion within the Aylesbury housing allocation. Furthermore, we support the inclusion of Aylesbury as one of only five strategic settlements, where the majority of development should be allocated.

2.12 However, as detailed above, we do consider that further opportunities should be taken maximise the development capacity of sites in these sustainable locations. For example, site WTV016 is only expected to delivery 150 dwellings, despite a well advanced planning application for 400 dwellings. This would reduce the pressure upon less sustainable settlements, which have a high housing allocation, such as the larger and medium sized villages.

Changes Sought:

2.13 The amount of development being proposed at the larger and medium sized villages should be reduced with the residual amount being added to the strategic settlements as the most sustainable location. Sites such as WTV016 could accommodate some of the additional housing needs from the villages.

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Policy S3 “Settlement hierarchy and cohesive development”

2.14 As detailed in our representations to Policy S2, we largely support the Council’s Settlement Hierarchy and agree that allocations should be made in accordance with Table 3. This would mean the majority of allocations will be located within the five identified strategic settlements with minimal development in the less sustainable locations across the District. In order to maximise the development potential of sustainable locations, more housing should be allocated to the strategic settlements, in particular Aylesbury.

Policy D1 “Delivering Aylesbury Garden Town”

2.15 We support the Council’s vision to deliver a garden town concept in Aylesbury. Aylesbury is rightfully identified within the plan as one of five strategic locations where growth should be focused. Further, it is the largest town in the District and therefore the infrastructure and lack of environmental constraints makes it the most appropriate location for the Garden Town principles to be developed.

2.16 Additionally, it is supported that in order to achieve the housing requirement at Aylesbury, there will be a need for sustainable urban extensions on greenfield sites around the town. Site WTV016 represents such a site on the edge of Aylesbury.

Policy D9 “Provision of Employment Land”

2.17 Aston Clinton Sarl note that the Council’s HEDNA identifies a surplus of 51 hectares of employment floorspace, as clarified at paragraph 4.95 of the VALP. As such, the Council are only proposing additional employment floorspace to allow for choice and flexibility, rather than to address a shortfall.

2.18 The Council’s HELAA currently identifies that site WTV016 is expected to deliver over 30,000 sqm of employment. Planning application 15/03806/OUT only proposes 5,000sqm of employment floorspace, with appropriate justification for this provided in the supporting material to the planning application and this approach is reinforced by the VALP. As a result, it is considered that the HELAA should be amended to reduce the expected employment floorspace to no more than 5,000 sqm and that the residential capacity should be increase to at least 400 dwellings, in response to substantial housing needs.

Policy H1 “Affordable Housing”

2.19 Policy H1 of the VALP states that the type, size, tenure and location of affordable housing will be agreed with the Council, taking into account the most up to date evidence. We do

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however note that paragraph 5.9 of the VALP states this will be negotiated on a site by site basis. Aston Clinton Sarl support this but consider that it should be specifically referenced in the policy wording, rather than supporting text. Market conditions and evidence will of course change over the course of the Plan period and it is therefore important that the policy is suitably flexible to respond to such changes and variances.

2.20 Aston Clinton Sarl welcome the acknowledgement that Starter Homes are likely to be included in the definition of affordable housing, which we understand might be clarified later this year. The VALP will of course need to respond to any new legislation / guidance that arises on this matter.

2.21 Notwithstanding the above, we note that paragraph 5.7 of the VALP states that affordable homes will be expected to be groups of no more than 18 homes. Aston Clinton Sarl are aware that affordable housing providers seek larger clusters for management reasons and as a result, rigidly apply such a requirement could deter said providers. Aston Clinton Sarl would therefore suggest that this cluster limit is increase or greater flexibility applied to the wording.

Changes Sought:

2.22 Policy H1 wording is amended to include confirmation that the type, size, tenure and location of affordable housing will be agreed with the Council on a site by site basis, that the policy is amended following publication of imminent Starter Homes legislation / guidance and that the affordable housing cluster limit is increased or at least flexibility increased.

Policy H7 “Dwelling Sizes”

2.23 Policy H7 proposes to implement the Government’s internal space standards, subject to the outcome of a viability study, the results of which are not know at this stage. Whilst Aston Clinton Sarl has no objection in principle to applying these standards, the NPPG is clear that local planning authorities should provide justification for requiring internal space policies. The NPPG then clarifies that the following areas should be considered in judging whether to implement the standards:

 “need – evidence should be provided on the size and type of dwellings currently being built in the area, to ensure the impacts of adopting space standards can be properly assessed, for example, to consider any potential impact on meeting demand for starter homes.

 viability – the impact of adopting the space standard should be considered as part of a plan’s viability assessment with account taken of the impact of potentially larger

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dwellings on land supply. Local planning authorities will also need to consider impacts on affordability where a space standard is to be adopted.

 timing – there may need to be a reasonable transitional period following adoption of a new policy on space standards to enable developers to factor the cost of space standards into future land acquisitions.”

2.24 Until the above evidence has been provided, which Aston Clinton Sarl is not aware has be done, the implementation of internal space standards is not justified.

Changes Sought:

2.25 The policy should be removed from the Plan until such time that a full needs and viability assessment has been carried out.

3.0 WTV016 “Aston Clinton MDA” – Site Specific Comments

3.1 The Council identify site WTV016 as an existing commitment, however the HELAA suggested a yield of 150 dwellings and circa 30,000sqm of economic floorspace. This section of the representations provides evidence on the suitability of the housing mix advocated in planning application 15/03806/OUT, principally 400 dwellings and 5,000sqm of employment floorspace. Furthermore, it demonstrates how site WTV016 is considered to be ‘deliverable’ for the initial phases of development, having regard to footnote 11 of the NPPF.

3.2 In respect of the mix of uses proposed in the aforementioned planning application, this is fully justified with the supporting Planning Statement and the approach is further reinforced by the emerging evidence relating to the VALP, and indeed the strategy it is employing.

Technical Considerations

Landscape

3.3 A Landscape and Visual Impact Assessment (LVIA) was undertaken in support of the planning application as part of a chapter within the Environmental Statement (ES). This confirmed that any impacts from an LVIA perspective are localised i.e. contained within the vicinity of the application site, and would be further reduced in time through the establishment of new planting. Wider impacts were not considered to be of significance.

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3.4 The Council’s Landscape Officer has reviewed the planning application and raised no objection to the proposals.

3.5 It is therefore clear that landscape considerations not would prevent the delivery of 400 dwellings on the site during the Plan period.

Ecology

3.6 An Ecology Chapter was prepared as part of the ES in support of the planning application. This chapter was supported by a range of detailed survey work. The ES concludes that the impact upon the majority of receptors will be negligible/neutral with some minor beneficial effects as well. The proposals also include the provision of a water meadow, which will deliver significant ecological benefits.

3.7 A Biodiversity Impact Assessment was carried out and this confirmed that a positive gain in biodiversity will occur.

3.8 The Council’s Ecologist raised no objection to the proposals and it is therefore clear that ecological considerations would not prevent the delivery of 400 dwellings on the site during the Plan period.

Flood Risk and Drainage

3.9 The planning application was supported by a Hydrology and Flood Risk Chapter in the ES, which confirmed that small parts of the site lie within Flood Zone 2 and 3 but that all residential development will be located outside of such areas. It also detailed that an on-site drainage strategy has been developed to cater for storm events, plus an allowance for climate change.

3.10 The Environment Agency raise no objection to the application proposals and it is and it is therefore clear that flood risk and drainage considerations would not prevent the delivery of 400 dwellings on the site during the Plan period.

Heritage and Archaeology

3.11 The planning application is supported by an Archaeology and Cultural Heritage Assessment as an appendix to an ES Chapter regarding such matters. This assessment concludes that during the operational phase, a negligible effect would occur upon the setting of nearby listed buildings. Historic England and the Council have raised no objection to the proposals in this regard.

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3.12 Within the northern part of the site a Scheduled Ancient Monument (SAM) exists in the form of a moated villa, surrounded by ridge and furrow features. Following extensive engagement with Historic England in recent months and some minor amendments to the scheme, Historic England now raise no objection to the application, citing that less than substantial harm would occur to designated heritage assets and advising the Council to consider this in the planning balance, as required by the NPPF. Aston Clinton Sarl consider that the substantial benefits secured through the delivery of market and affordable housing, coupled with the creation of over 550 jobs, would clearly outweigh any identified harm to heritage assets.

3.13 It is therefore clear that heritage considerations not would prevent the delivery of 400 dwellings on the site during the Plan period.

Transport

3.14 Within the ES supporting the planning application, a Transport Chapter was prepared. Furthermore, a Transport Assessment and Travel Plan were included as appendices to the chapter. The reports detailed how the proposed access arrangements were considered to operate safely and efficiently and that no serve impact would occur upon the highway network.

3.15 Extensive dialogue has taken place with Buckinghamshire County Council (BCC) Highways over the course of the last year and a final consultation response is expected immanently. BCC has confirmed that no adverse impact will occur upon the strategic highway network and that the only outstanding matter relates to local modelling work undertaken by Vectos, our Transport Consultants. These concerns relate to points of detail, which are typically part of a planning application process and will ultimately be resolved through negotiation.

3.16 Given the above, it is not considered that highway considerations would prevent the delivery of 400 dwellings on the site during the Plan period.

Play and Open Space

3.17 The planning application proposes to provide a NEAP (1,000sqm) and two LEAPs (500sqm each) on site. Comments have been received from the Council on these facilities and no objection is raised at this stage, with final details to be worked up at the reserved matters stage.

3.18 The application also proposes to provide a significant recreational open space in the form of a Heritage Park, which is supported by Historic England.

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3.19 Aston Clinton Sarl has agreed to make a financial contribution to towards off-site sports and leisure provision as part of a S106 Agreement, with an exact figure to be agreed in due course.

3.20 Given the above, it is not considered that play and open space provision matters would prevent the delivery of 400 dwellings on the site during the Plan period.

Education and Health facilities

3.21 BBC has commented on the planning application, seeking financial contributions towards primary and secondary school spaces, which Aston Clinton Sarl is willing to agree to. No contributions have been sought towards heath provision, as capacity already exists.

3.22 No issues are therefore raised in this regard to prevent the delivery of 400 dwellings on the site during the Plan period.

Noise and Air Quality

3.23 An assessment of potential noise and air quality effects arising from the proposed development have been carried out and are detailed within the Noise Chapter and Air Quality Chapter of the ES. The Council’s Environmental Heath Team has raised no objection to the proposed development and as such, it is clear no issues arises in this regard to prevent the delivery of 400 dwellings on site within the Plan period.

Ground Conditions

3.24 A Phase 1 Environmental Site Assessment has been carried out in support of the planning application, which concludes that the site poses a low to moderate risk to sensitive receptors.

3.25 A Geo-Environmental Site Appraisal has also been carried out which confirms that overall no significant contamination has been identified on site.

3.26 Given the above, it is clear that suitable mitigation measures can be put in place to ensure no adverse impacts would occur in terms of contamination and accordingly, no objection is raised by the Council’s Environmental Heath Team.

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4.0 Summary

4.1 Site WTV016 ‘Aston Clinton MDA’ is located within the Aylesbury Strategic Settlement, one of the most sustainable locations in the District. The site is already allocated for growth in the current development plan and the VALP identifies that it is suitable for 150 dwellings and circa 30,000sqm of economic floorspace. Whilst Aston Clinton Sarl welcome the identification of the site as an existing commitment, the level of development envisaged by the Council is not considered to make the most effective use of land, nor it is considered to respond to the latest evidence base prepared in support of the VALP i.e. an increase in housing needs and a surplus of employment land (particularly in the vicinity of Aylesbury).

4.2 Extensive technical work has been prepared in support of planning application 15/03806/OUT and the application is significantly progressed, with all statutory consultees comments received to date raising no objection. The only outstanding statutory consultee comments relate to BCC Highways, which Aston Clinton Sarl expect to resolve through receipt of final comments in the coming days.

4.3 Given the above, it is clear that site WTV016 can accommodate a residential-led mixed use development comprising 400 dwellings and 5,000sqm of employment floorspace. Subject to receiving an approval of our current application within the next few weeks, Aston Clinton Sarl consider that the majority of the proposed 400 dwellings could be delivered within the first five years of the Plan period, boosting the Council’s housing land supply position and demonstrating that the site is deliverable, having regard to footnote 11 of the NPPF. The Council’s HELAA should therefore be updated accordingly.

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