Vale of Aylesbury Local Plan Draft Local Plan Consultation
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For and on behalf of September Properties Vale of Aylesbury Local Plan Draft Local Plan Consultation Prepared by DLP Planning Ltd Milton Keynes September 2016 BU508/1– Draft Vale of Aylesbury Local Plan Consultation DLP Planning Ltd on behalf of September Properties September 2016 Prepared by: Nick Stafford MRTPI Associate Director Approved by: Nick Stafford MRTPI Associate Director Date: September 2016 DLP Planning Ltd Midsummer Court 314 Midsummer Boulevard Milton Keynes MK9 2UB Tel: 01908 440 015 Fax: 01908 357 750 DLP Consulting Group disclaims any responsibility to the client and others in respect of matters outside the scope of this report. This report has been prepared with reasonable skill, care and diligence. This report is confidential to the client and DLP Planning Ltd accepts no responsibility of whatsoever nature to third parties to whom this report or any part thereof is made known. Any such party relies upon the report at their own risk. 2 BU508/1– Draft Vale of Aylesbury Local Plan Consultation DLP Planning Ltd on behalf of September Properties September 2016 Contents Page 1.0 Introduction 4 2.0 Housing and Growth Strategy 5 3.0 Land at Fenny Road, Stoke Hammond 12 4.0 Conclusion and Recommendations 16 Appendix 1: Land East of Fenny Road – Location Plan (Drawing No D01) 3 BU508/1– Draft Vale of Aylesbury Local Plan Consultation DLP Planning Ltd on behalf of September Properties September 2016 1.0 INTRODUCTION 1.1 This report has been prepared in response to Aylesbury Vale District Council’s (AVDC) consultation on the Draft Vale of Aylesbury Local Plan (VALP). The representation, on behalf of September Properties, is submitted to provide comment on the housing policies in the plan, and to support further consideration of housing allocations in the village of Stoke Hammond. 1.2 September Properties hold an option over an 8.8 hectare site to the east of Fenny Road. Outline Planning permission has recently (June 2016 – LPA Ref: 14/03000/AOP) been granted on the ‘front’, western section of the site, for up to 74 dwellings and open space. This representation seeks to promote the whole, wider site, as indicated on Drawing No D02 at Appendix 1. This land is available, but in light of the emerging strategy relating to Stoke Hammond, can be used to unlock the potential for the provision of land for a new primary school alongside residential use. Full details of this potential are set out in Section 3 of this document. 1.3 The submission is intended to set out the client’s comments in respect of the emerging policy content generally, the evidence that underpins the draft plan and to promote the land under their control for allocation. 1.4 Accordingly, the representation is set out in three parts. The first part will consider the overall development strategy and the need for housing land. The report will then go on to consider the currently preferred strategy for the village of Stoke Hammond, before stating the reasons to allocate a wider site with additional community use at Fenny Road, Stoke Hammond. 4 BU508/1– Draft Vale of Aylesbury Local Plan Consultation DLP Planning Ltd on behalf of September Properties September 2016 2.0 HOUSING AND GROWTH STRATEGY Vision and Strategic Objectives 2.1 The spatial vision (paragraph 2.4j.) states that the rural areas (consider to include Stoke Hammond), will have to accommodate “proportionate growth”. While this aims to reduce the impact of development on the existing character of villages, it must be recognised that circumstances vary in different locations and that “proportionality” must recognise the local situation, rather than applying a standard approach to all villages. 2.2 In terms of the sustainable objectives set out at Policy S1 these are broadly supported. The policy is clear that in assessing the most sustainable locations priority will be given to delivering community needs to both new and existing communities (Policy S1c). The policy also states that, “The council will work proactively with applicants to find solutions so that proposals can be approved wherever possible, and to secure development that improves the economic, social and environmental conditions in the area”. Housing and Economic Needs Assessment 2.3 The Housing Strategy for the VALP is based on a raft of supporting evidence including the Housing and Economic Development Needs Assessment (HEDNA) that sets out the strategic housing needs for the area. There are a number of issues with this document and the conclusions that are drawn. 2.4 The National Planning Policy Framework (NPPF) requires that: Planning should proactively drive and support sustainable economic development to deliver the homes that the country needs. The NPPF requires that every effort should be made, objectively, to identify and then meet the housing needs of an area and take account of market signals (such as land prices and housing affordability), and set out a clear strategy for allocating sufficient land which is suitable for development in the local area, taking account of these needs (paragraph 17); 5 BU508/1– Draft Vale of Aylesbury Local Plan Consultation DLP Planning Ltd on behalf of September Properties September 2016 local authorities should significantly boost the supply of housing (paragraph 47); planning should deliver a wide choice of quality homes and widen the opportunity for home ownership; the evidence base for the Objective Assessment of Housing Need should be adequate, up-to-date and relevant (paragraph 158) and include Strategic Housing Market Assessments (SHMA) for the whole of the Housing Market Area (HMA) taking into account household and population projections including migration and demographic change (paragraph 159); and the Objectively Assessed Need for Housing has to be determined prior to applying any constraints or engaging the Duty to Cooperate (paragraphs 152 and 179). 2.5 Despite recognising some of these requirements in paragraph 3.7 and 3.8, the VALP goes on to state in paragraph 3.10 that: “The reports produced by ORS, identify that Aylesbury Vale sits within a best-fit housing market area that includes High Wycombe, Chiltern and South Bucks. There was a recognition that Aylesbury town sat within its own area but within a wider strategic housing market area. Aylesbury Vale also has links with housing markets in neighbouring areas, such as Milton Keynes.” 6 BU508/1– Draft Vale of Aylesbury Local Plan Consultation DLP Planning Ltd on behalf of September Properties September 2016 2.6 The report by ORS recognises a stronger link with other housing market areas, that the draft VALP somewhat underplays. As can be seen in Figure 1 below, the ORS report shows that the north of the District is strongly influenced by the Milton Keynes Housing Market Area and the east of the district is firmly within the influence of the Luton Housing Market Area. borough Figure 1: Housing Market Areas in Buckinghamshire (Source: ORS, 2015). 2.7 The VALP goes on to state in paragraph 3.11 that: “Although other councils have not yet completed their capacity assessments, there is likely to be an element of unmet needs required to be met by Aylesbury Vale. At present we are estimating a figure of 12,000 to meet unmet needs from Wycombe, Chiltern and South Bucks”. 7 BU508/1– Draft Vale of Aylesbury Local Plan Consultation DLP Planning Ltd on behalf of September Properties September 2016 2.8 In the Local Plan Inquiry for the Luton Borough Council Local Plan, a shortfall of 11,100 dwellings was predicted. A subsequent SHLAA revision has reduced this to 9,300 dwellings, although the reduction in the shortfall would require the agreement of the Inspector to allow a major modification to the submitted Luton Local Plan. 2.9 While Central Bedfordshire Council will accommodate some of the unmet need, the Metropolitan Green Belt will act as a constraint, leading to the need for VALP to accommodate a proportion of the unmet need also. Accordingly, the overall housing requirement for the VALP must be revised higher, to ensure that the Luton Housing Market Area’s needs are met. 2.10 Additional unmet need will come to AVDC area through Milton Keynes also, who are in the process of advancing their own “Plan:MK” Local Plan. While this plan is at a more formative stage than the Luton Local Plan, it is likely that the upgrading of the A421 and the large swathes of Green Belt in neighbouring LPAs will lead to a pressure for growth in the south of Milton Keynes, inevitably spilling into the AVDC area. Accordingly, additional sites for growth should be included in the VALP to accommodate this growth. While the VALP does direct a number of development sites around Milton Keynes, and in in nearby settlements including Stoke Hammond but also at Winslow, Buckingham, Newton Longville, Great Horwood and Maids Moreton, these sites are only used to meet the needs of AVDC and fail to meet any unmet need from the Milton Keynes Housing Market Area. It is therefore vital that additional land be allocated to accommodate this expected increase in housing need in the area. 2.11 It is unclear at this stage what discussions have taken place through Duty to Co- operate discussions regarding the need for AVDC to accommodate some of Milton Keynes’ job growth. However, it may be logical for a proportion of the planned development to the north of the Vale to effectively meet the additional needs of Milton Keynes, to be planned for through Plan:MK. Spatially this would seem logical, and would require additional growth to be planned elsewhere in the Vale to meet the need identified in the Vale.