FURTHER SUBMISSION BY SLOUGH BOROUGH COUNCIL TO VALE OF AYLESBURY LOCAL PLAN

For Hearing Session on Thursday 12th July- Matter 2.a Housing Market Area - Q29 (I) Matter 2.b Unmet need- Q29 (ii)

Inspector’s Question 29 (i)

Whether it is justified to base the housing requirement for the VALP solely on an analysis of the “best fit” HMA for the four Buckinghamshire authorities, bearing in mind that Aylesbury Vale itself is fairly evenly split three ways between the Oxford, Milton Keynes and South Bucks HMAs, has a significant relationship with the Luton HMA and directly borders the developed area of Milton Keynes?

1.1 Slough Borough Council objected to the Vale of Aylesbury Local Plan (VALP) on the grounds that it is unsound because it does not recognise the importance of using the “functional” Housing Market Area as the basis for deciding the extent to which it should accommodate unmet housing need outside of this area.

1.2 This is directly related to the Inspector’s question 29 1 (i) which asks whether it is justified to base the housing the housing requirement for the VALP solely on an analysis of the “best fit” HMA for the four Buckinghamshire authorities?

1.3 The Council does not consider that it is justified to use the “best fit” HMA that the Vale of Aylesbury Plan has used because this will have serious consequences for strategic planning to the north and south of the District.

1.4 The Council considers that housing needs should be met as close as possible to where they arise. As a result the most appropriate geography for determining housing requirements and distributions should be “functional” Housing Market Areas. Where a Local Plan area covers more than one “functional” Housing Market Area it should seek to address the needs of each of these areas.

1,5 In Aylesbury’s case, this means priority should be given to meeting its own housing needs across all three “functional” Housing Market Areas that it falls within. It is considered that the Spatial Strategy and housing distribution should recognise this.

1.6 The VALP has, however, been prepared upon the basis of meeting housing needs from the “best fit” Buckinghamshire HMA. It should be noted that this is a “best fit” to “Plan making” areas not Local Authority areas.

1.7 This arbitrary decision will have significant implications for the ability of Oxford, Milton Keynes and Luton to meet their housing needs. It will also have significant implications for meeting housing needs and plan making in South Bucks District. This is the specific issue that Slough Borough Council would like to highlight.

1.8 It is agreed by all parties that around 60% of South Bucks District which lies to the south of the M40 is not in the same Housing Market as the rest of Buckinghamshire when assessed on a “functional” basis.

1.9 This means that when judged upon a “best fit” to Local Authority boundaries basis, the whole of South Bucks is in a different Housing Market Area to the rest of Buckinghamshire. This was the recommendation of the 2015 HMA and FEMA report (ORS and Atkins) commissioned by the Buckinghamshire Councils which put South Bucks in the Slough/Reading Housing Market Area.

1.10 This only changed in June 2016, following the decision by South Bucks and Chiltern to prepare a joint Local Plan. It was on this basis that the report by ORS Atkins entitled “HMAs and FEMAs in Buckinghamshire: Updating the evidence”1 recommended the use of the “plan making” areas for determining the “best fit” HMA.

1.11 This study concluded:

“we would continue to recommend to the Buckinghamshire councils that the most pragmatically appropriate “best fit” for the Central Buckinghamshire housing market area based on Local Plan areas comprises Aylesbury Vale district, Wycombe district and the combined area of Chiltern and South Bucks districts [...] these “best fit” groupings do not change the actual geography of the functional housing market areas that have been identified – they simply provide a pragmatic arrangement for the purposes of establishing the evidence required ...” (para 36-37, p10).

1.12 The Vale of Aylesbury Local Plan therefore used this “pragmatic” approach to make provision in Policy S2 (Spatial Strategy for Growth for the delivery of 27,400 dwellings between 2013 and 2033 including the unmet need of 2,250 dwellings from Wycombe and 5,750 from Chiltern and /South Bucks Districts.

1.13 This ignored the actual geography and “functional” Housing Market Areas that have been identified both in the north and the south.

1.14 Whilst the Inspector’s question focuses upon the impact that the use of the “best fit” methodology will have upon Oxford, Milton Keynes and Luton, it is also important to note that this will have an adverse effect upon the southern part of South Bucks.

1.15 Exporting un met housing needs from South Bucks to Aylesbury is not considered to be reasonable or sustainable when there is not a functional or geographical link between the two.

1.16 The VALP has not taken account of the adverse effects that this will have upon the local housing market which is deprived of new housing. South Bucks District is already one of the least affordable areas in the country. Failure to build the required houses in this area will make affordability even worse. It will also restrict the supply of affordable housing in the area and result in people having to move long distances, in some cases outside of the functional Housing Market Area, in order to find suitable housing. This could also result in unsustainable commuting patterns back to the major employment areas in London, Slough, and Heathrow.

1.17 This issue is related to the Inspector’s question 29 1(ii).

Inspector’s Question 29 (ii)

Whether it is justified for VALP to make provision for a defined quantity of housing demand displaced from Wycombe, Chiltern and South Bucks in advance of adopted Local Plans for these areas defining the quantity of unmet need to make no provision for unmet need displaced from Luton when there is an adopted plan for that area which defines the quantity of displacement which Aylesbury Vale is likely to experience.

1.18 The key point is that, in advance of an adopted Local Plan, the level of unidentified unmet need for South Bucks that has been provided for in Policy S2 of the VALP, has not been properly tested. The adoption of the VALP as it stands will have significant implications for spatial planning in the South Bucks area.

1.19 The Chiltern/South Buck Local Plan has not been progressed very far. There was an Issues and Options in January 2016 and a Green Belt Preferred Options in October 2016. 1.20 The most recent document was a Green Belt Development Options Appraisal of November 2017 which according the Web Site “identifies, subject to further duty to co-operate discussions if relevant and final evidence base work, strategic Green Belt options which officers are likely to be recommending to the Councils to be removed from the Green Belt and included in the emerging Draft Local Plan as development proposals” 1.21 The web site also explains that “the published Local Development Scheme will not now be able to be met. Following local transport modelling and duty to co-operate engagement with Highways England the Councils are required to undertake additional specific strategic highway (motorway) junction modelling. This modelling will be published on the Emerging Local Plan Evidence Base of the website in due course. Once the timetabling implications for the Local Plan are known the Councils will review their Local Development Scheme”. 1.22 This does not suggest that the Chiltern/South Bucks local Plan is far enough advanced to be able to definitively quantify a level of unmet housing need at this stage. 1.23 The adoption of Policy S2 in the VALP with an allocation of 5,750 houses to meet Chiltern and South Bucks Districts would effectively pre judge the outcome of the Chiltern and South Buck Local Plan and enable it to plan for a shortfall of housing regardless of the impact that this would have upon the area.

1.24 One of the strategic planning issues in the area is that Slough has identified an unmet housing need of up to 8,000 houses due to the shortage of land in the Borough. This is similar in scale to the amount of unmet needs in Luton where a Growth Study has been commissioned to try to resolve this issue. A similar Joint Growth Study has been commissioned by Royal Borough of Windsor & Maidenhead, Slough, South Bucks and Chiltern and has received Government funding from the Joint Working Fund.

1.25 It is considered that the adoption of Policy S2 in the VALP with an allocation of 5,750 houses to meet Chiltern and South Bucks Districts would effectively pre judge the outcome of this Joint Growth Study. 1.26 As a result Slough Borough Council considers that Policy S2 of the Vale of Aylesbury Local Plan is unsound on the grounds that it has not justified why meeting all of South Bucks’ unmet housing needs outside of the “functional” Housing Market Area is the most appropriate strategy, when a more reasonable alternative would be to meet needs where they arise in a more sustainable way.

1.27 It is therefore suggested that Policy S2 Aylesbury Vale Local Plan should be modified so that Chiltern and South Bucks’ unmet need figure is reduced from 5,750 to 4,000.

1.28 It is also considered that the Inspector would be justified in further reducing the amount of unmet from South Bucks if it is considered that the need is unproven or it would be better to meet the proven unmet need from Luton or other areas in the “functional” Housing Market Area.