LAND AT BROOK FARM BROUGHTON, BUCKINGHAMSHIRE
REPRESENTATION ON VALE OF AYLESBURY LOCAL PLAN
REPRESENTATION ON VALE OF AYLESBURY LOCAL PLAN AUGUST 2016
F164901 LAND AT BROOK FARM BROUGHTON REPRESENTATION ON VALE OF AYLESBURY LOCAL PLAN
1.0 INTRODUCTION 1.1 The following representation has been prepared on behalf of Mrs Collier and Mr
Chambers in respect of the Vale of Aylesbury Local Plan ‘Draft Plan for Summer
2016 Consultation’
1.2 Our clients are owners of Brook Farm, Broughton Lane, Broughton, Aylesbury
HP22 5AN, and they are seeking to promote the inclusion of their land as
allocations in the Vale of Aylesbury Local Plan.
1.3 As can be seen on the Site Location Plan attached at Appendix 1, the site is a
large square shaped greenfield plot on the western side of Broughton Lane,
leading down to Bear Brook covering an area of approximately 4.3 hectares’
gross, with a net developable area of 3.4 hectares, which can deliver around 102
dwellings at 30 dwellings per hectare.
1.4 The boundaries of the site are predominately defined by mature hedgerows and
trees. The site is located at the edge of the East Aylesbury Major Development
Area known as Kingsbrook.
1.5 Following the development of the MDA, the site will therefore sit within the built
up area on the eastern side of Aylesbury, which will be comprised of the new
neighbourhoods and the existing village of Bierton.
1.6 The site has not previously been promoted through previous ‘call for sites’
exercises and this representation includes a completed Call for Sites submission
– copy attached as Appendix 2 with a site constraints plan showing the flood
plain implications and the net developable area.
1.7 It is therefore not currently identified as a potential allocation within the Vale of
Aylesbury Local Plan, nor has it been considered in the past as available for
future development. The changes surrounding the site will significantly alter the
context of the land and given possible options for expansion of the East
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Aylesbury MDA, our clients wish to identify their land as available to assist in that
expansion.
1.8 This representation will therefore provide comments on the content of the
emerging Local Plan and identify why it is considered the Land at Brook Farm,
Broughton should be included as an allocation.
1.9 This representation has been set out as follows:
1.0 Introduction
2.0 Comments on the Vale of Aylesbury Local
Plan
3.0 Summary
Appendix 1: Site Location Plan (Land at Brook
Farm, Broughton)
Appendix 2: Call for Sites Submission (Land at
Brook Farm, Broughton)
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2.0 COMMENTS ON THE VALE OF AYLESBURY LOCAL PLAN
2.1. The following comments are made in respect of the emerging Vale of Aylesbury
Local Plan.
2.2. In accordance with the council’s online consultation pro forma, the comments
below have been organised in relation to each chapter of the emerging plan.
CHAPTER 1-BACKGROUND
2.3. The ‘background’ chapter is considered to generally cover the overarching
framework relating to the preparation of the plan.
2.4. We do however hold some concern with the lack of clarity regarding the level of
growth which the district will be seeking to accommodate.
2.5. In regards to this, it is noted that it has been estimated that the councils
adjoining Aylesbury Vale will be unable to accommodate approximately 12,000
homes due to their constraints, and that the housing requirement for the district
will therefore be approximately 33,000 new homes over the plan period.
2.6. It is however stated at paragraph 1.13 that “The council will be robustly challenging
the level of unmet need, but this draft local plan has to based on this requirement as
a worst case scenario”.
2.7. We hold two concerns with this statement. Firstly, the emerging development
plan and strategy should be developed with a clear understanding of the
development needs which the district should be seeking to accommodate. If the
council are to dispute the level of unmet need in neighbouring authorities, it
becomes difficult to accurately assess the potential effectiveness of the proposed
strategy. Secondly, we are concerned with the use of the terminology ‘worst case
scenario’. In noting the objective of national policy, to significantly increase the
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delivery of housing, there should be no inferences that delivering beyond the
specifically identified need is a negative state of affairs.
2.8. That is to say, that the ultimately defined housing requirement should be treated
as a minimum and that the associated strategy facilitates the ability to exceed
this.
CHAPTER 2-VISION AND STRATEGIC OBJECTIVES
2.9. The vision and strategic objectives set out in the draft plan appear to correlate
with the core principles of the planning system, as set out in the National
Planning Policy Framework.
2.10. It is therefore considered that the vision and objectives promote a positive
agenda for the delivery of growth and development, and is appropriate for
Aylesbury Vale.
2.11. It is also considered positive approach, that development is to be distributed
across the entire district, and to facilitate the substantial growth of the town of
Aylesbury.
CHAPTER 3-STRATEGIC POLICIES
2.12. Whilst the visions and objectives of the plan, appear to promote a positive
agenda for the delivery of development, we are somewhat concerned with the
content of some of the strategic policies, most specifically policy S2 which sets
out the ‘spatial strategy for growth’
2.13. In regards to this, it is noted that the targeted level of development and the scale
of growth to be attributed across the district’s settlements is expressed as
specific figures.
2.14. As discussed in relation to the ‘background’ chapter, all targets and requirements
should be expressed as a minimum, in order to support the delivery of growth.
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In particular it is considered that setting fixed positions would be at odds with
the Strategic Objectives.
2.15. The growth of Aylesbury and its promotion as a Garden Town, is however
considered logical, as the settlement plays a major role in the delivery of the
district’s employment opportunities, services and facilities. Furthermore, given
the existing commitment for the town to expand to the east (e.g. the Kingsbrook
development), it is considered that additional sites compatible with this growth
should be supported through the plan.
2.16. Section (a) of policy S2 emphasises the need for “new homes to support economic
growth [that] will be accommodated through the effective use of brownfield sites or
sustainable Greenfield urban fringe sites”. Although our client’s site at Brook Farm
is currently detached with limited connectivity to services and public transport
links, the development within the locality will change the context considerably,
and it is anticipated that the projected development in the area will result in new
bus routes/road links/footpaths and closer proximity to vital facilities, improving
the sustainability of the site. It could therefore qualify as a “sustainable
Greenfield urban fringe site” where new residential development is acceptable.
2.17. Under Policy S3 on settlement hierarchy, we strongly support the integration of
the parish of Bierton (which includes Broughton) within the housing
requirements of Aylesbury. This will allow the eastward extension of the
settlement of Aylesbury as part of the Garden Town vision.
2.18. Being located in the parish of Bierton, our site at Brook Farm is therefore
favourably located in an area which is identified as suitable for residential
development. This is also supported by the Aylesbury Vale Draft Housing and
Economic Land Availability Assessment (HELAA- May 2016) map for the parish of
Bierton which shows most of the area surrounding the proposal site washed
over by light green (BIE018), indicating it is suitable for housing or economic
development.
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2.19. The Garden Town Vision masterplan, however, indicates that part of the land at
Brook Farm is designated as green infrastructure open space. As a significant
amount of land in the area is earmarked for development, we wish to bring the
land at Brook farm to the Council’s attention, as we consider it is an ideal site for
further expansion of the MDA which can include provision of a green buffer to
the Bear Brook, that is identified as flood plain, while preserving the public
access across the western side of the fields.
CHAPTER 4-STRATEGIC DELIVERY
2.20. As set out above, it is considered that the strategic policy to substantial grow the
town of Aylesbury and to facilitate the formation of a ‘Garden Town’ through the
eastern expansion is a logical approach to accommodating a large proportion of
the district’s development needs.
2.21. It is noted under policy D1 that it is identified that the housing requirement for
Aylesbury is 15,845 (including the requirements of Stoke Mandeville, Bierton and
Weston Turville due to their association with the urban expansion to the east
and south of the town). The residual housing requirement is identified as 8,221
homes.
2.22. The policy identifies that the housing development will be delivered through
previously developed sites and sustainable urban extensions, with a list of
potential housing allocations listed at Appendix A.
2.23. The potential housing allocations includes both previously developed sites within
the existing town as well as urban expansion sites to the south east of the town.
These sites have a total capacity of 6,829 dwellings.
2.24. There is therefore clearly a substantial shortfall between the residual
requirement and the capacity of the potential allocations.
2.25. Further to this, it is noted at paragraph 4.78 that due to Bierton and Weston
Turville forming part of the proposed expansion of Aylesbury, specific allocations
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for those settlements would not be made (e.g. the allocations made are as part
of the expansion), and that “Any other proposals for development at Bierton or
Weston Turville will therefore not be permitted except in exceptional circumstances”
2.26. Given the above situation, it is considered that in order to achieve the housing
requirement for Aylesbury, the council should be allocating a greater number of
sites and ensure the flexibility of policy to allow additional growth in Bierton and
Weston Turville which accords with the strategic expansion of Aylesbury on
unallocated sites.
2.27. In regards to the allocation of more sites, it is considered that ‘Land at Brook
Farm, Broughton’ clearly represents a site which could contribute towards
achieving the residual housing requirement and is extremely well located in the
context of the eastern expansion of Aylesbury.
2.28. The site will therefore have access to and support the services and facilities
provided in the Kingsbrook MDA.
CHAPTER 5-HOUSING
2.29. In regards to the chapter on housing, it is noted that the policies set a threshold
and proportions for delivery of affordable housing, dwelling sizes and mixes as
well as criteria which will be applied to proposals for rural exceptions site, rural
worker’s dwellings and, self-build replacement dwellings.
2.30. It is considered that the chapter covers all expected ‘housing-related’ policy
matters, and we have no comments to make.
CHAPTER 6-ECONOMY
2.31. It is noted that the policies set out in this chapter relate to protection and
provision of employment sites of all types, as well as the provision of
‘complementary facilities’, and supporting the development of businesses
compatible with residential areas, as well as retail, tourism and agriculture.
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2.32. It is considered that the expected ‘employment’ policy related matters have been
covered in this chapter and we have no specific comments to make on policy. We
would take this opportunity to highlight that consideration should be given to
identifying new employment sites, where they can contribute to the mix of land
use within the expansion areas.
CHAPTER 7 TRANSPORT
2.33. The transport chapter, sets out parking standards (vehicle and cycling), policy
relating to the provision and protection of footpaths and cycle networks, and
electric vehicle charging points.
2.34. We have no comments to make in relation to this chapter.
CHAPTER 8-BUILT ENVIRONMENT
2.35. The built environment chapter sets out policies in relation to the historic,
environment, design and amenity.
2.36. We have no comments to make in relation to these policies, however it is noted
that the ‘External Space Standards’ section of policy BE2 relates purely to the
residential development. It is therefore considered that this would more usefully
be located within the housing chapter of the plan.
CHAPTER 9-NATURAL ENVIRONMENT
2.37. In respect of the ‘Natural Environment’ chapter, it is noted that there is a wide
range of policies, including the assessment criteria for considering applications
related to specific designations (e.g. statutory ecological, landscape etc) as well as
matters including noise, air quality and light.
2.38. We have no comments to make in relation to this chapter.
CHAPTER 10-COUNTRYSIDE
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2.39. This chapter provides, policies on the re-use of rural buildings, equestrian
development, renewable energy developments and public rights of way.
2.40. Although, we have no comments to make on this chapter, it is considered that
the matter of renewable energy development provision, would be better suited
to be located within the ‘infrastructure’ chapter, as such development is not
exclusively suited for the countryside (and the policy contains sets out ‘validation
requirements’ for various sizes and forms of development e.g. developments of
10 or more dwellings etc).
CHAPTER 11-INFRASTRUCTURE
2.41. This chapter sets out policies in enhancement and provision of ‘green
infrastructure’, sports and recreation facilities, community facilities, flooding and
telecommunications.
2.42. As set out above, it is considered that renewable energy generating development
policy would be better suited to be located in this chapter.
2.43. We do however have no specific comments to make in relation to this chapter.
POLICIES MAP
2.44. It is noted that the drafted Policies Map, illustrates the location of the potential
allocations on the ‘settlement’ insets, and provides ‘strategic illustrations’ of
Aylesbury Garden Town.
2.45. In relation to this, it is considered that the Aylesbury inset being focussed purely
on the south east of the town is misleading, and should illustrate the context of
growth for the whole town on the inset.
2.46. Furthermore, as discussed, it is considered that additional allocations should be
made in relation to Aylesbury in order to address the shortfall between its
residual housing requirement and potential allocations as identified in the draft
plan.
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2.47. As highlighted, it is considered that ‘Land at Brook Farm, Broughton’ is ideally
located to accommodate such an allocation, and that its development would
accord with the emerging development strategy.
OTHER COMMENTS
2.48. We have no other comments to make.
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3.0 SUMMARY 3.1. This statement provides comments in relation to the draft ‘Vale of Aylesbury
Local Plan’ on behalf of Mrs Collier and Mr Chambers, owners of Brook Farm,
Broughton, Buckinghamshire
3.2. As has been set out, it is considered that the proposed strategic expansion of
Aylesbury to the south and east to form a Garden Town (which will also contain
Bierton, Stoke Mandeville and Weston Turville) to support the delivery of growth
in the district is considered logical, however there is a clear shortfall of
allocations in comparison to the identified residual housing requirement (and
the associated policy framework appears restrictive to the delivery of windfall
sites within Bierton and Weston Turville).
3.3. It is therefore considered that the council should seek to identify a greater
number of allocations, and that Land at Brook Farm, Broughton is ideally located
and suitable to be identified for housing.
3.4. In regards to this, it will be noted, that the site sits in close proximity to the
proposed urban expansion area, is within the heart of a new network of strategic
roads in and around Aylesbury, and can be delivered without resulting in
coalescence, with a protected green buffer formed along the Bear Brook, in
keeping with the spirit of the proposed Green Infrastructure proposals.
3.5. The site has not previously been submitted via the Call for Sites and therefore
this representation is accompanied by a formal submission of the site for
consideration.
3.6. We trust that these comments will be taken into account through the further
preparation of the plan.
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Appendix 1: Site Location Plan (Land at Brook Farm, Broughton)
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Appendix 2: Call for Sites Submission (Land at Brook Farm, Broughton)
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Vale of
Aylesbury Call for Sites
Local
Plan
Call for sites
Developers, landowners and the wider public are invited to put forward potential development sites (for any use(s)) in order to update the Housing and Economic Development Land Availability Assessment (HELAA) and provide evidence for preparation of the Vale of Aylesbury Local Plan.
The “Call for sites” includes potential sites for uses other than housing, such as employment, retail, gypsy and travellers, and leisure uses. Please enter the relevant information on the use(s) you consider appropriate for the site, including mixed uses, on the ‘Call for sites’ form. This information will contribute to the evidence base.
As this is a new plan, we are starting a new list of promoted sites. If you have previously submitted a site to the VAP Strategy, Core Strategy or earlier plan, please resubmit the site again, as previously submitted sites will not be considered.
It is important to note that the promotion of land does not mean the site will proceed to a detailed assessment in the HELAA and also does not imply that the Council considers that the site is suitable for development through the HELAA or through any planning decisions, either now or in the future. The Council’s views through HELAA reports cannot be taken as representing either an intention to allocate these sites in VALP, or as a material consideration in the determination of a planning application. Potential sites that have been identified will be further tested through the plan-making process, including Sustainability Appraisal/ Strategic Environmental Assessment, several stages of public participation and independent examination. How do I submit sites? Please complete the sites proforma with a Ordnance Survey site plan with the land clearly shown etched in red and send to Forward Plans either:
By e-mail: [email protected]
By post: Planning Policy, AVDC, The Gateway, Gatehouse Road, Aylesbury, Bucks, HP19 8FF, DX 4130 Aylesbury 1
The form will continue to be available to enable submissions to be made at any time in the future, to inform future HELAA updates.
If you have any difficulties or questions regarding completing this form or if you would like further information on the new Vale of Aylesbury Local Plan (VALP) please contact us on the details overleaf. VALP
Contact Details If you have any questions, comments or queries please contact us on the details below:
Forward Plans - Telephone: 01296 585439
Email: [email protected]
Address: The Gateway, Gatehouse Road, Aylesbury, Bucks, HP19 8FF, DX 4130 Aylesbury 1
Website: http://www.aylesburyvaledc.gov.uk/planning-policy/
VALP Address of Site (Please include a plan with the boundaries of the site marked in red)
Brook Farm, Broughton, Aylesbury HP22 5AN
Contact details
Name Frazer Hickling Organisation (if relevant) Phillips Planning Services Ltd Address Kingsbrook House 7 Kingsway Bedford MK42 9BA
Telephone 01234272829 Email [email protected]
Your Details
You are..? A Private Landowner A Planning Consultant (Please tick all that apply) A Public Land-owning Body A Land Agent A Registered Social Landlord A Developer Other (please specify)
If you are representing a client(s), please supply the Mrs Collier & Mr Chambers name(s) and The Barn, Brook Farm, Broughton addresses(es) of those Aylesbury HP22 5AN you represent
Ownership Details
Are you the current owner of the site? Yes If YES, are you... Sole owner Part owner
If you are not the owner, or the site is in multiple ownership, please provide the name(s), address(es) and contact details of all owners.
(Please continue on a separate sheet if necessary, and provide a plan showing extent of individual land holdings) Has the landowner (or each owner) indicated support for development Yes of the land?.
VALP Site Location
Site name (is the site known by a particular name?) Brook Farm Site address Brook Farm, Broughton, Aylesbury HP22 5AN
Site OS grid reference Northing: Easting:
Proposed Development / Land Use (please give details)
Development / Land Use 1st 2nd Details In the 1st column, please tick proposed Residential type of development / Up to 102 dwellings can be accomodated on land use. the 3.4 Ha of net developable land, at 30 dwellings per hectare. In the 2nd column, please tick any land Affordable Housing uses you would also consider appropriate. Specialist Residential In the details column, please specify the type of use and Gypsies & Travellers indicate the proposed mix of uses and number of Travelling Showpeople units, plots, pitches, amount of floorspace etc Community Facility
Leisure / Recreation
Retail
Employment Should the site be deemed not appropriate for residential development.
Renewable Energy
Mixed-use
Other (please specify)
VALP Site Details
Site area (hectares) Whole site Area Suitable for development 4.3 Ha 3.4 Ha Current or previous Primary land-use land use(s) Agricultural/ Horse grazing Secondary land-use Domestic Residential Existing structures (e.g. detached Agricultural Barn and the dwelling dwelling) Would development require relocation of the current use or Demolition of the barn demolition of existing structures? Adjacent land-uses (e.g. 2-storey To the north terraced housing / 2 Residential dwelllings + barns open farmland) To the east Several dwellings, barns and open farmland To the south Bear Brook watercourse To the west Open Farmland Relevant planning history See attached
Site Constraints: Are there any limitations that may prevent or constrain development on this site? (please give details)
Access Issues (e.g. limitations or problems relating Access is acceptable. There is reasonable visibility. Potential highway issues regarding frequency and speed of traffic along Broughton lane. However, intensity to site access) likely to diminish with the construction of the orbital link.
Topography or ground conditions South westerly slope (e.g. site slopes, varying site levels etc) Contamination/ Pollution/ Hazardous Uses n/a (e.g. unsuitable ground conditions, previous hazardous land uses, unstable/contaminated structures) Flood risk (liability of site to flooding) S-W of site Flood zone 2+ 3
Legal/ Operational Constraints (e.g. ownership constraints, n/a covenants, tenancies, ‘ransom strips’ or operational requirements of landowners) Environmental Constraints (e.g. negative effects on local Trees & hedges landscape wildlife designations, protected species, loss of mature woodland, loss of locally used open space or access to open space, )
VALP Utilities and Infrastructure Provision (e.g. provision of services to development including gas, electricity, water, sewerage and telecommunications)
Planning Policy Constraints Designated Greenfield/Open Countryside in adopted policy. (e.g. based on adopted policy, VALP emerging policy S2 and D1 plan for major development in the area with an designations or protected areas easterly extension of Aylesbury into the parish of Bierton/Broughton as part of including Conservation Areas, 'Aylesbury Garden Town Vision'. This site could qualify as a 'sustainable green- SSSIs, Local Nature Reserves) field urban fringe site'. Site is favourably located in an area which has been identified as suitable for housing or economic development.
Other considerations (any other issues that may affect Flood Zone SW of the site near the Bear Brook watercourse. See attached the developability of the site Site Constraints Plan
Can the constraints be overcome and are any of them likely to affect the achievability or timing of the development? Please give details
The emerging strategy for the area will modify the planning considerations for this particular site. The council's growth strategy as part of the East Aylesbury MDA and Garden Town Vision will allow for significant development in the surroun- -ding area. This will bring in new services, infrastructure and will undoubtedly improve the connectivity of Broughton
(through public transport for example). Better connectivity and closer services/amenities would improve the sustainability of this site at Brook Farm. It could therefore qualify as a 'sustainable greenfield urban fringe site' in the medium to long term. Development is considered acceptable at these urban fringe sites.
Site Achievability (please give details)
Is the site currently being marketed? No Is the site owned by a developer? No Is the site under option to a developer? No Please tick the likely timescale for the site Available immediately Within the next 11-15 years being developed SSdsdsaaslocations Within the next 1-5 years Years 15+ Site Allocations and Delivery Within the next 6-10 years
Once work has commenced, how many years do you think it would it take to Approximately 3 years complete?
Access to Site - Site Assessment (please give details) Are there any issues that would restrict access to the site by a No, there is good access onto the Broughton Lane representative of the Council undertaking further assessment? VALP Please provide any additional information you think may be helpful to the Council in its consideration of this site for development . Please also use this section if you require more space to respond to any of the earlier questions.
VALP
Phillips Planning Services Limited LAND AT BROOK FARM Kingsbrook House BROUGHTON, 7 Kingsway Bedford BUCKINGHAMSHIRE MK42 9BA
Tel. 01234 272829 Email. [email protected]