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Written Statement Vale of Aylesbury District Council Local Plan 2013-2033 Waldridge Garden Village Representation (Reference 32314) Matter 2.B Housing Need and Requirement: Unmet Need Prepared by Barton Willmore LLP June 2018 Written Statement Vale of Aylesbury District Council Local Plan 2013-2033 Waldridge Garden Village Representation (Reference 32314) Matter 2.B Housing Need and Requirement: Unmet Need Prepared by Barton Willmore LLP Project Ref: 27948/A5/Matter 2.B Reps Status: Final Issue/Rev: 01 Date: 19 June 2018 Prepared by: Alex Wilson Checked by: Iain Painting Authorised by: Iain Painting Barton Willmore LLP 7 Soho Square London W1D 3QB Tel: 020 7446 6888 Ref: 27948/A5/IP/AW Fax: 020 7446 6889 Email: [email protected] Date: 19 June 2018 COPYRIGHT The contents of this document must not be copied or reproduced in whole or in part without the written consent of Barton Willmore LLP. All Barton Willmore stationery is produced using recycled or FSC paper and vegetable oil based inks. CONTENTS 1.0 INTRODUCTION ....................................................................... 1 APPENDIX 1 : PEGASUS POSITION STATEMENT Waldridge Garden Village Representation (Reference 32314) Matter 2.B Housing Need and Requirement: Unmet Need Introduction 1.0 INTRODUCTION 1.1 This Written Statement has been prepared on behalf of Mr Elgin and Ashfield Investments Company Ltd, members of the Waldridge Garden Village Consortium (reference 32314), in respect of Matter 2.b of the Inspector’s ‘Matters and Issues’ entitled ‘Unmet Need’. 1.2 On behalf of the Waldridge Garden Village Consortium (hereafter referred to as ‘WGVC’), the Site has previously been promoted through the Local Plan by Pegasus Planning Group. 1.3 This Statement has been prepared with due regard to the tests of ‘soundness’, as set out in Paragraph 182 of the National Planning Policy Framework (NPPF), namely: • Positively prepared – plans should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development; • Justified – plans should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence; • Effective – plans should be deliverable over their period and be based on effective joint working on cross-boundary strategic priorities; and • Consistent with national policy – plans should enable the delivery of sustainable development in accordance with the policies in the Framework. 1.4 In accordance with the Inspector’s Guidance Note for submitting representations to the Examination, this statement seeks to respect the 3,000 word limit. We do not repeat points already covered in original representations submitted to the Local Plan on behalf of WGVC. WALDRIDGE GARDEN VILLAGE 1.5 Previously, the Site was promoted through the Local Plan process as part of the wider Waldridge Garden Village area (a potential new settlement). Please refer to representations Dated 5th September 2016 and the supporting ‘Waldridge Position Statement’, prepared by Pegasus Planning Group (found at Appendix 1). 27948/A5/IP Page 1 June 2018 Waldridge Garden Village Representation (Reference 32314) Matter 2.B Housing Need and Requirement: Unmet Need Introduction 1.6 The creation of ‘new settlements or extensions’ and their ability to deliver new houses is widely acknowledged within National Policy, including the National Planning Policy Framework (NPPF): “The supply of new homes can sometimes be best achieved through planning for larger scale development, such as new settlements or extensions to existing villages and towns that follow the principles of Garden Cities. Working with the support of their communities, local planning authorities should consider whether such opportunities provide the best way of achieving sustainable development.” [NPPF, Para 52] 1.7 The Site presents an opportunity to accommodate new housing within the District and is identified in the GL Hearn ‘New Settlement Scoping Study’ (June 2016) as a potential location to accommodate a new settlement of 6,000 dwellings in the future. MATTER 2.B UNMET NEED Q29 (II) 1.8 In the Matters and Issues, the Inspector has set out the following in respect of Matter 2.b: “A hearing session will be needed to hear those listed in my Qs29 and 51 who have a right to be heard and who have questioned 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 those areas defining the quantity of unmet need but 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.” 1.9 Under the Duty to Cooperate, Aylesbury Vale, Wycombe, Chiltern and South Bucks Council have agreed the distribution of unmet need across the Housing Market Area (HMA). Aylesbury Vale District Council (hereafter referred to as ‘AVDC’) has drafted the Vale of Aylesbury Local Plan (hereafter referred to as ‘VALP’) based on the assumption that neighbouring authorities will meet their housing requirements. 27948/A5/IP Page 2 June 2018 Waldridge Garden Village Representation (Reference 32314) Matter 2.B Housing Need and Requirement: Unmet Need Introduction 1.10 During the examination of the VALP, the Inspector can only consider the evidence in front of him at the time. 1.11 Emerging Local Plans inevitably come forward at different rates. In the future, neighbouring authorities may fail to bring forward Local Plans consistent with their housing commitments. One solution is that the VALP is delayed until the time when all Local Plans within the HMA have been progressed. This, however, would result in significant delays in the adoption of Local Plans, which would be contrary to national guidance. 1.12 Alternatively, AVDC has a duty to review matters which may be expected to affect the development of its area (Section 13(1) of the Planning and Compulsory Act 2004) and has a duty to keep the development plan documents under review, having regard to the results of any such review (Section 17(6) of the Planning and Compulsory Act 2004). In the scenario of a gap arising and a material shortfall in supply in the HMA, this should trigger the need for AVDC to review its Housing Chapter in the Local Plan accordingly. The VALP should be explicit on what would trigger the review. We seek to agree this with AVDC prior to the commencement of Hearing Sessions on the VALP. 1.13 Previous representations submitted by Pegasus Planning Group on behalf of WGVC, set out our client’s position in respect of unmet need within the wider sub region, including Luton. WGCV wishes to rely upon these representations in respect of this matter. Please find a copy enclosed at Appendix 1 for ease. 27948/A5/IP Page 3 June 2018 APPENDIX 1 PEGASUS POSITION STATEMENT September 2016 | NT | P16-0236 Jeremy Elgin Waldridge Garden Village CRITIQUE OF THE HEDNA AND UNMET NEEDS 1. INTRODUCTION 1.1 The objectively assessed need for housing (OAN) identified in the Vale of Aylesbury Draft Local Plan derives from the Buckinghamshire Housing and Economic Development Needs Assessment 2015 (HEDNA) prepared by ORS in January 2016. 1.2 This HEDNA has been prepared jointly by the authorities of Buckinghamshire and provides a shared evidence base to inform the preparation of the respective Local Plans. 1.3 The following report considers the assumptions within the HEDNA and identifies a number of concerns with the methodology employed and the currency of the assessment. 1.4 The HEDNA uses the 2012-based subnational population projections (SNPP) and subnational household projections (SNHP) as its base, although then deviates from these. However, the 2014-based SNPP and SNHP are both now available and account needs to be taken of these in accordance with the NPPG (2a-016). 1.5 The 2014-based SNHP indicate that across the plan period of Aylesbury Vale, the number of households is expected to increase by 21,027 (and by 42,772 across Buckinghamshire) as compared to the 2012-based SNHP which indicated that the number of households was only expected to increase by 18,404 (and by 40,847 across Buckinghamshire). This change is material and will result in a significant increase to the housing numbers within Aylesbury Vale and Buckinghamshire. 1.6 The identified contribution to the unmet needs of Chiltern, Wycombe and South Bucks is also considered within this paper. Pegasus Group Birmingham | Bracknell | Bristol | Cambridge | Cirencester | East Midlands | Leeds | London | Manchester Page | 1 September 2016 | NT | P16-0236 Jeremy Elgin Waldridge Garden Village 2. THE HOUSING MARKET AREA 2.1 The Validation Study of February 2013 identified that Aylesbury Vale was part of a Milton Keynes and Luton Housing Market Area (HMA) which included Aylesbury Vale, Milton Keynes, Central Bedfordshire, Bedford and Luton. 2.2 Inspector Ward commented upon the inter-relationships between these areas in his letter of 7th January 2014 and identified that these areas needed to be considered together, especially Aylesbury Vale and Milton Keynes. He also identified that there were significant issues with the ability of Luton to accommodate its own growth. However, Inspector Ward identified that there was no consistent evidence base for these areas and that as a result the needs of the HMA were not being planned for and that the duty to co-operate had not been met. 2.3 Since this time, Milton Keynes have identified a separate Milton Keynes HMA including Milton Keynes, Aylesbury Vale, Central Bedfordshire and South Northants in the Plan:MK Growth in Housing Topic Paper (September 2014). However, Milton Keynes have decided to assess their housing needs in isolation from the other authorities, but recognise that there may be a requirement to deliver growth beyond their boundary within Aylesbury Vale.