32314 Matter 2.B Waldridge Village Garden

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

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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).

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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.

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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.

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APPENDIX 1 PEGASUS POSITION STATEMENT

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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.

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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. Indeed, the Plan:MK Strategic Development Directions Consultation Document (January 2016) identifies that “…as some of the potential development areas are outside of Milton Keynes, any potential cross-boundary growth would need to be reflected in the planning policy documents for those adjacent areas…” and that this includes “…land beyond the administrative boundary of Milton Keynes to the south and west around Newton Longville and Whaddon in Aylesbury Vale…”. Therefore, at least one of the options for growth to meet some of the needs of Milton Keynes includes land within Aylesbury Vale and this would be additional to the objectively assessed need for Aylesbury Vale.

2.4 Bedford has since been identified as a separate HMA in the Bedford Strategic Housing Market Assessment (December 2015). Luton and Central Bedfordshire has also been defined as a separate HMA in the Luton and Central Bedfordshire Housing Market Assessment (Summer 2015).

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2.5 In Aylesbury Vale, the ‘Housing Market Areas and Functional Economic Market Areas in Buckinghamshire and the Surrounding Areas’ report identifies that the HMA includes Aylesbury Vale, Chiltern, South Bucks and Wycombe.

2.6 The HMA has therefore changed significantly in the last two years since the findings of Inspector Ward. It is acknowledged that the definition of a HMA is not an exact science and that different areas can be justified. However, the linkages identified with Milton Keynes particularly still exist and these will need to be taken into account.

2.7 The HEDNA provides a commentary of the HMA which was defined in the ‘Housing Market Areas and Functional Economic Market Areas in Buckinghamshire and the Surrounding Areas’ report. This identified that the HMA included the south eastern part of Aylesbury Vale, the entirety of Wycombe and Chiltern and a small area of South Bucks. For practical reasons and in light of the Planning Advisory Service (PAS) Technical Advice Note (July 2015), the HMA was aligned to Local Authority boundaries and included Aylesbury Vale, Chiltern and Wycombe, but excluded South Bucks.

2.8 It is now proposed that Chiltern and South Bucks will prepare a joint Local Plan and so the HEDNA recommends that South Bucks is included within the HMA for practical purposes. This is not supported by evidence and so may have implications for the housing requirements identified in the Chiltern and South Bucks Local Plan and for the Reading HMA (within which South Bucks actually lies) more generally. However, as the OAN of the authorities in the Buckinghamshire HMA appear to have been assessed independently rather than the OAN being assessed for the HMA and then disaggregated (as required by paragraph 47 of the NPPF), the inclusion or exclusion of South Bucks should not affect the OAN for each authority.

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3. POPULATION PROJECTIONS

Base population

3.1 The HEDNA suggests that the population of Aylesbury Vale was over-estimated in the 2001 Census and that therefore the population growth has been greater than identified in the ONS’s mid-year population estimates to 2011 as it started from a lower base. It adjusts the 2001 population to take account of this. This is a highly unusual exercise, as the Census provides the only comprehensive dataset for the nation which is not dependent upon statistical errors or sample sizes as all residents are legally obliged to provide accurate returns. The Census results should be afforded great weight and should not be dismissed as they have been by the HEDNA.

3.2 The HEDNA also identifies that the components of changes of the mid-year population estimates (without a negative allowance for Unattributable Population Change (UPC)) indicate that the population would have increased even faster than the difference between the adjusted 2001 population and the 2011 population. It therefore concludes that there is a need for some adjustment to the components of change identified in the mid-year estimates to take account of the alleged errors in the 2001 Census.

3.3 In Figure 24, the HEDNA undertakes further analysis to justify this adjustment to the components of change. The HEDNA compares the mid-year estimates (without an allowance for UPC) with other data sources identified by the ONS. It concludes from this that the mid-year estimates (without an allowance for UPC) over-estimate the population growth in Aylesbury Vale. From this it is concluded that the population growth has been less than the estimates indicate. However, this justification is not robust. The reason that the other data sources indicate that population growth has not been as great is due to the parameters of these datasets rather than anything specific to Aylesbury Vale, as set out below. Indeed, using these datasets would indicate that the mid-year population estimates over- estimate population growth in the vast majority of authorities and across the nation.

3.4 The estimated growth in population has not been matched by a corresponding increase in NHS patients registered in Aylesbury Vale. This is likely to be as a result

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of the significant rates of housebuilding which has occurred in Aylesbury Vale in the recent past, with many residents moving to the area. Many of these new residents are unlikely to have re-registered with NHS practices in Aylesbury Vale and so will continue to be registered in other locations. There is always a time lag associated with patient registration and given the recent increase in house-building in Aylesbury Vale this is likely to be particularly marked. Therefore, it would not be expected that the number of patients registered with the NHS with an address in Aylesbury Vale would be as great as the actual resident population.

3.5 The estimated growth in population has also not been matched by a corresponding increase in the school population. This is the norm across the nation for a number of reasons, including that this counts the number of pupils educated by the state in Aylesbury Vale rather than the number of pupils who are resident. Many will choose to attend school outside of the administrative area especially where there are so many large centres adjacent to Aylesbury Vale (including Milton Keynes, Thame, Bicester and Princes Risborough); and it does not include those pupils educated in private schools. Therefore, this is more representative of the type and location of schools that residents choose to attend rather than the number of resident school aged children.

3.6 The estimated growth in population has also not been matched by a corresponding increase in those receiving state pensions. Again this is the norm across the nation, as the state pension is only available to those who have paid sufficient National Insurance Contributions and so does not apply to all residents. Again, this measure should be afforded very little, if any weight.

3.7 Indeed, all of these measures are not sufficiently robust to indicate that the mid- year population estimates are over-estimating the population growth in Aylesbury Vale and if these measures were to be used nationally they would fundamentally undermine all of the mid-year population estimates.

3.8 The HEDNA draws on this alleged over-estimation to conclude that there is a problem with the mid-year population estimates in Aylesbury Vale. However, as identified previously, the justification for this conclusion would undermine the mid- year estimates in totality, despite the fact that they are prepared and validated by the ONS and represent the Government’s position.

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3.9 Nevertheless, the HEDNA makes these unjustified adjustments to the population estimates and presents this adjusted scenario in Figure 25. It is notable that from 2012 (the period subject to these unjustified conclusions) the population increase is lower in the adjusted scenario than even in the mid-year population estimates with a full allowance for UPC. Therefore, the HEDNA concludes that the population growth is lower than that identified by national statistics (the Census and revised mid-year population estimates) which are nationally recognised and robust.

3.10 Even if the argument of the HEDNA is supported, the UPC adjustment which has been included in the mid-year population estimates from 2001 has been partially justified to account for errors in the 2001 Census (see paragraph 3.34 of the HEDNA). However, this error has now been addressed as there is no dispute over the accuracy of the 2011 mid-year estimates. Therefore, the most up-to-date statistically robust data from the ONS should now be relied upon. However, the HEDNA makes an unjustified negative adjustment to the historic migration flows (which is then included in the projection of future migration trends) which decreases the estimated population far below that identified in the mid-year estimates.

3.11 Paragraph 47 of the NPPF requires that the OAN is established for the HMA and indeed it is more robust to do it at this scale as estimates and projections become more robust for larger areas. However, the HEDNA takes a different approach (contrary to national policy) and calculates the OAN for each Local Authority using a different method in Aylesbury Vale to the other three Local Authorities. Indeed, the adjustment to the mid-year estimates is only undertaken in Aylesbury Vale, despite the fact that an adjustment in the other direction may be required in the other authorities. As an example, in Wycombe the superseded mid-year estimate significantly under-estimated the population growth (by 5,500 in 2011) and so based upon the analysis for Aylesbury Vale this would suggest that a corresponding significant positive adjustment would be required in Wycombe.

3.12 Indeed, if national policy had been followed and the OAN calculated in a consistent way for the entire HMA then the adjustments to the base population of Wycombe and Aylesbury Vale are likely to balance out and support the mid-year estimates as identified by the ONS; rather than inconsistent adjustments being applied to one

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authority only with the effect of significantly reducing the estimated population. National statistics should be afforded due weight without these unjustified adjustments.

Migration flows

3.13 The HEDNA correctly identifies that the SNPP are based upon five year trends and that they are therefore subject to short-term variations. It therefore correctly considers 10 year trends in migration flows alongside the SNPP flows although bases these on the unjustified adjusted migration flows as identified previously. However, this will all need to be updated to reflect the 2014-based SNPP and the 2015 mid-year population estimates.

3.14 It is identified in paragraph 3.92 that the 2012-based SNPP results in an increase of 74,300 people; the 2004-14 flows result in 73,700 people; and the 2001-11 flows result in 64,700 people. Given that two of these three projections identify very similar numbers it is these that should be afforded greater weight, especially when the 2001-11 based flows will be far more influenced by the flows from a smaller EU (prior to Bulgaria, Croatia, Cyprus, the Czech Republic, Estonia, Hungary, Latvia, Lithuania, Malta, Poland, Romania, Slovakia, and Slovenia joining).

3.15 One of these trends should be used to reflect what is likely to happen assuming that recent trends continue. This is reflected by the HEDNA’s use of the 2004-14 trends. However, it must be acknowledged that Brexit may have implications for the levels of migration which will occur in the future. The effect of Brexit will not be able to be anticipated until the necessary negotiations have occurred with the EU, and so until this time it must be assumed that migration will continue as it has in the past.

3.16 Furthermore, the SNPP already underestimate the net international migration flows to the UK as recognised in paragraph 7.8. Indeed, the 2014-based SNPP assume that net international migration will decrease to 185,000 migrants by 2021 which is broadly equivalent to the non-EU migration alone which was experienced in 2015 (188,000 migrants). Therefore, the base projections used in the HEDNA already anticipate a significant reduction in net international migration which reflects a

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situation whereby as a result of Brexit no net additional migrants come from the EU to the UK. In all likelihood, there will still be some level of positive net in- migration from the EU even if this is on a points based system, and so the projections in the HEDNA will provide an absolute minimum, such that any net in- migration from the EU will require additional housing.

Household population

3.17 The HEDNA identifies in paragraph 3.94 that the approach to dividing the total population between households and communal establishments is consistent with the CLG approach. This is to be supported. However, once more this will need to be updated to reflect the 2014-based SNHP.

3.18 This approach assumes that the proportion of people over the age of 75 in communal establishments remains constant. Therefore, it is assumed that the number of bedspaces in communal establishments increases at the same rate as the population over 75. Depending on which projection scenario is used this equates to between 80% and 82%. However, there inevitably needs to be some flexibility in the application of this as some C3 dwelling units can provide for the needs of the elderly (especially in retirement villages) and vice versa.

Other factors

3.19 The HEDNA does not provide any detail on how it has calculated the births and deaths. It is assumed that the fertility and mortality rates are taken from the 2012- based SNPP but this would benefit from clarification and will need updating to reflect the latest projections.

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4. HOUSEHOLD PROJECTIONS

Household Representative Rates

4.1 The HEDNA relies upon the household representative rates identified in the 2012 SNHP. However, these have now been superseded by the 2014 SNHP and accordingly the HEDNA will need to be updated. Indeed, taking this opportunity to update the HEDNA will provide a longstanding evidence base which will not be superseded until the release of the 2016 SNHP in 2018. This update would therefore provide a window of two years in which to adopt the Local Plans.

4.2 The HEDNA suggests that the household representative rates of the SNHP should not be adjusted to take account of any recessionary effects as the housing market had changed before these recessionary effects took hold. However, if there is evidence that the accessibility of the market is preventing household formation then this should be taken account of within the OAN. This can either be addressed through an adjustment to the household representative rates or by the application of an upwards adjustment in response to market signals. If the latter approach is to be used, then it is still useful to incorporate adjustments to the household representative rates as a sensitivity test in order to inform the level of such a market signals adjustment.

Vacancies and second homes

4.3 The HEDNA makes an adjustment for vacancies and second homes which is derived from the 2011 Census and this is to be supported.

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5. AFFORDABLE HOUSING NEED

Existing need

5.1 The HEDNA seeks to estimate the existing number of households in affordable need. In so doing it reflects the categories identified in the NPPG (2a-024). However, in assessing the affordable needs of those in overcrowded housing, it concludes that those in owner occupation are not in affordable need.

5.2 It is highly likely that some proportion of owner occupiers in overcrowded accommodation cannot access suitably sized accommodation as the difference in cost for example between a 2-bed and 3-bed house is significant. The assumption of the HEDNA that none of these will be in affordable need is therefore very optimistic.

5.3 The HEDNA also proposes that those households in unsuitable housing are not in affordable need. It suggests that if affordable homes were provided for these households then another household would move into the unsuitable housing and that therefore the provision of additional affordable homes would do nothing to address the existing situation. The current household is defined to be in affordable need according to the NPPG (2a-024) and so provision needs to be made for them. Any other household that would move into the unsuitable housing would themselves be defined as being in affordable need and so again affordable provision would need to be made. The HEDNA’s approach to this is to support unsuitable housing as a form of accommodation rather than to accord with national guidance and provide a suitable alternative affordable house to those in need such that the unsuitable housing is not used, until it has been made suitable.

5.4 Indeed, in regard to both overcrowded households and those in unsuitable housing, the NPPG (2a-024) defines them as affordable housing and so in order to accord with national guidance these should be included in the calculation of the existing need (ensuring that there is no double counting).

Future needs

5.5 Paragraph 4.64 of the HEDNA identifies that the future affordable housing needs are calculated consistently with the projections of the HEDNA. The future affordable needs should therefore be reassessed to take account of the projections which are

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uplifted to provide additional workers identified in paragraph 7.48, but this is not undertaken and as such the affordable needs likely to arise are not assessed within the HEDNA. In any case, there will be a need to reassess the affordable needs as a result of the 2014 SNHP.

5.6 Paragraph 4.106 also identifies that those households unable to afford housing without welfare support within the private rental sector are not classed in affordable housing need. This is contrary to the NPPG (2a-024) which requires that households that cannot afford their own homes are classed within affordable need. Furthermore, this issue has been considered in the Stroud Local Plan, the Gloucester, Cheltenham and Tewkesbury Joint Core Strategy and the Eastleigh Borough Local Plan and in all these cases the Inspector has concluded that those in the private rental sector that could not afford their housing without welfare support are in affordable need. This is a significant flaw in the HEDNA.

5.7 Paragraph 4.72 identifies that the HEDNA only includes those who are eligible for welfare support as being in future affordable housing needs and concludes that this will therefore provide only a minimum level of affordable need. Indeed, in much of southern England households who are ineligible for welfare support will nonetheless be unable to access accommodation owing to the cost of housing. However, the HEDNA takes no account of such households contrary to the NPPG (2a-024). Indeed, the cost of housing in Buckinghamshire plays no part in determining the affordable needs within the HEDNA. This is a further significant gap in the assessment which undermines the weight to be applied to the affordable needs calculations.

Total affordable needs

5.8 These significant flaws result in the affordable needs of Buckinghamshire being grossly underestimated. If this is progressed through the Local Plan, it will give rise to a very significant population that are ineligible for welfare support (based on the current criteria) but are equally unable to afford housing and a population who will be forced to remain in uncertain private rental accommodation which may in itself become unaffordable if there are changes to the benefit system. Even with these flaws the HEDNA identifies a need for 9,940 affordable homes which equates to 24% of the total identified need.

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5.9 Once a robust assessment is undertaken, including the inclusion of the 2014 SNHP, the inclusion of the SNPP and a robust assessment of the affordable needs including the needs of those currently in the private rental sector and those who are not eligible for welfare support, both the total OAN and the affordable OAN will be demonstrated to be significantly greater than currently proposed. Indeed, if the private rental sector issue is addressed alone, in accordance with Inspectors findings elsewhere this would increase the affordable need from 10,100 to 16,000 dwellings across Buckinghamshire.

5.10 The HEDNA recognises that the affordable needs identified are minima, and accordingly does include the necessary adjustment to the consideration of the private rental sector as the upper end of the range. It also identifies that delivery should be frontloaded to address the existing affordable needs in paragraph 4.117.

5.11 Based on this minimum range it would be expected that the HEDNA would identify the affordable OAN as being towards the top end of this range. Indeed, if robust analysis was undertaken it would be significantly in excess of this range. However, paragraph 7.33 concludes that the affordable OAN should be 10,500 without any justification. This is both unjustified and contrary to the flawed evidence within the HEDNA.

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6. EMPLOYMENT FORECASTS

Economic Activity Rates

6.1 The HEDNA relies upon the economic activity rates identified in the OBR projections. However, these projections include the anomalous assumption that the economic activity of those aged 16 and 17 will be maintained despite the fact that these individuals are now required to be in full time education.

6.2 This assumption, whilst supported by the OBR is not tenable. It is inevitable that there will continue to be some decline in the economic activity rates of this age group as a result of compulsory education.

6.3 The result of applying these economic activity rates to the 2004-14 based projection results in an additional 28,817 economically active persons over the plan period in Buckinghamshire.

Employment Projections

6.4 Figure 98 presents the Oxford Economics forecasts for employment growth which suggests that there will be an additional 42,300 jobs across Buckinghamshire over the plan period).

6.5 It is this Oxford Economics projection which is used within the HEDNA without any consideration of alternative projections (although the report repeatedly alludes to the use of the Experian figures despite the fact that these are not used in the HEDNA). However, Figure 96 does present the comparative projections of Experian which are significantly greater than those of Oxford Economics. No consideration has been given to the projections of the other nationally recognised econometric provider namely Cambridge Econometrics. The HEDNA has relied upon the most negative economic growth scenario of those produced by nationally recognised econometric providers, with the effect that the OAN is reduced.

6.6 Any economic projection is necessarily uncertain, and as such the weight to be applied to any one projection should be considered in the light of comparators. Indeed, this uncertainty has been identified by a number of Inspectors with the conclusion that either a mid-point of the economic projections should be supported (see the Stroud Local Plan, the Gloucester, Cheltenham and Tewkesbury Joint Core

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Strategy or the South Somerset Local Plan) or a figure towards the top end of the range should be supported (see Test Valley Local Plan or the Herefordshire Local Plan). The first of these approaches provides for a realistic mid-point of the potential economic growth in the area and the latter ensures that economic growth is not hindered by insufficient employment land and housing. Given that a key tenet of the NPPF is to support and prevent barriers to economic growth, any economic projection which could prevent the economic prospects being achieved should be resisted. In the case of Buckinghamshire, the Oxford Economics projection could do just this and the Experian projections should also be modelled to provide a range.

6.7 Nevertheless, as identified in paragraph 7.38 even based on the bottom end of the economic growth projections it is unlikely that the number of additional economically active residents (28,817) will not be sufficient to provide for the additional jobs (42,300). Indeed, paragraph 7.38 identifies that the same position is true for Aylesbury Vale, with 13,400 economically active residents (although incorrectly termed ‘workers’ in the text) will not provide for the projected 17,600 jobs.

6.8 The balance between the economically active population and the resulting number of workers is dependent upon a number of issues including the employment rate (taking account of the unemployed), an allowance for double-jobbing and the commuting rate. The application of these rates will impact upon the number of jobs which can be supported in an area and it is necessary to undertake these calculations in order to identify the balance between workers and jobs.

Unemployment rate

6.9 The HEDNA identifies in paragraph 7.40 that the number of unemployment benefit claimants decreased by 3,400 from 2013 to 2015. It assumes that these have all found jobs and that the number of workers required to support the same level of economic growth has therefore reduced by 3,400. However, this is misleading and has significant repercussions for the assessment of needs to support economic growth.

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6.10 Firstly, those claimants were economically active to start with and so are not additional to the economically active population (although may be additional to the working population). This means that there is still a growth of 28,800 economically active persons, although the unemployment rate of this group may have reduced as a result of these former claimants accessing jobs.

6.11 However, the HEDNA adds the 28,800 economically active people (rather than workers) expected to be accommodated in the proposed housing to the 3,400 former claimants (who may or may not work in the area) to conclude that the proposed housing will support an additional 32,300 workers. This is not comparing like with like and so should not be afforded weight. The actual position will be that the economically active population will increase by 28,800, but that the unemployment rate may change such that a greater proportion of the economically active population will be available for work.

6.12 Secondly, many of the claimants may have reached retirement age or migrated out of the area and so have not become workers, but instead are simply no longer economically active within the HMA.

6.13 The correct approach is to establish the economically active population that will arise over the plan period and then to apply an unemployment rate to this, which should reflect claimants accessing the job market as follows.

6.14 The economically active population at 2013 was 271,665 according to Figure 93. The unemployment rate in 2013 (the start date of the plan period) was 5.5% (according to the Annual Population Survey), therefore it can be calculated that the employed population was 256,723. Figure 93 then projects that the economically active population is expected to increase to 300,482 by 2033. The unemployment rate in 2015 (which takes account of the reduction of the benefit claimants) was 4.3% and so assuming that this rate is maintained across the period to 2033 it would be expected that there would be 287,561 employed persons. This equates to an increase of 30,838 workers rather than the 32,300 identified by the HEDNA. Again, the HEDNA has adopted a less than robust method which results in a reduction to the OAN.

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To calculate the effects of the unemployment rate robustly, either the existing unemployment rate should be assumed to persist throughout the plan period or a policy-on approach to decreasing the unemployment rate can be assumed (providing this is realistic). Any further reduction to the unemployment rates would need to be viewed in the context of the significant reduction which has already occurred in Buckinghamshire.

Commuting rate

6.15 The HEDNA bases the assumed commuting rate on the 2011 Census and maintained throughout the plan period (as suggested by Inspector Ward) which is supported. This identifies that a small number of the newly arising employed population will out-commute and so will not support jobs in Buckinghamshire. An accordingly small increase in housing is therefore required to be able to support the same number of jobs.

6.16 However, this commuting rate is calculated across Buckinghamshire rather than for each district. This has the effect of over-estimating the number of workers required in some districts and under-estimating it in others. In order to be consistent with the remainder of the HEDNA the individual commuting rates of each district should be applied independently.

Double jobbing

6.17 The HEDNA makes an allowance for 5.9% of the employed population occupying more than one job. However, this allowance is not sourced or justified anywhere within the HEDNA. Whilst it is recognised that double-jobbing does exist and that some allowance is appropriate, this appears to be a very high assumption by comparison with other assessments provided by a number of different consultancies, which again has the effect of reducing the OAN. Indeed, the Welwyn Hatfield Strategic Housing Market Assessment Partial Update Addendum prepared by Turley’s assumed a rate of 3.9%; the Berkshire (including South Bucks) Strategic Housing Market Assessment prepared by GL Hearn assumed a rate of 3.9%; and A Review of the West Surrey SHMA as it relates to the Objectively Assessed Housing Need of Guildford prepared by Neil McDonald assumed a rate of 4.1%.

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Economic participation

6.18 The HEDNA assumes that the contribution from an economically active person to the economy will be maintained. However, it also identifies that the economically active population will become increasingly old. Indeed, Figure 93 suggests that the economically active population over the age of 64 will increase by 210% from 2013 to 2033.

6.19 The Labour Force Survey identifies that older workers (over 64) are far more likely to be self-employed, but that the sectors which are planned for growth in Aylesbury Vale, including high performance engineering, telehealth and rehabilitation technologies and ICT are more likely to be supported by an increase in employee jobs rather than self-employed positions.

6.20 The Labour Force Survey also identifies that older workers are far more likely to be in part-time employment, but that again the sectors which are planned for growth in Aylesbury Vale currently are largely reliant upon full-time workers. This preference for part-time working amongst older workers will not support the same level of FTE jobs.

6.21 The Labour Force Survey also identifies that the sectors which are planned for growth have very low levels of older workers.

6.22 Based on current information, there appears to be a disconnect between the projected growth of older workers and the planned job growth. This may give rise to a need for additional workers to support the planned job growth, especially in the specific sectors identified.

Uplift for economic growth

6.23 Despite the fact that the HEDNA assumes that the compulsory education of 16 and 17 year olds will not affect the economic activity of this age group; that the bottom of the range of job growth projections is assumed; that the unemployment rate is not robustly applied; and that the HEDNA assumes a very high rate of double jobbing, each of which underestimates the housing required to support economic growth, the HEDNA still concludes that the demographic OAN will not be sufficient

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to support economic growth (with a shortfall of some 8,600 workers). A robust assessment would demonstrate that this shortfall was significantly greater.

6.24 In order to address this shortfall, the HEDNA proposes that additional homes are required and uplifts the projection from 42,700 to 48,600 across Buckinghamshire (or from 18,800 to 21,200 in Aylesbury Vale). This uplift does not take account of the significant under-estimation of economic and housing growth as referenced above. A robust assessment would significantly increase the OAN to provide for economic growth.

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7. MARKET SIGNALS

7.1 The HEDNA undertakes an analysis of market signals as required by the NPPG. It recommends an uplift to respond to the identified pressures in the housing market based upon the approach adopted in Eastleigh and this is to be supported.

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8. PROPOSED OAN

8.1 The HEDNA brings all of this information together to identify an OAN of 50,000 homes for Buckinghamshire and 21,300 homes for Aylesbury Vale. As identified throughout this report this is based on a series of assumptions which serve to underestimate the true OAN which is in actual fact significantly greater.

8.2 Pegasus Group have undertaken some initial modelling work using the reputable Chelmer model and using robust assumptions. This indicates that the OAN for Aylesbury Vale is actually of the order of 23,800 homes without any adjustment for market signals or for affordable housing. This demonstrates the effects of the negative assumptions employed within the HEDNA, and this under-estimation will be reflected across the HMA. The effect of a robust assessment would be to increase the OAN across each of the 4 LPAs and therefore the unmet needs arising from Chiltern, South Bucks and Wycombe Districts as well as the OAN for Aylesbury Vale itself.

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9. UNMET NEEDS

9.1 The draft Vale of Aylesbury Local Plan proposes to address the unmet housing needs of Chiltern, South Bucks and Wycombe, which cannot be met within these administrative areas. It identifies a contribution of 12,000 homes to meet these unmet needs in paragraph 1.13 although identifies that this as a worst case scenario.

9.2 Given the identified flaws of the HEDNA the overall OAN across Buckinghamshire and the unmet needs will be significantly greater.

9.3 The Chiltern and South Bucks response to the Aylesbury Vale Local Plan 2013-33 Issues and Options Consultation identifies an unmet need of at least 7,500 homes and the New Wycombe Local Plan consultation document identifies an unmet need of around 5,000 homes. Whilst the capacity of these authorities has yet to be established precisely, the unmet needs of Chiltern, South Bucks and Wycombe should be assumed to be at least 12,500 homes even against the flawed OAN. Aylesbury Vale should therefore be planning to meet at least this number.

9.4 Furthermore, the draft Vale of Aylesbury Local Plan only considers the unmet needs of the remainder of Buckinghamshire and yet it is known that there is a very significant unmet need arising from London. With the unmet needs of London not being addressed in Buckinghamshire, there is likely to be an increased demand across the HMA with the local population being priced out of the market. There is therefore likely to be a need for additional housing to accommodate the projected population as well as those households unable to meet their needs in London.

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10. CONCLUSION

10.1 The HEDNA prepared jointly on behalf of the Buckinghamshire authorities provides a combined evidence base to progress the respective Local Plans. It is critical that this is robust in order to ensure that the Local Plans respond positively to the housing needs. However, the HEDNA adopts a number of assumptions which serve to under-estimate the OAN as identified throughout this report.

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RESPONSE TO THE DRAFT VALE OF AYLESBURY LOCAL PLAN CONSULTATION (7TH JULY 2016 TO 5TH SEPTEMBER 2016)

ON BEHALF OF JEREMY ELGIN

TOWN & COUNTRY PLANNING ACT 1990 (AS AMENDED) PLANNING AND COMPULSORY PURCHASE ACT 2004

Prepared by: NEIL TILEY

Pegasus Group

©Copyright Pegasus Planning Group Limited 2011. The contents of this document must not be copied or reproduced in whole or in part without the written consent of Pegasus Planning Group Limited Jeremy Elgin Response to the Draft Vale of Aylesbury Local Plan consultation

CONTENTS:

Page No:

1. INTRODUCTION 1 2. BACKGROUND 2 3. VISION AND STRATEGIC OBJECTIVES 3 4. STRATEGIC 4 5. STRATEGIC DELIVERY 15 6. HOUSING 23 7. ECONOMY 25 8. TRANSPORT 26 9. BUILT ENVIRONMENT 27 10. NATURAL ENVIRONMENT 28 11. SUSTAINABILITY APPRAISAL 29 12. NEW SETTLEMENT SCOPING STUDY 32

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Jeremy Elgin Response to the Draft Vale of Aylesbury Local Plan consultation

1. INTRODUCTION

1.1 Pegasus Group have been instructed by Jeremy Elgin to submit the following representations to the Draft Vale of Aylesbury Local Plan and the supporting evidence based documents. This response is structured to reflect the structure of the draft Local Plan and references are drawn to the supporting evidence as appropriate. The supporting evidence is then also responded to as appropriate.

1.2 The Draft Vale of Aylesbury Local Plan identifies an area of land with potential for a new settlement entitled Haddenham New Garden Village. This area of land provides the opportunity for a new stand-alone Garden Village (called “Waldridge Garden Village”) in close proximity to Wycombe District where much of the housing need arises. A self-contained garden village is being designed based on information included in technical studies which are being prepared to support the promotion of the site through the Local Plan process. These identify that the area provides the opportunity to develop a new settlement, and that any constraints can be addressed by appropriate mitigation. Therefore, it is considered that the development of Waldridge Garden Village would be deliverable in the plan period (with capacity for additional development post 2033). A Position Statement is appended to this response which summaries the work of specialist consultants who have been commissioned to consider the specific factors relating to the development of Waldridge Garden Village.

1.3 It is recognised that representations are also being prepared on behalf of other landowners with an interest in Haddenham New Garden Village. This demonstrates support for the principles of development of Haddenham New Garden Village and the intent to comprehensively design and deliver this new settlement.

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2. BACKGROUND

2.1 The Background section of the Draft Local Plan provides a useful context and is welcomed. However, there are a number of issues within the section which raise concerns as follows.

2.2 The NPPF requires that Local Plans are positively prepared. However, paragraph 1.13 of the Background section characterises the provision of housing to meet the unmet needs of neighbouring authorities as “a worst case scenario”. This should be reworded as providing a positive strategy to address the housing shortfall (in accordance with paragraph 14 of the NPPF).

2.3 Paragraphs 1.30 and 1.31 of the Draft Local Plan set out the proposed timetable for the progress of the Local Plan. Whilst this ambitious timetable is to be welcomed, the Council will need to be realistic. It is inevitable that there will be some slippages in the programme, particularly given the issues that the Plan needs to address.

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Jeremy Elgin Response to the Draft Vale of Aylesbury Local Plan consultation

3. VISION AND STRATEGIC OBJECTIVES

3.1 There are concerns relating to the negative terminology and clarity of the Vision and the Strategic Objectives which can be simply addressed through re-wording whilst maintaining the overall Vision and the Strategic Objectives, as follows.

3.2 The terminology within the Spatial Vision is not sufficiently clear. The term “appropriate amount of sustainable growth” is subjective and will differ based on an individual’s interpretation. The Spatial Vision should provide greater clarity and be more positive, including a reference to meeting needs.

3.3 Similarly, paragraph 2.4b should be phrased more positively such that unmet housing need from other areas will have been met in the most sustainable locations, rather than only where this is reasonable (which is again a subjective judgment).

3.4 Paragraph 2.4i identifies the vision for a new settlement to be developed in Aylesbury Vale which is to be supported, as it is considered that this is the only available strategy to ensure that the housing needs of Buckinghamshire are provided for. However, the paragraph only requires that the new settlement will be under development, but to meet the full housing needs, the vision should go much further and plan to deliver a significant number of homes within the plan period. This is supported by Table 1 which identifies a need for the delivery of 4,500 homes within the plan period.

3.5 The first Strategic Objective refers to the protection of existing sites, but it is not clear which type of sites will be protected and for what reason.

3.6 The second Strategic Objective again refers to meeting unmet needs only where this is “reasonable” which is a subjective measure and obviates the requirement of national policy to meet housing needs.

3.7 The second Strategic Objective refers to a phased approach to delivery. The adoption of a phased approach should not be a Strategic Objective (although may be required as a policy mechanism) as this serves to limit much needed housing delivery in the short-term. This Strategic Objective should be phrased more positively to “ensure a continuous supply with timely infrastructure delivery”.

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Jeremy Elgin Response to the Draft Vale of Aylesbury Local Plan consultation

4. STRATEGIC

Policy S1 Sustainable development for Aylesbury Vale

4.2 Policy S1 which reflects paragraph 14 of the NPPF is to be supported although it replicates national policy and so may not be required. The final part of this Policy requires clarification. It appears to reflect the approach to plan-making rather than decision-taking as it seeks to provide for the most sustainable locations which cannot be used in the determination of applications owing to the fact that only one site will be under consideration and there is no sequential test for the sustainability of sites. On the assumption that this part of the Policy does reflect plan-making it is unnecessary for it to be included in Policy as it does not relate to the determination of applications.

4.3 Furthermore, the final part of Policy S1 seeks to prioritise locations based on factors which are not location-specific, such as the mix proposed, infrastructure delivery and climate change effects. This part of the Policy needs clarification or could be deleted without affecting the nature of the overall Policy.

Policy S2 Spatial Strategy for Growth

4.4 Paragraph 3.11 summarises the findings of the Housing and Economic Development Needs Assessment (HEDNA) published in January 2016. However, the HEDNA adopts a number of assumptions which serve to under-estimate the objectively assessed need for housing and so it does not identify the full objectively assessed need as required by paragraph 47 of the NPPF. These assumptions are examined in further detail in the attached Critique of the HEDNA and Unmet Needs report.

4.5 The HEDNA identifies an objectively assessed need of 21,300 homes in Aylesbury Vale. However, initial modelling work undertaken by Pegasus using robust assumptions indicates that the objectively assessed need is actually of the order of 23,800 homes without any adjustment for market signals. This under- estimation is likely to occur across the HMA.

4.6 Paragraph 3.11 of the Draft Local Plan identifies an estimated unmet need for 12,000 homes to provide for the needs of Chiltern, South Bucks and Wycombe based on the HEDNA. The Chiltern and South Bucks response to the Aylesbury Vale Local Plan 2013-33 Issues and Options Consultation identifies an unmet need of at least 7,500 homes and the New Wycombe Local Plan consultation document identifies an unmet need of around 5,000 homes. Therefore, based on

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current information the unmet needs should total at least 12,500 homes (as compared to the identified 12,000) although it is acknowledged that the further capacity work still needs to be undertaken.

4.7 The HEDNA does not consider the objectively assessed needs of Milton Keynes and the draft Local Plan does not take account of the potential for some of the needs of Milton Keynes to be met in Aylesbury Vale as identified in the Plan:MK Development Directions Consultation.

4.8 Furthermore, there are a number of other authorities in the sub-region that are unable to meet their objectively assessed housing needs (OAN), including Luton. Where housing needs are unable to be met within a Housing Market Area, consideration should be given to meeting these needs in adjacent Housing Market Areas.

4.9 The HEDNA figures translate through to Policy S2 with the effect that the Draft Vale of Aylesbury Local Plan will not provide for the full objectively assessed needs of Aylesbury Vale; and the full objectively assessed needs of Buckinghamshire will not be provided across the HMA as required by paragraphs 47 and 179 of the NPPF, let alone any unmet needs of other authorities in the sub-region (including Milton Keynes and Luton).

4.10 The housing requirement should respond to the required update to the HEDNA; to the ongoing work regarding the capacity in Chiltern, South Bucks and Wycombe; and to the current and future needs of Milton Keynes and any other unmet needs of other authorities.

4.11 Paragraph 14 of the NPPF requires that the Local Plan meets the full, objectively assessed needs in the housing market area unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits. In such circumstances, paragraph 179 requires that local planning authorities should work together to meet development requirements that cannot wholly be met within their own areas.

4.12 In Chiltern, South Bucks and Wycombe the adverse impacts of meeting the full objectively assessed needs are currently considered to outweigh the benefits which results in an estimated unmet need of 12,000 homes (although recognising that further work is required to finalise this figure). Aylesbury Vale District Council have worked with these authorities across the housing market area to seek to

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meet these unmet needs in accordance with paragraph 179 of the NPPF and this is to be welcomed in order that the full objectively assessed needs are met across the housing market area. Indeed, no adverse impacts of meeting these full objectively assessed unmet needs in Aylesbury Vale have been identified and so based on the current evidence the District would be required to meet these full needs. This is the approach adopted in Policy S2 and Table 1 of the Draft Local Plan. However, paragraph 3.13 then adopts a different approach and proposes that the Local Plan will only meet “some unmet needs originating from neighbouring authorities” (my emphasis). This would result in the full objectively assessed needs not being met across the housing market area. This could only be justified if it was demonstrated that the adverse impacts of doing so would significantly and demonstrably outweigh the benefits, and if Aylesbury Vale District Council were working with other neighbouring authorities (outside of Buckinghamshire) to meet these unmet needs. If such evidence is provided and such joint working is undertaken then it may be appropriate to plan for only some of the unmet needs of Chiltern, South Bucks and Wycombe but at this point there is no evidence to support the wording of paragraph 3.13.

4.13 Furthermore, the Draft Local Plan has identified that a new settlement provides a sustainable option to meet the district’s needs (see paragraph 4.29). As this provides a sustainable option, there are clearly no adverse impacts which would demonstrably and significantly outweigh the benefits of the delivery of a new settlement. Therefore, even if planning to meet only some of the unmet needs is demonstrated to be justified, a new settlement would still be necessary as according to the Draft Local Plan it would be a sustainable solution to meet the needs of the district, including the needs of rural settlements in a sustainable location.

4.14 In terms of the distribution of development, paragraph 3.15 identifies that some of the housing needs of Buckinghamshire will be met on sites adjacent to Milton Keynes within Aylesbury Vale. This will prejudice the ability of Milton Keynes to meet its objectively assessed needs through sustainable urban extensions in Aylesbury Vale in the future (see response to Policy D3). Any such proposal would therefore need to be agreed under the duty to cooperate with Milton Keynes Council.

4.15 Paragraph 3.15 also identifies the need for a new settlement. This is to be supported as it will be required to meet the unmet needs of Chiltern, South Bucks

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and Wycombe in addition to the full objectively assessed needs of Aylesbury Vale (as well as any unmet needs from Milton Keynes); it provides the opportunity for these unmet needs to be met in close proximity to Wycombe and/or Chiltern where much of the unmet needs arise; it provides the opportunity for place- making as supported by the NPPF; and it provides the opportunity to minimise environmental effects by considering all potential sites across the District.

4.16 Policy S2 bullet (f) confirms this new settlement in the distribution of development and provides some guidance on the range of uses to be provided which is to be supported. It also identifies that the preferred option for this new settlement is yet to be determined. However, as set out previously one of the main justifications for a new settlement is the unmet needs of Wycombe, Chiltern and South Bucks. The proximity of any new settlement to these areas should therefore be afforded significant weight when considering the potential options, as the closer the new settlement is, the shorter and more sustainable travel flows to maintain social connections and access existing employment will be.

4.17 Bullets (c) and (d) of Policy S2 identify that Haddenham and Winslow will accommodate growth of 50%. However, these villages represent the options for a new settlement and so it is unclear how these two proposals inter-connect. The policy wording should be refined to indicate that this 50% growth is additional to any new settlement that may be delivered in close proximity to either of these villages. Furthermore, it may be that there is no need for the village to accommodate 50% growth if a new settlement in close proximity could accommodate some of this need more sustainably. Policy S2 should provide flexibility to enable this to take place.

4.18 Indeed, a comprehensively planned, sustainable New Garden Village also provides the opportunity to meet some of the shortfall in the villages thereby reducing the need for other sites.

4.19 All of the indicative percentage growth figures within Policy S2 are presented as absolute figures without any flexibility. The policy wording should be revised to allow for development broadly in accordance with the identified levels of growth, such that a few percentage points in excess of the identified percentage will be acceptable in principle.

4.20 There is also a lack of clarity about the contingency for development if one of the settlements is unable to deliver the identified percentage growth. For example, if

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Wendover was unable to deliver 25% growth, there is no mechanism for the resulting shortfall to be addressed.

4.21 Table 1 presents the distribution of the housing requirement between the settlements. However, this produces a housing requirement of 34,910 homes in contrast to the 33,300 identified in Policy S2. The housing requirement, its distribution and the way it is calculated will need further revision and clarification in order to provide a consistent and justified policy.

4.22 Paragraph 3.17 identifies that as a result of the housing requirement which provides for a boost to housing supply (as required by paragraph 47 of the NPPF) but does not meet the full objectively assessed needs, the Council are unable to demonstrate a five-year land supply. In order to address this situation, it is essential that sites which offer choice and competition to the market (as required by paragraph 47 of the NPPF) are supported including a new settlement which will provide for a different market to the urban extensions promoted at other settlements. Such opportunities are afforded by development at Waldridge Garden Village as it will provide new exemplary facilities designed to accord with the principles of garden villages.

4.23 Paragraph 3.18 proposes a phased housing requirement in order to ensure that a five-year land supply is able to be demonstrated in the short-term. This phasing is not supported by any evidence (such as housing needs being lower in the short-term), but is instead a policy-decision in order to mitigate the projected shortfall in housing development. The robustness of such a policy is questionable as it is not supported by evidence. The correct approach to dealing with deficiencies in housing land supply where these arise from the unmet needs of neighbouring authorities (besides taking a more positive approach to development) is to compartmentalise the respective housing requirements and the supply, such that the housing requirement for Aylesbury Vale of 21,300 homes (subject to the previous objections) will be served by the majority of sites across the district; the unmet housing requirement for Wycombe of circa 5,000 homes will be met at a new settlement at Haddenham; and the unmet needs of Chiltern and South Bucks of circa 7,500 homes will be met at a specific number of allocations (including Wendover) to be identified.

4.24 This mechanism is likely to allow a five-year land supply to be demonstrated for Aylesbury Vale (excluding the Wycombe and Chiltern/South Bucks development

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areas) using the Sedgefield approach as supported by the NPPG (3-035) without an unjustified phasing approach.

4.25 The five-year land supply position for the Wycombe and Chiltern/South Bucks development areas should be considered in isolation from the remainder of Aylesbury Vale, and preferably jointly with the areas to whose needs they are responding; so there would be a Wycombe District and Haddenham new settlement five-year land supply calculation and a Chiltern, South Bucks and development area within Aylesbury Vale five-year land supply calculation. Not only is this approach justified taking account of the available evidence, it has also been supported by many Inspector’s nationally including in the Gloucester, Cheltenham and Tewksbury Joint Core Strategy, the South Worcestershire Development Plan and the West Northamptonshire Joint Core Strategy. It also ensures that development responds to the location in which the needs arise, and prevents any additional unmet needs of neighbouring authorities being placed upon Aylesbury Vale without the capacity of those authorities firstly being re- examined.

4.26 Any approach to the five-year land supply will need to be complemented by a positive approach to plan-making and to decision-taking, such that a suitable choice of allocations is identified (including the new settlement) within the Local Plan and all applications for sustainable development are considered favourably. This will ensure that the undersupply of housing is addressed as quickly as possible.

4.27 Paragraph 3.22 comments on the windfall allowance of the Council. It identifies that as smaller villages will not have allocations, there will be no windfall development in this tier of the settlement hierarchy. This infers that windfall development will arise through allocations in the other tiers. However, the NPPF defines windfall development as “sites which have not been specifically identified as available in the Local Plan process”, which means that allocations cannot contribute to a windfall allowance. There appears to be some confusion over the definition of a windfall allowance and this will need to be revised to accord with the NPPF.

Policy S3 Settlement Hierarchy and cohesive development

4.28 Table 3 identifies the housing requirement for each settlement based on the proposals of Policy S2. The distributed housing requirements in terms of the

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percentage increase for the settlements appear to be based on the existing level of housing stock rather than on the evidence base which has assessed housing needs, the sustainability of settlements and the capacity of sites. It is acknowledged that the Council have undertaken a Settlement Hierarchy Assessment of the Vale both in 2015 and 2016 which examines the settlements in terms of their sustainability credentials and the HELAA which reviews the sites submitted to the Council in response to the “Call for Sites”; and the assessment of housing need, but this evidence does not appear to have been used to provide the justification for the distribution.

4.29 Table 3 identifies such a requirement for 1,043 homes at Haddenham and 834 at Winslow. Given the identified opportunities for a new settlement it is clear that these needs can be accommodated in close proximity to these settlements. With the development of a new settlement, it may be some (or all) of these housing requirements could be delivered at a sustainable location without the same need for development adjacent to the existing settlement. Indeed, such a new settlement provides the opportunity to meet the housing requirements of a number of less sustainable villages in a more sustainable location which will provide the opportunity for a comprehensively planned development. Therefore, the opportunities provided by a new settlement and their implications on housing requirements across the Vale should be considered.

4.30 Paragraph 3.27 identifies that the Council will resist development which compromises the open character of the countryside between settlements. However, many of the potential allocations (identified in the Policy Maps) will do just this and so there appears to be a disconnect between the supporting text and the proposals. This supporting text should be reworded to reflect the sustainable opportunities for development which may lie between settlements providing that this does not result in coalescence. The same may apply to paragraph 3.28.

4.31 Paragraph 3.29 suggests that there is a need for specific protection of locations that experience the strongest pressure for development. This is not justified as some areas with development pressures may be the most sustainable and the fact that they have development pressures should not automatically trigger a policy response of protection.

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Jeremy Elgin Response to the Draft Vale of Aylesbury Local Plan consultation

Policy S4 Green Belt

4.32 Paragraph 3.33 recognises the benefits of meeting housing needs close to where this arises, including the unmet needs of Chiltern, South Bucks and Wycombe being met close to the border. This is to be supported as it will ensure that households are accommodated as close as possible to their social and economic connections. Indeed, paragraph 3.39 identifies that this benefit may be so significant that it meets the exceptional circumstances to release land from the Green Belt. Based upon these findings it is clear that the opportunities for a new settlement in a sustainable location close to the border should be supported, and indeed, that this is preferable to Green Belt releases. This clearly supports the location of a new settlement at Haddenham.

Policy S5 Infrastructure

4.33 Paragraph 3.48 identifies that infrastructure should be delivered on-site wherever possible which is to be supported. This opportunity is afforded by a new settlement, which will deliver a range of land-uses including (but not limited to) local centres, schools, employment land and green infrastructure to serve the needs of residents as well as off-site infrastructure improvements including to public transport provision.

4.34 Policy S5 requires that new development should have appropriate regard to and take into account existing infrastructure deficiencies. This could be taken as a requirement that new development would be required to address existing infrastructure deficiencies which would be contrary to the CIL tests. The Policy will need clarification to ensure that this is applied in a way which meets these tests.

4.35 The final paragraph of Policy S5 proposes that the viability of proposals will be considered using an open book assessment. It appears to require that each and every development proposal would be expected to undergo a detailed viability assessment which is independently validated, regardless of what was being proposed. This onerous requirement will introduce significant delays to the determination period even where a proposal is policy-compliant. This is contrary to paragraph 173 of the NPPF and will be especially counter-productive where the five-year land supply position is marginal at best as it will delay development decisions.

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Policy S6 Protect transport schemes

4.36 The wording of Policy S6 needs refining. The second sub-bullet of bullet point (a) identifies that new development will be required to provide financial contributions (and/or provision) unless CIL is required and in this case it will only be the CIL contribution. Whilst the CIL Charging Schedule has not been adopted (or drafted) in Aylesbury Vale, Policy S6 will need to be sufficiently flexible to accommodate CIL once adopted. The current wording however, prevents a combination of financial contributions to address site specific issues alongside a CIL contribution to address more strategic issues.

4.37 Policy S6 also suggests that there will be a differentiation in the application of CIL to some proposals, and yet the CIL approach is unknown at present. It would be beneficial if this was explained in the supporting text.

4.38 The third sub-bullet of bullet point (a) requires that development which is not suitable for the roads will not be supported. The word ‘suitable’ needs clarification as this is a subjective term.

Policy S7 Gypsy, Traveller and travelling showpeople

4.39 Paragraph 3.70 recognises the amendment to definition of Gypsies and Travellers and identifies that work will be undertaken to update the Gypsy and Traveller and Travelling Showpeople Accommodation Needs Assessment to reflect this change. This is likely to reduce the number of pitches and plots required, and so working to the existing number is a pragmatic way forward to identify sufficient opportunities which can then be filtered down to provide for the actual need once this is known.

4.40 Paragraph 3.75 identifies the potential sources of supply for Gypsy and Traveller provision. The use of sites with temporary permission, existing sites, expansion of existing sites and the use of brownfield or derelict land is supported in the first instance as these reflect the location of the needs of Gypsy and Traveller communities. However, the paragraph suggests that there is insufficient capacity on such sites (based against the current assessment of need which does not use the Government’s definition) and Table 6 identifies a supply of 55 pitches against the currently identified need for 57. It is more than likely that following an updated assessment which reflects the change in definition that the requirement for pitches will reduce as the definition of Gypsies and Travellers has tightened. Therefore, the identified supply is likely to be sufficient to meet the needs without

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any specific allocations. However, if this is not the case and some additional provision is required, the Council should then have looked at sites which have been promoted for plots and/or pitches exclusively. These provide for available and achievable sites in terms of the NPPF which can readily meet the needs of Gypsies and Travellers in locations which accord with the second bullet point of paragraph 3.73 of the Draft Local Plan which identifies that provision should be made where the need arises. However, the Council has instead sought to secure pitches alongside traditional housing provision on strategic sites.

4.41 The delivery of pitches alongside residential development will impact negatively upon the viability of the strategic sites; it will require significant areas of land (to provide the necessary facilities and open space for Gypsy and Traveller communities) which will reduce the developable capacity of the strategic sites; it does not align with the locations where the need for pitch provision arises (as required by the second bullet of paragraph 3.3); and it may not be consistent with what is being proposed by the landowner which could render the site unavailable and unachievable (for housing and pitch provision).

4.42 The need for pitches and the deliverability of the current proposals will need to be considered to ensure that these needs can be delivered in appropriate locations and close to where the need arises rather than deferring to strategic sites.

Policy S9 Securing Development through neighbourhood plans

4.43 Paragraph 3.87 describes the policy position where a Neighbourhood Plan has been “made” in advance of the Local Plan. It identifies that the Draft Local Plan could now require a greater level of housing provision than was identified in the Neighbourhood Plan and that either the Neighbourhood Plan would need to be reviewed or allocations identified in the Local Plan. However, there are alternative mechanisms for delivering local needs in appropriate locations, including the delivery of a new settlement which provides the opportunity for increased levels of delivery whilst respecting the adopted Neighbourhood Plan. Such proposals should also be considered.

4.44 Policy S9 proposes that Neighbourhood Plans will have a year to progress to submission before reserve sites will be implemented. This could cause an additional year’s delay to the delivery of housing where no Neighbourhood Plan is brought forward which is particularly concerning where the Council identify that they are already struggling to identify a five-year land supply. Everything should

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be done within the Local Plan to bring forward sites as quickly as possible and address the housing shortfall.

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Jeremy Elgin Response to the Draft Vale of Aylesbury Local Plan consultation

5. STRATEGIC DELIVERY

Policy D1 Delivering Aylesbury Garden Town

5.2 Paragraph 4.5 identifies that the principles of development can be split into four categories, namely sustainable development, movement, community and green infrastructure. This appears to suggest that sustainable development is isolated from the other three, which is not in accordance with paragraphs 7 and 8 of the NPPF. It is suggested that the wording should be amended to reflect the NPPF such that sustainable development includes by definition consideration of movement, community and green infrastructure amongst a range of other social, economic and environmental considerations.

Policy D2 Delivering a new settlement

5.3 Paragraph 4.27 identifies that the delivery of a new settlement needs to be considered in order to meet the housing requirement. Against the housing requirement of 33,300 (which is likely to underestimate the full objectively assessed need) it can be calculated from Table 1 that existing commitments and completions provide for only 12,759 homes. There is also a potential supply of 16,225 from sites identified in the HELAA and an allowance for 714 homes from windfall sites. Therefore, even if every committed site was implemented, and every potentially suitable HELAA site was developed there would still only be a maximum capacity of 29,698 homes in Aylesbury Vale leaving a shortfall of 3,602. However, it is inevitable that a proportion of sites will not be developed and the shortfall will therefore be greater than this even if all of the potentially suitable HELAA sites were allocated. It is therefore necessary for a new settlement to be developed in order to address the shortfall. Indeed, Table 1 identifies that a new settlement would be required to deliver 13% of the total housing across the district.

5.4 The Council has correctly undertaken a New Settlement Scoping Study which provides an independent assessment of ‘areas of search’ which are unconstrained and which could deliver a new settlement. The Study identified 2 areas of search for further consideration, namely Haddenham and Winslow. Within each of these areas of search it identified a number of options for the location of the new settlement with the ability to provide a range of different housing numbers. The bullets in paragraph 4.32 however do not reflect this evidence and should be revised to read as “Option 1: at least 6,000 dwellings at Haddenham” and “Option 2: 6,000 dwellings at Winslow”.

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Jeremy Elgin Response to the Draft Vale of Aylesbury Local Plan consultation

5.5 Paragraphs 4.33, 4.34 and 4.35 identify the options for the location of the new settlement within these areas of search. However, it would benefit from further clarification with a preceding sentence which reads “Within these areas of search, 4 potential options have been identified including an extension to Haddenham, and extension to Winslow, a new settlement at Haddenham and a new settlement at Winslow.” Otherwise it is not clear that there 3 paragraphs are describing the options for the location and they can each be read in isolation as preferring every option.

5.6 Paragraph 4.35 expresses a preference for a new settlement at Haddenham. Indeed, it is considered that a new settlement at Haddenham provides the most sustainable location to respond to the unmet needs of Chiltern, South Bucks and particularly Wycombe being in close proximity to these (especially the latter) as compared to Winslow which is distant from all 3 authorities. The effect of delivering the housing needs of these 3 authorities remote from where they arise will inevitably impact on travel flows as households travel to maintain social and economic connections (including their current employment).

5.7 Haddenham also has a higher rate of concealed families and overcrowded households, and a lower rate of vacant dwellings and affordable homes compared to Winslow. All of these market signals indicate that there is a greater pressure on the existing housing stock in Haddenham which can be addressed by the provision of additional housing, including at a new settlement.

5.8 Haddenham also has a much better alignment of jobs and workers indicating that it is a far more sustainable location for growth than Winslow. There is also a higher proportion of residents in Haddenham who either work from home or who use sustainable modes of transport to travel to work. In regards to those who do use the car to travel to work, the residents of Haddenham are far more likely to travel less than 10km than the residents of Winslow.

5.9 Haddenham is also closer to a community hospital (at Thame), and Accident and Emergency Department (at Stoke Mandeville), a Railway Station (at Haddenham), a Leisure Centre (at Thame) and a cinema (at Thame).

5.10 Indeed, Haddenham clearly provides a far more sustainable location for a new settlement in all regards. This is even more pronounced when consideration is given to where the actual housing needs arise. The preference for the new settlement at Haddenham is therefore to be supported.

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Jeremy Elgin Response to the Draft Vale of Aylesbury Local Plan consultation

5.11 Paragraph 4.40 identifies that there is uncertainty with regard to the location of a new settlement and that further work will be required to determine the exact scale and layout of the new settlement through a detailed masterplanning process. This is to be supported and is a pragmatic proposal at this stage in the plan-making process.

5.12 However, from the preceding analysis it is clear that the provision of a new settlement should be directed towards Haddenham. The New Settlement Scoping Study identifies 2 options for such a new settlement, one being an extension to the existing settlement entitled Western Haddenham and one being a new Garden Village to the east of Haddenham (referred to as Waldridge Garden Village in this response).

5.13 DCLG produced a prospectus on Locally-Led Garden Villages, Towns and Cities in March 2016. This prospectus is designed to support the delivery of Garden Villages which are seen by the Government as providing a key part of the offer on housing growth. It identifies that “new garden villages…can be a suitable way of meeting local housing need, rather than building on to existing settlements.”

5.14 The development of new garden villages (as opposed to urban extensions) is also supported by the Taylor report which identifies a number of problems with the delivery of urban extensions including the artificially high land values which minimises the ability to provide infrastructure and community benefit; the long lead-in times and slow build-out rates given the competition and co-ordination of sequential developments; and the lack of co-ordination of infrastructure with delivery. The Waldridge Garden Village provides the opportunity to avoid these issues and to provide for a new garden village rather than an urban extension at the Western Expansion area.

5.15 The Western Expansion Area to Haddenham would be contrary to the “made” Neighbourhood Plan, although recognising that part of this plan has been quashed. The same is not true of Waldridge Garden Village, which will provide for an exemplar garden village supported by Government, whilst meeting the unmet needs of Wycombe (as well as Chiltern and South Bucks) as close to the border with Wycombe as possible. Indeed, the attached Position Statement summarises the progress which has been made to date to respond to the option identified in the Draft Local Plan and to reflect the principles of garden villages, as well as summarising the opportunities for sustainable development at this location.

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Jeremy Elgin Response to the Draft Vale of Aylesbury Local Plan consultation

5.16 The emerging masterplan provides for a mix of residential, employment, educational, community and green spaces including schools, leisure, retail, health and open spaces and the opportunity for a green transport link to Haddenham Village supporting sustainable modes of travel between the new settlement and Haddenham. It locates these uses in such a way as to minimise travel distances and to ensure that they are accessible to all.

5.17 The Waldridge Garden Village also meets the eligibility criteria of the DCLG prospectus by providing for a new discrete settlement which is between 1,500 and 10,000 homes and so clearly accords with the Government’s vision for future housing delivery. The Western Expansion Area would not accord with these criteria.

5.18 Furthermore, as identified in the New Settlement Scoping Study, Waldridge Garden Village is in an unconstrained area. It is lower in agricultural land quality than the Western Haddenham extension and so would accord with paragraph 112 of the NPPF. It also provides the opportunity for greater levels of development to meet housing needs beyond the plan period.

Policy D3 Delivering Sites adjacent to Milton Keynes

5.19 Policy D3 sets out the proposal for some of the housing requirement of Aylesbury Vale to be provided on sites adjacent to Milton Keynes. This will impact upon the infrastructure provision of Milton Keynes, and will have implications for the existing distribution and scale of development within Milton Keynes itself, as well as prejudicing the ability of Milton Keynes Council to meet its objectively assessed needs through sustainable urban extensions in Aylesbury Vale in the future.

5.20 Inspector Ward in his letter of 7th January 2014 identified that there is a “potential need for the growth of the urban area of Milton Keynes into Aylesbury Vale”. Indeed, the Plan:MK Strategic Development Directions Consultation (January 2016) identifies that development within Aylesbury Vale adjacent to Milton Keynes is one of the options to meet the needs of Milton Keynes. The proposal for this to meet the needs of Aylesbury Vale therefore prejudices the assessment of reasonable alternatives to meet the needs of Milton Keynes. Any such proposal would therefore need to be agreed under the duty to cooperate with Milton Keynes Council and will need to be considered in the context of the future development of Milton Keynes.

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Jeremy Elgin Response to the Draft Vale of Aylesbury Local Plan consultation

5.21 Furthermore, the proposal to deliver extensions to Milton Keynes to meet the needs of Aylesbury Vale, Chiltern, South Bucks and Wycombe will displace the supply from where the needs arise and in some cases this displacement will be over very large distances (for example from South Bucks). This can be partially addressed by linking the supply to the needs, such that any delivery at Milton Keynes would not meet the needs of Wycombe, Chiltern and South Bucks, but that these would be addressed at specific allocations (including a new settlement) at locations as close as possible to those authorities within Aylesbury Vale including Haddenham.

Policy D4 Housing development at strategic settlements (excluding Aylesbury)

5.22 Paragraph 4.56 identifies that in some settlements there may not be sufficient capacity to deliver the identified housing requirements. In such circumstances the settlement will be unable to deliver the housing requirement and this will result in a shortfall against the strategic housing requirement. Paragraph 4.56 goes on to identify that no village will be allocated more than their housing requirement. It is therefore implicit within the Local Plan that the shortfall will either not be met, or will be provided at strategic settlements and/or the new settlement. The Local Plan will need to provide clarity as to where this shortfall will be addressed.

5.23 Policy D4 identifies that all suitable sites will be allocated at Haddenham. This presumably does not currently include the suitable sites for a new settlement and the policy wording should be refined to reflect this. Furthermore, allocating these sites ignores the potential opportunity to deliver some of these needs at a new settlement which may be preferable. Further consideration will need to be given to the opportunities for addressing the needs of Haddenham at the new settlement.

5.24 The wording of Policy D4 also needs refinement. It seems to suggest that unallocated development even within the footprint of villages would only be allowed where allocations have not delivered at the anticipated rate. This would prevent any windfall delivery in the short-term and undermines any windfall allowance which is currently relied upon by the Council. It also uses the term villages in bullet point (a) and in the footnote despite the fact that this applies to settlements including Buckingham.

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Jeremy Elgin Response to the Draft Vale of Aylesbury Local Plan consultation

Policy D5 Housing development at larger villages

5.25 See response to Policy D4. Policy D5 seems to suggest that unallocated development even within the footprint of villages would only be allowed where allocations have not delivered at the anticipated rate. This would prevent any windfall delivery in the short-term and undermines any windfall allowance which is currently relied upon by the Council.

5.26 Paragraph 4.73 also identifies that not all of the larger villages will be able to meet their identified housing requirement (see Ivinghoe, Long Crendon, Steeple Craydon, Stone, Waddesdon, Whitchurch, Wing and Wingrave). Therefore, these unmet needs may need to be addressed at other locations and yet the Local Plan does not provide any indication of where this will be provided. It should be noted that depending upon the option chosen there may be capacity for delivery as part of a self-contained new settlement to address some of these unmet needs.

Policy D6 Housing development at medium villages

5.27 See response to Policy D4 and Policy D5. Policy D6 seems to suggest that unallocated development even within the footprint of villages would only be allowed where allocations have not delivered at the anticipated rate. This would prevent any windfall delivery in the short-term and undermines any windfall allowance which is currently relied upon by the Council.

5.28 Paragraph 4.83 also identifies that not all of the medium villages will be able to meet their identified housing requirement (see Brill, Cuddington, Gawcott, Grendon Underwood, Ickford, Maids Moreton, Marsh Gibbon, Newton Longville, North Marston, Padbury, Quainton and Stewkley). Therefore, these unmet needs may need to be addressed at other locations and yet the Local Plan does not provide any indication of where this will be provided. It should be noted that depending upon the option chosen there may be capacity for delivery as part of a self-contained new settlement to address some of these unmet needs.

Policy D7 Housing development at smaller villages

5.29 Paragraph 4.90 identifies that not all of the smaller villages will be able to meet their identified housing requirement (see Adstock, Akeley, Aston Abbotts, Bishopstone, Chackmore, Charndon, Dagnall, Dinton, Ford, Halton, Hardwick, Ivinghoe Aston, Ludgershall, Mentmore and Ledburn, Mursley, Thornborough, Turweston, Weedon and Whaddon). Therefore, these unmet needs may need to be addressed at other locations and yet the Local Plan does not provide any

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Jeremy Elgin Response to the Draft Vale of Aylesbury Local Plan consultation

indication of where this will be provided. It should be noted that depending upon the option chosen there may be capacity for delivery as part of a self-contained new settlement to address some of these unmet needs, especially those of smaller villages such as Ford which are close to one of the options for a new settlement at Haddenham.

5.30 Policy D7 allows for windfall development at the smaller villages subject to criteria. However, criteria (g) requires that the housing requirement for a smaller village should not be exceeded. This is not sufficiently flexible and should be revised to allow for development broadly in accordance with the identified housing requirement.

Policy D9 Provision of employment land

5.31 Paragraph 4.95 identifies that Aylesbury Vale has an oversupply of employment land. However, the actual position is that whilst the Council suggests it has an over-supply of employment land (including allocated, but undeveloped sites) it actually has fewer jobs than it does resident workers, with a net outflow of 15,385 workers according to the 2011 Census. Therefore, a net increase in jobs should be supported within the Local Plan to rebalance the jobs and workers, in addition to providing sites which secure existing business and facilitate the growth and/or relocation of existing businesses within Aylesbury Vale.

5.32 In order to achieve this sufficient employment land should be identified within the Local Plan including that proposed as part of mixed use developments which will provide for the most sustainable locations as well as providing for premises which reflect the needs of 21st century businesses. This positive approach is supported by Policy D9 which allows for employment development within allocations to provide for self-contained developments minimising the need to travel. Such an opportunity is provided by a new settlement with employment and housing well connected to one another.

Policy D10 Town, village and local centres to support new and existing communities

5.33 Paragraph 4.107 supports the provision of new local centres within major development centres, and recognises that this is key to provide for sustainable development as well as minimising the need to travel. Such an opportunity is again provided by the development of a new settlement which can support new

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Jeremy Elgin Response to the Draft Vale of Aylesbury Local Plan consultation

cultural, leisure, retail and community facilities to provide for the community and which will not compete with existing facilities at nearby settlements.

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Jeremy Elgin Response to the Draft Vale of Aylesbury Local Plan consultation

6. HOUSING

Policy H1 Affordable housing

6.2 Paragraph 5.3 identifies that according to the HEDNA there is a need for 6,580 affordable homes from 2013 to 2033. The Local Plan identifies a housing requirement for 33,300 homes in total and so it can be calculated that 19.8% of housing should be provided as affordable units according to the evidence of the Council. However, Policy H1 requires that a minimum of 31% of homes are affordable. This Policy therefore places an onerous obligation on residential developments which is not fairly or reasonably related in kind or scale and which is therefore contrary to both paragraph 173 of the NPPF and to the CIL tests.

6.3 The total affordable need would have to be far greater in order to justify this Policy, which in itself would justify an uplift to the housing requirement (and thereby reduce the percentage of affordable housing sought on each site); or the percentage requirement must be 19.8%.

Policy H5 Self/custom build housing

6.4 Policy H5 requires that all larger developments will provide a percentage of serviced dwelling plots for sale for self/custom build. This Policy is intended to be detailed within a SPD, but the details of this SPD will be critical to the soundness of the Policy and so this information should be provided within the Local Plan. Furthermore, awaiting the production of a SPD will only serve to delay the delivery of larger developments which will further undermine the already precarious five-year land supply position.

6.5 The requirement for self-build plots would need to be justified by a demand for such provision. However, the HEDNA identifies that “…this represents only a very limited number of people and an exceptionally small proportion of the overall housing need identified each year.” Based on the available evidence of demand, there is no justification for requiring provision on larger developments.

6.6 The provision of self-build plots within larger developments may adversely affect deliverability, as there is no certainty of the timescales and demand for such sites. Indeed, each plot would normally be sold individually and so a number of different purchasers would be required which may take time, then each would develop to their own timescales. Furthermore, self-builders tend to prefer smaller sites rather than components of large development sites and so on-site provision is unlikely to respond to the demand.

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Jeremy Elgin Response to the Draft Vale of Aylesbury Local Plan consultation

Policy H6 Housing mix

6.7 Policy H6 seeks to provide for a mix of housing as identified in the HEDNA or more recent evidence. However, this will not be applicable to all sites (such as the redevelopment of a building to flats) and so there needs to be sufficient flexibility within the policy wording to allow for alternative mixes.

6.8 Policy H6 also requires that larger development schemes provide for self- contained extra-care accommodation. This Policy will need to be demonstrated to be viable and that it responds to an identified need.

6.9 Finally, Policy H6 also seeks to apply the optional accessibility standards. This can only be applied where this is justified by an evidenced local need and where it would not compromise the viability of development. The justification within the HEDNA is not locally specific, but reflects the national rate of wheelchair use. The current justification is therefore insufficient to meet the requirements. Furthermore, no viability assessment has been undertaken and so the effects on viability are entirely unknown. Until and unless these pieces of work are undertaken the optional standards cannot be applied in Aylesbury Vale.

Policy H7 Dwelling sizes

6.10 See response to Policy H6. Policy H7 seeks to apply the optional space standards which would need to be justified by evidenced local need and where it would not compromise the viability of development. Neither of these have been demonstrated and so these optional standards cannot be required at present.

6.11 The optional space standards require larger homes, which will reduce the density of developments and thereby will generate a need for additional areas of land to be allocated for development to achieve the housing requirement. It is also likely to increase the cost of housing which will be counter-productive given the affordability issues which already exist in Aylesbury Vale, and will present further barriers to the accessibility of housing.

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Jeremy Elgin Response to the Draft Vale of Aylesbury Local Plan consultation

7. ECONOMY

Policy E5 Development outside town centres

7.2 Policy E5 sets the requirement for a sequential test for town centre uses outside of an existing centre. It then identifies the criteria against which retail proposals outside of these existing centres will be assessed. However, this does not make provision for any town centre uses or retail floorspace which may be required as part of a new settlement. The application of a sequential test to such proposals would be overly onerous and would be contrary to paragraph 26 of the NPPF which allows for town centre uses in locations which are in accordance with the Local Plan. The policy wording should be adjusted to accommodate town centre uses of an appropriate scale within the new settlement.

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Jeremy Elgin Response to the Draft Vale of Aylesbury Local Plan consultation

8. TRANSPORT

Policy T1 Vehicle parking

8.2 Policy T1 seeks to encourage sustainable transport modes. It also requires that infrastructure for electric vehicles should be provided in major development schemes. Whilst this is to be welcomed, further clarity on what is being sought is required and the viability of such provision will need to be tested.

8.3 Policy T1 also sets out the optimum parking standards. Paragraph 7.4 identifies that garages will not count towards these parking standards as they tend to be used for storage rather than parking. This may have implications for the density and viability of development and this will need to be tested.

Policy T2 Footpaths and cycle routes

8.4 Policy T2 seeks to safeguard and improve footpaths and this opportunity is provided by the Waldridge Garden Village.

Policy T3 Electric Vehicle infrastructure

8.5 Policy T3 requires that developments provide 1 electric vehicle charging point for every 10 dwellings, that trickle charge points are provided at employment sites, and that rapid charge points are provided at retail and leisure facilities. This again is to be welcomed although the viability of such provision will need to be tested alongside the other proposed policy requirements in order to demonstrate that the cumulative viability effects are consistent with paragraph 173 of the NPPF.

8.6 Furthermore, the capacity of the current electrical sub-stations will need to be demonstrated to be able to accommodate this Policy requirement.

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Jeremy Elgin Response to the Draft Vale of Aylesbury Local Plan consultation

9. BUILT ENVIRONMENT

Policy BE1 Heritage Assets

9.2 Policy BE1 proposes that development will not be permitted if it results in harm to conservation areas. However, this is contrary to paragraph 133 of the NPPF which identifies that applications should only be refused where the harm to designated assets is substantial and only where this harm is not outweighed by substantial public benefits.

9.3 The Policy also recognises that harm can be associated with the settings of conservation areas. The Western Expansion to Haddenham option for a new settlement lies immediately adjacent to and within the setting of the Haddenham Conservation Area and so will inevitably cause harm. However, the Waldridge Garden Village is large enough to provide the flexibility to avoid and/or minimise any harm to the setting of conservation areas and so should be preferred.

Policy BE2 Design of new development

9.4 Policy BE2 is followed by a section on the space between dwellings. It is not clear whether this is intended to be applied as policy or as guidance. There is also no supporting evidence for this section.

9.5 The effects of this section on the capacity of allocations has also not been considered, and so it is possible that this would significantly reduce the developable supply in which case additional allocations would be required. It may also affect the viability of schemes which will need to be tested.

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Jeremy Elgin Response to the Draft Vale of Aylesbury Local Plan consultation

10. NATURAL ENVIRONMENT

Policy NE1 Protected Sites

10.2 Policy NE1 bullet point (b) applies a sequential test to development that affects a SSSI or an ancient woodland. This is contrary to the second bullet of paragraph 118 of the NPPF. Each planning application needs to be determined on its own merits rather than being required to demonstrate that there are no preferable sites in terms of these impacts.

Policy NE3 Landscape character and locally important landscape

10.3 Policy NE3 relates to landscape. It sets a series of criteria that should be respected by developments. However, some of these criteria are less applicable to a new settlement as such a development will necessarily be more remote. The policy will need to be refined to recognise that an alternative set of criteria may be more appropriate for specific developments, including the new settlement.

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Jeremy Elgin Response to the Draft Vale of Aylesbury Local Plan consultation

11. SUSTAINABILITY APPRAISAL

11.1 A Sustainability Appraisal has been prepared in support of the draft Local Plan. This has assessed the existing baseline conditions for all potential allocations (including the new settlement) and considered the effect of residential development on these conditions. However, it does not assess the opportunities provided by the options including the improvement of services and/or masterplanning to minimise any harm or provide for enhancements. The Sustainability Appraisal does not therefore accord with the NPPG (11-013) which identifies that the mitigation of adverse effects and the maximisation of beneficial effects needs to be considered. Furthermore, the Sustainability Appraisal contains a number of mistakes which need to be corrected.

11.2 The Sustainability Appraisal as it relates to the options for a new settlement at Haddenham are considered in the following paragraphs, by way of example.

11.3 Paragraphs 4.2.2 to 4.2.5 identify the heritage assets which relate to each of the options. It identifies that the Grade II* Listed Building of Waldridge Manor and the Grade II Listed Buildings of Pasture Farm and Barn are within the indicative area of Option 2 (Waldridge Garden Village). It also identifies that the scheduled monument of a Nucleated Medieval Settlement lies within this option and that the development of this option would be within the Aston Sandford Conservation Area. However, all of these actually lie outside of the circular area defined on the options map. Whilst this circular area is indicative only, the landholdings are sufficiently large and unconstrained that the built form of the new settlement will be designed to minimise and where possible avoid these heritage assets and their settings. Indeed, the conceptual masterplan included in the attached Position Statement indicates a built form which would entirely avoid the settings of Waldridge Manor, the scheduled monument, and the conservation area. Therefore, the assessment of the impacts on heritage impacts is both misinformed and does not take account of the ability of Option 2 to avoid or minimise adverse impacts. Indeed, Option 2 should score more favourably than Option 3 which will necessarily impact on the setting of the Haddenham Conservation Area given the fact that the potential development area is limited by Flood Risk Areas and there is no flexibility to design around constraints.

11.4 Paragraphs 4.2.6 to 4.2.10 consider the baseline landscape for the options. It is identified that Option 3 is likely to have the highest visual impact from the existing settlement and that it also sets a precedent for growth towards Thame.

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In relation to Option 2 the Sustainability Appraisal identifies that this is disconnected from the settlement and so the impact would be greater, but also identifies that the impact on the setting of settlements is likely to be greater. These would appear to be at odds. In any case, the development of a new settlement at this location would be designed to incorporate buffers to the surrounding villages in order to avoid or minimise any impacts on their setting, as demonstrated through the conceptual masterplan.

11.5 Paragraphs 4.2.11 to 4.2.13 consider the biodiversity value of the options. A small woodland area is on the border of the Option 2 site as identified in paragraph 4.2.11. However, as set out previously, it is likely that any disruption to the biodiversity value of this area could be minimised through appropriate masterplanning of the new settlement. Otherwise, it is recognised that Option 2 is not considered to have high biodiversity value. Paragraph 4.2.13 identifies that in Option 3 there is a potentially biodiverse patch of woodland which would appear to be broadly consistent with the biodiversity receptors in Option 2, and yet for some reason Option 3 is scored more favourably in terms of biodiversity. This is especially surprising when this option does not provide the same flexibility in terms of land area which may provide additional opportunities for biodiversity enhancement. A fair assessment should consider Option 2 to score at least as well as Option 3.

11.6 Paragraph 4.2.14 considers flood risk and identifies that all options lie in Flood Zone 1 (low risk of flooding). However, it goes on to identify that Option 3 borders areas of Flood Zone 2 and 3 and that Option 2 has an area at medium/high risk of surface water flooding. Development in either location may therefore have adverse effects on flooding, but for some reason Option 2 is scored as providing a neutral or negligible effect without justification. Furthermore, any development of this scale would incorporate SuDS and there may be opportunities to mitigate and potentially improve flood risk.

11.7 Paragraph 4.2.15 identifies that all of the options consist of Grade 3a and 2 best and most versatile agricultural land. However, this is incorrect as the new settlement within Option 2 is actually Grade 4 and therefore not the best and most versatile agricultural land. This option should therefore score much more favourably than Option 3 which does consist of the best and most versatile land. However, for some unjustified reason both options score the same.

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Jeremy Elgin Response to the Draft Vale of Aylesbury Local Plan consultation

11.8 Paragraphs 4.2.16 to 4.2.17 discusses the existing sustainable transport connections to the options. Whilst it is true that Option 3 is closer to Haddenham and Thame Parkway train station and that it is better served by bus services, this negates any consideration of the potential for improvements to sustainable transport provided by the options. Option 2 would incorporate a Green Transport Link facilitating sustainable travel between the site and Haddenham, with connections to the existing transport infrastructure. It could also provide improvements to the existing bus services through financial contributions which would not be provided by Option 2.

11.9 Paragraphs 4.2.18 and 4.2.19 identify the health related facilities that currently exist. The only differentiation between the options is that Haddenham Medical Centre is not as close to Option 2. However, once more this entirely negates any consideration of any healthcare facilities that would be expected to be provided as part of a new settlement. Indeed, the provision of additional healthcare facilities to complement existing provision within a new settlement would be a significant benefit and would ensure that healthcare was accessible to all new residents. Furthermore, the higher order healthcare facilities of Thame Community Hospital and Stoke Mandeville Hospital are both quicker to access from Option 2 than from Option 3 using either public transport or the private car. Therefore, Option 2 should score at least as favourably as Option 3 in regards to health, if not more so.

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Jeremy Elgin Response to the Draft Vale of Aylesbury Local Plan consultation

12. NEW SETTLEMENT SCOPING STUDY

12.1 The New Settlement Scoping Study correctly identifies the Government’s support for new garden villages as part of the solution to boost housing supply. It draws attention to the paper on Garden Villages by Lord Taylor which identified that the current model of delivery which relied upon development adjacent to existing communities was ‘politically toxic’; that the sustainable opportunities for such development have been largely exhausted; and that the land values associated with such development have increased exponentially such that the delivery of infrastructure was undermined. Lord Taylor concluded that new villages and towns provided a solution to better meet housing need. In so doing Lord Taylor explicitly discredited development adjacent to settlements, such as that proposed in all but one of the identified options for a new settlement and supported the delivery of a freestanding new settlement such as that at Waldridge Garden Village.

12.2 The New Settlement Scoping Study also notes that the recent Government Prospectus for garden villages defined to apply only to new freestanding settlements. Nevertheless, the Study does go on to consider alternatives including extensions to existing settlements which will be subject to the issues identified by Lord Taylor and should therefore not be preferred.

12.3 The Study identifies the potential benefits of extensions and new settlements in paragraph 2.31. Extensions can link to existing infrastructure networks and can be perceived as having fewer environmental impacts. However, new settlements provide for truly sustainable development by delivering a holistic package of land- uses and supporting infrastructure. Indeed, a new settlement can deliver the infrastructure in a more sustainable and accessible form than would be provided in an existing village, and would not burden the existing infrastructure. Similarly, in terms of environmental impact a new settlement can provide scope for environmental improvements which are unlikely to be available to extensions. In all regards, freestanding new settlements have the potential to provide for more sustainable growth.

12.4 The Study also identifies that the scale of a new settlement and its relation with existing facilities (in the case of an urban extension) affect the ability to provide infrastructure. The Waldridge Garden Village has the capacity for a greater number of homes and has the potential to provide for nursery and primary schools, middle schools, a secondary school, a health centre, pharmacies, local

September 2016 | NT | P16-0236 Page | 32

Jeremy Elgin Response to the Draft Vale of Aylesbury Local Plan consultation

shops, pubs, post offices, community centres and local centres based on the thresholds in Table 2.

12.5 The Study identifies in the second bullet of paragraph 2.49 that urban extensions closer to existing settlements could result in competition which may compromise delivery rates. It also proposed that new settlements have a greater potential to achieve self-containment in paragraph 2.53.

12.6 Based on the methodology identified the Study identifies Haddenham and Winslow as representing strong candidates for major growth. It identifies a number of options at each of these settlements for further consideration including Waldridge Garden Village. This option (Option 2 at Haddenham) is the only one which accords with the Taylor Report and the Government’s Prospectus on Garden Villages.

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POSITION STATEMENT SEPTEMBER 2016 P16-0236 Pegasus Group Pegasus House Querns Business Centre Whitworth Road Cirencester GL7 1RT www.pegasuspg.co.uk I T 01285 641717 I F 01285 642348

Prepared by Pegasus Group

September 2016 Project code P16-0236

PLANNING DESIGN ENVIRONMENT ECONOMICS

COPYRIGHT The contents of this document must not be copied or reproduced in whole or in part without the written consent of Pegasus Planning Group Ltd. Crown copyright. All rights reserved, Licence number 100042093. CONTENTS

01 THE VISION 01 02 INTRODUCTION 03 03 A NEW SETTLEMENT 04 04 SITE CONTEXT 10 05 ENVIRONMENTAL CONTEXT 14 06 HERITAGE 32 07 ECOLOGY 34 08 TRANSPORT 40 09 GARDEN VILLAGE GUIDANCE 47 10 DESIGN PRINCIPLES 50 11 CONCEPT MASTERPLAN 52 12 GREEN INFRASTRUCTURE 57 13 DELIVERABILITY 67 14 SUMMARY 69 Waldridge Garden Village will challenge existing ways of working and thinking to push the boundaries of residential led design quality to create a highly desirable new settlement. The aim is to achieve a high quality development with strong identity, activity and ‘sense of place’. Waldridge Garden Village will become a place people will want to live and a destination worth visiting.

iviv WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 01 THE VISION

1.1 Walridge garden village will be designed to be inclusive of all users and encourage environmental sustainable travel choice and a transportation modal shift. Waldridge Garden Village will be more than just a housing development, it will be underpinned by the core values of Garden City principles but utilise the best and latest design guidance and be driven by sustainability. The key objectives are to: • Create an exemplary new settlement , including complementary facilities to serve the new and existing communities, eg. schools, sports and recreation facilities; • Minimise the need to travel; • Ensure the development relates with the surrounding neighbourhoods of Haddenham, Ford, Longwick and smaller villages; • Deliver a range of high-quality, well designed homes to meet the needs of local people; • Provide an appropriate amount of affordable housing; • Provide improved sustainable transport links between ‘Waldridge Garden Village’ and Haddenham, Thame and Princes Risborough; • Promote sustainable modes of transport; • Establish a network of green routes and create new parks and recreation spaces; and • Employment opportunities.

WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 1 2 WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 02 INTRODUCTION

2.1 Aylesbury Vale District Council are consulting on the Draft 2.3 There are a number of landowners including the majority Vale of Aylesbury Local Plan. This identifies a requirement landowner who are committed to exploring the opportunities for a new settlement to respond to the identified housing presented by the development of a new settlement and are requirement. A New Settlement Scoping Study (GL Hearn, prepared to engage and work with the Council with this July 2016) has been prepared to explore the options for the objective in mind. The majority landowner is therefore liaising location of such a new settlement. This identifies that one of with other local landowners in the identified area to explore the options under consideration is a new garden village at their interest and support for such a scheme. The Council Haddenham, known as Waldridge Garden Village. will appreciate that any such decision by landowners will 2.2 Following the publication of the New Settlement Scoping have significant and life-changing consequences. At present Study, the opportunities for the development of a new the implications for the landowners are unclear but work is garden village at Haddenham have been explored. A range of ongoing. It is known that a number of landowners are also specialist consultants have been commissioned to consider supportive of this proposed development and as such they are specific factors and the resulting work is summarised within likely to provide separate representations to the Local Plan. this Position Statement. 2.4 The identified option area is large enough that it can flex to take account of the landholdings of the interested parties whilst still providing for the critical mass to deliver a new settlement. Waldridge Garden Village can therefore be demonstrated to be available in accordance with the PPG (3- 020). 2.5 This Position Statement will be supplemented over time to provide a more comprehensive assessment as further work is undertaken.

WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 3 The Government’s approach to new settlements 3.1 The National Planning Policy Framework (NPPF) identifies that the supply of new homes can sometimes best be achieved through planning for larger scale development, such as new settlements. This is supported by the Planning Practice Guidance (PPG) which identifies that local authorities need to assess the opportunities provided by new settlements (Ref Para. 026 ID03-026 2140306). 3.2 The Taylor report on Garden Villages in 2015 identified the benefits of delivering new garden villages in order to boost housing supply and respond to the housing shortfall nationally. In particular, the report noted the problems associated with development adjacent to an existing settlement in terms of political support, delivery rates and infrastructure provision and recommended the delivery of new garden villages as an alternative. 3.3 In 2016, the Government responded and proposed to strengthen national planning policy to provide a more supportive approach for new settlements within the proposed changes to the NPPF. 3.4 The Government are supportive of such proposals as these provide another mechanism to address the housing shortfall nationally, as well as providing for self-contained communities in comprehensively designed and landscaped villages with the services provided within walking distance of all properties.

4 WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 03 A NEW SETTLEMENT

Why deliver a new settlement in Aylesbury Vale? 3.5 The Draft Vale of Aylesbury Local Plan identifies a housing requirement of 33,300 homes from 2013 to 2033 which responds to the identified objectively assessed needs of Aylesbury Vale as well as the unmet needs of the districts of Chiltern, Wycombe and South Bucks. 3.6 On the basis of the Council’s evidence, there are currently 12,759 homes which have either been constructed from 2013 or which are subject to commitments. This leaves a further 20,541 homes to be identified even if each and every one of these commitments is developed. The Council have identified that there is a capacity for 16,225 homes on sites which are potentially suitable. Even if all of these were to be demonstrated to be suitable and were delivered this would still leave a shortfall of 4,316 homes. Therefore, additional sources of housing supply will need to be supported within Aylesbury Vale to meet the identified housing requirement. In accordance with Government policy and given the lack of any alternative, this would necessitate the delivery of a new settlement. 3.7 The delivery of a new settlement provides the opportunity to meet the needs of rural settlements in a sustainable location without placing a burden on the existing infrastructure of these settlements.

WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 5 Where should the new settlement be located? 3.8 The New Settlement Scoping Study commissioned by will minimise the impact of flows as households travel to the Council undertakes a comprehensive and consistent maintain social and economic connections. assessment of the potential for a new settlement across 3.10 Haddenham has a higher rate of concealed families and Aylesbury Vale. The Study considers the environmental and overcrowded households, and a lower rate of vacant policy constraints and the landscape sensitivity of the entirety dwellings and affordable homes compared to Winslow. All of of Aylesbury Vale and identifies 11 potential areas of search. these market signals indicate that there is a greater pressure It then considers the suitability of these areas of search for on the existing housing stock in Haddenham which can be major growth and shortlists 2 options, namely Haddenham addressed by the provision of additional housing, including at and Winslow. a new settlement. 3.9 As there is sufficient capacity to meet the objectively assessed needs of Aylesbury Vale, the delivery of a new settlement can be seen to be responding to the unmet needs of Chiltern, South Bucks and Wycombe totalling 12,000 homes. The Draft Local Plan correctly identifies that these unmet needs should be met as GARDEN close as possible to where VILLAGE they originate, including at Haddenham which is close to the border with Wycombe District where an unmet need of 5,000 homes originates. This WIDER CONTEXT PLAN

6 WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 03 A NEW SETTLEMENT

3.11 The new Settlement Scoping Study identifies two options for the delivery of a new settlement near Haddenham. Option 2 is set out below along with the supporting text.

• Includes limited expansion of Haddenham based on existing permissions and preferred sites identified through HELAA. Land to the east of Haddenham (6) could deliver over 7,000 homes. • This could be sufficient to allow a secondary school as well as two primary schools, a small village centre, and employment area. • Consideration would need to be given to transport links to the existing settlement, including access to the rail station.

DISTRICT COUNCIL OPTIONS

WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 7 3.12 The Haddenham area also has a much better alignment of jobs and workers indicating that it is a far more sustainable location for growth than Winslow area. There is also a higher proportion of residents in Haddenham who either work from home or who use sustainable modes of transport to travel to work. For those who do use the car to travel to work, the residents of the Haddenham area are also far more likely to travel less than 10km than the residents of Winslow. 3.13 The Haddenham area is also closer to a community hospital (at Thame), an Accident and Emergency Department (at Stoke Mandeville), a Railway Station (at Haddenham), a Leisure Centre (at Thame) and a cinema (at Thame). Indeed, the Haddenham area clearly provides a far more sustainable location for a new settlement in all regards.

Why a new settlement and not an urban extension for Haddenham? 3.14 In the area of search of Haddenham, the New Settlement Scoping Study identifies 2 options capable of delivering a new settlement, namely either a Western Expansion of the existing settlement or a new settlement at Haddenham (known as Waldridge Garden Village).

8 WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 03 A NEW SETTLEMENT

3.15 The Taylor report has identified the benefits of a new 3.17 The landholdings covering the “Waldridge Garden Village” freestanding garden village as compared to the expansion of also provide sufficient flexibility to deliver a greater number an existing settlement. These include: of homes and a greater mix of land uses as well as providing • the ability of a new garden village to maximise the opportunity to avoid and/or minimise impacts on areas community benefit in the form of infrastructure rather and assets of particular importance. This flexibility is not than the infrastructure being prejudiced by artificially afforded by the Western Expansion area which is limited in high land values; size and by environmental constraints. • the ability of a new garden village to deliver rather than 3.18 In summary, the “Waldridge Garden Village” provides the being subject to competition from sequential sites most sustainable option for a new settlement. This Position especially in the case of Haddenham which is required Statement considers the opportunities provided by this option to deliver an additional 1,043 homes above the new and identifies a Vision and a Conceptual Masterplan which settlement; responds to these aspects. • political resistance to extensions as politicians look to address local opposition; • the slow build-out rates of extensions; • the ability of a new garden village to deliver to a planned schedule, providing services as and when they are required rather than relying on the existing services of a settlement; and • a choice of location for home owners/occupiers 3.16 Furthermore, Haddenham Garden Village is much closer to the border with Wycombe District than the Haddenham Western Expansion area and so ensures that needs are met as close to where they originate as possible.

WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 9 SITE CONTEXT PLAN

10 WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 04 SITE CONTEXT

4.1 The proposed “Waldridge Garden Village” is situated approximately 6.4km to the south west of Aylesbury, 2.2km to the south east of Haddenham, and 4.1km to the north west of Princes Risborough within the Aylesbury Vale District Council (AVDC) administrative area. The A4129 highway between Thame and Princes Risborough is located to the south and would form the primary vehicular access into the new settlement. 4.2 The new settlement is located within open countryside including arable and pastoral farmland between Ford village to the north, Owlswick village to the south east, the A4129 highway to the south, and Aston Sandford village to the west. The new settlement is, however, separated from these established villages.

SITE CONTEXT PLAN

WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 11 ENVIRONMENTAL DESIGNATIONS PLAN

12 WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 04 SITE CONTEXT

4.3 The new settlement encompasses Lower Waldridge Farm to the north east, Pasture Farm to the south, Aston Mullins and Kemps Farm to the north west. The A4129 highway near Black Barn Farm, Hill Ground Farm and Green Lane Farm is located immediately to the south along with pylons, transmission lines and an electricity sub-station. An unclassified lane is located to the east between Ford village, Lower Waldridge Farm and Owlswick village to the east, and between the A4129 highway near Hill Ground Farm, Black Barn Farm and Aston Sandford to the south west. 4.4 There are no statutory or non-statutory environmental designations located within the proposed area for the new settlement with the exception of public rights of way (PROW) and the Environment Agency (EA) Flood Zone corridor located to the north. Any surrounding environmental constraints could be incorporated into the new settlement as part of the concept masterplan for the proposed Waldridge Garden Village.

WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 13 General location of new village

AERIAL CONTEXT PLAN

14 WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 05 ENVIRONMENTAL CONTEXT

5.1 The proposed Waldridge Garden Village exhibits a number of opportunities in landscape and visual terms including land use, planning policy, landscape character, topography, watercourses, vegetation, public rights of way (PROW), agricultural land classification (ALC) and green infrastructure (GI).

WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 15 AGRICULTURAL LAND CLASSIFICATION PLAN

16 WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 05 ENVIRONMENTAL CONTEXT

Land Use Agricultural Land Classification 5.2 The current land use comprises medium to large scale 5.4 The Agricultural Land Classification (ALC) across the new arable and pastoral farmland with field boundaries defined settlement area is predominately grade 4 – poor with a by mature hedgerows, treebelts, small woodland copses, smaller area of grade 3 – good to moderate to the north near ditches and stock proof fencing. Ford village. The other options surrounding Haddenham are 5.3 The new settlement covers approximately 65 no. medium to located on the following ALC grades for comparison: large scale geometric arable and pastoral fields on level to Option ALC Grade gently undulating topography. Haddenham New Garden Village 4 - Poor Haddenham Western Expansion 2 - Very Good Winslow Northern Expansion 3 - Good to Moderate Winslow New Garden Village 3 - Good to Moderate

5.5 Using the information within these maps, it is clear that in order to accord with paragraph 112 of the NPPF, the development of the proposed Waldridge Garden Village should be preferred.

WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 17 LANDSCAPE DESIGNATIONS PLAN

18 WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 05 ENVIRONMENTAL CONTEXT

Landscape Designations Woodland, Hedgerows and Trees 5.6 There are no statutory or non-statutory landscape 5.7 The medium to large scale arable and pastoral farmland is designations covering the new settlement area. The proposed enclosed by mature hedgerows, treebelts, small woodland Waldridge Garden Village is not located within the Chilterns copses, ditches and stock proof fencing as shown on Figure Area of Outstanding Natural Beauty (AONB) which is located 3. The woodlands, hedgerows and trees could be effectively to the east, or the AVDC Local Plan Area of Attractive retained and accomodated within the new settlement and Landscape (AAL) or Local Landscape Areas (LLA) located would form part of the Green Infrastructure (GI) strategy to to the north west of Haddenham and Dinton. As such, the link into the wider surrounding landscape. landscape is therefore of ‘less than local importance’ in terms of the NPPF paragraph 115 hierarchy of landscape designations.

WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 19 Landscape Policy 5.8 The relevant landscape planning policies which relate to 5.11 The policies map defines AALs and LLAs which have the new settlement are detailed within the saved policies of particular landscape features and qualities considered adopted Aylesbury Vale Local Plan (AVLP, January 2004) and appropriate for particular conservation and enhancement the Draft Vale of Aylesbury Local Plan (VALP, July 2016). opportunities. Of the two categories, the AALs have the 5.9 The NPPF states within paragraph 115 that: greater significance. Development in AALs and LLAs should have particular regard to the character identified in the report “Great weight should be given to conserving landscape and ‘Defining the special qualities of local landscape designations scenic beauty in National Parks, the Broads and Areas of in Aylesbury Vale District’ (Final Report, 2016) and Aylesbury Outstanding Natural Beauty, which have the highest status Vale Landscape Character Assessment (2008). Development of protection in relation to landscape and scenic beauty.” that adversely affects this character will not be permitted 5.10 The Draft VALP states within Policy NE3 - Landscape unless appropriate mitigation can be secured. Where character and locally important landscape: permission is granted, the Council will require conditions or “The first stage in mitigating impact is to avoid the identified Section 106 agreements to best ensure the mitigation of any harmful impact. Where it is accepted there will be harm to harm caused to the landscape interest.” the landscape character, specific on-site mitigation will be 5.12 The proposed Waldridge Garden Village avoids any harmful required and, as a last resort, compensation will be required landscape effects upon these designations. as part of a planning application. Applicants must consider the enhancement opportunities identified in the Aylesbury Vale Landscape Character Assessment and how they apply to a specific site.

20 WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 05 ENVIRONMENTAL CONTEXT

5.13 The adopted AVLP states within Policy RA8: 5.14 The concept masterplan and green infrastructure (GI) “The design of new development proposals should respect strategy for Waldridge Garden Village would be designed and complement: to respect and compliment the character of the site within the AVDC Haddenham Vale mindful of character area, local a) the physical characteristics of the site and the building materials, historic settings, natural qualities and surroundings; important public views and skylines. b) the building tradition, ordering, form and materials of the locality; c) the historic scale and context of the setting; d) the natural qualities and features of the area; and e) the effect on important public views and skylines.”

WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 21 LANDSCAPE CHARACTER PLAN

22 WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 05 ENVIRONMENTAL CONTEXT

Landscape Character 5.15 The relevant landscape character areas to the new 5.16 The AVDC landscape character assessment considered the settlement are detailed within the Natural England, NCA 108, Haddenham Vale LCA 8.9 character area containing the new Upper Thames Clay Vales and the AVDC, Haddenham Vale settlement to be of “only moderate” sensitivity. The sensitivity LCA 8.9 character area. At the detailed local scale, the key of the character area has been described as: characteristics of the Haddenham Vale LCA 8.9 character “The landscape is distinctive in character and the historic area include: associations are reasonably well expressed in the field • Flat vale landscape; patterns and drainage network. Overall the sense of place • Backdrop of Chilterns; is considered to be moderate. The landform is fairly • Meandering network of streams; insignificant visually due to the low lying character. Tree cover is variable, changing in intensity as one moves from • Meadows; east to west across the area but the dispersed nature of the • Parliamentary enclosure; tree cover combined with the topography gives a moderate • Large scale open arable fields; degree of visibility. Overall the moderate sense of place • Smaller grazing parcels associated with streams and wet combined with the moderate visibility gives the landscape a ditches; moderate sensitivity.” • Sparse settlement pattern of dispersed farmsteads; 5.17 The new settlement being located within the low lying • Low level of woodland cover but with higher character and dispersed treecover of the Haddenham concentration of shelter belts, parkland and woodland Vale LCA 8.9 character area exhibits a high capacity to coverts in the west; accommodate a residential development. • Mature, often pollarded black poplar along streams and ditches; and • Tranquility.

WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 23 TOPOGRAPHY MAP

24 WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 05 ENVIRONMENTAL CONTEXT

Topography 5.18 The proposed Waldridge Garden Village is located within the generally level of the Haddenham Vale LCA 8.9 character area and exhibits little topographic variation. The landscape gently undulates between 75m AOD to the west and 95m AOD. The low topographic variation across the landscape is considered to exhibit a high capacity to accommodate a new settlement and sustainable cycle and walking routes.

WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 25 FLOOD MAP

26 WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 05 ENVIRONMENTAL CONTEXT

Watercourses 5.19 The gentle undulation in the north of the area contains a small ditch and tributary watercourse between Lower Waldridge Cottages and Wotton Grounds Farm to the north of the new settlement. The watercourse is protected by the Environment Agency Flood Zone between Kemps Farm and Lower Waldridge Farm to the north. A network of smaller field boundary ditches and dew ponds are situated across the landscape outside of the Environment Agency Flood Zone that could be integrated into a Sustainable Urban Drainage Strategy (SUDS) for the proposed Waldridge Garden Village. The local flooding parameters would not present a constraint to development of a new village.

WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 27 PUBLIC RIGHTS OF WAY PLAN

28 WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 05 ENVIRONMENTAL CONTEXT

Public Rights of Way (PROW) 5.20 There are a number of public rights of way (PROW) crossing or within close proximity to the new settlement location including the Outer Aylesbury Ring (OAR) recreational trail between Aston Sandford, Green Lane Farm, and the Midshires Way (ASA/5/1 and ASA/5/2) to the south, the public footpath between Aston Sandford and Waldridge Manor following the local ridgeline (ASA/9/2, DFM/130/1 and DFU 27/2) towards the centre, and between Waldridge Manor and Ford village (DFU/27/1) to the north of the new settlement. A bridleway (DFU/26/1) also connects Aston Sandford, Kemps Farm (DFU/26/1) and Ford village (DFU/24/1) to the west of the site. A network of the other PROW are located between Green Lane Farm, Little Acre Farm, and Owlswick to the south of the new settlement. The Aylesbury Ring recreational trail is not located within the proposed Waldridge Garden Village and is aligned approximately 900m to the north east between Ford and Kimble Wick and the new settlement would not be prominent from this recreational trail. The existing public rights of way could be effectively assimilated into the green infrastructure of the village.

WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 29 Landscape Opportunities – Green Infrastructure Strategy • The new settlement is not located within close proximity 5.21 The proposed Waldridge Garden Village provides many to the Chilterns AONB, or the AVDC Local Plan Area of opportunities to create a multi functional, holistic Attractive Landscape (AAL) or Local Landscape Areas environment which would provide for the green infrastructure (LLA) and is therefore of ‘less than local importance’ in strategy for Waldridge Garden Village as follows: planning terms; • The new settlement is predominantly located on • The new settlement would be designed to respect and agricultural land classification grade 4; compliment the character of the site, local building materials, historic settings, natural qualities and important public views and local skylines; • The new settlement being located with the “low lying character” and “moderate visibility” of the Haddenham Vale LCA 8.9 character area has a high capacity to accommodate a new settlement;

30 WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 05 ENVIRONMENTAL CONTEXT

• The low topographic variation across the landscape has a • The new settlement would improve legibility and high capacity to accommodate a new settlement; permeability with a strong movement network enhancing • The Environment Agency Flood Zone and network of and improving the existing PROW network as well as smaller ditches and dew ponds would be integrated into the creation of new routes linking to the Outer Aylesbury a Sustainable Urban Drainage Strategy (SUDS); Ring (OAR) recreational trail; • Existing woodlands, hedgerows and trees would be • The new settlement would create a diverse range of retained where appropriate and enhanced for landscape green spaces which successfully combine function, and ecological interest; ecology, SUDS and existing green space assets; • Biodiversity, habitat protection and enhancement • The new settlement would create a variety of play spaces measures would be included along wildlife corridors as and education opportunities; and part of the strategy; • The new settlement would improve existing green assets with the creation and enhancement of wildlife corridors to define the transition from the urban to rural edge.

WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 31 Designated heritage assets 6.1 A Heritage Appraisal has been undertaken of the area. This concludes that there are no heritage constraints which would preclude the development of the settlement, with appropriate design. It identifies the assets which need to be taken into account as follows. 6.2 Development should not physically impinge upon the extent of Waldridge Manor Grade II* Listed Building or Waldridge Village Scheduled Monument. The setting of these designated heritage assets, including immediately adjacent extant ridge and furrow earthworks could be taken into account in the formulation of detailed design plans. 6.3 Grade II Listed Buildings at Pasture Farm could be retained and their setting could be taken into account in the formulation of detailed design plans. Design plans could also take into account views from Aston Sandford Conservation Area, identified within the Conservation Area Appraisal.

32 WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 06 HERITAGE

Non-designated heritage assets 6.4 Historic farm buildings at Lower Waldridge Farm, Black Barn 6.7 No prehistoric or Roman period finds or features are Farm and Aston Mullins Farm are potentially of a significance recorded within the potential development area. The potential commensurate to a non-designated heritage asset. However for currently unrecorded below-ground archaeological current evidence does not indicate that these would represent remains cannot be ruled out at this stage. However, there is a major constraint to development. no current evidence to suggest that such remains are present 6.5 Heritage assets recorded on the Historic Environment which would preclude development from large parts of the Record comprising a possible windmill location, possible potential development area. pillowmounds and a 20th-century wind pump are considered, 6.8 These designated and non-designated Heritage Assets on current evidence, to be of a significance commensurate have been considered in the development of the emerging to non-designated heritage assets. Therefore these are Concept Masterplan, although it is recognised that further not considered to represent a significant constraint to assessment of the significance of these assets and their development. settings will be required to inform the layout of the final 6.6 Extant ridge and furrow earthworks within the potential development. development area are not associated with any ‘Priority Township’ and are considered to be of a significance commensurate to a non-designated heritage asset. However, the retention of ridge and furrow earthworks immediately adjacent to Waldridge Village Scheduled Monument would be considered in design plans.

WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 33 PLAN EC01 ECOLOGICAL DESIGNATIONS PLAN

34 WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 07 ECOLOGY

7.1 Walkover surveys were carried out by Ecology Solutions Ltd 7.3 The Chilterns Beechwoods Special Area of Conservation in August 2016 to ascertain the general ecological value of (SAC), also designated as the Ellesborough and Kimble the study area and to conduct an appraisal of the suitability of Warrens Site of Special Scientific Interest (SSSI), lies ecological features for use by protected species. approximately 4.3km east of the study area at its closest 7.2 The primary ecology constraints to the study area are the point. It is considered that there are mechanisms in place Small Wood near Aston Sandford Local Wildlife Site (LWS) to mitigate for any impacts that may arise from recreational in the southwest of the study area (see Plan ECO1) - albeit pressure on the Chilterns Beechwoods SAC, and as such it is this area is considered to be scrub but is identified on the not considered that there would be any adverse impacts from Magic website as ‘Deciduous Woodland’ and designated for any development proposals on the Chilterns Beechwoods its Hawthorn ‘woodland’ - and the presence of protected and SAC either alone or in combination with other plans or notable species from within the study area boundary (see projects. Plan ECO2)

WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 35 PLAN EC02 ECOLOGICAL CONSTRAINTS PLAN

36 WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 07 ECOLOGY

7.4 The majority of the site comprises grassland and arable fields separated by hedgerows and fences. The grassland fields are generally species-poor, in botanical terms although there are a small number of more species-rich fields present (see Plan ECO2). The grassland fields are either subject to hay cutting or are grazed by a mix of Horses, Sheep, Cattle and Pigs. The hedgerows are also generally species-poor, although again there are some more species-rich hedgerows. Small areas of woodland are present throughout the study area, which range from deciduous woodland to mixed coniferous and deciduous woodland, Poplar plantations and tall scrub. There are also areas of orchard, which have been identified on the Magic website as the Priority Habitat ‘Traditional Orchard’ (see Plan ECO2). In addition, a number of Black Poplar trees have been identified from the desk study in hedgerows within the study area, along with Snake’s-head Fritillary also recorded by the Buckinghamshire & Milton Keynes Environmental Records Centre (BMERC) as being within the study area. 7.5 Any development at the site could focus built form on the areas of lower ecological value, such as the species-poor semi-improved grassland fields, improved grassland fields and arable fields. The areas of greater ecological value in the context of the study area are the hedgerows (in particular the species-rich hedgerows), woodland, trees, ponds and species-rich semi-improved grassland, and therefore development proposals would aim to safeguard these features, wherever possible.

WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 37 7.6 Records of a number of bat species were returned by the (BMERC), although no records of roosts were returned. A number of trees and buildings within the study area have been identified as having potential to support roosting bats, while the hedgerows, woodland and trees offer suitable foraging and navigational opportunities. 7.7 There is an active Badger sett within the study area, and evidence of mammal push-throughs throughout the study area. It is considered the hedgerows within the study area offer suitable opportunities for Dormice, although no records of this species were returned as part of the desk study exercise. A Brown Hare, a priority species, was recorded off- site in an arable field contiguous with the study area, and it is considered the habitats within the study area offer suitable opportunities for this species. 7.8 A small number of notable birds were recorded within the study area during the surveys undertaken, with a larger number being returned from within the study area as part of the desk study exercise. 7.9 The areas of rough grassland within the study area offer potential suitable habitat for common reptiles, and indeed a record of Grass Snake was returned from within the study area as part of the desk study.

38 WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 07 ECOLOGY

7.10 There are a number of ponds within the study area, most of 7.13 It is considered that taking account of the above principles which were recorded as being dry during the survey, although and recommendations with an appropriate scheme / design there are relatively recent records of Great Crested Newts any potential effects on habitats and protected species could returned by the BMERC from a number of ponds within the likely be mitigated / compensated. Indeed, it is likely to be northern half of the study area. possible to demonstrate a net gain for biodiversity within 7.11 Further specific surveys would be recommended in respect the sites where appropriate enhancement measures can of bats, Badgers, Dormice, breeding birds, reptiles and Great be implemented. As such, there is not deemed to be any Crested Newts as part of any planning application. If such overriding ecological constraint to development of this land species are identified as being present during the survey for a village. work, Natural England licences (where applicable) may be required ahead of any works likely to disturb the species or its habitat. Furthermore, suitable mitigation / enhancement measures would be required such that no adverse impact on the species results from the development proposals, which should prove relatively simple given the large area of land. 7.12 The hedgerow network, woodland, trees and ponds will be retained where appropriate and integrated into the development proposals. The creation of green infrastructure including areas of open space throughout the study area as part of any development proposals, along with the creation of new areas of species-rich grassland, new native hedgerow planting, new native woodland and tree planting, and the creation of new ponds will create new opportunities for a range of wildlife.

WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 39 40 WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 08 TRANSPORT

8.1 Waldridge Garden Village is located in the Vale of Aylesbury, positioned to interact with surrounding towns and villages for services and employment. Located close to Haddenham, and roughly midway between Thame, Aylesbury and Princes Risborough, which collectively are the major origins and destinations for journeys that are not made wholly within the village: in addition the site is less than 4 miles from Haddenham and Thame Parkway Station and 7 miles from Princes Risborough Station. 8.2 A comprehensive travel plan will operate for the site that will guide residents and businesses towards non-car and ultimately towards carbon free modes of travel: the internal design of the village, and the travel connections to the rest of the transport network, will be modelled to optimise the potential for non-car and carbon free travel. 8.3 In addition, existing levels of home working in the Vale of Aylesbury are significant, and infrastructure and services for the village will facilitate the take up and growth of home working for residents.

WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 41 Access Bus Travel 8.4 The primary vehicle access routes will be from the A4129, 8.5 It is proposed that operators would be encouraged to provide with two separate access roads leading to two junctions buses along two principle routes via Waldridge: these would some 750m apart, the intention being to diffuse and separate connect Haddenham and Thame Parkway to Aylesbury via eastbound and westbound traffic. In addition to these access the development, and Thame to Princes Risborough station points a sustainable transport corridor will be developed via Waldridge. These services would complement existing towards Haddenham for cyclists and pedestrians and a bus- services on these corridors where they exist, and would gate could be provided as part of an accessible transport provide new services for Ford and Kingsey. These services strategy. An access to Stowells Lane could be provided to would ideally operate at least half hourly through the day allow a bus service to operate to Aylesbury via Ford. This six days a week, with increases in frequency and duration if route may be restricted to non-car traffic. demand is sufficient. These services would be pump-primed so that they are available as families move into the village, allowing sustainable travel habits to develop from the outset. 8.6 Bus routes through the development, and access to the highway network beyond the development, will benefit from bus priority measures to be agreed – these will ensure that bus journey times are car competitive

42 WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 08 TRANSPORT

Cycle Walking 8.7 The topography of Waldridge and the surrounding area is 8.9 The same topography that aids cycling also aids walking on favourable for cycling and several good quality cyclable routes a more local scale: as the site is basically flat. The layout are available at present following quieter roads. The site is and design will be developed to ensure that all dwellings are less than 3 miles from the Parkway Station which facilitating within walking distance of key facilities and that car use for cycling to this and to Haddenham, which is en-route. Journey short local journeys is not necessary. This will be achieved by to work figures from the last census show there is a culture the creation of routes that are suitable for use at night and in of cycling locally, and this can be built on. poor weather to facilitate utility walking and cycling. 8.8 The design of the Garden Village will facilitate the use of bikes locally within the settlement and make provision to for cycling to other destinations, including the provision to a sustainable transport corridor. The design of dwellings will incorporate cycle storage and all local facilities (shops, schools and employment areas), including the central bus stops, will be provided with cycle parking. A development brief would provide the latest best practice in this regard as Waldridge Garden Village progresses.

WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 43 Train Working from home 8.10 Waldridge is not served directly by a railway station but is 8.11 The promotion of home working is an alternative to travel three miles from Haddenham and Thame Parkway Station itself, and is facilitated by a number of factors, most and seven miles from Princes Risborough Station. Both especially suitable accommodation within the home and high stations have frequent (at least half hourly) services to speed internet. This is further supported by the provision London (approx 40 minutes) and are served by large car of non-employment facilities e.g. everyday shopping parks. In keeping with the objective of reducing car travel the requirements, locally as trips to these are often made as travel plan will encourage journeys to these stations by non- part of the journey to work. The layout of the Village and the car modes, most especially by the promotion of bus services development of local facilities will ensure that those who to reach the railway but also by the promotion of cycling to chose to work at home will not have to travel outside the these stations. village for other reasons during the course of their working day.

44 WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 08 TRANSPORT

Car share Carbon Free Travel 8.12 With the development of 4,500 homes rising up to 7,000 and a 8.13 Travel and urban infrastructure will be developed to facilitate pattern of employment and travel within the local area from carbon free living including transport. The trend towards the site, this is an ideal opportunity for a village wide car- electric vehicles (EVs) will be encouraged through the share scheme to be implemented. This can involve either a provision of comprehensive charging infrastructure, and journey-share database which would be linked to any district non-car modes such as cycling will be further encouraged and countywide initiative such as Bucks Car Share or a car- by this provision. In addition the developer will work with bus club type arrangement whereby residents and businesses operators to encourage cleaner buses. can rent car club vehicles for local journeys by the hour.

WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 45 46 WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 09 GARDEN VILLAGE GUIDANCE

9.1 As part of the masterplan development, research was 5. A strong local jobs offer in the Garden City itself, with undertaken into the Garden City movement. The father of the a variety of employment opportunities within easy Garden City movement, Ebenezer Howard, did not prescribe commuting distance of homes; a definitive set of principles or guidelines for the purposes of 6. High-quality imaginative design (including homes with planning new Garden Cities. Whilst a number of 20th century gardens), combining the very best of town and country interpretations stand testament to evolving national priorities living to create healthy homes in vibrant communities; for design and delivery of large housing projects, it is the qualities of the original developments and the sentiments 7. Generous green space linked to the wider natural expressed by Howard, which drive contemporary policy environment, including a mix of public and private makers and urban designers, such that: networks of well-managed, high-quality gardens, tree- lined streets and open spaces; “The advantages of the most energetic and active town life, with all the beauty and delight of the country, may be 8. Opportunities for residents to grow their own food, secured in perfect combination”. including generous allotments; 9.2 As the ancestor of the Garden Cities Association, the Town 9. Access to strong local cultural, recreational and shopping and County Planning Association (TCPA) has reviewed Garden facilities in walkable neighbourhoods; and City principles with a view to promoting their use within 10. Integrated and accessible transport systems - with a the planning and delivery of new residential development. series of settlements linked by rapid transport providing The TCPA’s report considers lessons learned from previous a full range of employment opportunities. garden city development including: 9.3 In the 21st century, Waldridge Garden Village provides 1. Strong vision, leadership and community engagement; the opportunity for more, better-quality and sustainable 2. Land value capture for the benefit of the community; housing to meet changing social needs and an increasingly low-carbon economy: affordable family housing, an 3. Community ownership of land and long-term stewardship increased range of accommodation for older people looking of assets; to ‘downsize’, and truly local services and employment 4. Mixed-tenure homes that are affordable for ordinary opportunities to provide the basis for a strong community people; with identity and interaction.

WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 47 48 WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 09 GARDEN VILLAGE GUIDANCE

9.4 These aspirations chime with the Garden City ethos; people 9.6 The Garden City principles provide some good precedents of all ages want to live in a vibrant working community, which for the strategic layout of the development, but are based on is positive and healthy with access to high-quality green car movement and car ownership and some face problems spaces and the countryside. with high speed routes due to the width of streets and high 9.5 Some of the strategic design principles for the layout of visibilities. The detailed layout of streets therefore needs Garden Cities has been followed including: to look at more contemporary examples, such as those promoted by the manual for streets. 1. Concentric model; 9.7 The density at Waldridge Garden Village will allow the 2. Central Park; creation of walkable neighbourhoods. Existing Garden Cites 3. A well planned development structure with clearly defined have low densities and greater land take, which promotes movement routes through the development; the use of the car to access facilities and is the opposite aspiration of Waldridge Garden Village which wishes to 4. A mix of complementary land uses that are conveniently provide walkable facilities and inclusive communities. located within the development proposals; 5. Enhanced natural environment; 6. Tree lined landscaped streets; 7. A landscape design approach adopted within the development blocks so that improvements to biodiversity and wildlife settings can be incorporated; 8. High quality homes that aid in creating variety and character to the area, but also provide a mix of homes to cater for the existing community’s needs; 9. Strong links to the wider countryside with a harmonious relationship created between the built form and the wider landscape; and 10. Integrated and accessible transport systems, where care is taken over the design of the streets to create attractive routes for pedestrian/cyclist movement.

WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 49 10.1 Waldridge Garden Village will be planned in a comprehensive • Development density - High density residential and and integrated manner reflecting partnership working and mixed-use development to be focused along public will set out the phasing of development along with timely transport corridors and in neighbourhood centres with provision of supporting infrastructure. The Masterplan for lower densities provided elsewhere to deliver an overall the site will encompass the whole of the development area range and choice to meet different needs; regardless of land ownership patterns and this will require • Sustainable transport corridors - Dedicated sustainable partnership working, involving all relevant parties. The new transport corridors including provision for public place will be designed by the following principles: transport, cycling and walking will form key elements of the overall masterplan and effectively link into the wider network; • Sustainable travel choices - Walking, cycling and public transport will be attractive, practical and convenient travel choices for all; • Neighbourhood centres - Provision of a full range of social and community facilities will be concentrated within mixed use neighbourhood centres located along public transport corridors and easily accessed by walking and cycling;

50 WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 10 DESIGN PRINCIPLES

• High Quality Sustainable Design and Distinctive • Landscape, biodiversity and heritage – The place Character – The masterplanning process will effectively will sympathetically integrate existing landscape, respond to the local context. It will also address climate biodiversity and historic features of the site into the change. New well designed neighbourhoods will be development; taking opportunities to protect, enhance created which have a distinctive character which and manage important features along with mitigation residents will be proud of; and enhancement measures to provide satisfactory • Integrating with Neighbouring Areas – The new compensatory measures; development will respond to local deficiencies and • Resource efficiency - Innovative and creative provide good connectivity to adjoining areas and be management of surface water and waste management informed by feedback from existing communities; solutions will be adopted to make the place more • Connected strategic green open spaces - Multi- environmentally sustainable. functional and connected green open spaces will form strategically important links to the surrounding area to provide routes for people, wildlife and open spaces for sports, recreation and play;

WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 51 HADDENHAM

CONCEPT MASTERPLAN

52 WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 11 CONCEPT MASTERPLAN

11.1 The Concept Masterplan within this document is not a detailed masterplan and is not a fixed layout, but the first steps in shaping a design that is flexible enough to provide guidance on the development of the area whilst providing specific enough guidance to ensure the area is designed appropriately. 11.2 The Waldridge Garden Village Concept Masterplan shows the general disposition of lands uses and the proposed structure of the development. At this stage we are exploring options to provide access from the A4129 (Thame Road) and Stockwell Lane. These access points would lead to a centrally positioned district centre that would provide radiating routes to the neighbouring development parcels and provide safe and attractive routes within 800m of the majority of the dwellings. To promote the creation of a walkable place, a well-connected movement network, accessible by all users, is proposed which helps ensure that all areas of the development are easy to navigate, safe and secure.

WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 53 PRINCES RISBOROUGH

PROPOSALS IN CONTEXT OF PRINCES RISBOROUGH

54 WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 11 CONCEPT MASTERPLAN

11.3 As a new settlement, the scale of the proposed development, 11.6 The green infrastructure will provide recreational combined with its strategic location and being well related opportunities for the existing and new population and include to Haddenham, Thame, Aylesbury and Princes Risborough, formal sports, play areas, allotments, trim trails, amenity means that a hierarchy of transport connections is required. space, enhanced ecological habitats, semi-natural open This includes a framework of multi modal connections at space and additional areas designated for sustainable urban regional and local levels. drainage. The scale and massing of the planting will aim to 11.4 Consistent with transport objectives, the infrastructure will create a natural urban edge to the site, accommodating both support the use of sustainable transport modes in preference areas of thick and denser planting suitable for screening to single occupancy car trips. Driving the design is the development and thinner areas allowing for framed and recognised need to provide sustainable transport corridors glimpsed views into and out of the site. Where possible, the through the site that connects Waldridge Garden Village with larger and more dense areas of planting will connect into a Haddenham, designed to accommodate bus-based rapid larger landscape structure of open spaces, trees and verge. transit, pedestrians and cyclists. Bus provision will be made to Thame Parkway Railway Station, Princes Risborough Railway Station and Aylesbury. 11.5 Landscape is an integral part of the design of the development proposals through integration of a strong landscape structure across the site. Through the considered location and use of open space across the development, the landscape structure also provides a clear definition to public and private spaces, whilst adding colour and seasonal interest to the residential environment. The development will look to sensitively integrate the existing landscape structure and will seek to preserve the townscape and visual setting of the existing villages. A working environment where biodiversity is protected and enhanced will be created. The community, particularly schools will be encouraged to get involved in schemes to manage the environment, particularly involving schools.

WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 55 56 WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 12 GREEN INFRASTRUCTURE STRATEGY

12.1 The following section addresses the opportunities and objectives for the Green Infrastructure (GI) strategy for the proposed Waldridge Garden Village. The new settlement would incorporate the principles the Buckinghamshire Green Infrastructure Strategy (April 2009) and the Aylesbury Vale Green Infrastructure Strategy (2011 – 2026).

WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 57 58 WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 12 GREEN INFRASTRUCTURE STRATEGY

12.2 The principles of the Aylesbury Vale Green Infrastructure Strategy (2011 – 2026) include: • GI should contribute to the management, conservation and improvement of the landscape; • GI should contribute to the protection, conservation and management of historic landscapes, archaeological and built heritage assets; • GI should maintain and enhance biodiversity and ensure that its development and implementation results in a net gain of biodiversity as identified in Biodiversity Action Plan (BAP) habitats and species plans; • GI should deliver the enhancement of existing woodlands and create new woodlands and tree features; • GI should create new recreational facilities, particularly those that present opportunities to link urban and countryside areas; • GI should take account of and integrate with natural process and systems; • GI should be managed to provide cost effective and multi-functional delivery and funded in urban areas to accommodate nature, wildlife, historic and cultural assets, economic benefits and provide for sport and recreation activities; • GI should be designed to high standards of sustainability to deliver social and economic, as well as environmental benefits; and • GI should provide focus for social inclusion, community cohesion and development and lifelong learning.

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12.3 The principles of the Aylesbury Vale Green Infrastructure Strategy (2011 – 2026) will be incorporated into the new settlement through: • Creation of a sustainable residential development with • Integration and enhancement of the public rights of direct walking/cycling links to surrounding rural and way (PROW) network including the Outer Aylesbury urban areas; Ring (OAR) recreational trail across the new settlement • Use of treebelt planting to absorb CO2 emissions and to to create a wide range of safe and accessible walking, retain the existing landscape character and ecological cycling and horse riding routes; resource; • Development of connections to the existing and proposed • Enhance the existing landscape framework within the highways with opportunities to improve the pedestrian new settlement to develop green corridors to enable and cycle network; access, recreation and to enhance biodiversity; • Provision of a network of public open space which • Creation of green corridors along the Environment compliments the existing green links providing for the Agency Flood Zone to provide a buffer and rural edge to needs of the new community including provision of play the village of Ford; and sports areas; and • Enhancement of the existing ecological resource through • Use of Sustainable Urban Drainage Systems (SUDS). habitat protection and creation, notably the small woodland copses and treebelts;

WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 61 62 WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 12 GREEN INFRASTRUCTURE STRATEGY

12.4 GI Framework Opportunities: • Enable the integration of the development into the • Existing trees and hedgerows to be retained and surrounding landscape by replicating landscape enhanced for landscape and ecological interest; character and strengthening the existing landscape framework; • Increase biodiversity with habitat protection and enhancement measures along wildlife corridors; • Create a diverse range of green spaces which successfully combine function, ecology, drainage and • Improve legibility and permeability with a strong existing GI assets; movement network - enhancing and improving the existing Public Rights of Way network as well as the • Create a variety of play and education opportunities creation of new routes; across the development; and • Improve existing GI assets with the creation and enhancement of wildlife corridors to define transition from the urban to rural edge.

WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 63 GREEN INFRASTRUCTURE STRATEGY PLAN

64 WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 12.5 The GI Strategy has developed a number of character areas including: • Character Area 1: Waldridge Gateway/Linear Park – a • Character Area 5: Green Buffer to Waldridge Manor linear parkland crossing the new settlement between and Medieval Village – an ecological corridor and green the unclassified lane near Aston Sandford, the District buffer to the east of the new settlement to protect the Centre, Recreation Area and Lower Waldridge Meadows. setting of Waldridge Manor and the medieval village • Character Area 2: Village Green – located towards Scheduled Monument (SM). the District Centre and Secondary School including • Character Area 6: Green Buffer to Aston Sandford – a Neighbourhood Equipped Area for Play (NEAP) and an ecological corridor and green buffer to the west of formal parkland. the new settlement to protect the setting of the Aston • Character Area 3: Sports and Recreation Area – location Sandford Conservation Area (CA). of sports pitches, Multi-Use Games Area (MUGA) on • Character Area 7: Outer Aylesbury Ring (OAR) Green higher ground to connect with the Secondary School and Corridor – green linkages through the garden village District Centre. to maintain the character of the Outer Aylesbury Rings • Character Area 4: Lower Waldridge Meadows (OAR) recreational trail. Community Wildlife Area – an ecological corridor to the north of the site with a series of SUDS attenuation ponds and woodland connecting to existing PROW and forming a buffer to the village of Ford.

WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 65 “ready for the opportunity”

66 WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 13 DELIVERABILITY

13.1 Waldridge Garden Village provides the most sustainable 13.4 This general location is known to be attractive to location to respond to the unmet needs of neighboring developers and there is a high demand for housing across authorities. Buckinghamshire. Waldridge Garden Village can therefore be 13.2 The site benefits from access to the strategic road network demonstrated to be achievable in accordance with the PPG and is not subject to any physical limitations or constraints (3-021). associated with infrastructure. The scheme can also be 13.5 Waldridge Garden Village is demonstrably deliverable within designed to address flood risk, landscape and heritage the plan period and would be expected to deliver at least factors. Waldridge Garden Village is a sustainable solution 4,500 dwellings in this time frame. However, there are also for housing subject to it being identified in the Local Plan, in opportunities for additional dwellings to be delivered either accordance with the PPG (3-019). within or beyond the plan period to accommodate up to 7000 13.3 There are a number of landowners including the majority dwellings in a sustainable environment. landowner who are committed to exploring the opportunities presented by the concept of a new settlement and are prepared to engage and work with the Council with this objective in mind. The majority landowner is therefore liaising with other local landowners in the identified area to explore their interest and support for such a scheme. The identified option area is large enough that it can flex to take account of the landholdings of the interested parties whilst still providing for the critical mass to deliver a new settlement. Waldridge Garden Village can therefore be demonstrated to be available in accordance with the PPG (3-020).

WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 67 68 WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 14 SUMMARY

14.1 Waldridge Garden Village presents an excellent opportunity 14.7 The Village will be developed with infrastructure for carbon to create a sustainable development in a strong landscape free travel, most notably provision for electric vehicles, and infrastructure which is well connected to public transport. with local facilities and high-speed broadband to encourage The development can create a dynamic new place and an sustainable choices that minimise the need for travel exemplar development. altogether. 14.2 The development will comprise a combination of new 14.8 Nearly all the advantages of sustainability, in the form of neighbourhoods providing education, community facilities bus services, infrastructure for electric vehicles, car share and retail. opportunities and the ability to create short local journeys 14.3 Waldridge Garden Village will also provide the opportunity for everyday needs including employment and education are to provide new jobs, open space, education and retailing a result of focusing development in one location rather than facilities. The design proposals include various substantial dispersing the same scale of development over a wider area. areas of open space within the site and on the northern The proximity to the major centres mentioned adds to this portion of the site towards Ford. Linkages between existing sustainability. areas of ecology can be developed to retain the most valued characteristics of the area. 14.4 This document has identified that it is possible to develop the In this context, the development will respect the land to the east of Haddenham in a sensitive and sustainable area’s local character and setting, and will accord way. with the principles of high quality design and best 14.5 The site is well located for travel to the Thame, Haddenham, practice to create a townscape that is rich, varied Aylesbury and Princes Risborough; the distances to these and sympathetic to its environment. The aim is to places lending itself to bus travel and cycling. In addition the presence of two railway stations that can be served by bus achieve a high quality place with a strong identity, and cycle provides non-car options for access to rail travel. activity and a strong ‘sense of place’. 14.6 The topography of the site lends itself to walking and cycling, which will be encouraged by the internal layout of the site and by provision of everyday facilities within the village, thus travel outside the village will be a choice not a necessity.

WALDRIDGE GARDEN VILLAGE | POSITION STATEMENT 69 www.pegasuspg.co.uk

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