STOKE MANDEVILLE PARISH COUNCIL
RESPONSE TO THE DRAFT VALE OF AYLESBURY LOCAL PLAN – FURTHER INFORMATION
Chapter 1 - Background
Para 1.4 – “Where possible, the content of these responses has been taken into account in the preparation of this draft plan”
The Parish Council invites the District Council to identify what proportion of the 4,500 comments have been taken account of and led directly to changes in this draft plan.
Para 1.6 – “Their feedback will be taken into account when the final local plan is prepared.”
The Parish Council asks how their feedback will be taken into account in the final local plan.
Para 1.13 – “The Councils to the south of Aylesbury Vale District have identified an estimated collective unmet need of 12,000 homes.”
Having reviewed the approach taken by Wycombe District Council in their Local Plan, who are expecting Aylesbury Vale to provide for an unmet need of at least 5,000 homes, the Parish Council is concerned that the Duty to Co-operate is being exploited unfairly by neighbouring Councils. Whilst planning constraints do exist, that does not explain why Wycombe is planning for significantly lower housing densities than Aylesbury Vale and refusing to consider a review of Green Belt sites.
Those two actions alone would reduce, if not eliminate, unmet housing need in Wycombe District. The Council suspects that a similar approach may have been adopted by Chiltern and South Bucks District Councils, meaning that the estimated collective unmet need of 12,000 homes is a major overestimate. The Parish Council expects Aylesbury Vale District Council to robustly challenge the level of unmet need to ensure the final local plan reflects reality.
Para 1.14 – “As that will not deliver the amount of housing we may need, the Council is considering some different approaches to meeting housing need.”
The Parish Council is concerned that devising approaches to meet housing need is premature until there is greater clarity about the precise level of housing need, particularly unmet housing need elsewhere.
Para 1.14 – “There will need to be specific provision for affordable housing given the high cost of housing in the District and specific provision to meet specialist needs such as housing for the elderly.”
The Parish Council expects the District Council to make provision for all types of specialist housing need, including for people with disabilities and special needs. This should be assessed in conjunction with disability groups, charitable bodies, and healthcare providers, including the Clinical Commissioning Group.
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STOKE MANDEVILLE PARISH COUNCIL
RESPONSE TO THE DRAFT VALE OF AYLESBURY LOCAL PLAN – FURTHER INFORMATION
Para 1.17 – “The provision of infrastructure to support the new housing is essential…”
The Parish Council believes that the provision of infrastructure to support housing is critical to the development of sustainable communities and its importance should never be underestimated. There are particular deficits in certain sectors and geographical areas that must be planned for and met by future housing growth.
The Parish Council urges the District Council to prioritise the preparation of a comprehensive Infrastructure Delivery Plan, involving all service providers, to ensure it reflects the needs of existing and future communities and is based on robust assessments of demography and growth. The Parish Council hopes that relevant bodies such as the County Council are properly resourced for this work.
Para 1.19 – “The proposed delivery of East West Rail will also increase connectivity.”
The Parish Council is disappointed that Aylesbury Vale District Council describes East West Rail in such an uncertain way. It trusts that Aylesbury Vale remains committed to securing the completion of the East West Rail project in a timely manner to support growth across the District.
Para 1.19 – “It is important to mitigate the effect of new transport infrastructure, such as the proposed HS2.”
The Parish Council is confused by the approach adopted by Aylesbury Vale District Council towards HS2, the Government’s highest priority transport infrastructure project. Whilst the project has yet to achieve Royal Assent, the recent publication of revised Safeguarding Directives by HS2 Ltd and statements made by the new Prime Minister and Transport Secretary leave little doubt about the Government’s position.
Having faced the threat of HS2 for more than six years, Stoke Mandeville Parish Council, is surprised at the ambivalence of the District Council. Despite being required to consult HS2 Ltd on planning applications within the safeguarded area, Aylesbury Vale chooses not to show the line of route on the key map (Draft VALP – Potential Housing Allocations – South East Aylesbury). This must be rectified.
Para 1.21 – “Conclusions will need to be reached on the housing numbers from the other Councils in Buckinghamshire and surrounding areas.”
The Parish Council believes that these conclusions are critical to the local plan and fundamentally affect the scale of growth and its distribution. Finalising this evidence must be a priority action for the District Council, ahead of any other work.
Para 1.21 – “Traffic modelling of impacts of the proposed development is being prepared and has partly informed this draft plan, but this will need finalisation and will need to show how impacts can be addressed.”
Whilst the Parish Council accepts that traffic modelling is essential, until there is agreement on the fundamental matter of housing numbers, it could be abortive and expensive work.
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STOKE MANDEVILLE PARISH COUNCIL
RESPONSE TO THE DRAFT VALE OF AYLESBURY LOCAL PLAN – FURTHER INFORMATION
Chapter 2 – Vision and Strategic Objectives
Para 2.1 – “It sets the ambition and direction for the District as a whole, which all relevant strategies and delivery plans of the Council and its delivery partners should support.”
Whilst the Parish Council understands and recognises the hierarchy of the development plan, it is concerned that such a statement implies a top-down dictatorial approach to planning. It suggests that all other plans should be subservient to rather than informed by the local plan. The Parish Council would prefer the use of words that imply partnership and collaboration.
Spatial vision
The Parish Council believes that the spatial vision for the District is generic and vague, with little to make it specific to Aylesbury Vale. There are unique characteristics and strengths within the District that could be referenced which would give the vision a unique Vale flavor, such as its links to the Paralympic Games and its motorsport heritage.
Para 2.4 – Sections a-f
Again the Parish Council thinks that these statements are generic and idealistic, with little to differentiate them from anywhere else other than the inclusion of place names in sections c and d. As stated above, Aylesbury Vale has characteristics and strengths that could be referenced.
Para 2.4 – Section g
The Parish Council is disappointed that the significant growth in Aylesbury is not described as being led by or at least supported by neighbourhood planning, since much of this growth is in areas and Parishes that are developing neighbourhood plans, such as Stoke Mandeville and Weston Turville. It is surprised that this particular feature about Aylesbury’s growth is not mentioned in any of the ten aspirations for the town.
The Parish Council questions how the District Council will secure the sixth aspiration, where it refers to “well-designed, connected, healthy, safe and integrated greenfield urban fringe sites” that will help “deliver identified strategic infrastructure without compromising the character of surrounding villages or community cohesion.” Stoke Mandeville Parish Council is sure it is not alone in asking how these ‘urban fringe sites’ in neighbouring Parishes will avoid coalescence.
It believes that section g needs to be developed in conjunction with the Town and Parish Councils who will be supporting and making major contributions to the growth of the town, rather than prepared in isolation from those Councils. Without such involvement, this collection of aspirations reads as a number of ‘motherhood and apple pie’ platitudes.
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STOKE MANDEVILLE PARISH COUNCIL
RESPONSE TO THE DRAFT VALE OF AYLESBURY LOCAL PLAN – FURTHER INFORMATION
Para 2.4 – Section j
The Parish Council is pleased that the District Council wishes to see the rural areas (including Stoke Mandeville) remain predominantly rural in character, but is not clear how this will be achieved bearing in mind the significant risk of coalescence between Aylesbury and Stoke Mandeville village. It does, however, dispute the statement that growth will have been proportionate and reflect community aspirations, since it has already experienced the District Council recommending that applications be approved where growth is far from proportionate and clearly fails to reflect local aspirations.
It would welcome understanding how and from what point the District Council will ensure that development reflects the character of the local circumstances, since recent events suggest that this principle is not currently applied. The Council looks forward to the development of a well-managed network of green infrastructure but does ask how this, once established, will be maintained.
Strategic Objective 1
The Parish Council would welcome a definition of ‘balanced sustainable growth’ and whether this will be achieved through adopting ‘a flexible and pro-active approach to promoting sustainable development’. It suggests that perhaps a clearer objective would be to state that the Council will ‘plan for homes and jobs that match existing and future needs, on a combination of greenfield and brownfield sites across the District.’
Strategic Objective 2
The Council reiterates its previous point about unmet needs from elsewhere. It suggests that the statement should be strengthened from ‘if reasonable and sustainable’ to ‘where proven’. It also repeats its point about housing being required to meet a range of needs rather than just those of an ageing population.
Strategic Objective 3
The Parish Council recognises the importance of infrastructure but suggests that the District Council may wish to state that the list (numbered 1 to 7) is not in any priority order, since it is felt that social care and health infrastructure may be significantly more important in many communities than accessible green infrastructure (for example).
It is also confused by the specific reference to HS2 linked to the provision of broadband in remote areas, since in the earlier chapter it talked about HS2 as a proposal. The Parish Council would welcome increased clarity on this matter since it has faced the threat of HS2 for more than six years, and has engaged with the Promoter throughout this period, a requirement not expected of developers.
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STOKE MANDEVILLE PARISH COUNCIL
RESPONSE TO THE DRAFT VALE OF AYLESBURY LOCAL PLAN – FURTHER INFORMATION
Strategic Objective 5
The Parish Council welcomes the District Council’s desire to enhance local centres and village facilities and looks forward to further discussions to identify how such improvements can be achieved in the Parish.
Strategic Objective 6
The Parish Council would appreciate knowing how and from what point the District Council will manage development in a way that ensures the protection and enhancement of the District’s built, natural and historic environment. It seeks this clarification, since one particular recent application recommended for approval by the planning authority fails to protect or enhance any of these three aspects in Stoke Mandeville village.
Strategic Objective 8
Whilst the Parish Council applauds the spirit of this objective, it is rather meaningless without offering any thought to the actions that will help achieve this. It also questions whether the District Council’s actions in relation to hire of sports pitches actually increases health inequalities across Aylesbury.
Chapter 3 – Strategic
Policy S1 – Sustainable development for Aylesbury Vale
If a policy that describes sustainable development is assessed against the number of times that the word or phrase is used, then there would be little doubt that this policy is truly ‘sustainable’. The Parish Council believes, however, that the repeated use of the word and applying the rather limited definition from the NPPF does Aylesbury Vale residents few favours.
The Council had hoped that, in line with the area’s status as a growth area, the District Council might have sought to define sustainable development within the Vale as something that was exemplary and sought to enhance the area. The policy instead states that when ‘assessing the most sustainable locations priority will be given to…’ followed by a list of worthy aspirations.
Since this follows a paragraph dealing with how applications will be determined, one might consider that this list of worthy aspirations are criteria against which applications will also be judged. The Parish Council does not believe that this is the case since it reads this section as about how Aylesbury Vale District Council will compare and assess sites identified by landowners and developers.
Para 3.6 – Third bullet point
Stoke Mandeville Parish Council questions the extent to which the draft Local Plan has been shaped by infrastructure capacity and constraints. It believes that existing capacity and constraints – particularly in
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STOKE MANDEVILLE PARISH COUNCIL
RESPONSE TO THE DRAFT VALE OF AYLESBURY LOCAL PLAN – FURTHER INFORMATION the key areas of transport, education and health – should be a key determinant in where and how growth is allocated and planned. Previous failures to adequately assess infrastructure need have contributed to the deficits faced by existing residents of the Vale.
Para 3.11
As previously stated, the Parish Council believes that the estimate of unmet housing need from elsewhere in Buckinghamshire is over-inflated and MUST be challenged to arrive at a reliable and realistic figure, before allocating sites that may be unnecessary. The Council also notes that the total number of homes does not currently include any element of unmet need from other neighbouring areas to the north, east or west of Aylesbury Vale.
Para 3.12
The Parish Council is not convinced that the HEDNA has reached the right conclusion about the need for employment land during the plan period. Whilst the need for 22 hectares of new employment land may be all that is required to match housing growth, Aylesbury Vale has historically struggled with increasing levels of out commuting. The Council urges the District Council to review this requirement to ensure all is done to better balance the number of residents with jobs in the District.
Para 3.15
Stoke Mandeville Parish Council is concerned about the accuracy of the opening statement in this paragraph, when it identifies Aylesbury as a centre for growth. The reality is that, whilst Aylesbury will grow, the majority of the allocations that comprise that growth are actually within neighbouring Parishes, namely Bierton, Weston Turville, Stoke Mandeville and Stone.
Para 3.16
As a consequence of allocations planned within Stoke Mandeville Parish in Hawkslade, Stoke Leys and Stoke Grange wards, the village of Stoke Mandeville is unlikely to see development once the Local Plan is made. It is therefore likely that the village will not benefit from improvements to local infrastructure, such as health or community facilities.
Policy S2 – Spatial Strategy for growth
The Parish Council contests the figure of 33,000 homes since it includes an unproven estimate of unmet need from other areas of Buckinghamshire. The Council urges Aylesbury Vale District Council to robustly challenge these estimates and encourage neighbouring Districts to do more to meet their own needs. It also expects the District Council to expedite discussions with other planning authorities about their unmet needs so that a final figure of homes can be established as quickly as possible.
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STOKE MANDEVILLE PARISH COUNCIL
RESPONSE TO THE DRAFT VALE OF AYLESBURY LOCAL PLAN – FURTHER INFORMATION
The Parish Council notes the intention to use both brownfield sites and ‘sustainable greenfield urban fringe sites’ for the development of Aylesbury Garden Town. Most of the latter greenfield sites fall within adjacent Parishes including Stoke Mandeville and it would appear have been selected since they ‘will provide or support delivery of identified strategic infrastructure requirements and sustainable transport enhancements…’.
The Council understands and acknowledges this rationale but is disappointed that a similar rationale was not applied when considering and determining recent planning applications in Stoke Mandeville.
Table 1 – Spatial strategy for growth in Aylesbury Vale
Although the Parish Council recognises that the draft Local Plan reflects a point in time and that things change, it would welcome clarity from the District Council about how recent planning decisions will be reflected when this table is updated. Will the residual requirement for Aylesbury reduce by 307 homes, or only 190? The latter is a more accurate reflection of the circumstances but would require 117 homes being reflected elsewhere.
Para 3.18
The Parish Council is not clear how the proposed delivery rates of 1,623 dwellings per year (for the first five years of the Plan period) and 1,859 dwellings per year (for the remaining 13 years) have been calculated. If anything, the Council suggests that the delivery rate for the first five years should be reduced further to reflect recent completion rates and the latter number raised accordingly.
Paras 3.24 – 3.29 – Settlement hierarchy and cohesive development
Whilst the Parish Council would not challenge the village’s designation as a larger village in the proposed settlement hierarchy it remains concerned about potential coalescence, despite statements to the contrary in the draft Local Plan. It hopes that the District Council will strengthen its position on coalescence in the final policy S3 and will be robust in giving ‘more specific protection in locations that are, or will be experiencing, the strongest pressures for development.’ The Parish Council believes that this clearly applies to Stoke Mandeville and that this principle should be used from this point on.
Para 3.44 Whilst the whole paragraph is somewhat nebulous, the Parish Council is concerned that the final sentence does not seem to be grammatically correct and therefore generally meaningless. It would suggest that this is rectified in a future version.
Para 3.46
Once again there is specific and detailed reference to HS2, which is welcome, but this is inconsistent with other parts of the Local Plan where this project is overlooked or disregarded. The Parish Council trusts that this matter will be addressed in the District Council’s response to the consultation.
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STOKE MANDEVILLE PARISH COUNCIL
RESPONSE TO THE DRAFT VALE OF AYLESBURY LOCAL PLAN – FURTHER INFORMATION
Para 3.54
The Parish Council believes that the District Council is setting itself a very ambitious, and potentially unrealistic, target for the preparation of a comprehensive Infrastructure Delivery Plan and the Community Infrastructure Levy schedules. To identify and co-ordinate the infrastructure needs of the Vale and its phasing in the light of such significant (but not confirmed) growth will require collaboration between a large number of public sector bodies and service providers in a very short timescale.
The Parish Council would not wish to see such important work rushed or short-circuited merely to meet a self-imposed deadline. It suggests that the work is more complex than suggested in Policy S5 (Infrastructure) and requires a detailed understanding of existing infrastructure and facilities (including both deficits and surpluses), an appreciation of the opportunities that growth may provide – which could in turn influence the location and allocation of development – and a commitment from all parties to work collaboratively to maximise the benefits of the Community Infrastructure Levy.
Para 3.56
Stoke Mandeville Parish Council is pleased that protected transport schemes WILL be considered in the determination of future planning applications. It is, however, disappointed that this approach is not already rigorously applied for existing applications. In one recent case in the Parish such a thorough assessment would have led to a significant improvement in the proposed scheme for all concerned.
Para 3.59
The Parish Council does not understand why the existing, published safeguarding directives have been omitted from the proposals maps in the draft Local Plan. The principal authority, the County Council, published details of the route in March 2010 and has updated these maps ever since when changes have been made. The inclusion of the line (even if just labelled proposed) would have reduced the confusion and the number of questions from the local community.
Policy S6 – Protected transport schemes
Stoke Mandeville Parish Council is pleased to see the policy include the statement, ‘Development which is not suitable for the roads that serve the development and which have a severe traffic impact will not be supported’ but is not sure if this goes far enough. Firstly, if a development is not supported, does this automatically mean it is opposed by the planning authority, and secondly what constitutes a severe traffic impact. The Council feels that this term needs a more transparent definition.
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STOKE MANDEVILLE PARISH COUNCIL
RESPONSE TO THE DRAFT VALE OF AYLESBURY LOCAL PLAN – FURTHER INFORMATION
Policy S7 – Gypsy, Traveller and travelling showpeople provision
The Parish Council is unable to comment on this policy or the supporting information, since it presents only a partial picture. It looks forward to the publication of the updated Gypsy and Traveller Accommodation Assessment, so it can provide a more detailed response.
Para 3.83 – 3.84
Stoke Mandeville Parish Council is pleased to have embraced neighbourhood planning and be one of the 27 areas where a plan is in place or being developed. A significant reason for taking forward this work was to allow the community to have a say in the location and specification of growth. It is therefore disappointed that despite consulting with the community about key development sites, these views were overlooked in recent decisions on contentious planning applications.
Para 3.86 – 3.87
Both paragraphs include important commitments from the District Council about support for the neighbourhood planning process. The Parish Council agrees that good communication between the parties is critical and looks forward to receiving regular evidence and information to support its neighborhood plan. It hopes that this will include advice on how to best disaggregate Census data to better understand its four wards.
Chapter 4 – Strategic Delivery
Para 4.4
The Parish Council believes that reference to the Aylesbury transport strategy is tangled and unclear and must be further clarified and enhanced in the final Local Plan. The final section of this paragraph also feels rather idealistic, some might even suggest ‘motherhood and apple pie’.
Para 4.7
The Council considers that the vision for Aylesbury Garden Town includes little that sets it out as unique or specific to Aylesbury.
Para 4.8 – Second bullet point
The Parish Council welcomes the aspiration to design and build to high standards in ways that are sensitive to the District’s local character, but is unclear how this will be achieved, managed and enforced. It looks forward to seeing more detail on this aspect in the near future.
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STOKE MANDEVILLE PARISH COUNCIL
RESPONSE TO THE DRAFT VALE OF AYLESBURY LOCAL PLAN – FURTHER INFORMATION
Para 4.8 – Fourth bullet point
The Council looks forward to working with the District Council to help shape the accessible, sustainable and well managed green infrastructure network, especially the aspiration for a linear park next to HS2 in the Hawkslade ward. It does, however, question how a small corridor of approximately 180m width can accommodate housing, a linear park, a distributor road and enhanced visual mitigation for existing homes that the Parish Council continues to petition for.
Para 4.8 – Sixth bullet point
The Parish Council is keen to understand how the District Council will ensure how ‘the residents of the new growth areas at Aylesbury will feel a strong sense of their own community identity as well as feeling an integral part of a successfully growing, vibrant town.’ It looks forward to further discussions to help inform and shape its emerging Neighbourhood Plan.
Para 4.8 – Eleventh bullet point
The Council trusts that the District Council is working closely with the education authority to achieve this specific aspiration.
Para 4.8 – Twelfth bullet point
The Parish Council looks forward to understanding how the District Council will narrow the gap between the most affluent and less well-off communities and what specific actions it will take.
Para 4.12
Stoke Mandeville Parish Council trusts that Aylesbury Vale will soon specify exactly what number of houses will be accommodated in the existing Aylesbury urban area on previously developed land. This would clearly help give an indication of the number needed on greenfield sites elsewhere.
Para 4.21
The Parish Council notes that the transport strategy is still a work in progress but hopes that it will be involved in consultation and engagement on the strategy and plans as they develop in coming months.
Policy D1 – Delivering Aylesbury Garden Town
The Council is concerned that the housing requirement set out in this policy appears to differ from the number set out elsewhere in the draft Plan. The District Council must ensure that there is total consistency throughout the Plan.
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STOKE MANDEVILLE PARISH COUNCIL
RESPONSE TO THE DRAFT VALE OF AYLESBURY LOCAL PLAN – FURTHER INFORMATION
Table following Para 4.69
Stoke Mandeville Parish Council expects the District Council to clarify the commentary about Stoke Mandeville in this table. It believes that this should read as follows – ‘The residual requirement of 172 homes will form part of Aylesbury’s requirement, meaning that it may be part of growth in Stoke Mandeville Parish but NOT in Stoke Mandeville village.’
Chapter 6 – Economy
Table 10 – Key employment sites
The Parish Council is pleased that Triangle Business Park is identified as a key employment site that merits protection. It urges the District Council to offer similar protection to other employment sites within Stoke Mandeville Parish.
Chapter 12 – Appendix A
Strategic settlements (Aylesbury)
The Parish Council queries the site address for SMD006 – identified as land between Oxford Road and Wendover Road – and for SMD009 – also identified as land between Oxford Road and Wendover Road. It believes that both descriptions are incorrect and must be rectified.
Policy Map Insets
Draft VALP – Potential Housing Allocations – South East Aylesbury
Following recent recommendations made by the District Council’s Planning Committee, this plan / map is now out of date and is likely to give Stoke Mandeville residents a misleading impression of potential future growth. This must be updated as a priority to not only identify potential allocations – some of which are clearly disputed by the Parish Council – but also to identify sites where consent has been granted or where applications are under consideration.
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