VALE OF AYLESBURY LOCAL PLAN DRAFT CONSULTATION SUBMISSIONS ON BEHALF OF BERKELEY STRATEGIC LAND LIMITED SEPTEMBER 2016 Berkeley Strategic 1.0 INTRODUCTION 1.1 This submission is made in response to the Vale of Aylesbury Local Plan - Draft Plan for Summer Consultation Document (August 2016) (“the Draft Plan”). It is made on behalf of Berkeley Strategic Land Limited (“Berkeley”). 1.2 The submission has regard to representations made by Berkeley to the New Wycombe District Council Local Plan June 2016. It is Berkeley’s view that Wycombe District Council (WDC) has greater capacity to accommodate housing in its Green Belt than stated in its New Local Plan (see below). Berkeley is therefore of the opinion that Aylesbury Vale District Council (AVDC) should not be seeking to accommodate nearly a third of Wycombe’s housing need in its plan when this is fundamentally undeliverable (see below). 1.3 Berkeley’s view as to the ability of WDC to meet more of its OAN is based on a Green Belt review, which has been undertaken by Chartered Landscape Architects, fabrik (“the fabrik review”). It shows that there is indeed greater capacity available in Wycombe’s Green Belt. Sites at Flackwell Heath and Bourne End, controlled by Berkeley, are identified below as examples. 2.0 AYLESBURY VALE’S NEW LOCAL PLAN 2033 Background 2.1 The Draft Plan covers the period 2013 – 2033 and sets out a spatial strategy for the delivery of some 33,300 new homes over the Plan period. 2.2 The Draft Plan has been informed by the Buckinghamshire Housing and Economic Development Needs Assessment 2016 (HEDNA). The HEDNA looked at housing need within the Buckinghamshire Housing Market Area (HMA), which includes Aylesbury Vale District Council (AVDC), as well as Chiltern, South Bucks and Wycombe Districts. The housing need in AVDC was found to be 21,300 over the Plan period. 2.3 The Draft Plan is also providing for an estimated unmet housing need of 12,000 from other authorities in the HMA. This includes 5,000 new dwellings (one third) of Wycombe’s housing need of 15,100. The total planned level of housing in Aylesbury Vale District is therefore 33,300 new dwellings. 2.4 Paragraph 3.11 of the Draft Plan states, with reference to the 12,000 dwelling un-met need, that: “Further capacity work within the housing market area may mean that this will change, so a definitive housing number cannot yet be established.” 2.5 Berkeley supports the need for additional housing capacity work. As set out below, it has detailed evidence to show that WDC has greater capacity within its Green Belt than that identified within its emerging New Local Plan. Vale of Aylesbury Local Plan Summer Consultation August 2016 1 Berkeley Strategic The Spatial Strategy for Growth. 2.6 The Buckinghamshire HEDNA identifies a housing need in AVDC of some 21,300 homes over the Plan period. The Draft Plan seeks to identify enough land to meet this need plus an additional 5,000 homes to meet Wycombe’s unmet need and a proportion of the unmet need from Chiltern District and South Bucks District Council. This has resulted in an AVDC “Spatial Strategy for Growth” (Policy S2) that seeks to deliver 33,300 dwellings over the plan period (2013 – 2033) or 1665 dwellings per annum (dpa). 2.7 AVDC’s most recent 5-year housing land supply position statement (January 2016) shows that between 2001 and 2015 an average of 817 dpa were completed across the district. This means the required rate of delivery is more than double the rate achieved in recent past. Moreover, that statement identifies that there is already a shortfall of 921 completions for the first two years of the Plan. In addition, the housing trajectory only shows housing delivery for AVDC (21,300). Having regard to these issues it is assumed that the additional unmet need of 12,000 will need to be back-loaded with more completions towards the end of the plan period, which must raise concerns over delivery. 2.8 Table 1 - Spatial Strategy for Growth in Aylesbury Vale, which can be found at page 32 in the Draft Plan, shows that even after considering potential sites through its Housing Land Availability Assessment, AVDC is short of suitable sites to accommodate 3,268 dwellings of the 33,300 dwelling target. Moreover, a site still needs to be identified for the 4,500 homes in the new settlement. This raises serious question marks as to the capacity of the district to accommodate the additional homes. 2.9 AVDC states that it is intending to submit its Plan to the Secretary of State in March 2017; to hold the Examination in Public during spring 2017; and to adopt the Plan in the summer of 2017. Having regard to the scale of development proposed and the ‘cross-border’ issues, which are bound to generate a high level of comment and objection, and which, consequently, will require careful and detailed examination, this timetable is optimistic at best. In addition, the Wycombe Local Plan will still be at examination during the summer of 2017. Due to the interlinked nature of the two plans, this may delay the adoption of the Plan. 2.10 Based on the example of Oxfordshire, where the four district councils are being asked to accommodate Oxford City’s unmet need, but where overall the housing numbers are significantly lower than the figures being proposed in Buckinghamshire, it is likely to be two years at least before AVDC Plan is adopted. This can only but give rise to a further cause for concern in terms of the delivery of housing in Wycombe District and across the HMA. 2.11 Berkeley notes that the Draft Plan includes a proposal for a new settlement of some 6,000 new homes, 4,500 of which are to be provided in the plan period. Two possible locations have been highlighted: Haddenham and Winslow. If AVDC has yet to decide on a preferred location for the new settlement, it is again difficult to see how it will have an adopted Plan in place by next year, and how the new settlement can deliver 4,500 homes in the Plan period. By the time the Plan is adopted, planning is secured, the land assembled and Vale of Aylesbury Local Plan Summer Consultation August 2016 2 Berkeley Strategic enabling infrastructure delivered, it is unlikely that the new settlement will deliver any housing until the second half of the Plan period meaning that 4,500 homes would need to be delivered in 10 years, not in a 20 year plan period. This is considered to be unachievable. 2.12 AVDC is also planning to build over 8,000 dwellings at Aylesbury (this is in addition to the existing 5,419 dwellings in the pipe-line from existing allocated sites and other developable sites) and over 4,000 on sites adjacent to Milton Keynes which will require joint working with Milton Keynes Council. The Milton Keynes plan is still at an early stage meaning there is uncertainty about the role of growth on the edge of Milton Keynes as well as unresolved infrastructure issues etc. Moreover, it has taken many years to deliver the existing strategic allocations at Aylesbury and there is no reason to expect that further allocations will come forward any more quickly. 2.13 The Draft Plan does not allocate specific sites in Aylesbury (potential sites are identified) but states at paragraph 4.12 that, where possible, development will be located at suitable previously developed sites in the existing Aylesbury urban area to regenerate the town. The remainder will be linked into sustainable urban extensions on greenfield sites around the town. 2.14 The lead-in times and dwelling completion rates on brownfield sites and regeneration schemes and on large strategic sites tend to be longer than on smaller green field sites. This is because brown field sites frequently have site clearance/contamination issues that slow up development and large strategic green field sites often have land assembly issues, complex section 106 agreements that take longer to negotiate and complex infrastructure requirements that need to be in place before new homes are delivered. 2.15 Seeking to accommodate some 8,000 new homes on large strategic sites on the edge of Aylesbury and on brown field sites within the town, in addition to existing committed sites for 5,419 dwellings, also raises a market saturation issue and is likely to result in developers progressing more slowly than would be the case if AVDC had chosen to adopt a more dispersed strategy with a larger number of smaller sites spread around the district’s larger settlements. 2.16 These factors bear significantly on the ability of the Draft Plan to deliver the number of homes anticipated in the plan period. More importantly, they call in to question the very soundness of the Plan as drafted. There are similar issues with development on sites adjacent to Milton Keynes and as explained above, significant delivery issues with the new settlement. 2.17 In addition to these spatial planning issues, the timely delivery of wider infrastructure projects will be key to AVDC meeting its ambitious housing targets. Paragraph 3.44 of the Draft Plan highlights East–West Rail and the A421 expressway as two such key infrastructure projects. 2.18 East-West Rail is a strategic railway connecting East Anglia with Central, Southern and Western England with stops at Oxford, Aylesbury and Winslow. The project was initially due to be built in two phases with completion by March 2019.