June 2018 | NT | P16-1398/P17-1569 Matter 1: Development Strategy CALA Homes Ltd VALE OF AYLESBURY LOCAL PLAN EXAMINATION MATTER 1: DEVELOPMENT STRATEGY ON BEHALF OF: CALA HOMES LTD Pegasus Group Pegasus House | Querns Business Centre| Whitworth Road | Cirencester | Gloucestershire | GL7 1RT T 01285 641717 | F 01285 642348 | W www.pegasusgroup.co.uk Birmingham | Bracknell | Bristol | Cambridge | Cirencester | East Midlands | Leeds | Liverpool | London | Manchester ©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 Vale of Aylesbury Local Plan Examination Matter 1: Development Strategy CONTENTS: Page No: 1. INTRODUCTION 1 2. MATTER 1 – DEVELOPMENT STRATEGY 2 June 2018 | NT | P16-1398/P17-1569 Vale of Aylesbury Local Plan Examination Matter 1: Development Strategy 1. INTRODUCTION 1.1.1 This short Hearing Statement complements the representations to the Proposed Submission Draft Plan (October 2017) provided by Pegasus Group on behalf of CALA Homes Ltd, and addresses the additional evidence which has become available in the interim including the representations submitted by participants, the response to Q40 prepared by the Council and the Inspectors Agenda. It does not re-iterate the points made in and should be read alongside previous representations. June 2018 | NT | P16-1398/P17-1569 Page 1 Vale of Aylesbury Local Plan Examination Matter 1: Development Strategy 2. MATTER 1 – Development Strategy The distribution of growth 2.1.1 In our previous representations to the Regulation 19 consultation, it was identified that regardless of the fact that Edlesboourgh is one of the most sustainable and least constrained Larger Villages; and the fact that Ickford is equally as sustainable as the other Medium Villages, they are both planned to receive a disproportionately low level of growth. 2.1.2 The Inspectors Agenda Session 11, suggests that: “Some of the arguments are that settlements of similar sustainability scores or of similar sizes have different sized allocations but perhaps that misses the point that the allocations are meant to be capacity based.” 2.1.3 Whilst it is agreed that allocations will be informed by their respective capacities, it is necessary for these allocations to provide (or at least facilitate) a sustainable distribution of growth across the District. The spatial distribution does not achieve this for a number of reasons. 2.1.4 Firstly, the distribution takes no account of the respective sustainability and constraints of individual Larger and Medium Villages. For example, the Larger Villages of Pitstone and Steeple Claydon are both less sustainable than Edlesborough (according to the Council’s Settlement Hierarchy Assessment) and yet are planned to receive greater levels of growth; and the Medium Village of Stewkley is less sustainable than Ickford (according to the Council’s Settlement Hierarchy Assessment) and yet is planned to receive greater levels of growth. Similarly, Medium Villages which are equally as sustainable as Ickford are planned to receive much greater levels of growth. The Local Plan does not therefore provide for the most sustainable distribution of growth, and fails to provide for the needs of sustainable Larger and Medium Villages (namely Edlesborough and Ickford). 2.1.5 Secondly, the justification for the level of housing in some settlements not being commensurate with the sustainability of those settlements (regardless of the capacity of allocations) is that Neighbourhood Plans have been made in response to the saved policies of the previous Local Plan (including the housing requirement which was developed in the context of a different national policy context). June 2018 | NT | P16-1398/P17-1569 Page 2 Vale of Aylesbury Local Plan Examination Matter 1: Development Strategy 2.1.6 The Examiner of the Edlesborough Neighbourhood Plan explicitly identified that the Neighbourhood Plan would be replaced by the VALP. The reason for this, is that the VALP was expected to provide for a sustainable distribution to meet the objectively assessed needs. However, the VALP has proposed a distribution which deliberately avoids any reconsideration of the distribution from areas with Neighbourhood Plans contrary to the expectation of the Examiner. Such an approach set a two tier approach to the distribution, with those areas with Neighbourhood Plans maintaining the numbers of the previous (non-NPPF) Local Plan and all other areas having to compensate for the resultant under-provision. In summary, not only is there no robust justification for the distribution of growth, it actively serves to bias the distribution away from those areas with Neighbourhood Plans. 2.1.7 Thirdly, the justification for excluding some potential allocations from further consideration was again that a Neighbourhood Plan which does not provide for the sustainable distribution of the objectively assessed needs. There is therefore no robust justification for excluding some potential allocations from further consideration. 2.1.8 Fourthly, as set out in other representations, the VALP does not provide for the full objectively assessed needs including unmet needs (by a significant margin) and so the refusal to consider additional sites within Neighbourhood Plan areas will further bias the distribution necessary to achieve the full objectively assessed needs. 2.1.9 Fifthly, there is absolutely no justification for the disproportionately low level of growth in Ickford. 2.1.10 In summary, the refusal to consider the spatial distribution holistically (as the distribution to Neighbourhood Plan areas has not been considered) or to consider allocations in Neighbourhood Plan areas is not justified, it is not positive for those areas, and it does not reflect sustainable development. Similarly, the absence of any justification for the distribution of growth between Medium Villages prevents a sustainable distribution of growth. The proposed allocation at Ickford 2.1.11 The proposed allocation at Land off Turnfields, Ickford is less sustainable than the potential allocation at 42 Worminghall Road (according to the Sustainability Appraisal). June 2018 | NT | P16-1398/P17-1569 Page 3 Vale of Aylesbury Local Plan Examination Matter 1: Development Strategy 2.1.12 On the matter of the draft allocation of land at Turnfields, Ickford for 20 dwellings, the Inspector should be made aware of the fact that there is a pending application relating to that land (LPA ref.17/02516/AOP). The application was submitted on 3rd July 2017 and has yet to be determined almost a year later. 2.1.13 It would appear that the application has been held up due to objections from the following:- - The LPA’s Landscape Officer - The Lead Local Flood Authority (LLFA) 2.1.14 The relevant consultation responses are attached. 2.1.15 In summary the LPA’s Landscape Officer considers that the proposed development would be likely to result in significant adverse landscape character and visual impacts to the site and the immediate surroundings. The objections are both in principle and proposal specific. 2.1.16 The LLFA objects to the proposed development due to insufficient evidence to prove that the proposed surface water drainage scheme is feasible. 2.1.17 The Applicant has suggested that options are available which could be funded by the developer but has thus far presented no evidence to demonstrate that these would be feasible and/or viable. 2.1.18 These objections to the planning application bring into question the deliverability of the site regardless of whether it is 20 units as per the draft allocation or 30 units as per the current planning application. The absence of allocations at Edlesborough 2.1.19 The issues at Edlesborough are also further complicated by the fact that there is evidence of difficulties in bringing forward some of the sites that are allocated in the made Edlesborough Neighbourhood Plan (NP). These allocations are relied upon to deliver to achieve even the unsustainable distribution of growth proposed in the Local Plan. 2.1.20 The NP allocation at Slicketts Lane has been the subject of an outline application for 40 dwellings (LPA ref. 17/02539/AOP) since 12th July 2017. June 2018 | NT | P16-1398/P17-1569 Page 4 Vale of Aylesbury Local Plan Examination Matter 1: Development Strategy However there have been very strong objections from the LPA’s Conservation Officer regarding the impact of the development on the settings of 3no. nearby listed buildings. She has recommended refusal. 2.1.21 There has also been an objection from the Conservation Officer from the adjoining LPA (Central Bedfordshire) who were not consulted on the application. There are also questions about whether they were even aware of the proposals to allocate the land in the Neighbourhood Plan and whether the setting of Bellows Mill (which sits in the adjoining authority area) had been properly taken into account by the NP. Notably the site allocations policy does not refer to this building although it does refer to the other two listed buildings. It is also understood that there are concerns from the LPA’s Landscape Officers and it is difficult to see how the LPA is going to balance the loss of this greenfield site as allowed for in the NP with the landscape and heritage objections which appear to bring into question whether the site should have been allocated in the first place. 2.1.22 A revised master plan has been submitted by the Applicant but concerns remain. There are also outstanding objections relating to drainage. 2.1.23 The NP allocation at Land at Good Intent is allocated for 15 dwellings in the made NP (NP Policy EP3). Criterion (iii) of the policy requires that the site has vehicular access from Cow Lane only (via site EDL003A), but with pedestrian and cycle access from Good Intent. It is understood that the landowner has been unable to secure the necessary access from Cow Lane and a planning application was submitted with alternative access arrangements (LPA ref.