CD.SUB_.011 Vale of Aylesbury Local Plan Submission Consultation Statement (AVDC, February 2018)

Summary of Major Issues raised through Draft Plan consultation & how addressed in Proposed Submission VALP 83... A Draft Housing and Economic Development Needs Assessment HEDNA and Housi

Vale of Aylesbury Local Plan

Submission (Regulation 22) Consultation Statement

January 2018

Contents

1 Purpose of the document

Regulations The Vale of Aylesbury Local Plan Stages in preparing the VALP Statement of Community Involvement Sustainability Appraisal

Evidence Base

3

2 Scope of The Plan - 2014 (Regulation 18) 10

3 Issues and Options – 2015 (Regulation 18) 14

4 Draft Plan – 2016 (Non-Statutory) 18

5 Proposed Submission Plan – 2017 (Regulation 19) 29

B Deposit Point Location and Opening Hours 87

C List of Specific, General and Other Consultees 88

Tables

1 Stages of engagement in the production of the Vale of

Aylesbury Local Plan

5

2 Summary of representations received from Duty to

Co-operate Bodies at Reg 19

54

4. Specific SCI requirements for each consultation stage 76

5 Summary of Major Issues raised through Draft Plan

consultation & how addressed in Proposed Submission VALP

83

1 Purpose of the document

1.1 This version of the consultation statement sets out how the Council has involved residents and key stakeholders in preparing the Vale of Aylesbury Local Plan For each consultation stage it describes the background to the work, the various periods of consultation that have been held, along with who was invited to make representations and how This is then followed by a summary of the main issues that were raised at each stage and how they have been addressed It should be read alongside the Duty to Cooperate Statement of

Compliance which also explains how we have engaged actively and constructively with duty

to co-operate bodies, including neighbouring authorities, about strategic issues and the outcomes achieved

Regulations

1.2 This Consultation Statement describes how the Council has undertaken community

participation and stakeholder involvement in the production of the Local Plan to date, setting out how such efforts have shaped the Plan and the main issues raised during each consultation It is produced to respond to and therefore fulfil the requirements set out in the Town and Country Planning (Local Planning) (England) Regulations 2012, and specifically Regulation 19 and Regulation 22(1) part (c) This requires the submission to the Secretary of State of a statement setting out:

● which bodies and persons the local planning authority invited to make representations under Regulation 18;

● how those bodies and persons were invited to make representations under Regulation 18;

● a summary of the main issues raised by the representations made pursuant to

Regulation 18;

● how any representations made pursuant to Regulation 18 have been taken into

account;

● if representations were made pursuant to Regulation 20, the number of

representations made and a summary of the main issues raised in those

representations; and

● if no representations were made in Regulation 20, that no such representations were made

The Vale of Aylesbury Local Plan

1.3 This consultation statement accompanies the Submission Vale of Aylesbury Local Plan (VALP) in accordance with Regulation 22 (1) (c) The VALP is the emerging Local Plan for the district and will, once adopted, replace the 2004 Aylesbury Vale District Local Plan (AVDLP) saved policies The VALP sets out a clear strategic direction for the district, whilst enabling neighbourhood planning to come forward should communities so wish The VALP also contains:

1 Housing and jobs numbers for the Local Plan period, which is through to 2033

2 Strategic vision, objectives and strategic policies – including for Aylesbury Garden Town

3 Development Management Policies – including design policies, affordable housing, housing mix, employment, infrastructure delivery, green belt policy/criteria for

assessing proposals within, tourism, gypsy and travellers, change of use, renewable energy and climate change

4 Site Allocations for housing, employment, retail, gypsy and traveller sites and green infrastructure

5 Locally valued landscape designations and a reviewed green belt boundary

6 A reviewed Aylesbury town centre boundary and retail frontages

7 Detailed Infrastructure to be set out in policies and proposals in an Infrastructure

Delivery Plan

1.4 The VALP has been prepared in accordance with the National Planning Policy Framework (NPPF) and National Planning Policy Guidance Consultation has been taken within the context of Paragraph 155 of the NPPF which states:

“Early and meaningful engagement and collaboration with neighbourhoods, local

organisations and businesses is essential A wide section of the community should be proactively engaged, so that Local Plans, as far as possible, reflect a collective vision and a set of agreed priorities for the sustainable development of the area, including those

contained in any neighbourhood plans that have been made.”

1.5 Aside from demonstrating compliance with the aforementioned Regulations this statement also highlights how AVDC has met the requirements of paragraph 155 of the NPPF and the Statement of Community Involvement (SCI) (November 2013 update)

Stages in preparing the VALP

1.6 The specific stages in the plan preparation are set out below in Table 1

Table 1: Stages of engagement in the production of the Vale of Aylesbury Local Plan 1

2 April – 28 May 2014 An 8-week Scoping (Regulation 18)

Consultation was undertaken asking respondents to tell us if the

proposed scope for the plan was correct, and if anything should not

be included or was missing Around 250 responses were received at

this stage Forums for communities, stakeholders and developers

were held in late 2014 to share initial findings of the evidence A

‘Call For Sites’ was commenced inviting the submission of sites that

would be considered in the technical evidence to inform the VALP

site allocations and overall growth capacity

8

From 23 October- 4 December 2015, we published a VALP Issues and

Options document with a draft evidence base for comment A Draft

Housing and Economic Development Needs Assessment (HEDNA)

and Housing and Economic Land Availability Assessment (HELAA)

evidence studies were published, along with other evidence to

support the VALP Issues and Options As part of this, exhibitions

were held at key larger settlements in the district The total number

of respondents was 771, providing 4,480 individual responses to the

questions A summary report of the issues raised is available at:

On 7 July- 5 September 2016 we published the next stage of the plan,

the VALP Draft Plan, for 8 weeks consultation, including Policy Map

Insets with a suite of supporting documents This stage of the plan

included a developed preferred spatial strategy, fully written policies

and proposed allocations This engagement was accompanied by a

series of exhibitions and a report of comments received has been

published Please see:

http://www.aylesburyvaledc.gov.uk/vale-aylesbury-local-plan-draft-plan More than 1,600 responses,

comprising over 5,000 comments, were received After this time,

various evidence documents to inform the next stage of plan making

were commissioned or finalised and published when completed

8

During 2017, further evidence to inform the VALP Proposed

Submission stage was completed to inform the Proposed Submission

Plan including a Sustainability Appraisal, Habitats Regulation

6

1

Please note that as well as the stages outlined in table 1.0 there was also regular and on going dialogue

with key stakeholders including adjoining authorities (please see the Duty to Cooperate Statement of

Compliance (November 2017) for more information)

Assessment, transport, viability, landscape, open space/sports,

cumulative impact assessment for Aylesbury and an updated

Housing and Employment Land Availability Assessment The VALP

Proposed Submission was agreed by full Council on 18 October 2017

The plan was published for a final period of public comment prior to

being submitted to Government for independent examination This

took place over a six week period, from 2 November 2017 until 14

December 2017

988 responses, comprising 2441 comments, were received On the

penultimate day of the Regulation 19 consultation, it became

apparent that an earlier draft version of the Plan could be accessed

online through the Council’s website This was the case even though

the main VALP consultation page – to which the vast majority of

respondents referred – contained the links to the most up to date

draft The responses which referred to the older draft were

identified, 6 in total, and carefully reviewed The Council’s view was

that none of these 6 consultees had been prejudiced by referring to a

previous draft However, in an abundance of caution these 6

consultees were notified and given an extended deadline of 15

January 2018 to submit any amended or further representations on

the changed elements of the Plan which were minor in nature

Further checking during the processing of representations at the

start of 2018 identified a further three responses which referred to

the older draft of the Plan As before, consideration was given to

whether these consultees had been prejudiced as a result of this but

the Council concluded that this was not the case Nonetheless, the

three respondents in question were contacted and given an

extended deadline (13 working days as with the previous group) to

submit amended or further representations on the changed

elements of the Plan

TOTAL WEEKS CONSULTA TION

28

1.7 The above table shows how we have fully complied with the requirements in the

Regulations in terms of consulting on the content of the emerging VALP Views collected in

response to our 2013 consultation on the withdrawn Vale of Aylesbury Plan (VAP) were

also fed into the VALP options consultation October-December 2015 Since the formal

commencement of work on the VALP, a comprehensive evidence base has been developed

upon which policies and proposals within the emerging VALP have been founded and there

has also been extensive engagement with local communities and stakeholders at various

key stages

1.8 Throughout the preparation of the VALP, the Council considers it has succeeded in

front-loading consultation as far as possible by continuously engaging with local communities,

businesses and stakeholders An example of this is the ‘Call For Sites’ which continues to

provide the opportunity to submit sites for consideration in the next stage of plan making

There is also ongoing engagement with key stakeholders including Buckinghamshire County Council on evidence base documents and neighbouring councils (see Duty to Co-operate Statement of Compliance)

Statement of Community Involvement (SCI)

1.9 The 2013 adopted Statement of Community Involvement (SCI) contains information on how the Council will consult on the different aspects of planning in planning policy and development management terms This is in accordance with the legal requirements set out

in the Planning Acts2 and Regulations3 The purpose of the SCI is to show how and when community engagement will take place for planning and development The SCI identifies the key groups that the Council consults with, the underlying intention being to engage with anyone who has an interest in the future of the District as a place to live, work or visit

1.10 The Town and Country Planning (Local Planning) (England) (Regulations 2012) prescribe a series of ‘Specific and General Consultation Bodies’ that the Council has to consult with during each consultation stage Below are the groups of specific and general consultation bodies Appendix C outlines the specific organisations and other bodies that the Council considers to have an interest in the preparation of planning documents within Aylesbury Vale

Specific Consultees

● National, regional and local government

● Parish and town councils

● Statutory bodies and groups e.g the environment agency and English Heritage

● Emergency services

● Adjoining planning authorities

● Utility companies e.g Water and electric companies

● National Health Service bodies

● Internal council groups including members and officers

General Consultees

● National organisations e.g the National Trust

● Local organisations and societies e.g residents associations

● Businesses and economic groups e.g Bucks Thames Valley Local Enterprise Partnership

● Environmental groups e.g Bucks & Oxon Wildlife Trust

● ‘Hard to reach’ groups

Other Consultees

● Individuals

● Housebuilders / Agents / Landowners / Housing Associations

● Schools / youth groups e.g Aylesbury Youth Action

1.11 The Council maintains a database of these specific and general consultation bodies

together with local organisations and individuals that have expressed an interest in being consulted on or kept informed of the development of planning policy The database is live and continuously updated The database includes all those listed as specific and general consultation bodies and others including those listed in Appendix C

2

Those referred to are the Town and Country Planning (Local Planning) (England) Regulations 2012;

Planning and Compulsory Purchase Act 2004; Town and Country Planning Act 1990; and

The Town and Country Planning (Development Management Procedure) (England) Order 2010

3

Neighbourhood Planning (General) Regulations 2012.

1.12 The SCI was adopted in 2013 and sets out methods of consultation for formal consultation stages including:

● Circulating material by email or letter

● Making information available on the website

1.13 This submission consultation statement sets out how the Council have met the

requirements of the adopted SCI for the preparation of the VALP For more detail on each

of the requirements of the SCI and how these have been addressed is shown in Table 2 1.14 As well as consultation on the VALP policy document, there has also been consultation on

the evidence base and supporting documents Specifically there has been consultation on the Sustainability Appraisal (SA) and on going dialogue with key stakeholders as part of the Duty to Cooperate

Sustainability Appraisal (SA)

1.15 The SA is an iterative process and there have been various stages throughout the

preparation of the plan The iterations of SA are listed below All stages, and the key

findings, are summarised in the final SA Report which is published alongside the Proposed

Submission VALP

Sustainability Appraisal Date Completed/

Consultation Held

Information that was appraised

SA Scoping Report September 2015

Published for consultation with VALP Issues and Options, October

2015

Baseline information for Aylesbury Vale This Scoping Report has been prepared as the first stage of the SA process in order to inform the environmental assessment of the plan This report was published for consultation with the

consultation bodies as required by Regulation 12 (5) of the UK SEA Regulations 2004

Reasonable Alternatives

SA Report

October 2015

Published for consultation with VALP Issues and Options, October

2015

This report assesses the reasonable alternatives stage of plan-making, also known as ‘options’ AVDC has considered a range of different sites and policies for development within the Vale of Aylesbury This SA Report document represents a

SA of the reasonable alternatives for strategic spatial sites identified by AVDC

Assessment of

Reasonable Alternatives

July 2016

Published for consultation with VALP Draft Plan July 2016

This report concentrates on the high level assessment of reasonable alternatives being considered as part of the planned consultation on the local plan This document does not constitute

an Environmental Report in line with the SEA Directive, it is a record of assessments of

reasonable alternatives (options) for housing and mixed-use housing and employment sites in Aylesbury Vale (Aylesbury)

Proposed Submission November 2017

This report is the VALP SA Report In line with the Regulations, a report (known as the SA Report) must be published for consultation alongside the draft plan that essentially ‘identifies, describes and evaluates’ the likely significant effects of

implementing ‘the plan, and reasonable alternatives’ The report has been taken into account, alongside consultation responses, when finalising the plan

https://www.aylesburyvaledc.gov.uk/sustainability-appraisal-sa

Evidence Base

1.16 As well as consultation on the VALP document, there has also been consultation on the

evidence base and supporting documents Specifically there has been consultation with technical experts on the following:

● HELAA: through steering group (versions 1, 2) and Buckinghamshire County Council

● HEDNA: consulted all adjoining districts and districts in the housing market area;

● The SFRA and Water Cycle Strategy: consulted Buckinghamshire County Council, the

Environment Agency, Anglian Water, Thames Water and Bedford Group of Internal

Drainage Boards

● The Habitat Regulations Assessment: consulted Natural England

● The SA scoping report: consulted the Environment Agency, Natural England and

Historic England

● Countywide Traffic Modelling reports in 2017 for Aylesbury and Buckingham jointly

prepared with Buckinghamshire County Council (the Highways Authority): consulted

Aylesbury Vale Advantage and Buckingham Town Council

● Aylesbury and Buckingham transport strategies: consulted with AVDC and

Buckinghamshire County Council

● County-wide Green Belt Review: prepared with other Buckinghamshire district councils and consulted BCC

● Bucks Gypsy and Travellers and Travelling Showpeople Accommodation Assessment: prepared with other Buckinghamshire district councils

● Infrastructure Delivery Plan: consulted with Buckinghamshire County Council, Clinical Commissioning Group, utility companies, water companies, power networks, Local

Enterprise Partnerships

1.17 As well as the consultation stages outlined in this document, there has been on-going

dialogue between a number of stakeholders as part of the Duty to Cooperate Further

detail about this is contained within the Duty to Cooperate Statement of Compliance

2 Scope of the Plan -2014 (Regulation 18)

Public engagement on Scope of the Plan, 2014

2.1 The consultation ran from 2 April until 28 May 2014 This was a first part of meeting

the Regulation 18 requirements on engaging on a local plan The emphasis was to mark the commencement of preparing a new plan and get frontloaded input from

communities and stakeholders before evidence was collected and issues and options generated

2.2 There were four questions asked in this consultation:

 Are all of the policy topic areas listed in the consultation document appropriate for inclusion? (if not, please say why and where else they should be covered)

 Is there anything missing from the list that should be included within VALP? (please specify)

 Do you have any specific suggestions about what the strategy or policies should contain? (please provide as much detail as possible)

 Do you have any other comments?

2.3 In addition a ‘Call For Sites’ pro forma (form) was published inviting sites to be

submitted

2.4 These particular questions were asked in order to help the Council identify the key

issues in relation to plan making, and develop options, growth ranges, what kinds of development should be provided for in the plan, what infrastructure is needed and any other matters

2.5 The following documents were produced to support the public consultation:

• Scoping Consultation (Regulation 18) - Consultation Document

• Scoping Consultation (Regulation 18) - Comments Form

• Call for Sites – Consultation Document and Sites Pro forma

Bodies and persons invited to make representations

2.6 Appendix C , the consultation list, includes the general and specific bodies who were

consulted at this stage Individuals have not been listed

How bodies and persons were invited to make representations

2.7 A consultation document and comment form was published and distributed with a letter

to individuals and stakeholders already on the Council’s database of people who had previously commented during the plan making process or who had expressed an interest

in the VALP The consultation material was also made available on our website, at council offices, libraries and area offices, in conformity with the SCI

2.8 The following methods were available at the is stage of consulting on the plan

Comments could be submitted in a number of ways:

• Electronically via Survey Monkey: https://www.surveymonkey.com/s/VALP-Scoping

• Emailed to: VALPconsult@aylesburyvaledc.gov.uk

• Posted to: Planning Policy, AVDC, The Gateway, Gatehouse Road, Aylesbury, Bucks, HP19 8FF, DX 4130 Aylesbury 1

2.9 Other methods of publicity were:

● VALP Newsletter – 31 March 2014

● Use of the Council’s website – website changes 26 March 2014, 1 April 2014

● Weekly ‘Bulletin’ sent to all parish and town councils – weekly throughout 2014

● Press release (2) - 7 April 2014 and 24 May 2014

Summary of the main issues identified

2.10 A detailed summary of the issues raised by organisations was made available at

https://www.aylesburyvaledc.gov.uk/vale-aylesbury-local-plan-scoping-consultation

2.11 The following are some of the main points raised:

 Where specific site allocations have not been included in the Plan it will be

necessary to provide a basis for Neighbourhood Plans and development management decisions

 The Spatial Strategy should be supported by a transport / traffic modelling

assessment that takes into account development in neighbouring areas

 A number of authorities may not be able to accommodate all of their identified housing needs and may be looking to Aylesbury Vale to accommodate some additional growth Recognising that Aylesbury Vale forms part of a wider Housing Market Area that is not confined to its own administrative boundary, it is crucial that AVDC seeks to work with neighbouring authorities such as Milton Keynes from the outset, to gain a full understanding of housing needs

 Self build opportunities should be included

 Would like confirmation that infrastructure including roads, rail, schools and hospitals will be provided early in any development It should follow population by families and business A plan for the plan would be most helpful

 There should also be the opportunity at this stage of the process to identify sites that should not be developed: e.g to preserve open space(s) in settlements; to prevent coalescence between settlements; to preserve a locally cherished view or area of ecological value that might not be otherwise designated

 There is no reference in the scope to biodiversity, green infrastructure or

landscape issues Planning policies should therefore encourage, as best practice, communication with and consultation of the Buckinghamshire Local Nature Partnership in order to identify and promote coherent ecological networks across Aylesbury Vale Planning policies should therefore set a framework for the clear recording and reporting on measures to be taken for the positive management of networks of biodiversity The spatial strategy is currently limited and needs to be expanded to make specific reference to the influence of key settlements in neighbouring authorities such as Milton Keynes The currently proposed focus of the strategy on Aylesbury and Buckingham would potentially limit the scope to achieve development in other sustainable locations within the district

 The VALP should be positively prepared in accordance with the guidance in the NPPF and policies should provide clear guidance as to the level and location of future growth for the area There should be a clear policy outlining how the development on specific sites should come forward to help secure the sustainability aspirations of the Council

2.12 40 responses were received via the Survey Monkey questionnaire, and around 200

responses were received via email and post

2.13 In terms of neighbouring authorities, we received responses from Wycombe District who

sent a fairly high level response stating they were happy with overall scope and need to work with them on the VALP; Bedford Borough provided a similar high level response; Luton gave a more detailed response drawing our attention to what they had done so far and that they would be likely to look to us to help meet growth needs; Central

Bedfordshire Council had no comments but thanked us for consulting them; South Bucks commented that we need to allocate more housing and work together on the Duty to Co-operate

2.14 We had around 150 developer-promoted sites received at the ‘Scope of the Plan’

consultation stage Developer responses and sites promoted are set out at

https://www.aylesburyvaledc.gov.uk/vale-aylesbury-local-plan-call-sites-consultation) but are summarised in the following paragraphs

2.15 A number of large sites were promoted around Milton Keynes including land East of

Whaddon, Salden Chase, land north of Newton Longville (and all around the north of the village) and a site east of Newton Longville, as well as Eaton Leys A large extension called Shenley Park was also promoted at this stage

2.16 At Winslow, a number of sites have been submitted including Verney Road and Land off

Little Horwood Road

2.17 At Buckingham – a large site to the south land adjacent to the industrial estate, Land off

Osier Way, Land between the A421 and Tingewick Road, and south of Tingewick Road 2.18 At Aylesbury – Fleet Marston, Land East of Weedon Hill, Land north of Watermead,

Berryfields East, Land between Stoke Mandeville and Walton Court/Southcourt, and the whole of south-west Aylesbury, Hampden Fields and a separate submission from the Weston Turville golf course, and a smaller site off Broughton Lane We also had the land between A41 and the canal (Aylesbury East) and a further extension of Aylesbury East closer to the A41 roundabout/Aston Clinton

How the issued raised have been addressed

2.19 In terms of how the issues raised have been addressed, this is in essence led to the Council

commissioning further evidence which was required in order to help the development of formal issues and specific options that could be consulted on at a next stage The key areas were:

 All Call for Sites submission fed into the first two versions of the HELAA (Housing and Economic Land Availability Assessment)

 The Call for Sites process would continue outside the formal consultation period to allow the ongoing submission of new sites and updated information on existing sites

 A new HEDNA (Housing and Economic Development Needs Assessment) was

prepared for an agreed Housing Market Area and methodology covering ‘Central Buckinghamshire’ This was Aylesbury Vale, Wycombe and Chiltern districts

 A report was commissioned to review the evidence base documents Aylesbury Vale Landscape Character Assessment and Aylesbury Vale Areas of Sensitive Landscapes

to see if having such evidence would comply with the NPPF

3 Issues and Options - 2015

(Regulation 18)

Stakeholder Forums prior to Public Consultation, 11, 12 November 2015

3.1 The formal public consultation was preceded by stakeholder forums All district members

were invited to an event on 11 November whilst all parish and town councils were invited

to send a representative to an event on 12 November 2015

12 November 2015 Parish Forum - How bodies and persons were invited to make

comments

3.2 An officer presentation shared information on the emerging Housing and Economic

Development Needs Assessment evidence, emerging work on constraints reviews and initial stages of the Housing and Economic Development Land Availability Assessment, development management policies and forward timetable There was then a question and answer session where those attending could raise queries and comments, these were all noted down along with the answers provided Some feedback was also provided after the event to specific questions

3.3 There was also a facilitated table discussion which centred around the draft plan aims and

the draft approach to employment Each table again had roughly 6-8 people in the

discussion and an officer leading who was taking notes on comments made The

discussion at the table and any questions asked were circulated in a feedback note sent out to those who attended

3.4 An email was sent to all parish and town councils on 12 October 2015 notifying and

briefing on the publication of an emerging evidence base for the VALP These were draft reports and comments were invited on their content and factual accuracy alongside the Vale of Aylesbury Local Plan Issues and Options consultation which closed on 4 December

2015 The reports were:

• Draft Housing and Economic Development Land Availability Assessment

• Draft Settlement Hierarchy Assessment for the Vale of Aylesbury Local Plan

• Draft Review of Areas of Attractive Landscape and Local Landscape Areas

3.5 The Issues and Options Consultation, as well as shaping the emerging options for high

level policies about development numbers and distribution, also shaped the vision for how the district will be and the ‘sense of place’ hoped to be achieved through the plan This was an issue raised particularly by parishes at the community view stage (during VALP Strategy, 2011) but also through comments made by technical stakeholders amongst their comments on other issues We have addressed these issues in the overall vision of the plan, which has then informed the strategic objectives and subsequently the VALP policies

in a ‘golden thread’

Public Exhibitions – November 2015

3.6 Public exhibitions were held as follows:

3.7 The feedback received at the exhibitions in the form of post-its following discussions with

individual officers has been published at aylesbury-local-plan-%E2%80%93-issues-and-options-consultation

https://www.aylesburyvaledc.gov.uk/vale-3.8 The panels displayed at the exhibitions are available to download at

options-consultation

https://www.aylesburyvaledc.gov.uk/vale-aylesbury-local-plan-%E2%80%93-issues-and-Issues and Options Public Consultation

3.9 This ran from 23 October to 4 December 2015 (6 weeks)

Publicity

3.10 A letter was emailed or posted on 23 October 2015 to all statutory consultees and active

consultees on our mailing list Letters included a web link to the consultation documents and how to respond An emailed letter was used where there was an email address, otherwise a printed and posted paper letter was relied on See Appendix C for who was contacted by emailed letter or posted letter on this public consultation, in accordance with our adopted SCI

3.11 The consultation was also advertised on the Council website for the whole consultation

period

3.12 A press release was issued to the media on 8 October 2015

3.13 A Summary Leaflet and Poster were produced and a display was maintained at the AVDC

Gateway offices from 23 October to 4 December when the consultation ended The leaflet and poster were also used at all exhibitions to advertise on the day of the exhibition

3.14 The primary consultation documents published as PDF documents on the Council website

were the VALP Issues and Options Consultation Document and Issues and Options

Comment Form

Consultation Questions

3.15 13 questions were asked; some were “yes” or “no” questions with detailed comments;

some were tick box answers from a range of options Some questions stated the

conclusion from the evidence base but for all questions there was the opportunity to suggest alternatives, for example a different settlement hierarchy to the one in the

published settlement hierarchy evidence paper

Methods of Feedback

3.16 We received feedback by the following methods:

 a ‘Survey Monkey’ questionnaire was the Council’s preferred method of

feedback

 email

 material sent in writing to AVDC at the Gateway offices

The Response

3.17 The total number of respondents was 771, providing 4,480 individual responses to the

questions There were also a number of new sites promoted to the Council and further information on sites that had already been promoted to the Council

Summary of the main issues identified

3.18 A detailed summary (319 pages) of the issues raised by organisations was made available

at and-options-consultation

https://www.aylesburyvaledc.gov.uk/vale-aylesbury-local-plan-%E2%80%93-issues-3.19 There was also a published summary of responses from neighbouring councils and from

utility companies

https://www.aylesburyvaledc.gov.uk/vale-aylesbury-local-plan-%E2%80%93-issues-and-options-consultation These responses informed the situation for the purposes of the Duty to Co-operate for ongoing engagement and also infrastructure planning

3.20 In terms of the overall issues raised, responses largely focused on the amount of housing

being proposed and the role of unmet need in that figure The main response was that the number should be lower without any unmet need However some responses suggested that any unmet need from the south of the county should not be accommodated in the north of Aylesbury Vale There were a number of comments on the content of the Housing and Economic Development Needs Assessment which were passed on to the Council’s consultants

3.21 There were also a significant number of comments on the implications for growth in the

villages from the Settlement Hierarchy Some considered the Settlement Hierarchy needed

a major revamp, with its assertions outdated and unsophisticated Some respondents considered it inappropriate to define 31 villages of hugely different populations and

facilities all as 'large' Eight have populations in excess of 2,000; six have less than 800 There are over 100 villages within rural areas, providing rich heritage that needs

protecting for future generations

3.22 In meeting the Duty to Co-operate it is important that the comments of adjacent

authorities are given particular consideration Aylesbury Vale is a potential location for unmet need from several adjacent Council areas and this formed a significant part of the response at the Issues and Options stage The responses recognised that the figure for unmet need is subject to confirmation from the respective authorities and so following review of those authorities’ constraints and supply, the need figure could change The NPPF states that plans should be based on a strategy which seeks to meet development needs, “including unmet requirements from neighbouring authorities where it is

reasonable to do so and consistent with achieving sustainable development”

3.23 Buckinghamshire County Council made significant comments in response to the Issues and

Options consultation and the responses to the questions are set out in Appendix 3 to the

11 May 2016 VALP Scrutiny Committee Broadly, the County Council considered that the overall strategy should be reconsidered to direct more development away from the smaller settlements to Buckingham and the southern part of Aylesbury Vale, and that Haddenham could be a location for a new settlement The County Council stated it

fundamentally disagreed with a blanket assumption of an expansion of all larger villages and smaller villages; it considered that any village expansion should be on merit and considered on a case by case basis

How the issued raised have been addressed

3.24 The issues raised were reported to the VALP Scrutiny Committees (11 May, November 7

2016) along with information about what was to happen next This included the collation

of further or revised evidence and formulating policy in response to all of the following: new evidence, the representations, views of Members at the intervening meetings, updated events such as new household projections or planning decisions on sites or neighbourhood plan progress

3.25 In terms of how specific issues have been raised:

 A new Buckinghamshire HEDNA (Housing and Economic Development Needs

Assessment) was prepared, including South Buckinghamshire District Council and a draft report was published in January 2016 Further reports followed in 2016

 The settlement hierarchy was revised in 2016 and a new category ‘Medium Villages’ was created taking in some of those previously classified as ‘Large’

 A new settlement option for distributing growth was considered further with a New Settlement Scoping Study commissioned and ultimately published in summer 2016

 Further HELAA (Housing and Economic Land Availability Assessment) work took place with a ‘version 3’ report finding capacity at Medium and Smaller villages

 It was acknowledged in the consultation for the forthcoming Draft Plan that

infrastructure remained an evidence gap which would be filled once comments on the Draft Plan had been received

4 VALP Draft Plan - 2016

‘News For Parishes’ July 2016

4.1 The formal public consultation was accompanied by a request from AVDC for each parish

and town council website to display a statement ‘News for Parishes’ of publicity provided

by AVDC explaining the public consultation

4.2 There was an advertisement on mix 96 radio station on 3 June 2016

and-a-brand-new-town/

https://www.mix96.co.uk/news/local/2004421/33000-new-homes-for-aylesbury-vale-Parish and Town Council Presentation/Information session, July 2016

4.3 On 13 July 2016 an engagement event took place with parish and town councils held at

Aylesbury Gateway All parish and town councils were invited to send a representative; 67 people attended

4.4 An officer presentation shared information on progress of preparing the plan, the findings

of further evidence including the HEDNA, HELAA and green belt review and, the

application to make Aylesbury a Garden Town A key area discussed in both the

presentation and question and answers was what the emerging Draft Plan housing target and settlement hierarchy meant for individual settlements/parishes and neighbourhood plans in preparation

Draft Plan Public Consultation

4.5 From 7 July to 5 September 2016, consultation took place on the Vale of Aylesbury Draft

Plan

Publicity

4.6 See Appendix C for who was contacted by emailed letter or posted letter on 6 July 2016 on

this public consultation, in accordance with our adopted SCI

4.7 The Council webpages were changed for 7 July 2016 displaying:

 the consultation document – the Draft Plan

 new and updated evidence base documents including the Sustainability Appraisal

 information about how to comment – the online comment form, how to write to the Council and email us

 exhibitions to come and see displayed consultation material including the plan itself, talk to officers, make representations

4.8 A press release was made on 7 July 2016 notifying and briefing the media on the start of

the public consultation period on the Draft Plan and the exhibitions that will take place

4.9 80,000 VALP Summary Leaflets were distributed in the 'Change of bin collections days'

mailed to households a month in advance of the consultation starting, and displayed at Commercial AVDC roadshows and parishes where additional exhibitions were held 4.10 45 posters were printed and displayed in car parks, community centres and libraries 4 e-

bulletins were sent to 30,000 residents 1 tweet announced the consultation on 7 July

2016

4.11 The consultation documents including evidence base were made available electronically

on a memory stick, available on request either given at exhibition or posted

Exhibitions – July to September 2016

4.12 Exhibitions included static displays at locations including the AVDC Office at The Gateway,

Aylesbury and the swimming pools at Aylesbury and Buckingham, and a roadshow of manned interactive exhibitions around the Vale over the summer:

Manned Exhibition

Roadshow

Haddenham Village Hall Social Centre 11 July 11am-8pm

Buckingham Community Centre 13 July 11am-8pm

Aylesbury Friar’s Square Shopping

Centre

14 July 10am-5pm

Newton Longville Village Hall, 2 Paradise 27 July 10:30am-7.30pm

Wendover St Anne’s Hall 4 August 11am-8pm

Aylesbury Friar’s Square Shopping

Centre

5 August 10am-5pm

Whaddon Jubilee Hall 8 August 4pm-8pm

Winslow Public Hall 10 August 10am-8pm

Aylesbury AVDC Office, The Gateway 11 August 4pm-8pm

Weedon Bucks County Show 1 September

8.30am-4.30pm 4.13 There was an estimated average turnout of over 350 visitors per manned exhibition event

Consultation Questions

4.14 There were no specific consultation questions this time – it was simply inviting comments

on the VALP Draft Plan and supporting evidence

The Response

4.15 More than 1,600 responses were received, comprising over 5,000 comments

Summary of the main issues identified

4.16 A summary report (57 pages) of the response and the actual response content received

has been published at https://www.aylesburyvaledc.gov.uk/valp-previous-consultations

Set out below is an overview of key themes and issues raised by respondents in their responses to the Vale of Aylesbury Draft Local Plan consultation summer 2016 This is based on a extract from a summary report currently being drafted, therefore, the contents should be treated as provisional, incomplete, and may be subject to change in the final report The following is an extract of that report on the identified issues raised:

Housing Need and Housing

4.17 Direct or indirect reference to the need for Housing was included in almost all responses

The majority of respondents focussed on the 33,000 housing units’ requirement,

questioning this figure, with the general public objecting to the volumes and development bodies suggesting the figures could be too low, particularly with reference to specific land allocations

4.18 There was a marked dislike for the AVDC area potentially picking up unmet housing need

from neighbouring districts In particular it was strongly perceived that High Wycombe, was planning to allocate its own needs into the AVDC area Respondents strongly agreed with statements in the VALP that AVDC will resist actions of this nature

4.19 The volume of housing proposed influenced the discussion (as a cause) of the following

issues below Many respondents were concerned that the proposed housing volume will fundamentally alter the character of the existing villages and communities and result in

‘infilling’ development throughout the area Another concern is that the increase will mainly serve for an increase in demand for housing from London and other areas resulting

in an increase in commuting and would not serve the needs of existing communities 4.20 A minority of respondents brought up the issue of Brexit and its potential impact on future

housing needs for the area not being sufficiently incorporated into the VALP

Transportation Infrastructure

4.21 This concern went ‘hand-in-glove’ with the concern over housing volume Respondents

noted that the proposed housing allocations will impact the ability of the current

infrastructure to handle additional demand and questioned the ability of the existing systems to absorb this increase Respondents questioned that recent traffic modelling and planning had either allowed for the VALP proposals, or that the VALP had adequately considered this issue in its planning stage The majority concern was for regional traffic (vehicular) although the upgrading of rail infrastructure and cycle routes were also

frequently mentioned

4.22 Traffic increase, with its attendant impacts on air quality, noise and community safety

(particularly around schools) was of concern to respondents The impact of traffic

volumes and mix on village roads and main feeder routes was seen to be an important issue including the impact on journey times into Aylesbury at peak times

4.23 A minority of respondents linked the requirement for transportation infrastructure in the

VALP with HS2 development and suggested that cumulative impacts required further investigation

4.24 Respondents were concerned that the proposed housing volumes would create significant

strain on the area’s infrastructure in general terms This includes the built environment, in addition to transportation infrastructure, (transportation infrastructure was often

mentioned as a separate concern) Respondents would have greater comfort in the VALP

if an infrastructure plan was available which took account of or incorporated the VALP proposals Respondents were not convinced that the infrastructure, as exists currently, would be able to handle significant increases in capacity and use

Transport

4.25 The concern of transport provision and capacity was highlighted as a separate concern to

the transportation infrastructure per se The capacity of bus route connectivity to main centres such as Aylesbury was a concern as well as access to the proposed rail

developments in the area

Services

4.26 With regard to the provision of services, social and structural to support the influx of

proposed new household levels, respondents were concerned that the current services (health, doctors, hospitals, schools, shops and pubs) would be overwhelmed by demand resulting in lower levels of access for current residents and loss of amenity Access to Doctors and GPs was a key concern along with education provision and availability of school places for the children and young people in the area

Conservation

4.27 This concern was strongly tied in to the possible impacts of development and change, to

the existing community infrastructure and character, surrounding landscapes and a worry that development will ‘infill’ areas destroying the Character of the area Respondents were protective of what assets they perceive their area already possesses and are

concerned that these will be lost under the VALP proposals

Affordable Homes

4.28 The need for affordable homes was raised by many respondents, who strongly agreed

with the VALP proposals on requirements for affordable housing A concern is that the provision for this in the VALP will not prove to be strong enough, or enforced, resulting in local residents being ‘priced out’ of their communities by the external demand This was a cross generational concern from current residents

Settlement characterisation

4.29 This was raised by respondents who disputed the community/village classifications in the

Settlement Hierarchy which informed the VALP and which, it was felt, opened up

communities to receiving larger development allocations All the general public

respondents who made a statement in this category felt that their community had been overstated, and therefore required the VALP to review this issue

Consultation Process

4.30 The VALP consultation process itself was raised by respondents as a concern There were

three main areas of concern The first was the form itself Many respondents stated that they found it confusing and difficult to use The second concern was the timing of the consultation process, which, having occurred over the summer period, was seen as a holiday period which made it more difficult for those respondents to fully assimilate the information and participate in the process A number of respondents who had

participated in a presentational event stated that they found the materials available insufficient to properly understand the potential impacts on their local area

Neighbourhood Plans

4.31 Respondents questioned how the recently agreed and approved Neighbourhood Plans

(NPs) had, or had not, been taken into consideration into the VALP process NPs were widely seen to have reflected local community needs and agreements and many

respondents were concerned that this process had apparently been superseded by the VALP, with minimal cross fertilisation from the NPs This had the potential to disillusion participants with the local democratic processes

Agricultural Land

4.32 Respondents concerns were related to general conservation issues, with respondents

stating that it was undesirable that agricultural land should be used for housing

development

Employment

4.33 Respondents were concerned that the increase in household volumes would not be

supported by an increase in employment opportunities in the area, and that the result would be an increase in out of area commuting and additional social strains, potentially on the current residents for employment access

VALP Plan

4.34 Many respondents were positive for the VALP plan, seeing it as a statement of Aspiration

for the area, as well as proof that a range of key issues and positions had been considered

in the regional planning process However, these respondents also recognised that the delivery of the VALP will determine the success of the plan and most were concerned that this would not match the principles and approaches espoused in the VALP documentation Consequently the VALP was seen as a ‘positive step’ not necessarily the final answer These respondents outnumbered those who rejected the VALP plan as a cynical and unrepresentative process aiming to foist development on the region

4.35 Many of the Developer/landowner submissions questioned whether national Planning

guidelines had been followed and approaches to the VALP process suggesting that the VALP was unnecessarily restrictive in its approach to site allocation and density

4.36 This was a general response, mainly from neighbouring Authorities, as a statement of

recognising (and endorsing) the need for co-operation across District and Borough lines and to the wider area of potential influence Individual respondents tended to see co-operation as a mechanism to minimise the allocation of unmet demand from surrounding areas into the VALP area

Environment

4.37 A minority of respondents focussed on the environmental impacts of the proposed

development plans as a key concern, for biodiversity, water quality and habitat protection

It was referenced more widely by the site development responses which referred to site specific studies which concluded minimal impacts for the proposed developments

Development Management Policies

4.38 The draft local plan included a full suite of development management policies for

consultation They did not carry any weight at present and could be revised prior to

submission including to ensure consistency with any new Government planning policy requirements This would include the new starter homes requirement which had just received Royal Assent

The following policies were noted as being of particular interest:-

 Affordable Housing Policy (S6) – this would require 31% affordable housing

 The County Council’s parking standards (T1)

 Policies to protect town and village centres (D10), and

 The inclusion of an overall design policy (BE2)

Call For Sites – Updated position, July 2016

4.39 The Call For Sites webpage (which began at the end of the ‘Scope of the Plan’ consultation

with those sites submitted and was kept updated periodically with new sites thereafter) was updated on 6 July 2016 with the following text The text included a link to a summary report with all the basic information of the sites promoted, a set of location maps

showing the location of all the sites and a ‘Call For Sites’ form to send in more sites So as

at 6 July 2016, we had 407 sites promoted under the ‘Call For Sites’ process and those received at the Draft Plan would be added to those numbers Due to other work

commitments, the Call For Sites summary report and maps were not updated after 6 July

2016, but all sites submitted during 2016 up to the end of the Draft Plan consultation period were assessed in the HELAA study of capacity and maps and site details shown in that report

4.40 The following text is from the Council’s webpage summarising the position on received

Call For Sites promotions as at July 2016

In spring 2014, we carried out a Call for Sites consultation We asked developers and

landowners to promote sites, for any use, to be considered in the Vale of Aylesbury Local Plan (VALP) Sites submitted up to 5 September 2016 were included in HELAA version 4 Sites

submitted after this time will be included in future reviews of the Plan after its adoption

There are currently 407 sites promoted as of 6 July 2016 The sites promoted do not indicate where we think future development should be they are just the views of site promoters Planning applications will continue to be determined in line with the adopted Vale of Aylesbury Local Plan (2004) policies until they are replaced by the VALP

The following summary report (6 July 2016) of Call for Sites submissions sets out key

information for all sites

To submit a site, please complete the following form

How the issued raised have been addressed

4.19 The issues raised were reported to a VALP Scrutiny Committee (7 November 2016) and

also what was to happen next This included the gathering of further or revised evidence, and the formulation of policy in response to all of the following: new evidence, the

representations, views of Members at the intervening meetings, updated events such as new household projections or planning decisions on sites or neighbourhood plan progress Table 3 to this consultation statement sets out the main issues and a council response as work proceeded towards the Proposed Submission plan

Website statement - December 2016

4.20 Changes to the VALP forward timetable and a likely reduction in housing numbers and a

new capacity approach for the villages were advertised on the Council website in

December 2016 as follows:

Changes to the Draft Vale of Aylesbury Local Plan 2016/17

The timetable for preparing the Vale of Aylesbury Local Plan (VALP) was extended to ensure that all essential evidence was in place before we submitted it for examination

The key reason for the delay was due to the complexity of the Sustainability Appraisal (carried out

by external consultants) and the task taking longer than predicted as a result This is a critical piece

of evidence which has to feed into the content of the Plan and, as such, we had to ensure there was sufficient time for this to be done thoroughly and to enable its findings to be taken into account There were a number of significant changes to the context of the Draft Plan after it was published in summer 2016, including:

 The total number of houses we needed to plan for was reduced from 33,000 to around 27,000 due to an update to our housing requirements and other districts finding more capacity

 As a result of the reduction in our housing figures, we suggested that the consideration of a new settlement should be deferred until we know the route of the Oxford-Cambridge Expressway

 We moved away from the proposed percentage approach to apportioning development to

settlements, and instead used a capacity-led approach Please see the following The changes are set out in more detail in the December 2016 VALP Scrutiny Committee minutes

VALP Progress Updates - April 2017

4.21 On 7 April 2017, a ‘Submission Draft Update’ was published on the Council website to

update on a short delay to the timetable towards Proposed Submission to allow for the completion of further evidence gathering to be completed (particularly Transport

evidence, the Sustainability Appraisal, SFRA Level 2 and Sequential Test on Flood risk) and

to be able to take account of the findings of those studies On 21 April 2017 an

Explanatory Note was published on the Council’s website to explain the changing

approach being considered for the VALP to determining the level of development in the villages as a number of queries have been raised as to how the approach will apply to those areas currently preparing neighbourhood plans

May 2017 Re-consultation

4.22 As part of our process of continuous quality checking, it came to our attention that some local plan consultees may not have received specifically addressed communication at the time the draft VALP was published for consultation In order to ensure that everyone who may have wished to comment on the draft plan was able to do so, we wrote to these consultees to invite them to make comments if they had not already done so This was done via email for those consultees who had provided an email address, and by letter to those who had only provided a postal address

4.23 The first paragraph of the letter sent out was as follows:

Last summer we undertook public consultation on a draft Vale of Aylesbury Local Plan This involved a flyer to all households in the Vale, ten public consultation events, static exhibitions and coverage in the local media As part of our process of continuous quality checking, it has come to our attention that some local plan consultees may not have received specifically addressed communication at the time the draft VALP was published for consultation last summer In case you had not been aware that the plan had been published for consultation, we are giving you the opportunity to comment now on the draft VALP before it is finalised in the next few months If you have already responded, please be assured that your comments are being taken into account and there is no need to comment again

The Response

4.24 Summary of responses to VALP further consultation May 2017

A total of 17 responses were received as follows: Utilities (CLH Pipeline x2), Parish Council (1), residents (5) developer/agent/landowner interest (9)

Summary of the main issues identified

A report has been published on the Council website

https://www.aylesburyvaledc.gov.uk/valp-previous-consultations

4.25 The following is a selection of key issues raised in the May 2017 consultation:

• North Marston Parish Council note that North Marston is a small village with few

facilities available They consider the school would be unable to cope with housing

growth, noting that the transport network is poor and their village lacks the capacity to support a larger amount of housing

• Concern about agreeing housing numbers for Aylesbury Vale before Wycombe,

Chiltern and South Bucks have consulted on a housing figure for their areas

• Uncertain implications of the Housing White Paper

• Homes on newly built estates are too expensive and out of reach to normal

people Council representatives should say what is needed, otherwise find a builder who will

• The new homes being built are bland in design terms Even though land is

expensive and in demand, straight roads with terraced houses make more

housing

• Ecology: with the decline of bees and other useful insects, each house should have

a small front garden and a larger one at the back and include a safe place for small children to play

• All houses built should be for people who were born, reside or have connections with this area Young people have to move far away to find a home

• Concern about not receiving consultation material last year

• CLH Pipeline submitted two maps regarding a pipeline that runs through the

borough

4.26 Further site promotions were received in the May 2017 re-consultation:

 Land at Adstock

 New Settlement at Haddenham

 Land at Aylesbury Golf Club, Bierton

 Land South West of Weston Turville

 Land at Hollingdon Road, Hollingdon

 Land at Finmere Aerodrome Tingewick

 Land adjacent To Raven Crescent and Linnet Drive, Westcott

4.27 Issues raised by site promoters included the following:

 Further consideration should be given to identifying and meeting Objectively

Assessed (Housing) Needs (OAN)

 Talk to neighbouring authorities to ensure unmet needs are met

 A capacity led approach will not deliver the OAN While understanding the

capacity for each settlement is important, this should not be a limiting factor to development

 The Draft Local Plan, as currently written, is unsound with respect to delivery The

proposed phasing of the housing requirement does not plan positively to address the District’s short-term housing need and would fail to provide a five year supply

of deliverable housing The Plan over relies on the delivery of very large

allocations, which will be slow to deliver and vulnerable to unanticipated delays

 Limitations of 10 year migration trends In line with Professor Simpson’s research

referred to in the HEDNA, it would be more prudent to use the existing

demographic profile from the 2014-based projections rather than the 10-year adjusted projections

 Following the LPEG report and the Housing White Paper (Fixing our Broken

Housing Market), a common OAN methodology is to be published for consultation Were this based on an LPEG approach there would be an uplift of 2,624 dwellings

above the current proposals for Aylesbury Vale The Council should follow this approach in relation to migration trends in any subsequent consultation of the VALP

 The Council would be unwise to halt progress on identifying a location for a new settlement until a Local Plan review as this important component of the

requirement for the District should be planned for in the current Plan Period

 Haddenham can take more growth than indicated in the January 2017 HELAA and

September 2016 VALP consultation draft Evidence points towards Haddenham as the most appropriate location for a new settlement, which should be included as a preferred option in the Submission Local Plan and favour an approach which would increase growth to the village, over proposals for a new standalone

settlement

 Would expect to see the inclusion of high level infrastructure and projects needed

to support the Local Plan and wider strategic initiatives planned for the Aylesbury area Evidence supports the use of the existing social and community

infrastructure at Haddenham to enable increased growth in the village

 Growth south and west of Aylesbury has been sterilised by the proposed route

for HS2 Therefore, the focus for new development needs to be elsewhere

 The restriction to only allow further development in exceptional circumstances at Bierton and Western Turville in paragraph 4.78 does not allow for the flexibility the NPPF requires

 Wendover cannot be completely divorced from a strategy for development,

though the Council should be mindful of the Housing White Paper with regard to Green Belt

 Support Draft Policy S3, insofar as it allows for future development at the village of

Westcott

 Policies D7 and D8: The wording of D8 is very restrictive for villages that have

opportunities to provide small scale development Such development should be proportionate to the size of the village and have no outstanding material

considerations to address

 Disagree that smaller villages and settlements have not been allocated any level

of residential development in the Plan Development should be distributed evenly across the District to spread the impact of new homes across services and facilities available The development of a small scale residential scheme in a small village will assist in the provision of homes for local people as the community grows

 Support aspects of Draft Policy D7 with regards to directing new development to the edge of existing settlements However the Policy is unsound as parts are

inconsistent with national planning policy and the Framework’s objective to significantly boost housing supply The wording of the second paragraph is vague and should be revised

 Due to cost it can often be difficult to deliver specialist housing for older people in

parallel to traditional residential development Specialist housing for older people such as Continuing Care Retirement Communities (CCRSs) often require greenfield sites that may not otherwise come forward for general housing The Plan must therefore be sufficiently flexible to support the development of specialist housing for older people to meet identified need

 The Plan should reflect national guidance and make provision for the

redevelopment of existing employment sites, including Vale Industrial Estate, in

order to meet housing needs Draft Policy E2 conflicts with the NPPF in applying a

level of protection outside key employment areas and which may not be required

to be retained for employment

 Clarity sought with regard to the number of new homes that RAF Halton could

deliver and whether new homes replacing those on the barracks would count as

‘new homes’

4.28 In terms of response to the issues raised at the Draft Plan stage – please see

Table 3 in Appendix A

5 VALP Proposed Submission – 2017

(Regulation 19)

Stakeholder Forums prior to Public Consultation, 2 and 4 October 2017

5.1 The formal public consultation was preceded by stakeholder forums All district

members were invited to an event on 2 October and all parish and town councils were invited to send up to two representatives to an event on 4 October

4 October 2017 Parish Forum - How bodies and persons were invited to make

comments

5.2 An officer presentation shared information on progress of preparing the plan, provided

an update on the Duty to Co-operate, introduced the Infrastructure Delivery Plan as a recent submission to the evidence base, and discussed the current weight of the Plan

as well as forward timetable A Buckinghamshire County Council officer also presented further on infrastructure delivery and submission of a bid for the Housing

Infrastructure Fund This was followed by a visual demonstration of how to comment

on the online consultation system and an accompanying leaflet handout, ‘How to make your views known’, was distributed There was then a question and answer session where those attending could raise queries and comments 57 people attended

5.3 Two key areas were discussed in both presentation and question and answers The first

was the spatial strategy, in particular the site allocation process in terms of the

settlement hierarchy and its relation to Neighbourhood Plans The second was the potential changes to housing numbers if the Plan were not submitted before the end of March 2018, due to the Government’s proposed standardised calculation for

objectively assessed housing need (OAN)

Proposed Submission Consultation

5.4 The main consultation ran from 2 November to 14 December 2017 (6 weeks)

Comments on the early draft of the Proposed Submission Plan

5.5 On the penultimate day of the consultation, the Council became aware that an earlier

draft version of the Plan could be accessed online through the Council’s website This was the case even though the main VALP consultation page – to which the vast

majority of respondents referred – contained the link to the most up to date draft The responses which referred to the older draft were identified, six in total, and carefully reviewed The Council’s view was that none of these six consultees had been

prejudiced by referring to a previous draft However, in an abundance of caution these six consultees were notified and given an extended deadline of 15 January 2018 to submit any amended or further representations on the changed elements of the Plan which were minor Five of the six consultees responded

5.6 Further checking during the processing of representations in the New Year identified a

further three responses referring to the older draft were identified Again, these respondents were contacted and given an extended deadline to submit amended or further representations on the changed elements of the Plan Two of the three

consultees responded

Publicity

5.7 A letter was emailed or posted on 24 October 2017 to all statutory consultees and

active consultees on our mailing list This correspondence encouraged consultees to activate their account on the consultation system or register a new account It included

a web link to the consultation system and provided information on other ways to respond A further letter was sent on 1 November 2017 informing consultees of the impending start of the consultation This provided a link to the Vale of Aylesbury 2013-

2033 page of the website, a list of which documents were available to view and further information on using the consultation system Also included were a Statement of Representation Procedure and a Statement of Availability, the latter of which listed the opening times of all the locations where documents could be viewed An emailed letter was used where there was an email address, otherwise a printed and posted paper letter was relied on See Appendix C for who was contacted by emailed letter or posted letter on this public consultation, in accordance with our adopted SCI

5.8 The Council webpages were changed for 2 November 2017 displaying:

 the consultation document – the Proposed Submission Plan

 the publication documents, including supporting evidence base and drafted topic papers

 the Statement of Representation Procedure and Statement of Availability,

providing information on the documents available to view electronically and in hard copy as well as the location information to access hard copies

 How to comment – the online comment form, how to write to the Council and email us

 A slot on the rotating images on the main Council homepage to drive people to visit the VALP pages

5.9 The consultation publication documents, including evidence base, were made available

electronically on a memory stick, available to be posted on request

5.10 The consultation was advertised in the July and November edition of the Aylesbury

Vale Times, the magazine for residents of Aylesbury Vale which is distributed to 80,000 households

5.11 An article was published in Aylesbury Town Matters, Aylesbury Town Council’s

publication

5.12 An opinion piece was published in the Bucks Herald

5.13 Posters were displayed in town centre car parks, community centres, libraries, internal

Council noticeboards and sent to parish councils

5.14 Content in the MyAccount e-newsletters for August, September, October and

November informed 44,000 MyAccount holders of the upcoming consultation

5.15 An animated ‘Powtoon’ video on the progress of the Plan was posted on the Council’s

website, Facebook page, Twitter feed and YouTube account

5.16 4 posts on the Council’s Facebook page announced and advertised the consultation, as

well as 11 tweets

5.17 The consultation was announced and promoted on mix 96 radio station on 23 October

and 7 December

5.18 There were press releases in October, November and December to generate coverage

in local and regional media

Consultation Questions

5.19 Consultees were encouraged to frame their comments within the context of the Plan’s

soundness, legal compliance and compliance with the Duty to Co-operate Both the form on the consultation system and the downloadable document response form had tick boxes for respondents to explicitly state a yes or no answer on these three

elements, as well as selecting which of the four tests of soundness they felt were not fulfilled The response also had ‘free text’ fields to enter a full representation, a

summary and suggested changes to the Plan Respondents were also required to indicate whether or not to participate in the oral examination and how to be notified about future updates on VALP According to paragraph 182 of the NPPF, the four ‘tests

of soundness’ are defined as:

 Positively prepared – the plan 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 – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;

 Effective – the plan should be deliverable over its period and based on

effective joint working on cross-boundary strategic priorities; and

 Consistent with national policy – the plan should enable the delivery of

sustainable development in accordance with the policies in the Framework

Methods of Feedback

5.20 We received feedback by the following methods:

 an online consultation system was the Council’s preferred method of feedback: https://aylesburyvaledc.jdi-consult.net/localplan

 email

 or written to AVDC at the Gateway offices

The Response

5.21 988 responses were received, comprising 2441 comments Of the original responses

658 (67%) were made via the online consultation system, 262 (26%) were submitted via email and 68 (7%) were posted paper responses

Summary of the Main Issues Identified

5.22 This section summarises the main issues raised at the proposed submission publication

stage It is not intended to be a definitive list of all representations received; it is a broad summary of the main issues raised (in accordance with Regulation 22(1)(c)(v))

5.23 The main issues raised are summarised below For each policy or supporting text the

total number of representations are identified, which is then broken down into how many representors supported or objected to the plan

 SA - The SA for the VALP fails to appropriately consider alternatives,

alternatives suggested include looking at a smaller scale of growth for Aston Clinton, looking at NLV001 combined with NLV020, a variation with some growth at edge of MK and reduced amounts at strategic settlements and options relating to higher levels of growth

 HEDNA - There are a number of comments on the HEDNA some in support but more in objection, relating also to the comments made on S2 Comparison is made between older versions of the HEDNA and the newer ones where the OAN has reduced

 The plan fails to recognise the Oxford to Cambridge growth corridor and the NIC work done in relation to this The Government’s proposed standardised method to calculating the OAN is commented on too It is suggested that additional provision for housing should be made in the context of these two issues

 Unmet need - There is support for unmet need being provided for in Aylesbury Vale but also comments saying further work should be done to find more capacity in the southern bucks authorities – suggestions include increasing density, more capacity at Princes Risborough, further additional sites Concerns have also been raised that in the future there is likely to be additional need identified for Aylesbury Vale through the issues mentioned above may mean the unmet need can’t then be met

 DTC - There is little evidence of cooperation with councils to the north of the district, particularly Milton Keynes, specifically concerning the proposed spatial distribution and allocation at the edge of Milton Keynes, provision of a bypass, and the East to West rail link The Buckinghamshire authorities have not cooperated enough on employment needs

 The best fit HMA identified is ‘convenient’, in reality it’s more complicated and the needs of the wider region should be looked at

 It is suggested there should be a additional policy on Canals

 Reliance on large MDAs being delivered quickly around Aylesbury is optimistic

 Infrastructure – not enough focus on road capacity, footpaths, Stoke

Mandeville Hosptial, Chiltern railways services, Tring train station, broadband, sewerage

 Neighbourhood planning – further growth at places that have a neighbourhood plan should be decided by the local community through the neighbourhood plan process– e.g Buckingham and Stoke Mandeville VALP undermines

neighbourhood planning

5.25 Chapter 2: Vision and Strategic Objectives

Total number of Comments received 49

Main issues:

 Spatial vision doesn’t mention the growth of Milton Keynes

 The vision and objectives do not give enough emphasis to the Chilterns AONB

 There is no policy regarding education that will deliver the vision

Supported 16 S3 Settlement hierarchy and cohesive development Objected 44

Mains issues:

Policy S1

 Having such a large amount of growth concentrated around Aylesbury will lead

to more traffic problems, this is not sustainable

Policy S2

HEDNA

 Comments were made questioning the latest assessment of housing need in the HEDNA with comparisons being made to previous assessments which produced a higher OAN, saying it shouldn’t be lowered at a time of pressure for increasing housing delivery

 Most comments made stated the OAN should be higher, with a number of detailed technical reports and comments identifying why

OAN

 There are also comments suggesting the plan should adopt the Governments proposed OAN methodology now in VALP which would mean 30,000 new houses over the plan period plus 8,000 unmet need, and not leave it until a Local Plan review

 As it is considered that the OAN is underestimated significant additional

allocations should be identified

 The housing requirement should be expressed as a minimum

 Concerns have been raised that the plan is proposing too much housing and the impact this will have on wildlife

Unmet need

 The plan should acknowledge that the 8,000 unmet need is provisional

depending on the examination of Wycombe and South Bucks/Chiltern’s Local Plan

 There is a suggestion that unmet needs shouldn’t be taken from the part of South Bucks that is outside the functional HMA

 If the capacity cannot provide for the unmet need on top of such a increase in Aylesbury Vale’s own OAN then it is questioned whether the MOU is useless

 Comments made that Aylesbury Vale should take some of Luton’s unmet needs

 There is a objection to taking any unmet needs and the suggestion the

acceptance of this should be delayed

 The housing need should be met closest to where it arises Only the southern part of Aylesbury Vale is well related

 In terms of the new settlement option some suggest this in addition to existing allocations and some instead of so much growth at Aylesbury or other existing settlements

 There are also the suggestions of various other amendments to the distribution

of growth including that there should be more growth on the edge of Milton Keynes instead of Aylesbury or Buckingham, more growth at Haddenham, more growth at Buckingham, both the more and less growth at Aylesbury, both more and less growth at RAF Halton

 Objections were raised to the amount of housing around Aylesbury and the impact this would have on its character, the AONB, coalescence with surrounding villages, the roads and other infrastructure Concern is raised that there isn’t enough employment in the town for these houses If this amount of housing is proposed at Aylesbury a full ring road is needed

 There is a concern that the transport effects of Aylesbury Garden Town haven’t been considered alongside the growth at Wendover and Princes Risborough or other impacts from outside the district

 Objections to the allocation of sites in Buckingham and Winslow above the amount of growth set out in the neighbourhood plans and comments that the location of further growth should be decided by a review of neighbourhood plans

 Suggestion there should be more growth at Aylesbury and Buckingham

 Concerns about coalescence between Halton and Wendover and the impact on infrastructure

 Comments are made that Halton should be treated separately to Wendover and just as a smaller village There is also support them to be considered together as the growth will impact on both settlements

 Objections to the amount of growth proposed at Maids Moreton, which is higher than growth proposed at the other medium villages

 Suggestions that Brill and Marsworth should be classed as smaller villages

 Surplus and vacant existing employment sites can be released for allocation of housing rather than so much greenfield land

 A number of additional sites were put forward for allocation, mainly for

housing sites, including (but not exclusively):

o Land at Buckingham Road, Winslow - Crevichon Properties Ltd 31845

o NLV020 (SWMK phase 2) - SWMKC 32287

o Number of sites to the south west of Milton Keynes - Marrons planning

29372

o CAL003 - FCC Environment 32265

o Marsworth Airfield - Ainscough Strategic Land 32319

o Land at Gawcott -The University of Buckingham 31844

o Land south of Gawcott – Mr T Annable 32241

o Waldridge Garden Village to the east of Haddenham - Waldridge Garden Village Consortium 32314

o Greenway Project, Land north of Winslow - Amarillo Ltd & Scandale Ltd

32109

o Berryfields, East Aylesbury - Arnold White Estates 32001

o North of Waddesdon - Arnold White Estates 32001

o Land East of Fenny Road, Stoke Hammond - September Properties

32277

o HAD002 - Richborough Estates 32286

o GHW013 - Taylor Wimpey South Midlands 32254

o Eaton Leys, Milton Keynes - Gallagher Estates Ltd 32326

o Finmere airfield - Corbally (Finmere) Group and Mrs Vanessa Tait

32293

o Haddenham Airfield, Haddenham - Lands Improvement Holdings (LIH)

32300

o Land South West of Weston Turville - Bellway Homes 32302

o Site adjacent Leighton-Linslade - Paul Newman New Homes 32292

o BIE027 and GUW008 - CALA Homes Limited 32297

o Stoke Mandeville sites - Manor Oak Homes 29966

o Land at Winslow Road, Wingrave- Careys New Homes 32267

o Land at Calvert Green - Persimmon Homes Midlands 32264

o Land at Cheddington - Society of Merchant Ventures 32202

o Land West of Canal and south of Halton Lane, Wendover - Manlet Group Holdings 32324

o Land north of Aylesbury Road, Wendover - CEG 32243

o AYL087 – Aviva Life & Pensions 32283

o Brook Farm, Broughton - Land at Brook Farm 32131

o Fleet Marston, Aylesbury - Barwood Land and Estates 32310

o Additional land at Rabans Lane, Aylesbury - Aylesbury Vale Estates LLP

32240

o

Delivery

 It was suggested that the plan needs greater flexibility/contingency

 Comments were made about the delivery rates, particularly about large

strategic sites not being able to deliver as needed with suggestions that there is

an over reliance on these It was suggested that more smaller sites should allocated in the larger and medium villages

 Comments were made on whether Aylesbury can deliver such high levels of housing and whether market saturation will be reached

 It was suggested that there needs to be a higher allowance for

non-implementation than the 5.2% buffer currently proposed

 The use of reserve sites was suggested

 It was stated that VALP doesn’t deliver a robust 5 year housing land supply against VALP’s housing requirements

Employment

 There is a lack of justification for Aylesbury Vale meeting the unmet

employment needs of the southern Bucks authorities, Aylesbury Vale has poor connectivity and is unlikely to meet B8 requirements and sites delivered

 The site selection and SA process is flawed

 Comment that the employment provision should be higher for the amount of housing

Other

 Preparation of the Charging Schedule should be undertaken alongside the VALP as the two documents will directly influence the deliverability and sustainability of one another

 The Sustainability Appraisal of the VALP, states that a more dispersed approach was examined but no further detail is provided within the SA, this should have been examined as a alternative option

 There needs to be up to date flood modelling for sites WTV018, BIE022 and STO016 to satisfy that the sites can accommodate the proposed amount of development

Milton Keynes should be recognised as a strategic settlement in the settlement hierarchy, otherwise its role is undermined

Policy S3

 A number of comments state that the Aylesbury Vale District Council does not adhere to its own policy, as the planned developments at Halton, Hampden Fields, Stoke Mandeville and BUC043 in Buckingham lead to coalescence and the diminishing of settlement identities and are therefore contrary to this policy

 Comments have been made stating that the commitment to the preservation

of the character and identities of settlements and the prevention of coalescence is important, but the wording in the supporting paragraph 3.22 is too weak to ensure this

 Comments have stated that the proposed hierarchy is considered the

appropriate way to deliver housing requirements

 Comments have been made stating that there is an over-reliance on a small number of development locations to achieve housing targets

 Comments request that additional development should be allocated to the identified Large and Medium villages

 A comment requesting a third criterion to prevent development that would harm the Chilterns Area Of Outstanding Natural Beauty or its setting

 One comment requested for settlement boundaries to be defined

 Comments requested the housing requirement to be expressed as a minimum figure

 Comments state that the wording of Policy S3 is too restrictive, which will

prevent the delivery of necessary levels of development

Policy S4

 Objections to the removal of land from the Green Belt at Halton It isn’t

considered any less important that the Green Belt in Southern Bucks and should be kept to preserve the AONB That the site is already developed is not justification to remove it from the Green Belt Any redevelopment should not reduce its openness

 There are also objections to the allocation of housing at RAF Halton if it’s still within the Green Belt

 Support for the removal of land from the Green Belt to the north of Wendover

no longer being proposed

 Support for the extension of the Green Belt to the west of Leighton Linslade and also objection to this based on the failure to demonstrate exceptional

circumstances

Policy S5

 There is concern that sufficient infrastructure will not be delivered in reality Specific mention is given to infrastructure to support RAF Halton allocation and the funding/delivery of the link roads around Aylesbury, roads infrastructure in rural areas

 The existing infrastructure is already under strain, it is important that the necessary infrastructure is delivered up front or early in the provision of new development The wording on this should be strengthened

 Concern is raised that this policy is looking to address existing deficiencies, it should only be sought where they are necessary to make the development acceptable

 More detail is required about the infrastructure that is needed

 Where larger sites are under different land ownerships the delivery of

infrastructure needs to be ensured by having the appropriate mechanisms in place

 There should be more recognition about East to West Rail and Oxford to Cambridge arc

 There is also a number of support comments for this policy

Policy S6

 The policy does not mention the requirement to monitor Gypsy and Travellers

or have a enforcement plan

 Objections have been made to the allocation of Oaksview, Boarstall This has been recently refused permission, there is a over supply of sites in the area, it

is close to the MOD sites and prison, the site has a dominant and unnatural impact on the open countryside and would have a detrimental impact on the area, overlooks residential properties, has poor access to services and it doesn’t meet the criteria in D10 The site does not appear to have a sewerage connection, groundwater aquifers would need to be protected from pollution if

it does need disposal set up

 Allocations should only be made for those that meet the definition, not those that are unknown, reducing the amount of allocations needed to just existing

sites that meet the criteria of policy D10

Policy S7

 Five comments were supportive of Policy S7 and 10 were objections

 One comment stated that the wording of Policy S7 was problematic as

‘previously developed land’ can be ambiguous

 One comment requested a caveat in Policy S7 regarding the impact

development has on local character

 Comments have stated their support of Policy S7, but have also noted that it is important the policy is not read such as to prioritise previously developed land over green field land for development

Policy S8

 Comments were made stating that the allocation of specific sites in

Neighbourhood Plan Areas prejudges the Neighbourhood Plan process, and that S8 needs to ensure that neighbourhood plans are the principal vehicle by which allocations are made

 Comments requested for Policy 8 to include a requirement for Neighbourhood Plans to be reviewed to ensure that the contribute towards the strategic policies of the VALP

 Made comments stated that Policy S8 is not clear as to what weight

Neighbourhood Plans are to be given in the planning process and what the relationship between VALP and existing Neighbourhood Plans is

 Policy S8 has received comments supporting it on the basis that it reinforces the need for Neighbourhood Plans, and that it recognises that Neighbourhood

Plans should be in general conformity with the strategic policies of VALP

 It should be ensured that the allocations are deliverable within the expected time period and enough have been allocated

 The delivery rates are ambitious and a significant increase, therefore a greater buffer should be used with further allocations to allow for flexibility

 The windfall allowance should include larger sites than 4 dwellings too and therefore would be a higher number than 962

 Two comments stated that Policy S9 should include a schedule of reserve sites

to be released if monitoring indicates a shortfall in the five year housing land supply position

 Comments requested for Policy S9 to specify that the Plan will undergo an early review

 A number of comments were made on specific issues on specific sites

 Comments were made supporting references to settlement’s historic

environments in site allocation’s supporting paragraphs

5.27 Chapter 4: Strategic Delivery

Aylesbury

Supported 1 D-AYL052 PO Sorting Office, Cambridge Street,

Aylesbury

Supported 0 D-AYL059 Land at junction of Buckingham Street and

New Street, Aylesbury

Objected 2 Supported 0

D-AYL077 Oaklands Hostel, 3 Bierton Road,

settlements, larger villages & medium villages

Supported 3 D-BUC043 Land West of AVDLP allocation BU1

Moreton Road, Buckingham

Supported 1 D-BUC051 West Buckingham, Land bound by

Brackley Road and the River Great Ouse

Supported 1 D-BUC046 Land off Osier Way (South of A421 and

East of Gawcott Road)

Supported 0 D-HAD007 Land North of Rosemary Lane Objected 12

Supported 2

Supported 5 D-WIN001 Land to East of B4033, Great Horwood

Road

Objected 19 Supported 0 D-SCD003 Land at Queen Catherine Road Objected 2

Supported 0 D-SCD008 Land at Molly’s Folly/Molly’s Field, West

of Addison Road

Supported 0 D-STO008 Land South of Creslow Way, Stone Objected 1

Supported 1

Supported 1 D-CDN001 Land North of Aylesbury Road and rear of

Great Stone House

Foscote Road

Supported 1 D-MGB003 Leopold Farm and area to the West Objected 1

Supported 3 D-NLV005 Land South of Whaddon Road and West

of Lower Road, Newton Longville

Objected 3 Supported 0 D-QUA001 Land South West of 62 Station Road Objected 0

Supported 1 D-QUA0014-016 Land adjacent to Station Road,

Quainton

Supported 1 D3 Housing development at smaller villages Objected 10