Winslow Town Council Response to Draft VALP
1) The original draft VALP document on page 32 indicated the Housing Requirement for Aylesbury was 14,113 and the District total was 33,344 but in the more recent version the figures are 15,845 for Aylesbury (a 12.2% increase) and the Total is 34,910 (a 4.7% increase), when the official requirement is 33,300. How and why have these significant changes occurred? Suddenly, for no clear reason, Aylesbury’s share of the district-wide total for new homes has shot up from 42.3% to 45.4%. However, this is still well short of the 51% indicated as the target delivery share for Aylesbury in the VALP Issues and Options document, with an excessive proportion now allocated to the north of the District.
2) Paras 1.38 and 1.39 state about a 40,000 increase in the Vale’s population during the Plan period. This does not equate with an increase of 33,300 homes, which, even with an overall reduction in average occupancy rate from the current level by 2033, would surely see an increase of at least 70,000 in population. Does the 40,000 figure exclude the ‘unmet need’ element and is only detailing the result of the Vale’s OAN? This is not clear and should be.
3) It would appear that the pressure to deliver a successful Local Plan is resulting in an over-reaction to the ‘duty to cooperate’. The unmet need figures from HMA partners appear to be unnecessarily high and need to be very carefully scrutinised.
4) There are grave concerns over the unmet need element of the total housing figure in the draft VALP, which we are advised could increase further. It already represents a 56% increase on the figure for new homes to meet the Objectively Assessed Need for the Vale. Neighbouring LPAs are stating that with the land they are able to allocate for new homes in their Local Plans, they have reached their capacity and expect/assume they can simply shunt their excess into the Vale. This must logically mean that when the next series of formulating new Local Plans comes round, unless the situation changes very radically indeed, the Vale will be expected to provide all the new homes required to meet the growth needs of these 3 neighbouring Local Authorities as well as the Vale’s and undoubtedly the unmet needs of other LPAs. This is an irrational and unacceptable scenario. Government and the ‘overspill’ LPAs should be made aware that this scenario must be recognised and addressed now in the expectation that common sense will prevail and some of the proposed overspill is relocated away from the Vale.
5) Para 1.19 read logically suggests that the delivery of the new A421 expressway is further away than east-west rail. We anticipate that delivery EWR is now 2022 at the earliest so this limits the timescale for a new settlement that relies on the A421 for access. On the other hand, if the A421 is to be funded by development it gives time for the funding to be got in hand, though supplying houses and then building the infrastructure would be unnecessarily chaotic.
6) Para 1.21 suggests that the plan has been informed by incomplete traffic modelling “traffic modelling of impacts of the proposed development is being prepared and has partly informed this draft plan”. Essentially traffic modelling is not yet done, and for A413 this is very important. Traffic is treated in terms of impact mitigation which seems unnecessarily simplistic, there is the important matter of whether the necessary traffic flows are possible in the first place, especially for A413, Little Horwood Road and A421. Very little consideration seems to have gone into transport beyond the grand projects of HS2, EWR and the expressway. Road improvements are needed and need to be complemented with improved public transport which is important in terms of reducing congestion and climate change.
7) Para 1.27 suggests that the district is planning to interfere with Neighbourhood Plans contrary to the founding principle of these plans. Potentially the District is forming an opinion which it will later have no right to uphold against the Parish.
8) With over 3,000 households on the housing register (para 1.51) and only 349 affordable homes being built on average each year it is obvious that the build rate must be increased and that a greater emphasis needs to be made on building affordable homes that meet the needs of the local community. (For more specifics see our response to H6 below).
9) Para 1.46 refers to the 35,025 residents who commute out of the Vale for work. More emphasis should be placed on providing employment within the Vale and developing local strategies to achieve this.
10) Para 1.57 says that Silverstone and Buckingham have “reasonable north bound access” to the M1 and M40 motorways. A more specific explanation would be useful here. The A413 north of Buckingham is not reasonable and using the A43 to reach the motorway is likewise not reasonable.
11) Para 2.4 leaves a number of questions. 2.4 (b) refers to “unmet needs from other housing areas”, it is not clear what this refers to, other counties, other districts or other parishes. 2.4(h) refers to active links between Winslow station and Buckingham, presumably a bus service? With regards to the provision of a new settlement, the first in Buckinghamshire since Milton Keynes in 1961, it is hoped that this will be built to the same standard as an independent town and not compromised by trying to reduce the cost and tacking it on to an existing settlement.
12) Para 2.6.1 talks about a more intensive use of existing sites. This can only be done where appropriate, ensuring that the rural character of settlements is maintained and that neighbourhood plans are respected. Transport infrastructure includes public transport something that is so often forgotten or at the bottom of the list. AVDC need to ensure that public transport, which is vital in the rural areas, is an integral part of the planning structure, along with BCC. We note that for point 7, on the issue of climate change, no reference is made to public transport.
13) It is hoped that the aims (para 3.15) of minimising the need to travel and optimising sustainable means of travel by maintaining and enhancing the roles of Aylesbury, Buckingham, Winslow, Wendover and Haddenham in the Vale’s settlement hierarchy is actually adhered to. This will require investment in public transport and investment in creating employment opportunities.
14) S1 needs qualification. It commits the LPA to do everything possible to approve a proposal, regardless of merit. It makes no mention of taking into account Neighbourhood Plans. Para’s 3.17 and 3.18 then acknowledge that even with VALP in place it will still not be possible to meet the required five year housing land supply requirement even with phasing in the early years. Is there any evidence to suggest that this is a proposal which would be acceptable to the Planning Inspectorate or is it the case that despite this ‘plan’ we will still be subject to speculative applications from developers? The concern is that, despite an up to date Local Plan, developers will anticipate that because of the lack of a demonstrable current 5 year housing land supply that Planning Inspectors at Appeals will approve applications that are in conflict with VALP because of the ‘presumption in favour of sustainable development?’
15) WTC does not agree with the proposed spatial strategy. The distribution between Aylesbury and rural areas is fundamentally flawed (see also WTC‘s response to Settlement Hierarchy). Without taking into account Buckingham, the percentage growth in rural north-east corner of Vale will be almost three times that proposed for Aylesbury! Growth of 50% in Strategic settlements appears entirely arbitrary. The level of planned growth adjacent to MK seems unsustainable.
16) The differences in the percentage growth levels between settlements seem somewhat arbitrary. There are large settlements with almost the same population as two of the strategic settlements and small settlements restricted to 5% growth which could accommodate more as they are strategically located (e.g. Whaddon is in 5% category but growth will actually be 375% whereas Great Brickhill which is equally close to MK will only be 5%)
17) There is a clear and recognised need for a specific Policy to prevent coalescence. What is stated in Policy S3 ‘Settlement Hierarchy and cohesive development’ and in Policy D4 – Section b) is inadequate. Winslow has the hamlet of Shipton on its doorstep which is currently geographically separate from the town and should remain so. Paragraphs 3.26 to 3.29 have some robust statements regarding the prevention of coalescence, and would seem to rule out the joining together of Little Horwood, Great Horwood and Winslow (and therefore a new settlement at Winlsow), but unfortunately this is not reflected in Policies S3 or D4. Communities and AVDC need a Policy which is detailed and substantive to argue the point at an application’s determination and at an Appeal Inquiry to prevent community coalescence. What AVDC is suggesting would leave them naked in defending the non-coalescence argument.
18) WTC welcomes the proposal to release green belt land at Wendover / Halton.
19) Note that in Paragraph 3.43 which defines and details the term infrastructure, which “covers a wide variety of services and facilities provided by private and public bodies,” does not include mention of Shops, Banks, Post Offices, Pubs, Restaurants, Council facilities etc. Surely an error for these not to be included.
20) We note that growth will be accompanied by delivery of infrastructure, services and facilities in the right place at the right time. (Para 2.4 d), and that ‘new settlement’ will be under development (para 2.4 h 6). This second statement does not suggest that the new settlement will only be developed if there is a proven need.
21) The Oxford to Cambridge Expressway, mentioned in Paragraph 3.63, is only a ‘study to investigate,’ so AVDC cannot and should not, as they appear to have done, justify major growth in the north of the district (Northern Vale) as being sustainable, reasonable and practical because of a much improved East/West road, as this ‘project’ lacks any certainty of when delivery will be during the Plan period, nor what the route will be, nor even if it will be delivered by 2033. If as the Plan seems to suggest, Aylesbury is at the heart of the London – Oxford- Cambridge ‘golden triangle’ then that’s where the Oxford to Cambridge Expressway should run through and that’s where the major development should be. WTC believes that in the strategic interests of Aylesbury Vale the best route for the Expressway would be via A4146/A418 and not the A421. This would link Aylesbury into the Oxford – Cambridge ‘knowledge arc’ and support the housing growth at Aylesbury. Wheras a route via Winslow would ensure that all benefits go to MK (and would also require 35-40k of entirely new road in open countryside).
22) A disproportionate amount of the housing development requirement in the draft VALP is proposed for the north of the district, in spite of the fact that it is not well connected to major road corridors of the road network and there are no firm plans to deliver road improvements to either the A413 north of Aylesbury nor the A421 west of the bottle dump roundabout prior to 2033. In spite of this, VALP proposes that the Northern Vale (including Buckingham) should deliver either 9,800 new homes i.e. 28.1% of the District’s total or, including the new settlement, 14,300 new homes which would be 41% of the District’s total. In the past, the Northern Vale has delivered 22% of the District’s growth. The ‘unmet need’ portion of the housing growth is 12,000, representing 36% of the District’s total, which emanates from neighbouring LPAs bordering the south of the Vale. So what are the figures for the Southern Vale which ‘relates more strongly to higher-value markets and the unmet housing needs in Districts to the south’ and has historically delivered 18% of the District’s housing growth? With Aylesbury now due to deliver only 45.4% of the District’s growth, where in the VALP Issues and Options the indication was that it would deliver 51% against a historical 60% of the housing growth of the District, that leaves us with the Southern Vale delivering 26.5% of the total if the new settlement were to be located at Haddenham – 8,900 new homes and only 13.4% if the new settlement is located north of Winslow – 4,500 new homes. The facts speak for themselves – the Northern Vale has poor transport provision, it is relatively remote from the Districts which are generating the very significant unmet housing needs figure in the draft VALP total, the proposition that with the new settlement the Northern Vale would be expected to deliver almost as much housing growth as Aylesbury, all add up to one conclusion, namely that the level of housing growth being demanded in the VALP of the Northern Vale is both unreasonable and unrealistic.
23) S5 is clear in stating “infrastructure is provided in a comprehensive way in line with new development” and yet there seems to be no plans for this to be the case in reality. This is most obvious when looking at transport. The transport section makes no reference to road changes/improvements or public transport enhancements. The EWR and the Expressway are not due until the early 2020’s and so will not be delivered in line with new development. There is also no minimum scale given to this statement, it is vital that however small the development any additional burden placed on the community must be supported with extra infrastructure.
24) Clarity is also needed on how the 25% of the CIL contributions due to Neighbourhood Plan communities will be distributed.
25) It needs to be noted that East West Rail brings only limited benefits in terms of supporting sustainable development and is already five years behind delivery schedule. Latest projection for services is 2022 (at the earliest) not 2020 as shown in draft VALP. There will be very little benefit in terms of travel to MK as the rail station is not close to either employment centres or the retail hub. While EWR will improve journey to Oxford for limited number of people, the links to Cambridge and further east are a very long way off and of little relevance to Winslow residents. Likewise, the proposed journey time to London (74 mins from Winslow) is no incentive for relocation to this area. (c.f. Bicester 46 mins / Leighton Buzzard 30 mins / Haddenham 40 mins / Aylesbury 60 mins.)
26) It appears that the approach to be taken to Gypsy and Traveller sites provision is that AVDC will take the easy way out and make many of the illegal pitches permanent, many of which are in open countryside and therefore in theory where planning permission should not be permitted, instead of advocating the obvious and practical approach of developing smallish sites on large housing developments, including the new settlement. As stated in Paragraph 3.65, when referring to the provision of suitable sites for Gypsies and Travellers, “it is important to ensure that development is located in the most appropriate locations,” which obviously precludes sites in open countryside.
27) Regarding Policy S9, as with S1, the stricture that “should a Neighbourhood Plan not progress to submission within a year of the adoption of the Local Plan, the Council will implement the reserve sites set out in the plan,” appears somewhat draconian. It really does not allow communities which await the adoption of the Local Plan in order to ensure certainty as to the strategic figure fornew homes delivery to 2033 in their community, before embarking on a neighbourhood plan, (an approach supported by AVDC in the past) it is quite likely that there will not be sufficient time to ensure their plan will have reached the submission stage in 12 month period specified. A period of 18 months rather than 12 months would appear more reasonable and in the scheme of things to 2033, the extra 6 months will be of little or no consequence.
28) The ‘Delivering a new settlement’ (4.27) section offers a welcome alternative to simply adding on to an existing settlement. As the NPPF says “The supply of new homes can sometimes be best achieved through planning for larger scale development”.
29) Para 4.43 states a number of objectives for a new settlement which clearly cannot be met at Winslow. Primarily the objective that the development “ensure infrastructure facilities and services are delivered in the right place at the right time”. As infrastructure is likely to be funded by the development it will naturally have to follow afterwards. Similarly the first objective refers to the need “to ensure that housing development is accompanied by employment”. Presently there is a deficit of employment opportunities in Winslow relative to the population, and this plan gives no suggestions as to how this would be rectified with the arrival of new settlements. With so many heavyweight factors overwhelmingly favouring the choice of Haddenham rather than Winslow as the location for the new settlement, why was the term ‘marginally preferable’ used in Para 4.35? What possible factor(s) could irrationally turn matters on their head and conclude that Winslow could suddenly be the better option? See separate report on the New Settlement Scoping Study prepared by Winslow Town Council.
30) What is the rationale for the huge (4,135) increase in housing close to Milton Keynes? Milton Keynes Unitary Authority has more undeveloped land to the east of the M1 than is occupied by the whole of the existing city of MK. Including areas such as Whaddon and Newton Longville (and potentially Winslow and the Horwoods) will only serve to encourage the western expansion of MK. Ultimately this will be to the detriment of Aylesbury Vale as these communities will relate more and more to MK and not Aylesbury, nor to those ‘unmet need Authorities.’
31) In the ‘Delivering the allocated sites’ section for large and medium villages, there is no mention of those with well advanced Neighbourhood Plans such as Wingrave, which are likely to be ‘made’ before VALP is considered for adoption and the housing delivery numbers of those NPs. NB It is recognised that to base the housing delivery target for one’s NP upon an emerging Local Plan is potentially fraught with danger at an Appeal Inquiry.
32) What is the rationale and the evidence base for the mere 3% difference between the target housing growths for medium and large villages? Heading the large villages is Aston Clinton with over 3,800 residents, followed by Edlesborough, Long Crendon, Pitstone, Stone/Bishopstone/Hartwell, Weston Turville and Wing all with over 2,500 residents and all these obviously because of their size have good infrastructure provision (schools, shops, good bus services, a range of community facilities etc) that many of the medium villages can only dream of. Contrast these large villages with the likes of Cuddington – pop. 650, Gawcott/Lenborough – pop. 900, Ickford – pop. 690 and North Marston – pop. 700, some of the smaller ‘medium villages’ with minimal facilities. As the basic demographic growth over the 20 year period has been identified by AVDC at 15%, a figure of 19% for the medium sized villages is not unreasonable as it only covers a little more than their own anticipated growth in demand for new homes. What is highly suspect is asking the larger, very sustainable villages to only provide 22% growth. The fact that Aston Clinton is not expected to provide more than its existing commitments surely proves the point. This community is well able and should provide more homes than a mere 22% increase to 2033, as should other large villages. A minimum of 30% housing growth would seem more just and equitable for these large villages, if not a minimum of 35%.
33) D4 makes no mention of a Settlement Boundary or anything similar. The Neighbourhood Plan needs to be referred to.
34) In the ‘Delivering sites at smaller village’ (4.85-4.87) section, it can be agreed that on average the smaller villages will have a new housing growth need to purely meet their own requirements during the Plan period of about 15% (the baseline demographic growth identified by AVDC for the Plan period). The 5% increase on housing stock therefore looks unreasonably low when the district wide growth figure is 45%. Where is the evidence that underpins this growth figure? The evidence we see in the table in this section makes it abundantly clear that many of the smaller villages in the Vale are well capable of delivering far more than 5% housing growth to 2033. 38% of the smaller villages (17 out of 45) have been identified as already meeting the 5% growth figure via completions and commitments and VALP still has 17 years to run! It is not rational to state only 3 years into the Local Plan that 17 villages “do not require further sites” and “only permit approximately x homes” for many others, which is tantamount to confirming that planning permissions will not be granted for applications for new homes beyond the 5% cap. It must make sense to allow smaller villages to grow at a rate relevant to their individual needs and aspirations. To constrain the likes of Calvert Green, Dinton, Great Brickhill, Oakley, Soulbury etc to 5% housing growth appears unjustified and unreasonable. What would be wrong with stating that the increase in the housing stock for small villages should be a minimum of X%?
35) In D9 ‘Provision of employment land,’ there is mention of live-work developments. It is anticipated that nationally the need for live-work units will steadily increase. In order to avoid ‘uncertainty’ in relation to planning applications for a change of use to a live-work unit, AVDC would be strongly advised to include a clear definition of what constitutes a live-work unit in the final version of VALP in order to eliminate inevitable uncertainty. Also, live-work does not appear in the Glossary with a definition.
36) 4.106 refers to the importance of community services and local facilities and the strategy to protect local shops, pubs and post offices to prevent the decline of communities. This also needs to make reference to the local Parish or Town Council office which is at the heart of the localism agenda, and offers the best opportunity to improve the local community. Likewise an extensive list of community facilities in 11.16 makes no mention of the local council office.
37) D10, in a similar vein to S1, seems to suggest that any proposals for town centres will be approved regardless of merit and the wishes of the local community. It needs to be made clear that high-grade retail needs to be given priority and that residential use should be a last resort. For strategic communities in particular, most of which are expected to grow by 50% by 2033 and will therefore have a very significantly higher population at the end of the Plan period than currently, which will undoubtedly increase demand on our High Streets, it will be vitally important to resist changes of use of existing retail units on the High Street. There does not appear to be recognition in the draft VALP of this issue accompanied by the necessary robust Policy. Section I3 states that the council will “resist proposals for the change of use of community buildings and facilities” the same assurance should be given that the council will protect retail buildings. This would go some way towards supporting the statement in 4.110 that Aylesbury Vale District Council recognizes the need for retail growth in communities and will encourage it.
38) In 5.7, the simple statement that affordable homes should be in groups of no more than 15 to 18 is totally unacceptable, another instance AVDC where one size does not fit all. At 31% affordable homes contribution, a 48 home development would/could have a single cluster of 15, clearly a single cluster for such a site would not constitute the spirit and principle of the original guidance, by Government of seamless distribution. For a 480 home development it would be 10 x cluster of 15 and for a 2,400 homes development it could be 41 x clusters of 18. This is not the way to achieve ‘seamless distribution of affordable homes throughout a development.’ Cluster sizes need to reflect the scale of the development, not have a blanket cluster size irrespective of the scale of the development. For the 48 home development a cluster size of 5 would be reasonable, for 480 perhaps 10 and for 2,400 why not 30? The oft used excuse that the Housing Associations insist on this large cluster size is not correct. They do not want pepper potting but are amenable to cluster sizes that reasonably relate to the size of the development.
39) Policy H4 requires some qualification on the size of a replacement dwelling to be permitted. We suggest a footprint no larger than twice the size of the existing dwelling.
40) There is clear evidence from discussions in Winslow (between aspiring self-builders, WTC, AVDC and developers) that there is a need for the development of a SPD for self/custom build housing.
41) Policy H6 Housing mix – There is a justified perception that too often AVDC has simply approved the housing mix proposed by developers, even when these are in direct conflict with the needs of the district and the community and this is still happening. Recently, an application for over 40 homes in a medium sized village with a made Neighbourhood Plan, which included a Housing Needs Survey which identified the housing mix that community needed, firstly had confirmation that AVDC had approved what was described at the call-in Public Inquiry as a “good housing mix,” when all the market housing was to be 4 and 5 bed homes, in direct contravention of an up to date Housing Needs Survey. Then the application was approved, hence the call-in. In July of this year, Winslow was informed that for the largest site for new homes detailed in their Neighbourhood Plan, AVDC had approved the following housing mix for the largest and most important site for housing identified in the NP:-
Type Aff. Rent Aff. Part Ownership Market
18 x 1 Bed Flats 18 0 0
39 x 2 Bed Flats 18 21 0
41 x 2 Bed Houses 11 0 30
58 x 3 Bed Houses 16 0 42
85 X 4 Bed Houses 0 0 85
This represents 68% of the affordable homes as flats when the recommendation is 15%. There are no market 1 and 2 bed homes when the recommendation is 22%. 54% of the market housing would therefore be for 4 bed homes when the recommendation for 4 and 5 bed market homes is 27.5%. Clearly these examples are unacceptable, particularly when the premier planning document of the Development Plan in both instances is a made Neighbourhood Plan and it appears no regard was paid to these by the relevant Officers. The very worrying fact is that currently AVDC is supposed to be operating an approval system for the housing mix for a development very similar to that identified in H6, yet these appalling housing mixes continue to be foisted on communities. Obviously, the Policy needs significant improvement to ensure that it functions to ensure the Vale generates the housing mix it requires, based on Housing Needs Surveys and not what developers prefer. One immediate improvement that should be instituted is that where there is a made Neighbourhood Plan, AVDC should be obliged to consult with the relevant Parish or Town Council at an early stage, regarding the proposed housing mix in a new application for their comments. For Policy H6, for developments above a certain size, proportionate to the size of the community, 5% perhaps, the proposed housing mix for all such applications should be referred to all Parish and Town Councils for their comments. Who is in the best position to advise on the specific needs for housing in a community other than the Parish or Town Council? One realises that Officers need to take the bigger, pragmatic view on the needs of the wider District but it can surely be agreed that there is a place for the truly local input here.
42) It is very surprising indeed that there appears not to have been any effort to produce a figure for the net jobs growth for the Plan period. One would normally expect that a Local Plan would not only provide a target figure for the delivery of housing to 2033 but also a target for the new jobs to be generated to 2033 in what is designated as a ‘growth area.’ Surely a Local Plan must show that it is sustainable and a key element of that sustainability would be to show that its net employment growth should ideally reduce out-commuting from the Vale by 2033. Without a clear indication of a jobs growth target and therefore a seeming admission that AVDC did not wish to tackle this thorny issue, will this not invite criticism or worse from the Planning Inspector at the Examination? In a document of over 220 pages, does not a mere 5 pages devoted to Employment on employment sites speak volumes?!
43) Either in Policy E2 ‘Other employment sites’ or in a separate Policy, there needs to be a robust protection of land designated for employment use which, when developed, will significantly address a community’s lack of sustainability because currently there is a very significant under provision of employment on employment sites in that community. This is of particular importance for communities with Neighbourhood Plans which include Employment Policies. In the draft VALP, there does not appear to be clear recognition of this issue. If it is not addressed, one can envisage, with only Policy E2 to refer to, that there will be little to resist an application for example to utilise an employment site for a new supermarket and describing this as an alternative employment use.
44) An explicit policy statement is needed to ensure that designated employment sites will not be converted to residential use in strategic settlements such as Winslow where there is already a shortfall in local employment opportunities.
45) We endorse the proposal for “provision of ancillary facilities for employees in business, industrial and warehousing developments” (6.9). This sounds like good planning and makes life easier for everyone, especially working families. We suggest therefore that the first occurrence of ‘appropriate’ in Policy E3 should be replaced with ‘encouraged’.
46) E5 needs to refer to the importance of the settlement boundary and the Neighbourhood Plan in any decisions taken regarding employment land.
47) Essentially it seems that there is no plan for creating employment opportunities, especially with regards to meeting the needs of local communities. Linking new employment to new housing is too simplistic. There are neighbourhoods which are already underprovided and need redress.
48) Policy E8 does not support tourist accommodation in smaller settlements. Many tourists would prefer to stay at accommodation in smaller communities. There are already many successful B&B operations in smaller communities. This could also prevent the conversion, and thereby preservation, of large country properties to hotels.
49) Surely appropriate evidence should be required for any proposal under Policy E9.
50) It is very concerning that only 8 pages are given to transport and the majority of these are focused on vehicle parking. There is no clear vision of how transport infrastructure will be developed to meet the extra demand put upon it with the arrival of over 30,000 homes. How this need is going to be met, through improved transport infrastructure, improved public transport or by some other means is not resolved.
51) Vehicle Parking – we were advised this was going to follow the BCC standards but it does not. Justification for different parking standards for Aylesbury compared with rural villages is obvious yet AVDC is again going down the track of ‘one size fits all.’ Also, there is no mention of garage provision and size. If residents don’t use garages for parking but instead use it for storage should not the basic design of these houses be changed? See attached for details of BCC Parking Standards recommendations.
52) In light of more and more land being used for development it is an absolute must that new developments are well landscaped and that planting schemes put forward by developers are adhered to and actually carried out. More emphasis needs to be placed on good landscape design with large numbers of trees to break up the flat monotony of new developments.
53) The current wording of Policy BE2 may restrict opportunities for modern design and simply encourage developments which are a pastiche of historic local development, often with mixed period styles of dwelling.
54) It interesting to note in 9.44 that “Trees and woodlands take many years to mature“but no mention of replanting them or replacing them elsewhere before they actually are mature. In regards to NE8 and where trees around sites are lost AVDC must ensure that replacement provision is carried out.
55) Policy NE6(a) is too restrictive. It needs to be reworded to allow wider community or leisure uses.
56) Policy C2 needs a provision to prevent or minimise light pollution from outdoor equestrian facilities.
57) A clear policy on the siting of wind turbines is required.
58) National housing statistics which confirm completions, housing starts etc do not include those new dwellings which result from the conversion of office space into new homes. Is VALP allowed to include such conversions to new homes in its delivery figures to meet its targets?
59) Page (294) (Maps). What is the rationale for adding parcels 109 & 110 west of Leighton Linslade to the green belt? This is a much contested development site is it not?
60) Planning guidance makes it clear that Local Plans should include detail on the provision of infrastructure and where this is not available indicate fall back positions. Several aspects of the Plan, depend on infrastructure delivery which is by no means certain. When can we expect to see the necessary detail in respect of infrastructure delivery?
61) We would like to see a statement to the effect that any additional housing (etc) delivered over and above the VALP requirements will be taken into account in subsequent revisions or plans. To do otherwise might be seen as penalising communities that voluntarily take on an additional share of the development burden.
62) There are other aspects of the Plan which rely on evidence which is yet to be published. Surely it would be very dangerous to proceed to submission without all of the evidence being available.
63) Can you assure us that submissions made during the consultation process will be responded to either by changes to reflect those submissions or explanations as to why they have not been acted upon? It is recognised, of course, that such responses would need to be ‘generic’ in nature rather than specific to every individual submission. Without clear responses it is likely that the same issues will be raised time and again including at Examination.
64) The published timetable for adoption of VALP seems to be extremely unrealistic. If the Plan is submitted in March 2017 then adoption sometime in mid to late 2018 would seem more likely than the published date of mid 2017.
Winslow Town Council September 2016