Blog: 5 October 2018Two (or more) wrongs don’t make a sound plan

Michael Knott

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Michael Knott

Planning Director

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All is not lost! Perhaps it is Aylesbury Vale’s Local Plan Inspector who will stem the tide of Local Plan Examinations being little more than going through the motions.

Aylesbury Vale’s Inspector has raised several fundamental issues in his interim findings note, some which have ‘severely troubled’ him.

The fact that the interim findings were withheld by the council for a month, allowing for a rebuttal to be produced and considered by the Inspector is not the main issue, though it is concerning that such closed ‘negotiation’ was permitted as part of a public process.

Indeed, whilst the focus for those involved will be the Inspector’s note, the council’s rebuttal provides much insight into some of the aforementioned concerns with the examination of Local Plans and ensuring plans support, rather than prevent, the delivery of the Government’s objectives.

First is the issue of early reviews. “Predictable events” should be planned for and “known unknowns” should be addressed through contingencies. Such an approach is said to reduce the dependence on an early review. It’s difficult to challenge this approach and could have implications beyond Aylesbury, Milton Keynes or even the Arc’s Central Area.

The council is correct in its rebuttal that Milton Keynes’ Inspector has allowed ‘Plan:MK’ to proceed based on an early review. But whilst I agree with Aylesbury Vale District Council (AVDC)  that this appears to be inconsistent, I think they may have missed the point. If only one of these two Inspector’s is right in not ignoring OxCam growth and the implications of Heathrow’s expansion, then the most appropriate resolution is for Milton Keynes to identify additional development sites now within Plan:MK. This could, and should, be done by Milton Keynes Council in similar timescales whilst AVDC is progressing the VALP.


Similarly, AVDC has pointed an inconsistency between the approach taken by Wycombe’s Local Plan Inspector in assessing the district’s housing requirement. Whilst Wycombe’s Inspector has advised she does not intend to publish interim findings, it’s not unfair to say that the Buckinghamshire SHMA (‘HEDNA’) was subjected to considerably less – blink and you’d missed it - scrutiny at Wycombe’s examination. Certainly, there has been no suggestion of an increase, consistent with Aylesbury.

My colleague James Donagh (Development Economics Director) advises “If we take the council’s point that Wycombe's housing need should comprise a greater uplift above demographic need than Aylesbury Vale, to reflect greater affordability pressures in Wycombe, it would be reasonable to assume that the uplift for Wycombe should be at least 25% and probably 30%, increasing housing need to between 14,000 and 14,200, compared to the Councils (Wycombe and Aylesbury Vale) assessment that Wycombe has a need for 13,100 homes. If we combine these, objectively assessed need for Aylesbury Vale and Wycombe reaches a probable 36,200, compared to the Councils assessment of need for 32,500 homes.”

Like Milton Keynes Council on the topic of early reviews, Wycombe will unlikely thank AVDC for identifying a potential inconsistency.

It would not be surprising for Milton Keynes’ and Wycombe’s Inspectors to set out the circumstances explaining why different approaches have been taken on these issues. One could sympathise with AVDC for raising concerns in the consistency of approach taken by Inspectors. It is right that the specific circumstances vary and this could explain such differences. But, in this case, the circumstances are so similar that justifying different approaches could be difficult.

Perhaps now is the time for MHCLG and PINS to begin taking a tougher line in supporting Local Plan preparation, as Mr Clark is doing at Aylesbury. An effective plan-led system relies on plans that meet the tests of soundness. As one now retired Inspector wrote in early 2015, ‘a planned review cannot make an unsound plan sound’. Wise words!

Posted with the following keywords:
Household projections, housing need, Standard Method, Aylesbury, Wycombe