Aylesbury Vale Area

Object

VALP Main Modifications

Representation ID: 2936

Received: 11/12/2019

Respondent: Buckingham Town Council

Legally compliant? No

Sound? No

Representation Summary:

The removal of this site is based on flawed and incomplete evidence in the view of the Buckingham Town Council, which means that it is not soundly based on evidence. The implications of the removal of this site for VALP have not been reflected in the rest of the document and which makes the Plan unsound through lack of internal consistency.

Change suggested by respondent:

Reinstatement of 300 homes at site BUC 051 or removal of all allocated sites from Buckingham pending further traffic modelling.

Full text:

The removal of this site is based on flawed and incomplete evidence in the view of the Buckingham Town Council, which means that it is not soundly based on evidence. The implications of the removal of this site for VALP have not been reflected in the rest of the document and which makes the Plan unsound through lack of internal consistency.

1. AVDC's justification for removal of site.

1.1 In Paragraph 2 there appears to be an incorrect assumption made regarding other sites in the BNDP [Site references are those of the BNDP]. To quote ED 215B -"The reserved allocated site, Site M, will only be required if one or more of the allocated sites with a total of 80 outstanding units is not brought forward before 2025." It is then stated that the council is confident that Sites G & I (having an allocation of 400 & 100 respectively) will be brought forward by then.

1.2 Site G (400) has indeed been brought forward and is under construction, along with site H (50) homes as part of the St Rumbold's Fields development.

1.3 It is noted elsewhere that Sites J (39) & K (28) are unlikely to be brought forward before 2023/2024 and there does not seem to be any immediate interest in developing these sites at present. If not brought forward by 2025 these sites could contribute to the shortfall of 100 houses which would trigger the release of the Reserve Site.

1.4 It is submitted that it is erroneous to assume that Site I will be brought forward by 2025. The site forms part of the Tingewick Road Industrial Estate. Unit A is occupied, and Unit C has been recently renovated and is currently being marketed for let. BTC has been in contact with the letting agents who confirmed that their instructions from the owner were to let the premises. Given the renovation work, it is perhaps uncertain that the owner intends to sell the land for development in the near future.

1.5 There is a good possibility that the Reserve Site would have been triggered in 2025.

1.6 In paragraph 4, reference is made to the Inspector's Interim Findings (August, 2018) in particular paragraph 49 of that document. The Inspector himself will be best placed to know his own meaning here, but it can be read to inquire as to why apparently necessary infrastructure to facilitate development is not included in VALP. This paragraph appears under the sub-heading Infrastructure and this site is one of a number so identified throughout the district cited therein. It is not abundantly clear that this was not simply pointing to the lack of completeness of the draft, rather than pointing out the potential non-viability of the site itself, although that appears to be the interpretation that AVDC has chosen to place upon it.

1.7 AVDC seeks to rely on the further modelling undertaken by BCC and the selection of the second option that produced, which was to remove the site from VALP . What was not then done was to consider properly where that would leave Buckingham as the second settlement during the Plan period. It is true to say that the BNDP has delivered significant housing through site allocations that are being developed as well as windfall, brownfield and infill numbers, facilitated by the BNDP's policies. The argument based on the available evidence set out in 2 below, demonstrates that it should not be Site M alone that is removed but the additional sites allocated by VALP. This leaves Buckingham with few options for sustainable growth unless a Western Link Road is part of the infrastructure, and that inability should be reflected in the whole of VALP with necessary modifications.

1.8 Again in paragraph 7 of ED215B, AVDC appears to be attributing its reasoning to the words of the Inspector in his Interim Findings. Paragraphs 36 & 37 are quoted. These paragraphs appear under the sub-heading Spatial Development Strategy and thus are not necessarily as aligned with paragraph 49 above, as AVDC seems to think. Again the Inspector will be best placed to know his own meaning, but the view of BTC is that this is a much wider discussion of policy in the context of a need for further housing allocation, and noting that the north of the Vale needed to provide housing for workers commuting to Milton Keynes, who would need to commute even further from the majority of housing allocation around Aylesbury. It is not necessarily apparent that it was a justification for removing housing allocations from Buckingham ( & Winslow and Steeple Claydon) and placing them in North East Aylesbury immediately adjacent to Milton Keynes. This is especially so when paragraph 35 of the Interim Findings is read - "Yet all three of the northern settlements lie within the Milton Keynes Travel to Work Area and the Milton Keynes Housing Market Area." In paragraph 36, there is an acknowledgement that Buckingham (& Winslow) are attempting to provide employment and services to ensure that they do not become dormitory towns for employment. In addition VALP itself denotes Silverstone as the major employment centre in the north of the Vale, but is placing a large amount of housing at a greater distance from that employment site.

1.9 BTC asserts that this interpretation by AVDC does not bear close scrutiny and thus does not justify the removal of site BUC051 in isolation from the rest of VALP as it seeks to do.

2. Specific Evidence as to traffic congestion in Buckingham
2.1 The Buckingham Transport Strategy [BTS] is the main evidence document for transport infrastructure needs in Buckingham in the evidence base of VALP.

2.2 Although it is stated that further modelling etc will be required, the BTS ranks in terms of priority the Western Link Road highest in terms of the goals of the BTS, primarily reduction of town centre congestion as a result of through traffic; and the left hand slip lane for A422/A413 roundabout the lowest.

2.3 In the BTS BUC051 is taken as a commitment and the additional development is at BUC025 [a site further west of BUC046 on the A422]; BUC043 [Moreton Road]; BUC046 [Osier Way]. It also assumes that Silverstone Park to the north is a future employment centre.

2.4 The additional modelling is supplied by ED 214A & ED 214B, the need for which is stated to have arisen out of a discussion at the Public Hearings in July 2018.

2.5 The conclusion is that a Western Link Road could not be supported by the level of development so far allocated. The first option suggested by BCC is to bring forward increased development, but that has been rejected by AVDC in favour of the second option, which is to remove BUC051 from VALP. Although not stated it could be assumed that with the time constraints on an already delayed Local Plan, this was the easiest & quickest option, but it was not the only option as appears to be suggested in ED 215B by AVDC. It is submitted that this is further evidence of the tendency identified by the Inspector in his Interim Findings to not place the same criteria to planning in the north of the Vale.

2.6 The problem is that the further modelling does not give the whole picture of the impact of all allocated development in Buckingham on the traffic congestion modelled to this level.
ED 214A by Jacobs considers the possibility of reducing the development at BUC051 to 125 homes, assuming that BUC043; BUC046 & MM006[DS2] remain as well as all development at original stated numbers [DS]:

"As requested by BCC, a Buckingham Town Centre Model was developed to assess the impacts of the proposed Local Plan developments on an already congested Buckingham Town Centre, and also to assess if a reduced amount of development at BUC051 would be feasible without mitigation measures to remove traffic from the town centre. In this model, two roundabouts were included and assessed: Bridge Street/WestStreet/Market Square roundabout and Moreton Road/Stratford Road/Market Square roundabout.......
In summary, both town centre junctions are already operating over capacity in the 2033 DM and therefore the additional marginal impact at these junctions in the DS and DS2 scenarios is unacceptable, even with a reduced quantum of development in DS2. In both DS and DS2 scenarios, appropriate mitigation measures would need to be considered."

The main focus is the two junctions: Bridge Street & West Street & Moreton Road/A422 Stratford Road. The conclusion being that even without development allocated, the junctions will be over capacity at the end of the Plan period.

2.7 So any further development will cause further congestion in the town centre - not just the addition of BUC051.
2.8 ED 214B runs modelling removing BUC025 and including BUC051 to the original Countywide modelling. This seemed to conclude that there was little difference.
2.9 What has been absent from the two new reports is any assessment of the impact of the other sites - MM06; BUC043 & BUC046.
2.10 BUC046 is a site on the A421 by-pass, it could be argued that traffic generated will use the A422 to either the A421 junction to Milton Keynes or continue to A413/422 roundabout. At this junction traffic heading towards Milton Keynes intuitively will not benefit from a left hand slip lane mitigation; traffic heading from Milton Keynes to BUC046 development may be assisted by it in that stated aim would be to avoid travelling through town centre. It seems unlikely that it would do so anyway unless to access town services.
2.11 Traffic from BUC046 heading to the major employment centre at Silverstone Park may still seek to access A413 from town centre or A43 from West Street.
2.12 BUC043 on the A413 Moreton Road. It is assumed that traffic heading to Milton Keynes will drive down to junction at A413/A422 [ignoring possible short cut down Addington Road to A422; or alternatively driving to Maids Moreton and accessing A422 via Mill Lane - this route already shows heavy use in the various models] and then proceed to A413/A422. There will still be traffic at this junction as the left hand slip lane encouraging traffic to use A413 to the west, will not assist in this direction of travel.
2.13 The reverse journey on return from Milton Keynes may be assisted by traffic using left hand slip lane, easing queues, and easing traffic entering town centre [though it is not apparent why traffic seeking to remain on A421 to the west would do so anyway. It will not assist traffic which wishes to remain on A422 to access A43 [though the left hand slip lane in conjunction with a Western Link Road further along would.] That is assuming vehicles have not used Mill Lane access to Maids Moreton.
2.14 It would appear intuitively that little is eased by mitigation measure.
2.15 MM06 would intuitively follow the same pattern as BUC043, except that it is much more likely that Mill Lane access to A422 would be used. The current levels of use of this road are clear on the modelling diagrams, although it is not the focus of the reports.
2.16 This mitigation scored the lowest of the possibilities in the BTS.
2.17 There is no evidence presented by AVDC as to why removing BUC051 prevents further traffic congestion as opposed to the removal of BUC046 & BUC043 as development sites. ED 214B suggests that removing BUC025 and replacing it with BUC051 has little impact. Therefore it could be reasoned, albeit at a simple level, that BUC046, which is also sited on A421, could be removed. There has been no modelling done to prove or disprove this.
2.18 Given the findings as to the junctions, and given that MM006 & BUC043 will undoubtedly impact on one of these junctions substantially, it is surprising that no further modelling work evidence has been commissioned or brought forward by AVDC to justify the inclusion of these sites but the removal of BUC051.
2.19 BTC submits that there is insufficient holistic evidence to support the removal of BUC051 from VALP on the reasons given by AVDC.
2.20 As is stated above, there is no attempt to consider holistically the impact of this decision on the related policies within VALP as outlined above.