Aylesbury Vale Area

Object

VALP Main Modifications

Representation ID: 3423

Received: 17/12/2019

Respondent: Mr Phil Yerby

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

(Officer's summary)

Of particular concern are the inconsistencies in what is claimed in delivery times
for critical infrastructure which directly conflicts with already published draft
s106 documents for both AGT4 (specifically planning app 16/00424) and AGT3
(specifically planning app 16/01040). Detail is within the submission from HFAG.

Change suggested by respondent:

Not provided

Full text:

Aylesbury Vale District Council Local Plan Examination
Main Modifications
I am a former Aylesbury Vale District Council (AVDC) cabinet member and local
District Councillor for Stoke Mandeville, Weston Turville and Stoke Mandeville. I
founded the Hampden Fields Action Group in 2011 and continue to be an active
member (I fully support the HFAG submission to you). As such I have taken a
very active interest in the development of the various iterations of Aylesbury
Plan for the past ten years as far back as the South East Plan which was made
defunct in 2010. I came before you during your 2018 public hearings into the
VALP regarding AGT3 and the Transport Strategy.
I would like to make the following points in consideration of the Main
Modifications proposed by AVDC which I hope will assist in drawing together
some key elements.
Countywide Model
This model has been significantly criticised from at least five different
independent sources. Those independent assessments have been made by:
1. Transport Planning Practice, an Independent Transport Consultancy
with expertise in modelling, especially Mr David Thompson who
appeared before you on 20th July 2018 and has revisited the VALP
since the publication of the Main Modifications;
2. Mouchel Ltd on behalf of Highways England in correspondence to
BCC obtained under Freedom of Information (attached to this
letter);
3. Milton Keynes Council in a letter to the Inspector dated 16th
December regarding the VALP main modifications (obtained from
Milton Keynes public records);
4. Aecom itself, BCC's own transport consultants in correspondence to
BCC and contained within supporting VALP documentation
5. Dr Cullen Riley in documentation on behalf of La Salle LLP and to
the public hearing meeting of 20th July 2018
I will not repeat those very clear and consistent criticisms here but it must now
be clear that the model is not suitable for the purposes it is being used for. We
all understand that in some circumstances these limitations may be overcome
and a non webTAG compliant model can be used for some Local Plans. However,
in the case of the VALP, where such significant infrastructure requirements are
proposed, the approach is unsound. NPPG Guidance "Transport Evidence Bases
in Plan Making" published 13th March 2015 makes it very clear on this specific
point:
"How is the WebTAG approach useful in the transport assessment
of the Local Plan?
An assessment should adopt the principles of WebTAG by assessing the
potential impacts of development within the framework of WebTAG
objectives. For most Local Plan assessments the full methodology
recommended will not be appropriate. The Highways Agency's Project
Appraisal Report System may provide some useful guidance on methods
more appropriate in these cases. Assessments involving major new
transport infrastructure should, however, employ the methods set out in
WebTAG."
It is common ground that the VALP contains "major new transport infrastructure"
including roads that have been deemed "essential" in order to be built on Level 3
floodplain. The argument that the Countywide Model is "based on WebTAG
principles" fundamentally fails to acknowledge this guidance when taken as a
whole, the significant and vast underperformance of this model within the Local
Market Validation Report and the margin of non-compliance is significant i.e.
screenline and journey time validation among many others.
In addition, it is not in dispute that the base model is now six years out of date.
Aylesbury has undergone significant underlaying traffic growth since that time and
the model underperforms in key areas where major development is proposed, e.g.
Halton/Wendover.
The model needs to be updated, WebTAG compliance achieved and new model
runs presented to the public and the Inspector.
Aylesbury Transport Model (ATM)
In some circumstances, weaknesses in the broad countywide models may be
overcome by more local, WebTAG compliant models which focus on a specific area
or town. In such a situation, the more detailed local model could be relied on to
'bridge gaps' in the broader model. In the case of the VALP no such models exist.
The Aylesbury Transport Model has only been validated for one small section of
the town (the Eastern section) yet it is being used to justify the Aylesbury
Transport strategy and significant housing growth not only around the town. Such
an approach cannot be justified.
The Inspector will be aware that a WebTAG compliant model must be in place
before any public money will be invested. That means the ATM must be in the
process of being updated or certainly should be. Why have any new or updated
model runs/outputs not been released to the public and the Inspector?
Aylesbury Transport Strategy (ATS)
The Aylesbury Transport Strategy has now become part of the VALP. There is no
evidence that is before the public or the inspector that the ATS can be justified.
The premise of cross-town commuting is assumed in the ATS but no supporting
evidence exists beyond one Origin and Destinations survey from 2014. This 'myth'
has been passed on and amplified by BCC and AVDC in various documents as far
back as the 2001 Aylesbury Land Use and Transport Strategy (ALUTS). No
"reasonable alternative" has been considered from the outset.
The Inspector will note that it appears the VALP no longer relies on Bucks
County Council's (BCC) flagship Transport policy Local Transport Plan 4
(LTP4). At paragraph 46 of the interim findings the Inspector stated "The
Buckinghamshire Local Transport Plan 4 is not even part of the evidence base for
VALP". In the main modifications document all reference to LTP4 has been
removed. It appears BCC have no confidence in a document relied on previously
to support the Aylesbury Transport Strategy and VALP.
At the Public Hearing on 20th July 2018 the BCC representative reassured the
hearing that the "latest data shows that it [cross town commuting] is significant".
I noted the use of the present tense to suggest that such data was already at an
advanced stage of preparedness - why else would the BCC representative have
made such a claim? Nearly 18 months on, again I cannot find any updates released
to the public or to the Inspector.
Thus, there remains no documented evidence before the Inspector to demonstrate
that the Aylesbury Transport Strategy has been positively prepared or will be
effective. Additionally, there appears not to have been any consideration of
reasonable alternatives, which means that the plan cannot be justified.
Road Alignments
At paragraph 50 of the Inspector's Interim findings he states:
"If, in the modifications which the Council should prepare in
response to my recommendations, it is decided to show what could
be interpreted as a precise alignment, the Council will need to bear
in mind NPPF paragraph 152. This advises that significant impacts
on any of the dimensions of sustainable development should be
avoided and, wherever possible, alternative options which reduce or
eliminate such impacts should be pursued."
I cannot be sure what the Council's position is regarding this point. It appears
not to have been addressed. It is clear from specific planning applications
relating to AGT3 (AVDC reference 16/1040/AOP) and AGT4 (AVDC ref
16/0424/AOP) that for the ELR(S) and the Southern Link Road the road
alignments in VALP are those already approved at Committee by the Council as
exact alignments. Reasonable alternatives, including those that would have a
lesser impact on the flood plain, have not been considered. (The inspector may
want to refer back to Hampden Fields Action Group's evidence on what they and
I regard as inadequate sequential testing).
Deliverability
Like others I remain concerned about the 'book end' approach to costing of
major infrastructure projects which plan to be delivered in such a short
timescale. Even if we were to accept the Countywide model in its entirety we
know from the model runs that all the infrastructure contained in Run 2 is
required for what they believe to be adequate mitigation. What is clear is that if
any part of that infrastructure fails to come forward the whole strategy fails.
Of particular concern are the inconsistencies in what is claimed in delivery times
for critical infrastructure which directly conflicts with already published draft
s106 documents for both AGT4 (specifically planning app 16/00424) and AGT3
(specifically planning app 16/01040). Detail is within the submission from HFAG.
Both North East Aylesbury Link Road (NEALR) and the Western Link Road (WLR)
are now claimed to be deliverable within the plan period when previously they
were not. According to page 92 of the Main Modifications document the NEALR
is to be funded by the "Oxford to Cambridge Expressway". This statement
appears to lack any publicly documented evidential base given the preferred
route alignment announced by the Government. Whilst it is stated that the
Western Link Road is "likely to require grants e.g. DfT.".
BCC have applied for a Housing Infrastructure Fund grant which, according to
the BCC Cabinet papers from February 2019, they anticipated getting approval
for in June 2019 but no such funding has been announced, possibly because of
the lack of a webTAG compliant basis for the request.
Even in the most optimistic case that the grant is given in full it remains unclear
that the infrastructure mitigation costs can be covered, let alone delivered on
time. Accordingly this section of the plan is not positively prepared.
What must be done to make the VALP sound?
1. A webTAG compliant model must be developed using 2019 (or 2020) as
the base year including up to date actual traffic counts. It must accurately
reflect the current situation on the Aylesbury network as it is required to
by NPPG. It must be fully validated given the infrastructure requirements
of the plan.
2. New model runs must be completed and made available to the public for
scrutiny.
3. Alternative road infrastructure should be considered within the updated
model runs.
4. Alternative alignments that have a lesser impact on the floodplain should
also be considered.
5. It naturally follows that the Aylesbury Transport Strategy should be
revisited in line with points 1-4 above.
6. Funding and timing of key infrastructure needs to be demonstrated to be
deliverable.
I hope this assists the Inspector with his examination. I am very happy to
provide more information should he wish and am willing to attend any Public
hearing should he feel one is necessary.