Aylesbury Vale Area

S4 Green Belt

Showing comments and forms 1 to 19 of 19

Object

VALP Proposed Submission

Representation ID: 124

Received: 02/11/2017

Respondent: Penny Miles

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation:

I do not feel that the removal of the Green Belt restrictions from RAF Halton adheres to the national guidelines relating to removal of this status

Full text:

I do not feel that the removal of the Green Belt restrictions from RAF Halton adheres to the national guidelines relating to removal of this status

Object

VALP Proposed Submission

Representation ID: 515

Received: 10/12/2017

Respondent: Mrs Roz Green

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

I am concerned about the word 'inappropriate' in the statement 'The Green Belt will be strongly defined and protected from 'inappropriate' development'. It is ambiguous and can be interpreted to give a desired answer. The Green Belt should be protected without any alteration to its boundaries.

Officer note: changed from support to Object - due to criticism

Full text:

I am concerned about the word 'inappropriate' in the statement 'The Green Belt will be strongly defined and protected from 'inappropriate' development'. It is ambiguous and can be interpreted to give a desired answer. The Green Belt should be protected without any alteration to its boundaries.

Support

VALP Proposed Submission

Representation ID: 552

Received: 08/12/2017

Respondent: Chiltern Society

Representation:

We strongly support the inclusion of a specific policy in relation to the Green Belt, which is consistent with national policies in paragraphs 79 - 91 of the National Planning Policy Framework. In particular, it is important to preserve the openness of the Green Belt and fulfil the 5 purposes for including land within it.

Full text:

The Chiltern Society is a charitable body with 7000 members. We campaign for the conservation and enhancement of the Chilterns National Character Area, which includes the Chilterns Area of Outstanding Natural Beauty (AONB) and part of the London Green Belt. Our role in the planning system is coordinated through a network
of voluntary planning field officers and co-ordinators. As drafted we consider that the allocation of the RAF Halton site could lead to the site's removal from the Green Belt in the long term and would therefore not be consistent with national policy as set out in paragraphs 79 - 91 of the National Planning Policy Framework (NPPF). In particular the development must satisfy paragraphs 79 and 80 relating to the openness and permanence of the Green Belt and the 5 Green Belt purposes. The Council has not demonstrated that exceptional circumstances exist for potentially removing the site from the Green Belt in future, thus contradicting 83 of the NPPF. We do not accept that pressure for housing is a valid reason for demonstrating exceptional circumstances. The RAF Halton site is located entirely within the Green Belt and in the immediate setting of the Chilterns AONB. Therefore we consider that any development here must be carefully designed to fullyrespect these designations.

Object

VALP Proposed Submission

Representation ID: 632

Received: 13/12/2017

Respondent: Mr Andrew Docherty

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

The 25-30% extension/replacement building guideline should be expressed as excluding, or after, permitted development rights, which do not require express planning permission.

Full text:

The 25-30% extension/replacement building guideline should be expressed as excluding, or after, permitted development rights, which do not require express planning permission.

Support

VALP Proposed Submission

Representation ID: 684

Received: 13/12/2017

Respondent: Whaddon Parish Council

Representation:

WPC Support.

Full text:

WPC Support.

Object

VALP Proposed Submission

Representation ID: 1108

Received: 14/12/2017

Respondent: South West Milton Keynes Consortium

Agent: Carter Jonas - Associate SWMK Consortium

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

Green Belt Assessment Part 2 - RAF Halton (July 2016)

do not consider conclusions of assessment to be sound. a site already previously developed is not in itself justification for its removal from Green Belt. It is the contribution towards openness that the site makes that should be assessed. The assessment undertake suggests the site contains substantial built-form. This is disputed, whilst a number of the buildings are substantial in their own right (up to three storeys in height) they are concentrated in a small part of the site and are listed. Their setting is protected by the surrounding openness.

Full text:

Please find attached representations to the Proposed Submission Vale of Aylesbury Local Plan consultation, which are submitted on behalf of the South West Milton Keynes Consortium.

In summary, representations are made to the following:

* Paragraphs 1.9 to 1.12
* Paragraph 1.13
* Paragraph 1.17
* Paragraph 2.4
* Paragraph 2.6
* Policy S2 + Objection to Policy S2 Report
* Policy S4 & Paragraphs 3.25 to 3.35 + [2016] EWCA Civ 466 Judgement
* Policy S5 & Paragraphs 3.36 to 3.46
* Paragraphs 3.75 to 3.77
* Paragraphs 3.78 to 3.80
* Policy D1 & Paragraphs 4.1 to 4.29
* Policy D-NLV001 & Paragraphs 4.110 to 4.119
* Additional Allocation D-NLV020 + Environment Agency Flood Mapping Plan, Landscape & Visual Technical Note, Highways & Transport Note, Highway Improvements Plan and Concept Masterplan
* Policy D-HAL003 & Paragraph 4.131 to 4.138 + Landscape & Green Belt Statement
* Policy T1 + Highways & Transport Note
* Housing & Economic Lands Availability Assessment (January 2017) + Concept Masterplan and Landscape & Visual Appraisal
* Sustainability Appraisal (September 2017)
* Green Belt Assessment Part 2 - RAF Halton (July 2016)

Those representations which are supported by a separate technical document or plan are provided in a separate e-mail.

Can you please confirm receipt of these representations, and continue to keep us informed of progress with the Local Plan?

Object

VALP Proposed Submission

Representation ID: 1195

Received: 14/12/2017

Respondent: Newton Longville Parish Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

The review carried out for the four Buckinghamshire districts was not robust or thorough. The housing density should be consistent. Assess the contribution Green Belt sites make to the Green Belts purposes and identify the exceptional circumstances needed to release Green Belt land. Give more consideration to the issue of the lack of suitable sites as being exceptional circumstances which justify the release of some Green Belt land. Green Belt within southern Aylesbury Vale could meet housing need around Aylesbury. Consider a new Green Belt in northern Aylesbury Vale on the Milton Keynes boundaries. Consider a Strategic Green Gaps policy.

Full text:

Please see attachment for full rep

Submission draft version of Vale of Aylesbury Local Plan (VALP)
Representation by Newton Longville Parish Council - 14th December 2017
Newton Longville Parish Council representation - AVDC VALP submission draft Page 1 of 42
1. Introduction
1.1. This submission endorses the submission made by North Bucks Parishes
Planning Consortium (NBPPC) which should be read in conjunction with this
submission.
1.2. Newton Longville Parish Council consider that the draft plan is capable of
being found legally compliant and sound, subject to modifications being
made to the plan to deal with the issues highlighted below. Whilst issues are
identified on compliance with the Duty to Cooperate, it is hoped that it is a
lack submission of evidence rather than a failure to comply. These issues
had been pointed out to AVDC prior to publication of the draft submission
plan.
1.3. Newton Longville Parish Council requests participation at the Examination in
Public in relation to the points raised in this representation as well as those
made and in the submission by NBPPC. The parish council wishes to take
part in discussions on the plan and on modifications that may be required.

Object

VALP Proposed Submission

Representation ID: 1259

Received: 08/12/2017

Respondent: Chiltern Society

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

We consider that the RAF Halton site should remain within the Green Belt in the long term and that any development should not reduce the openness of the Green Belt. The plan should remove the reference to removing the site from the Green Belt in the future.
We support the proposal to prepare a Masterplan to design a high quality scheme with landscaping and green infrastructure to avoid detrimental impacts on the setting of the Chilterns AONB.

Full text:

The Chiltern Society is a charitable body with 7000 members. We campaign for the conservation and enhancement of the Chilterns National Character Area, which includes the Chilterns Area of Outstanding Natural Beauty (AONB) and part of the London Green Belt. Our role in the planning system is coordinated through a network
of voluntary planning field officers and co-ordinators. As drafted we consider that the allocation of the RAF Halton site could lead to the site's removal from the Green Belt in the long term and would therefore not be consistent with national policy as set out in paragraphs 79 - 91 of the National Planning Policy Framework (NPPF). In particular the development must satisfy paragraphs 79 and 80 relating to the openness and permanence of the Green Belt and the 5 Green Belt purposes. The Council has not demonstrated that exceptional circumstances exist for potentially removing the site from the Green Belt in future, thus contradicting 83 of the NPPF. We do not accept that pressure for housing is a valid reason for demonstrating exceptional circumstances. The RAF Halton site is located entirely within the Green Belt and in the immediate setting of the Chilterns AONB. Therefore we consider that any development here must be carefully designed to fullyrespect these designations.

Object

VALP Proposed Submission

Representation ID: 1271

Received: 08/12/2017

Respondent: Arnold White Estates

Agent: Gardner Planning Ltd

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Representation:

The text at para 3.31 and 3.33 is supported, but S4 needs to refer to a change of Green
Belt boundary.

Full text:

I attach the response to the consultation on the Proposed Submission VALP on behalf of Arnold White Estates. This is in the format of a full written Response because it deals with matters that cannot be adequately set out in a simple form.
However, a completed facsimile of you form is attached as an appendix with contact details and a summary of the representations (by policy number on separate sheets).
Please acknowledge receipt, note that I wish to participate in the Examination and keep me advised of progress.

Full summary given where it was more than 100 words (more detail in the main report):

S2

1. In order for the Plan to be 'sound' it must be based on robust evidence. The ORS
HEDNA, and thus the basis for the housing numbers in Policy S2 of the PSVALP, is long
and detailed, but essentially flawed. Its robustness is challenged by comparison with
three other sources in which ORS arrives at an annual OAN (970 homes p.a. for the
District) which is well below these: the ONS household projections (1,092), the GL
Hearn 2015 HEDNA (1,326) and the DCLG new methodology (1,499). Even the early
versions of the VALP/HEDNA had a higher OAN based on ONS 2012 projections. Yet
when these figures rose in the 2014 based projections (from 18,404 to 21,028) the
ORS figures fell (from 21,289 to 19,385). Also, the adjustment for migration trends
and other adjustments seem to fluctuate wildly (compare fig 109 in October 2015
with fig 122 in September 2017).
2. The HEDNA's low number is based on an early assumption that the use of a 10-year
migration trend is superior to that which continues to be used by ONS, even though
ORS have raised this point many times in recent years and are likely to be in close
touch with ONS. The ORS methodology reduces the ONS 'demographic starting
point' by over 4,000 households or 19%. There are then many further 'adjustments'
which are very detailed but almost incomprehensible. Even without the higher
numbers of the DCLG new methodology, it fails the test of "simpler, quicker, and
more transparent". A principle of the new methodology is to add a margin well
above household projections. Whilst the DCLG 2017 consultation states that Plans
submitted before 31.3.17 "will continue with the current plan preparation", the ORS
HEDNA numbers are so different to those derived from other sources that a complete
re-assessment is required and the PSVALP should then be based on the new, simpler
and transparent methodology.
3. The GL Hearn 2015 HEDNA arrived at an OAN (without allowance for accommodating
unmet housing needs of adjoining Authorities) of 1,326 home p.a. mainly because it
added housing needs of greater economic growth. The Cambs-MK-Oxford Growth Corridor vision and proposals of 2017, supported in the Autumn Budget, reinforce
and extend that growth potential and the consequent need for more housing.
4. The provision for unmet housing needs of adjoining Authorities may be inadequate
when the new DCLG methodology is applied to their numbers which are significantly
higher than currently anticipated.
5. The 5-year housing land supply figures are wrongly calculated in PSVALP paras 3.78 -
3.80 and Table 7 because inadequate provision is made for 'persistent underperformance'
and the correct figures show that a 5-year supply cannot be provided.
This is contrary to NPPF para 47.
6. PSVALP Policy S2, in terms of housing numbers, is therefore unsound because it is
not:
* Positively prepared - the objectively assessed housing needs are not based on
clear and robust evidence, and unmet requirements from adjoining Authorities
may be higher than anticipated.
* Justified - this is not the most appropriate strategy based on the evidence.
* Consistent with national policy - no account is taken of the Housing White
Paper and the growth proposals for the Cambs-MK-Oxford Corridor; and
provision for the 5-year housing land supply is inadequate.

D1 & S2

1. Whilst the term "Garden Town" is unobjectionable, the reality is that all the
Aylesbury sites are just urban extensions, two of which (AGT5 Berryfields and AGT6
Kingsbrook) already have planning permission and two (AGT3 Aston Clinton and AGT4
Hampden Fields) are the subject of applications submitted in early 2016.
2. In reality, therefore, the majority of "Garden Town" already (or almost) has planning
permission. Only two sites AGT1 (South Aylesbury) and AGT2 (South-West Aylesbury)
effectively seem open to discussion.
3. In relation to PSVALP Policies CP2 and D1, this Response raises objections to the
proposed allocation of both sites:
* AGT1 (South Aylesbury, 1,000 homes) is a collection of 6 small sites in different
ownerships without highway access, such that delivery must be in doubt.
* AGT2 (South-West Aylesbury, 1,550 homes) is severely constrained by HS2 of
which the centre line forms the south-west boundary of the site such that for at
least 100m into the site there can be no housing, and even beyond that living
conditions would be uncomfortable. The conclusion of the Core Strategy
Inspector's report in June 2010 on this site was "This would have a major
impact on the deliverability and potentially, the viability of the SGA, through
significant land take in the SW site".
The Plan is therefore unsound because
Positively prepared - two major sites have been allocated not based on clear and
robust evidence.
Justified - this is not the most appropriate strategy based on the evidence. Two
other sites proposed by GPL/AWEL are more sustainable, provide significant
benefits, are deliverable and are not adversely affected by HS2.
Berryfields East
1. The AWEL Berryfields East site (Appendix 3 in Full Response) to the NW of Aylesbury
should be considered as part of the growth of Aylesbury as a 'garden town'. The site
was submitted in response to the 'call for sites' in April 2014. It has a gross area of
some 20ha and a net developable area of some 11ha, with a capacity for some 350
homes.
2. The HELAA response was to raise concerns about landscape, impact on the setting of
the Scheduled Ancient Monument and biodiversity. These were broadly the reasons
for rejecting an appeal on the site in 2012. However, the scheme has been radically
revised since then to take account of the reasons for dismissal and has been
considerably reduced in terms of site area and numbers of dwellings. The appeal
decision related to some 1,380 dwellings on the larger site of some 33ha net.
Appendix 3 shows the revised illustrative masterplan, which has regard to the
Inspector's findings, and, for comparison, the rejected masterplan.
3. As well as a substantial reduction in site area and numbers of dwellings, the revised
scheme demonstrates significant changes since the last scheme was dismissed 5
years ago:
* The Western Link Road is now constructed and the Berryfields development has
advanced which changes the character and appearance of the local countryside
and the setting of the SAM.
* A substantial gap is provided between the eastern boundary of the
development area and Weedon Hill Urban Extension further to the east.
* Extensive open countryside in the new scheme would enhance the countryside
setting.
* The need for housing growth around Aylesbury is much greater than in
2010/12, and this Response has demonstrated that the PSVALP will have a
shortfall in requirements of thousands of homes.
* The site is unaffected by HS2.
* The landscape objection falls away because of the LUC study which designates
the nearest landscape designation being the Quainton-Wing Hills, some 2.76
km from the site to the nearest point just south of Weedon.
4. The HELAA seems to be assessing the 2010 scheme which is now superseded. The
new proposals are achievable, suitable and deliverable (the site is in single
ownership), and all within 5 years.
5. The proposal for the 'Aylesbury Linear Park' is supported. The plan on p66 is
somewhat difficult to read in the vicinity of Berryfields East but shows this Park as the
open land south of the Western Relief Road partly on land in the same ownership as
Berryfields East. Development on Berryfields East would therefore facilitate this
section of the Linear Park/green infrastructure network. Such integration of
development and green infrastructure is encouraged in Policy I1:
The Council will work with partners to ensure that existing and new green
infrastructure is identified, planned, delivered, enhanced and managed in a
strategic way as an integral part of supporting sustainable communities and
sustainable growth. The Council will implement the most up-to-date green
infrastructure strategies. Green infrastructure networks whether existing or
potential are expected to be a key part of site masterplanning as required in the
VALP.
6. Berryfields East, capacity 350 dwellings, should therefore be added to the list of
sites for Aylesbury in Policies S2 and D1.
Waddesdon
1. Waddesdon has been 'under-scored' in the settlement hierarchy by one factor -
distance to a main settlement - based on inaccurate measurement (see paras 2.28 -
2.30 above). In fact, Waddesdon is a 'large' large village with extensive facilities
(including a school, retailing, employment, good public transport, police and fire
stations, hotel and stately home), but is fundamentally harmed by the passage of
heavy traffic on the A41, which bisects the settlement.
2. However, Waddesdon is classed as a 'large village' in the hierarchy, which means
(emphasis in bold):
* As stated in the introduction to this report, the settlement hierarchy purpose is
not only to identify the current role of settlements through the facilities and
services they provide, but also to help define a sustainable settlement hierarchy
to facilitate decisions through the Vale of Aylesbury Local Plan on which
settlements are best placed to accommodate future development.
* Larger, more sustainable villages that have at least a reasonable access to
facilities and services and public transport, making them sustainable locations
for development.
3. Despite this encouragement, there are no housing allocations in the PSVALP for
Waddesdon.
4. In several places PSVALP mentions that the impact of HS2 will have to be mitigated.
This is particularly important to the opportunities for development at Waddesdon.
Here, HS2 passes close to the north of Waddesdon and the proposed AWEL
development (Appendix 4) includes mitigation measures that will shield the village.
5. The Inspector's Report on the NP included the following extracts:
In my assessment, the promotion of this major development to the north of the
village, together with a projected A41 Relief Road, is a matter of strategic districtwide
importance which falls properly to be considered as part of the preparation of
the VALP.
6. In several places PSVALP mentions that the impact of HS2 will have to be mitigated.
This is particularly important to the opportunities for development at Waddesdon.
Here, HS2 passes close to the north of Waddesdon and the proposed AWEL
development (Appendix 4) includes mitigation measures that will shield the village.
7. The proposed development at Waddesdon (Appendix 4 in full Response) includes the
advantages as fully set out in the full Response, e.g.
* provision of some 600 homes, either in the context of the housing shortfall
detailed or as an opportunity site
* the creation of a Garden Village development
* facilitation of a relief road and improvements to the central area of the village
* provision of a village green
* improvement to the appearance of the site by removal of poor and redundant
agricultural buildings
8. These are interesting times when much of planning orthodoxy is being overturned in
order to meet society's real needs (especially housing). It is turning away from
negative stances of protectionism against development towards positive action which
benefits all parts of the community which it serves. The first policy (S1) in the DP
begins:
The council will work proactively with applicants to find solutions so that proposals
can be approved wherever possible, and to secure development that improves the
economic, social and environmental conditions in the area.
9. AVDC has the opportunity to put this into practice at Waddesdon and include the
AWEL development proposal as a strategic site in the Local Plan in Policies S2 and
D1.

Object

VALP Proposed Submission

Representation ID: 1691

Received: 14/12/2017

Respondent: Richborough Estates

Agent: RPS Planning & Development

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

It is noted that some 800 dwellings are proposed to be placed in land which is currently occupied by the Green Belt. Given the Spatial Vision (Criterion a) is to 'strongly protect the Green Belt', RPS would suggest there exists the potential for conflict within the Plan.

Given this potential conflict RPS would suggest the Council give greater consideration to the positive allocation of additional land on land outside the Green Belt in settlements in the south of the District, including Haddenham

Full text:

Attached report makes comments to the Proposed Submission VALP, by RPS on behalf of our client Richborough Estates, contains full comments on the policies and includes at appendix 1 a Housing Need Technical Review by Barton Willmore (November 2017).

Object

VALP Proposed Submission

Representation ID: 1836

Received: 14/12/2017

Respondent: Paul Newman New Homes.

Agent: Development Planning and Design Services Ltd

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation:

The Council have failed to demonstrate 'exceptional circumstances' to justify inclusion of the sites west of Leighton-Linslade, particularly given the justification to 'balance the loss of the Green Belt in other areas' despite the VALP abandoning proposals to remove Green Belt land at Wendover. The flawed assessment relies on an out of date and withdrawn policy context and it is clear from the planning history that normal development management policies have been adequate in protecting the site from development. Furthermore it is considered that sites which perform equally or more strongly than these sites should be considered preferable.

Full text:

Attached representations to the Proposed Submission Vale of Aylesbury Local Plan prepared and submitted on behalf of Paul Newman New Homes.

PNNH control approximately 42.4 hectares of agricultural land to the west of Leighton Linslade in the east of the District. The site is located within the parish of Soulbury immediately adjacent to the built up edge of Leighton Linslade between the existing town and the Stoke Hammond and Leighton Linslade bypass (A4146).

Object

VALP Proposed Submission

Representation ID: 1870

Received: 11/12/2017

Respondent: Halton Parish Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Yes

Representation:

Remove all references to lifting of Green Belt or other protected status on land within Halton.

Full text:

Halton Parish Council (HPC) supports AVDC's desire to provide housing on the current RAF
base sited within Halton within the existing building footprint on the site. This is providing that
sufficient employment, leisure, retail and infrastructure are included as part of any housing
development. Whilst HPC acknowledges that the Defense Infrastructure Organisation (DIO)
wants to sell the land for the highest price, HPC is keen to ensure that protected land, including
land with green belt status, is preserved for future generations during the opportunity to build on
to-be-vacated Ministry of Defense (MoD) land. Whilst the HPC has not been engaged in the
development of the VALP, we welcome the opportunity to add local knowledge to ensure that
development of the MoD land is of sufficient quality commensurate with the local area.
Issues
 Some of the VALP wording suggests that the 1,000 houses will be sited in Wendover,
not Halton.
 Halton will need to lose its classification as a "smaller village".
 Halton is not part of a strategic settlement.
 The VALP is unclear that the dwellings proposed for the RAF Halton site are within
Halton.
 HPC looks forward to early involvement in producing the Masterplan / SPD specific to
land in the parish of Halton.
 Information and Infrastructure
 Green Belt and Other Protected Land.
 Mixed Use
 VALP Policy map.
 Infrastructure
 Transport.
 Remove Uncertainty.

Support

VALP Proposed Submission

Representation ID: 1905

Received: 14/12/2017

Respondent: Central Bedfordshire Council

Representation:

We fully support the conclusions of the Council with regards to Green Belt, and in particular welcome the extension of the Green Belt West of Linslade in order to provide a comprehensive approach to Green Belt policy.

Full text:

see attachment

Object

VALP Proposed Submission

Representation ID: 2018

Received: 14/12/2017

Respondent: Crest Strategic Projects

Agent: Savills Southampton

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

VALP allocates RAF Halton (a Green Belt site), the correct (and sound) approach would be to justify any redevelopment of that site via exceptional circumstances, and hence to remove the appropriate areas of land from the Green Belt. It has been acknowledged by AVDC that there is not the evidence base to justify the allocation / amendment of Green Belt boundaries at this time. Thus, the allocation is premature, and the proper approach, as advocated by the NPPF, is to consider major development in the Green Belt only in 'exceptional circumstances'.

Full text:

On behalf of Crest Strategic Projects (CSP), I enclose a suite of documents as formal representations on the above plan.

The lead representations statement (Savills) provides a detailed account of CSP's stance on the VALP as a whole. A range of inter-related objections are set out, relating to the amount and distribution of housing, site-specific allocations, and the consideration of alternatives within the Sustainability Appraisal. Particular objections are raised in respect of Shenley Park (site WHA001), which was included in the previous draft of the VALP, but is now omitted; and proposed allocation sites at RAF Halton, Buckingham and Winslow, which CSP objects to. The document should be read in conjunction with the following appendices:

* Appendix 1a - Shenley Park Vision Statement (Savills Urban Design Studio). This demonstrates and explains how the proposed development of Shenley Park can be delivered, not simply as a means to meet growth requirements for Aylesbury Vale in an optimal location and in a timely way, but to create a sustainable and integrated community with access to new facilities and nearby employment.
Please note that due to file size, the above is contained in my separate email ('email 2').

* Appendix 1b - Landscape and Green Infrastructure statement (The Landscape Partnership). This demonstrates that there are no landscape reasons why Shenley Park /WHA001 should not be included within the VALP. Concerns about the sensitive gap between Whaddon and Milton Keynes can be overcome by design and site planning. The north-west of the Site should include a permanent defensible buffer between built development on the Site and Whaddon comprising woodland planting and accessible semi-natural green space.
Please note that the above is accompanied by a series of figures and photographs in a separate file. Due to file size these are sent separately (in 'email 3').

* Appendix 1c - Technical note relating to highways and transport (RPS). This provides evidence on highways and transport matters, confirming that there are no significant transport constraints that would otherwise hamper the consideration of site WHA001 as a viable option for sustainable growth and timely delivery in the VALP.

* Appendix 2 - Draft Scoping Opinion (Aylesbury Vale District Council). This confirms that a formal EIA scoping report submitted by Savills on behalf of CSP satisfactorily sets out the likely environmental effects of the proposed development and determines the scope of the future assessment for the EIA

* Appendix 3 - Review of RAF Halton (Savills). This paper demonstrates that the VALP's allocation of RAF Halton is unsound, and should be removed and replaced with a site that is properly evidenced, available, deliverable and have a realistic prospect that it will deliver an appropriate number of dwellings within the plan period.

* Appendix 4 - Sustainability Appraisal Review (Savills). This shows that the Sustainability Appraisal of the VALP contains a number of flaws and inaccuracies, and that taking the SA as it is currently prepared may render the VALP being found 'unsound'. Correcting inaccuracies and appraising another alternative option for growth would offer a sound, sustainable way forward for the VALP.

* Appendix 5 - Technical report on housing need and local market absorption (Savills). This provides an analysis underlying CSP's view that a reduction in total housing targets (from the 2016 draft VALP to the current Submission Draft), is not justified, along with consideration of market issues.

* Appendix 6 - Review of housing land supply (Savills). This sets out an analysis to show that whilst AVDC is ostensibly able, in mathematical terms, to show a 5 year housing land supply in the Submission Draft VALP, there are number of substantial shortcomings in the intended approach relating to geographical distribution and overall levels of development.

* Appendix 7 - RAF Halton technical note relating to transport (RPS). This identifies that RAF Halton would not improve the proportion of travel by sustainable modes, by being remote from neighbouring areas or facilities, would not reduce the need to travel by relying on insufficient patronage to support a range of new facilities; and would not improve the efficiency of transport networks, by relying on lower order roads, including unsuited B-class and other rural roads and lanes for its outward connectivity.

* Appendix 8 - Representation forms (Savills). These are contained in AVDC's pro-formas, and set out CSP's representations on individual elements of the plan. There is a considerable element of overlap between these and the above-listed documents, and therefore the submission should be read as a whole.

Object

VALP Proposed Submission

Representation ID: 2023

Received: 14/12/2017

Respondent: Crest Strategic Projects

Agent: Savills Southampton

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

the Council is seeking to circumvent the need to make out an exceptional circumstances case for bringing forward a Green Belt site as an allocation. The VALP should have encompassed a proper and robust Green Belt assessment to consider the allocation (or otherwise) of RAF Halton. Since it has not done so, the only acceptable way forward is for the allocation of RAF Halton to be removed from the VALP as a formal allocation and noted only as a potential future mixed-use site, pending the Plan's 'early review'.

Full text:

On behalf of Crest Strategic Projects (CSP), I enclose a suite of documents as formal representations on the above plan.

The lead representations statement (Savills) provides a detailed account of CSP's stance on the VALP as a whole. A range of inter-related objections are set out, relating to the amount and distribution of housing, site-specific allocations, and the consideration of alternatives within the Sustainability Appraisal. Particular objections are raised in respect of Shenley Park (site WHA001), which was included in the previous draft of the VALP, but is now omitted; and proposed allocation sites at RAF Halton, Buckingham and Winslow, which CSP objects to. The document should be read in conjunction with the following appendices:

* Appendix 1a - Shenley Park Vision Statement (Savills Urban Design Studio). This demonstrates and explains how the proposed development of Shenley Park can be delivered, not simply as a means to meet growth requirements for Aylesbury Vale in an optimal location and in a timely way, but to create a sustainable and integrated community with access to new facilities and nearby employment.
Please note that due to file size, the above is contained in my separate email ('email 2').

* Appendix 1b - Landscape and Green Infrastructure statement (The Landscape Partnership). This demonstrates that there are no landscape reasons why Shenley Park /WHA001 should not be included within the VALP. Concerns about the sensitive gap between Whaddon and Milton Keynes can be overcome by design and site planning. The north-west of the Site should include a permanent defensible buffer between built development on the Site and Whaddon comprising woodland planting and accessible semi-natural green space.
Please note that the above is accompanied by a series of figures and photographs in a separate file. Due to file size these are sent separately (in 'email 3').

* Appendix 1c - Technical note relating to highways and transport (RPS). This provides evidence on highways and transport matters, confirming that there are no significant transport constraints that would otherwise hamper the consideration of site WHA001 as a viable option for sustainable growth and timely delivery in the VALP.

* Appendix 2 - Draft Scoping Opinion (Aylesbury Vale District Council). This confirms that a formal EIA scoping report submitted by Savills on behalf of CSP satisfactorily sets out the likely environmental effects of the proposed development and determines the scope of the future assessment for the EIA

* Appendix 3 - Review of RAF Halton (Savills). This paper demonstrates that the VALP's allocation of RAF Halton is unsound, and should be removed and replaced with a site that is properly evidenced, available, deliverable and have a realistic prospect that it will deliver an appropriate number of dwellings within the plan period.

* Appendix 4 - Sustainability Appraisal Review (Savills). This shows that the Sustainability Appraisal of the VALP contains a number of flaws and inaccuracies, and that taking the SA as it is currently prepared may render the VALP being found 'unsound'. Correcting inaccuracies and appraising another alternative option for growth would offer a sound, sustainable way forward for the VALP.

* Appendix 5 - Technical report on housing need and local market absorption (Savills). This provides an analysis underlying CSP's view that a reduction in total housing targets (from the 2016 draft VALP to the current Submission Draft), is not justified, along with consideration of market issues.

* Appendix 6 - Review of housing land supply (Savills). This sets out an analysis to show that whilst AVDC is ostensibly able, in mathematical terms, to show a 5 year housing land supply in the Submission Draft VALP, there are number of substantial shortcomings in the intended approach relating to geographical distribution and overall levels of development.

* Appendix 7 - RAF Halton technical note relating to transport (RPS). This identifies that RAF Halton would not improve the proportion of travel by sustainable modes, by being remote from neighbouring areas or facilities, would not reduce the need to travel by relying on insufficient patronage to support a range of new facilities; and would not improve the efficiency of transport networks, by relying on lower order roads, including unsuited B-class and other rural roads and lanes for its outward connectivity.

* Appendix 8 - Representation forms (Savills). These are contained in AVDC's pro-formas, and set out CSP's representations on individual elements of the plan. There is a considerable element of overlap between these and the above-listed documents, and therefore the submission should be read as a whole.

Support

VALP Proposed Submission

Representation ID: 2269

Received: 14/12/2017

Respondent: DIO

Agent: Jones Lang LaSalle

Representation:


As set out above part of the site has limited value in terms of the role and function of the Green Belt. AVDC should continue to remove part of RAF Halton from the Green Belt as it is built up and has an urbanising effect within the Green Belt. It is the right time in the planning process to promote the redevelopment of the site and a Local Plan review would be too late in the process.

Full text:

SEE ATTACHMENT

Object

VALP Proposed Submission

Representation ID: 2334

Received: 14/12/2017

Respondent: South West Milton Keynes Consortium

Agent: Carter Jonas - Associate SWMK Consortium

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

The proposal to include threshold increases does not align with the approach to Green Belt openness as explained in John Turner v Secretary of State for Communities and Local Government, East Dorset Council [2016] EWCA Civ 466 - see attached. As made clear in the judgment, the question of impact on the openness of the Green Belt is not restricted to a volumetric approach and has a visual dimension to it.

d) departs from the NPPF, paragraph 89, e.g. the 4th bullet point does allow for the replacement of a building subject to certain caveats, these are not suitably reflecte

Full text:

Please find attached representations to the Proposed Submission Vale of Aylesbury Local Plan consultation, which are submitted on behalf of the South West Milton Keynes Consortium.

In summary, representations are made to the following:

* Paragraphs 1.9 to 1.12
* Paragraph 1.13
* Paragraph 1.17
* Paragraph 2.4
* Paragraph 2.6
* Policy S2 + Objection to Policy S2 Report
* Policy S4 & Paragraphs 3.25 to 3.35 + [2016] EWCA Civ 466 Judgement
* Policy S5 & Paragraphs 3.36 to 3.46
* Paragraphs 3.75 to 3.77
* Paragraphs 3.78 to 3.80
* Policy D1 & Paragraphs 4.1 to 4.29
* Policy D-NLV001 & Paragraphs 4.110 to 4.119
* Additional Allocation D-NLV020 + Environment Agency Flood Mapping Plan, Landscape & Visual Technical Note, Highways & Transport Note, Highway Improvements Plan and Concept Masterplan
* Policy D-HAL003 & Paragraph 4.131 to 4.138 + Landscape & Green Belt Statement
* Policy T1 + Highways & Transport Note
* Housing & Economic Lands Availability Assessment (January 2017) + Concept Masterplan and Landscape & Visual Appraisal
* Sustainability Appraisal (September 2017)
* Green Belt Assessment Part 2 - RAF Halton (July 2016)

Those representations which are supported by a separate technical document or plan are provided in a separate e-mail.

Can you please confirm receipt of these representations, and continue to keep us informed of progress with the Local Plan?

Support

VALP Proposed Submission

Representation ID: 2417

Received: 14/12/2017

Respondent: Wendover Neighbourhood Plan Steering Group

Representation:

We agree the general principles.

Full text:

Response to Proposed Submission Vale of Aylesbury Local Plan (VALP) - see attachment for detailed responses on specific parts of the plan.

Overview and Summary

1) The following comments are being made by the Wendover Neighbourhood Plan (WNP) Steering Group (SG) on the proposed submission Vale of
Aylesbury Local Plan (VALP). Please note that extracts from the Plan, or a summary of their contents, are in italics, and our response is in ordinary type.

2) The current position is that the SG is completing the work in researching the
factual data for the WNP and completing its engagement events to ensure all issues are covered. During the first part of 2018 a detailed Questionnaire will be sent to residents and the timetable for the project to produce the WNP has been drawn up with the aim of producing the WNP in late 2019. The SG is an independent group of residents who operate under the auspices of the Parish Council but may take different views on the VALP. The aim of this response is to reflect the views of the SG but also the opinions and priorities of the residents who have given feedback to date, on the issues that concern them. We have sought to include all the main items of feedback to date in our comments, but ongoing research, and our Questionnaire, will undoubtedly throw up other ideas to implement, and concerns to be addressed.

3) The key points we would wish to make are:-

* We welcome the recognition of Wendover's distinctive identity as a settlement in the south of Aylesbury Vale.
* We welcome the adjustment to the draft Green Belt proposals and the limitation of development within the Town which accords with the great majority of views expressed by the public.
* We understand the decision to allocate 1000 or so homes to the brownfield site at RAF Halton: however there is insufficient detail on either the numbers of homes (and the lack of definition is an issue), or their types and tenure and size. The public support a variety of types of affordable homes to meet local needs but have still to be consulted on the mix of provision.
* The public have made it clear that, whilst they support affordable housing of all types, in appropriate locations within the Town, and if necessary at RAF Halton, they have asked that appropriate and sufficient infrastructure is provided at RAF Halton to include new, or expanded, health, and schools provision, the maintenance and expansion of sports and leisure facilities, the appropriate retention and development of heritage assets, and the provision of a range of jobs closely connected to the new housing provision and appropriate to the labour market needs. The SG must reflect this in its development of the WNP.
* The proposed development at RAF Halton will have a close and intimate impact on Wendover and we have concerns about the policies which have yet to be developed for the provision of employment land, and the maintenance and enhancement of the shopping centre in Wendover
* Transport issues have been raised in many responses. Parking is considered a vital local issue for the Town centre businesses and we do not feel that this has been adequately addressed; in terms of the existing network, the impact of the new proposed homes will impose too great a strain, without a range of highway improvements and safety measures, as well as provision for enhanced public transport (range and availability of bus services) and trains (capacity).
* Details of the Garden Town and proposed expansion of Aylesbury has repercussions for the surrounding area but is insufficiently addressed - we had understood there would be a consultation on this issue in the Autumn of 2017 but this is awaited.
* The impacts of HS2 will be significant yet there are few details known at this stage of the mitigation impacts. Given its effects on residents business and workers in the Town we are anxious to know more given the longer term impact on the whole community.
* We welcome the principle of sustainability underlying the whole plan and feel all measures to meet the challenge of climate change should be taken.

4) The community of Wendover is faced with unique difficulties in addressing the VALP response. The impact of development proposed at RAF Halton will affect it significantly, yet no details of the proposed settlement plan (described as a Masterplan in some documents) are yet available. RAF Halton is not within the Parish of Wendover, nor does it appear to be covered in the Halton Neighbourhood Plan. We think it desirable that there are specific proposals in any VALP to ensure there is proper and meaningful debate on the future of the RAF Halton site, and surrounding heritage and green infrastructure, in Halton and Wendover Parishes, so that the public can work together with landowners and the Government to ensure that the ultimate development of the site is for the benefit of the whole community and reflects the contribution of those living and working in the areas.

5) In addition we think that there will be a need for revisions to the VALP as well as a joint Neighbourhood Plan (involving Wendover, Halton, and the MOD) at a later stage of the VALP process to ensure that proper planning principles are adhered to and the full consultation promised is in fact provided.

6) We now comment on specific provisions of the VALP by reference to page and paragraph numbers. We have made some separate comments on the documents included as supporting evidence.

Object

VALP Proposed Submission

Representation ID: 2591

Received: 14/12/2017

Respondent: Natural England

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

This policy offers an opportunity to
address NPPF Para 117 and
mitigate for any losses to
biodiversity i.e. NPPF Para 109.

Full text:

Please find attached Natural England's response to Aylesbury Vale Local Plan Reg 19 consultation.