Aylesbury Vale Area

MM010

Showing comments and forms 1 to 30 of 45

Object

VALP Main Modifications

Representation ID: 2746

Received: 18/11/2019

Respondent: Alan Caldwell Associates Ltd

Agent: Miss Shontelle Williams

Legally compliant? Yes

Sound? No

Representation Summary:

The Allocation at Wendover is woefully inadequate and consideration should be given to further allocation around Wendover to address the specific needs of the town, while also creating a sustainable spatial development pattern for the southern part of the District.

Change suggested by respondent:

The District will consider the safeguarding additional area to the north of Wendover to ensure a sustainable spatial pattern of development can be developed, if required.

Full text:

The Allocation at Wendover is woefully inadequate and consideration should be given to further allocation around Wendover to address the specific needs of the town, while also creating a sustainable spatial development pattern for the southern part of the District.

Object

VALP Main Modifications

Representation ID: 2794

Received: 02/12/2019

Respondent: Halton Parish Council

Legally compliant? Yes

Sound? No

Representation Summary:

The current wording implies Halton is a residential suburb of Wendover which is factually
wrong. We believe this will lead to bad planning and bad place making because it
assumes the facilities of Wendover are easily available to the community of Halton which
is not true. We believe the Plan needs to discretely recognise that there has to be some
additional facilities at Halton.

Change suggested by respondent:

Wendover will accommodate around 132 new homes
and Halton will have 1,000 new homes at RAF Halton
which is now confirmed to be closing in 2026. This
recognises the sustainability of Wendover and the
railway station, however there will be a requirement for
infrastructure and community facility developments at
Halton in line with Garden Village principles.. No further
growth is allocated at Wendover reflecting the
environmental const

Full text:

The current wording implies Halton is a residential suburb of Wendover which is factually
wrong. We believe this will lead to bad planning and bad place making because it
assumes the facilities of Wendover are easily available to the community of Halton which
is not true. We believe the Plan needs to discretely recognise that there has to be some
additional facilities at Halton.

Object

VALP Main Modifications

Representation ID: 2929

Received: 11/12/2019

Respondent: Buckingham Town Council

Legally compliant? No

Sound? No

Representation Summary:

Buckingham remains named as an area of focus for development. If there is concern as to viability of the sites due to BTS new modelling, then Buckingham needs to be withdrawn from the settlement designation to protect from speculative development brought forward on the basis of housing need [as stated in MM079 115/4.122] and subsequent transport modelling. This does not demonstrate internal consistency within the approach of VALP in light of the last minute removal of site BUC051.

Change suggested by respondent:

Either the policy needs to be amended to remove further housing until further transport modelling is undertaken, or site BUC051 should be reinstated.

Full text:

Buckingham remains named as an area of focus for development. If there is concern as to viability of the sites due to BTS new modelling, then Buckingham needs to be withdrawn from the settlement designation to protect from speculative development brought forward on the basis of housing need [as stated in MM079 115/4.122] and subsequent transport modelling. This does not demonstrate internal consistency within the approach of VALP in light of the last minute removal of site BUC051.

Object

VALP Main Modifications

Representation ID: 2963

Received: 12/12/2019

Respondent: S G Raven

Legally compliant? Yes

Sound? No

Representation Summary:

Mismatch between S2 and D3 (now D4) for Smaller Villages. Delivery policy implies restriction on number of dwellings permitted for sites in Smaller Villages - non-compliance with NPPF 34. As those that are assessed as suitable for development in the HELAA are not allocated in the Plan and if not allocated through neighbourhood plans, they have to come forward as windfall sites. However half of the suitable sites are larger than what is generally considered "windfall".

Change suggested by respondent:

In policy D3, now renumbered D4, (c) for Smaller Villages, remove the qualifier "(normally 5 dwellings or fewer)"

Full text:

S2 (i) Sites at Smaller Villages will come forward through neighbourhood plan allocations or windfall applications and not through allocations in the VALP. A specific limit or % increase is not set (3.20) the only proviso now being that developments should be small scale within the capacity of the settlement to accommodate growth. However the corresponding policy D3 (renumbered D4) (c) for delivering sites at Smaller Villages continues to state a limit of 5 homes despite the Examiner's comments (ED166) that the delivery policy for Smaller Villages needs to be changed to remove any apparent restrictions on future development to bring it in line with NPPF para 34. AVDC agreed to modify the policy in its response (ED180B Acting on Interim Findings, Proposed Action 5: Villages, 19) but has not done so in the proposed modifications. As it stands, the policy is similarly restrictive to the former AVDLP policies RA13 and RA14 declared obsolete and non-compliant with the NPPF.
The HELAA has identified some 20 sites in Smaller Villages as being suitable for development, which could contribute roughly 200 new homes in the District. Of these, roughly half are sites with a capacity for more than 5 homes (including a site in Nash (NSH003) of which I am a landowner that is the only one there not already completed to have come forward that was assessed as suitable). With a lack of smaller sites coming forward, the Plan should not preclude development of these HELAA sites for more than 5 homes in order to sustain smaller village and neighbouring communities.

Object

VALP Main Modifications

Representation ID: 2980

Received: 12/12/2019

Respondent: Arnold White Estates

Agent: Arrow Planning Ltd

Legally compliant? Yes

Sound? No

Representation Summary:

The modified but low housing numbers in the Plan can only be justified if the Plan includes a
commitment for an early review. That linkage is essential because the Plan has been prepared under
NPPF 2012 which was allowed by Government as a 'stop-gap' measure. Full housing provision for
the VALP would be some 48,000 homes over the Plan period using the 'standard method' so even
the Plan is providing 30,233 homes that is some 18,000 homes short. The 'early review' commitment
is now proposed for deletion so that Plan, based on the numbers now proposed, is unsound not being
effective or consistent with national policy.

Change suggested by respondent:

As it stands the housing numbers are unsound. Either the 'early' Review is re-established (and the
consequence of not doing so reflected in a new Policy) or the housing numbers and allocations
should be increased significantly increased thus making the current version of the Plan unsound.

Full text:

On behalf of my client Arnold White Estates Ltd I attach our representations on the forms provided. I draw your attention to the difficulty I have found in making these submissions. The Schedule of Modifications does not show the relevant page numbers in the Plan as proposed to be modified, which means cross-referencing is very difficult. For example, in the Modifications Schedule MM027 shows a modification to para 4.7 at p62. The Modified Plan shows this as para 4.9 at p67. The Modification Schedule and the Modified Plan should have the same page and paragraph numbers. Also, for example, there are two Policies D2. In the forms I have sought to group linked Main Modifications on one form where a combined response is then provided. Where necessary I have inserted a blank page to accommodate text that would not fit within the box provided. I trust all of my text will be captured.

Object

VALP Main Modifications

Representation ID: 2981

Received: 12/12/2019

Respondent: Chiltern District Council and South Bucks District Council

Legally compliant? Yes

Sound? No

Representation Summary:

The VALP is sound as submitted and the proposed Main Modification would result in it being not positively prepared or effective. MM010 should therefore be discarded.

Change suggested by respondent:

The proposed change should not be carried forward into the Inspector's report as a required Main Modification which is necessary to ensure that the VALP is sound.

Full text:

The fourth bullet-point in Policy S2 ('5,750 homes to meet the needs of Chiltern/South Bucks Districts') in the VALP Proposed Submission document provides clarity on the scale of growth proposed over the plan period. The proposed removal of this bullet-point would make the VALP less clear and certain than it was on fulfilling the commitment to meet an element of Chiltern and South Bucks District Councils' housing need which is enshrined in a memorandum of understanding between AVDC, CDC and SBDC dated 3 January 2018.

With reference to paragraph 35 of the NPPF (2019), the removal of this text from Policy S2 would render the VALP not positively prepared or effective and therefore not sound.

Object

VALP Main Modifications

Representation ID: 3013

Received: 13/12/2019

Respondent: Crest Nicholson

Agent: Mr James Brewer

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

Support and agree with conclusion that Shenley Park is the most appropriate site to allocate adjacent to Milton Keynes. Suggests amendment to second paragraph in Policy S2

Change suggested by respondent:

recommend that the second paragraph within Policy S2 is amended to read 'The strategy also allocates growth at two sites adjacent to Milton Keynes which reflects its status as a strategic settlement immediately adjacent to Aylesbury Vale District' as both Salden Chase and Shenley Park are now allocated for residential development.

Full text:

Please see attached document 32735 Crest Nicholson Section 4 and the comments below that set out Crest Nicholson's support, subject to minor changes, to MM010.

Crest Nicholson would recommend that the second paragraph within Policy S2 is amended to read 'The strategy also allocates growth at two sites adjacent to Milton Keynes which reflects its status as a strategic settlement immediately adjacent to Aylesbury Vale District' as both Salden Chase and Shenley Park are now allocated for residential development.

Crest Nicholson support bullet (f) of policy S2 that increases the housing provision in the North East of Aylesbury Vale from 2,212 to 3,362. As the Inspector noted in document ED181 'I stated that it was for the Council to decide how it wished to meet the need for any additional allocations. The suggestion that it be met entirely by an allocation in the Milton Keynes area would adequately address the specific recommendation of paragraph 37 of my Interim Findings. The source for identifying the allocation is entirely within the Council's discretion. I have no reason to dispute the Council's choice of focussing its attention on those sites identified on pages 248-254 of the HELAA report V4 (January 2017)'.

Crest Nicholson agree with both the Inspector and AVDC that the HELAA report provides the most appropriate piece of evidence from which to determine which site should be allocated for residential development. Of the three options considered next to Milton Keynes, namely Shenley Park, Eaton Leys and an extension to Salden Chase, only Shenley Park is considered suitable for residential development in the HELAA, a conclusion that is also borne out by the Sustainability Appraisal addendum that has been provided as part of the main modifications evidence base. Shenley Park was also the only site of the three included in the 2016 version of the VALP (Regulation 18).

Attachments:

Object

VALP Main Modifications

Representation ID: 3028

Received: 13/12/2019

Respondent: Highbarrow Holdings Limited

Agent: Mr Garry Hutchinson

Legally compliant? No

Sound? No

Representation Summary:

See attached.

Change suggested by respondent:

See attached.

Full text:

See attached.

Attachments:

Object

VALP Main Modifications

Representation ID: 3088

Received: 17/12/2019

Respondent: Vanderbilt Strategic

Agent: Mr Mark Krassowski

Legally compliant? Yes

Sound? No

Representation Summary:

Policy S2 does not redress the imbalance between the allocation of housing in AGT and the designated larger villages such as Aston Clinton. The proposed increase of 308 units for the larger villages listed in Table 2 is inadequate and fails to provide a sustainable and immediately deliverable approach to delivering new housing.
The reliance on the larger strategic sites to deliver much of the Districts housing over the remainder of the Plan period will slow the delivery of new housing (including the provision of affordable housing) and do nothing to assist existing larger villages.

Change suggested by respondent:

A higher housing figure is required to be identified for the larger villages. This requires a review of the Sustainability Appraisal methodology and and the conclusions drawn from it. In particular, it is very clear that Aston Clinton, a designated larger village, is able to accommodate more housing and this should be reflected in Table 2, rather than retaining a figure (625 units) based on historic commitments. Aston Clinton is a sustainable settlement which is identified in the Sustainability Assessment as 'best placed to accommodate future development'.

Full text:

It is not considered that Policy S2 goes far enough to redress the imbalance between the allocation of housing in Aylesbury Garden Town and the designated larger villages such as Aston Clinton. The proposed increase of 308 units for the larger villages listed in Table 2 is inadequate and misses the opportunity to provide a sustainable and immediately deliverable approach to delivering new housing.
The reliance on the larger strategic sites to deliver much of the Districts housing over the remainder of the Plan period will slow the delivery of new housing (including the provision of affordable housing) and do nothing to assist existing larger villages.

Object

VALP Main Modifications

Representation ID: 3136

Received: 26/11/2019

Respondent: Armstrong Rigg Planning

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

Include the words 'at least' in policy S2 for Buckingham's housing figure

Change suggested by respondent:

Revised wording
Buckingham will accommodate growth of at least 2,166 new homes. This growth will enhance the town centre and its function as a market town and will support sustainable economic growth in the north of the district.

Full text:

See attached document

Attachments:

Support

VALP Main Modifications

Representation ID: 3206

Received: 11/12/2019

Respondent: South Oxfordshire District Council

Representation Summary:

SODC does not consider that changes to the housing requirement for the Aylesbury Vale Local Plan or additional allocations will have any significant negative effect on South Oxfordshire.

Full text:

Dear Sir/Madam
South Oxfordshire District Council response to the Aylesbury Vale Local Plan Main Modifications Consultation.
Thank you for giving South Oxfordshire District Council (SODC) the opportunity to comment on the Main Modifications Consultation documents. Having reviewed the modified Local Plan and supporting documents, SODC can confirm that we are satisfied the modified plan is sound, legally compliant and justified.
We acknowledge that the housing requirement has increased from 27,400 to 28,600 in addition with the number of homes to be delivered in the plan period which includes an increased buffer of 5.7% to account for under delivery. Overall, this results in 30,233 homes planned for in the modified plan. Further to this, the increased housing requirement of the modified plan is largely to be met on one additional site in the north east of the district on the edge of Milton Keynes and with amendments to site capacities.
SODC does not consider that changes to the housing requirement for the Aylesbury Vale Local Plan or additional allocations will have any significant negative effect on South Oxfordshire.
South Oxfordshire District Council supports the modification of the plan to remove reference to the need for an early review as this plan appropriately deals with the issues at hand. Additionally, the council supports the deletion from the supporting text in paragraph 3.15 which states 'We expect a new settlement to form part of that Local Plan'. While we acknowledge this may be necessary in the future to account for any changes in national policy and the impact of nationally important infrastructure projects, we believe the approach to distributing growth cannot be predetermined and must follow due process based on the most up to date evidence base.
South Oxfordshire District Council, 135 Eastern Avenue, Milton Park, Abingdon, Oxfordshire
OX14 4SB www.southoxon.gov.uk
South Oxfordshire District Council notes that Aylesbury Vale District Council's
position in relation the Oxford to Cambridge Expressway has subsequently changed
since the submission of the plan. Aylesbury Vale no longer supports the proposal
which has resulted in modifications to Policies T2 and T3. South Oxfordshire District
Council recognises that these changes may be necessary to reflect the updated
political position of the council. However, we would like to ensure the council
continues to engage and work collaboratively with neighbouring authorities and
statutory bodies under the requirement of duty to co-operate to understand the
impact and required mitigation associated with the Oxford to Cambridge Expressway.
Kind Regards
Ryan Hunt
Planning Officer

Support

VALP Main Modifications

Representation ID: 3209

Received: 11/12/2019

Respondent: Wycombe District Council

Representation Summary:

The Wycombe District newly adopted Local Plan (2013-2033) sets out that our unmet housing need of 2,275 dwellings will be accommodated in Aylesbury Vale. This was first agreed in a Memorandum of Understanding through the Duty to Co-operate. We note the provision of 2,250 dwellings which was previously identified in policy S2 'Spatial strategy for growth' has been deleted. It is understood that this is still within the total housing requirement of policy PS2 for least 28,600 dwellings, which is also in the supporting text in paragraph 3.13 and Table 1 of VALP. We welcome that the unmet need figure has been corrected from 2,250 to 2,275 dwellings.

Full text:

Dear Sir or Madam,
Response to Vale of Aylesbury Local Plan Main Modifications (2013 - 2033)
Thank you for the opportunity to comment on the Vale of Aylesbury Local Plan (VALP) Main Modifications. Wycombe District Council falls within the same Housing Market Area (HMA) and Functional Economic Market Area (FEMA) as Aylesbury Vale, which is the Buckinghamshire HMA and FEMA.
The Wycombe District newly adopted Local Plan (2013-2033) sets out that our unmet housing need of 2,275 dwellings will be accommodated in Aylesbury Vale. This was first agreed in a Memorandum of Understanding through the Duty to Co-operate. We note the provision of 2,250 dwellings which was previously identified in policy S2 'Spatial strategy for growth' has been deleted. It is understood that this is still within the total housing requirement of policy PS2 for least 28,600 dwellings, which is also in the supporting text in paragraph 3.13 and Table 1 of VALP. We welcome that the unmet need figure has been corrected from 2,250 to 2,275 dwellings.
Yours faithfully
Charlotte Morris

Object

VALP Main Modifications

Representation ID: 3212

Received: 13/12/2019

Respondent: Mr Ian Reading

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

why has VALP not taken into account the Oxford - Cambridge
Expressway?
The major road infrastructure project has not been fully taken into their plans
at this stage having been deleted from their Spatial Vision (para 2.4d) and from
the list of major infrastructure projects that require co-operation (para3.39),
They state that (para3.81) they may only potentially consider this at some time
in the future.
They have deleted their declared support for this project (modified policy T3
at para7.21)
In my view this project if it were to become reality would alleviate the necessity
to develop Aylesbury and surrounding districts to the extent that we now see in the new Modified Plans.

Full text:

Still it seems that AVDC have not grasped the nettle with the proposed
Modifications to the VALP.

For instance, why have they not taken into account the Oxford - Cambridge
Expressway.
The major road infrastructure project has not been fully taken into their plans
at this stage having been deleted from their Spatial Vision (para 2.4d) and from
the list of major infrastructure projects that require co-operation (para3.39),
They state that (para3.81) they may only potentially consider this at some time
in the future.
They have deleted their declared support for this project (modified policy T3
at para7.21)
In my view this project if it were to become reality would alleviate the necessity
to develop Aylesbury and surrounding districts to the extent that we now see in the new Modified Plans.
I cannot see that AVDC and BCC's strategic thinking and planning has any
merit at all, it is muddled, particularly when considered against the reasonable
alternatives.
HOUSING NUMBERS
The modified plan suggests that housing numbers for several large developments have increased .
D-AGT4 Hampden Fields, which affects me more directly, suggests that the numbers have increased from 3,111 to 3,358.
The phrase " at least" suggests to me that this is the minimum number proposed.
This when considered along with D-AGT1, D-AGT2, D-AGT3 and D-HAL003
means a minimum of 8,705 properties.
When you take that figure and add it on to the Kingsbrook Estate (2,350) and the new Aston Reach development (1,400) and alll the other smaller developments that have/are taking place then the East/South/South East of Aylesbury is looking at a minimum of 13,000 new homes.
The road infrastructure required to cope with all the extra traffic has not been adequately assessed and the proposed new road network is badly thought through,
The road network in the Aylesbury area is already congested and is frequently at tipping point.
The Plan however shows no evidence of any updated transport assessment based on these new figures.
Just one incident in the town or surrounding area is enough to bring gridlock to the road network which has happened in the past.
HS2
The area D-AGT2 is stated as being dependant on the delivery of HS2 (para4,41)
As yet no decision to this project has been taken. The Plan therefore cannot be approved until that final decision.
Should approval for HS2 to go ahead not be given after the "Oakervee" review,
then how is this going to impact on the area D-AGT2. Who will pay for all the necessary infrastructure needed if any one at all and would this mean the development in this area is frozen until further notice.
AVDC and BCC's ability to fund their desired road system is at risk as they have not positively prepared for such a outcome.
In summary, AVDC and BCC need to rethink the whole future development of Aylesbury and district as what they are proposing in the "Modified Plan" does not make sense.
Regards

Object

VALP Main Modifications

Representation ID: 3246

Received: 07/01/2020

Respondent: Jill Mead

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

The A421 cannot cope now with every day traffic so more homes at Shenley Park, Salden Chase together with Tattenhoe Park and Kingsmead would be unbearable. Infrastructure has to be in place first.

Our health service is at full stretch now so any extra development would bring it to its knees. Our hospitals cannot cope.

Full text:

Dear Sir,

I would like to register my objections to the VALP Main Modifications. The letters 'MM' and numbers refer to appropriate modifications.

I think the public examination (PE) should be reopened.

The A421 cannot cope now with every day traffic so more homes at Shenley Park, Salden Chase together with Tattenhoe Park and Kingsmead would be unbearable. Infrastructure has to be in place first. (MM007,010,076)

Our health service is at full stretch now so any extra development would bring it to its knees. Our hospitals cannot cope.(MM007,010,076)

I chose to live in a village, not be part of a huge housing estate but further expansion would swallow us. Villages to the north deserve the same protection as those to the south of Aylesbury Vale. (MM13,014,031)

Further development would mean a reduced quality of life, this isn't progress (MM070,076)

There is no provision for a Secondary School at the Shelley Park development therefore not in line with BCC policy. (MM076)

AVDC and MKC need to work together with the adopted policies in the adopted Plan:MK. They need to comply with the 'Duty to Cooperate' (MM072 to076)

In respect of Newton Longville I ask for the PE to be reopened.

Yours sincerely,

Mrs Jill Mead

Newton Longville resident.

Object

VALP Main Modifications

Representation ID: 3259

Received: 10/12/2019

Respondent: Hamlin Estates

Legally compliant? No

Sound? No

Representation Summary:

The plan seeks to increase the overall target for housing delivery - which is welcomed. This includes an increase for Middle Villages - which is also welcomed.

However, there is no explicit provision for these villages (or other settlements) to accept, where appropriate) additional houses on unallocated sites. It is known that a number of settlements are stating, explicitly, that they have no further allocations so are 'full up' and need not even consider any other sites, no matter how sustainable any other site(s) may be.

Change suggested by respondent:

The VALP should make explicit that the housing totals are minima and, where additional housing is required to meet these minima other sites can come forward as 'windfall' sites.

Full text:

The plan seeks to increase the overall target for housing delivery - which is welcomed. This includes an increase for Middle Villages - which is also welcomed.

However, there is no explicit provision for these villages (or other settlements) to accept, where appropriate) additional houses on unallocated sites. It is known that a number of settlements are stating, explicitly, that they have no further allocations so are 'full up' and need not even consider any other sites, no matter how sustainable any other site(s) may be.

Object

VALP Main Modifications

Representation ID: 3260

Received: 04/12/2019

Respondent: Sam Woolmer

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

(Officer's summary)
I'd like to complain about the Housing Numbers and impact to the local community. The changes made to the numbers of houses proposed in the areas below appear to have been significantly altered and give no indication of the final numbers of housing developments, with the phase changed from 'around xxx' to 'at least xxx':


Change suggested by respondent:

Not stated

Full text:

With regard to the above, I'd like to complain about the Housing Numbers and impact to the local community. The changes made to the numbers of houses proposed in the areas below appear to have been significantly altered and give no indication of the final numbers of housing developments, with the phase changed from 'around xxx' to 'at least xxx':
Areas -
D-AGT1
D-AGT1
D-AGT3
D-AGT4
D-HAL003
This is an unacceptable position to take and I would very strongly disagree with the published plans. Where does the development end?
I.How many houses are going to be built and what has been done to asses the impact to local area;
2 in particular the transport system? I see no evidence that 'has been positively prepared, seeking to meet objectively assessed development and infrastructure requirements'
The roads around Aylesbury are already heavily congested and will become grid-locked with the additional traffic from these developments yet this has not been adequately addressed. The road network needs to be fully assessed and new relief roads put in place BEFORE major building takes place.
I live on the A41 and suffer frequent and regular vibrations with the current level of traffic (so much so that there are cracks in my walls and we regularly get woken with the house shaking). The roads are not fit for purpose currently and urgent work is required to build new roads to cater for the current and proposed increase to traffic and this should be part of the development for the area.

Object

VALP Main Modifications

Representation ID: 3262

Received: 04/12/2019

Respondent: Mr Tim Woolmer

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

Officer's summary
With regard to the above, I'd like to complain about the Housing Numbers and impact to the local community. The changes made to the numbers of houses proposed in the areas below appear to have been significantly altered and give no indication of the final numbers of housing developments - changing from 'around xxx' to 'at least xxx'.

Change suggested by respondent:

Not stated

Full text:

With regard to the above, I'd like to complain about the Housing Numbers and impact to the local community. The changes made to the numbers of houses proposed in the areas below appear to have been significantly altered and give no indication of the final numbers of housing developments - changing from 'around xxx' to 'at least xxx':

Areas -
D-AGT1
D-AGT1
D-AGT3
D-AGT4
D-HAL003

This is an unacceptable position to take and I would very strongly disagree with the published plans. Where does the development end? Is it going to be acceptable to go 100%...200% over the numbers indicated?! What has been done to asses the impact to local amenities and in particular the transport system? I see no evidence that 'has been positively prepared, seeking to meet objectively assessed development and infrastructure requirements'

The roads around Aylesbury are already heavily congested and will become grid-locked with the additional traffic from these developments yet this has not been adequately assessed. The road network needs to be fully assessed and new relief roads put in place BEFORE major building takes place.

I live on the A41 and suffer frequent and regular vibrations with the current level of traffic (so much so that there are cracks in my walls and we regularly get woken with the house shaking). The roads are not fit for purpose currently and urgent work is required to build new roads to cater for the current and proposed increase to traffic and this should be part of the development for the area.

Object

VALP Main Modifications

Representation ID: 3263

Received: 11/12/2019

Respondent: Gleeson Strategic Land

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

Supports the objective to deliver at least 28,600 dwellings sustainably with a focus on strategic settlements. Supports Winslow being a strategic settlement.
We note that the housing requirement for Buckingham, Haddenham and Winslow state that growth will be a certain figure, rather than a minimum or 'around' as is the case for Wendover.
On the basis that the aspiration is to deliver at least 28,600 the terminology for these settlements could be interpreted as a ceiling. Therefore, for consistency, the figures for all strategic settlements which feed into the overarching housing requirement figure should be a minimum or 'around' figure. (officer summary)

Change suggested by respondent:

The policy wording in relation to S2 parts b, c and d should therefore be revised as follows:
b. Buckingham will accommodate growth of at least 2,166359 new homes. This growth will enhance the town centre and its function as a market town, and will support sustainable economic growth in the north of the district.
c. Haddenham will accommodate growth of at least 1,03251 new homes. This will be supported by infrastructure and recognise the important role of Haddenham and
Thame railway station.
d. Winslow will accommodate growth of at least 8971,166 new homes, linked with the development of East-West Rail and the new railway station in Winslow

Full text:

Dear Sir / Madam
VALE OF AYLESBURY LOCAL PLAN - MAIN MODIFICATIONS CONSULTATION
Your Ref: 31567
Gleeson Strategic Land Limited and Linden Homes ("hereafter referred to as Gleeson/Linden") control the land edged red on the enclosed site plan. We participated in earlier rounds of public consultation for the Vale of Aylesbury Local Plan ("VALP") and now provide our comments on the Main Modifications Consultation.
Policy S2 Spatial strategy for growth
Gleeson/Linden continue to support Policy S2 in terms of its objectives to:
(i) Deliver at least 28,600 new homes; and
(ii) accommodate this development sustainably with a focus on the identified strategic settlements.
In this regard Gleeson / Linden also continue to support the identification of Winslow as one of five key 'strategic settlements'. The re-opening of Winslow Railway Station on the 'East-West Rail' line significantly enhances the sustainability of Winslow.
However, and whilst housing numbers for four out of these five settlements have been reduced (Aylesbury Garden Town aside), we would note that the housing requirement for Buckingham, Haddenham and Winslow state that growth will be a certain figure, rather than a minimum or 'around' as is the case for Wendover.
On the basis that the aspiration is to deliver at least 28,600 the terminology for these settlements could be interpreted as a ceiling. Therefore, for consistency, the figures for all strategic settlements which feed into the overarching housing requirement figure should be a minimum or 'around' figure. The policy wording in relation to S2 parts b, c and d should therefore be revised as follows:
b. Buckingham will accommodate growth of at least 2,166359 new homes. This growth will enhance the town centre and its function as a market town, and will support sustainable economic growth in the north of the district.
c. Haddenham will accommodate growth of at least 1,03251 new homes. This will be supported by infrastructure and recognise the important role of Haddenham and
Thame railway station.
d. Winslow will accommodate growth of at least 8971,166 new homes, linked with the development of East-West Rail and the new railway station in Winslow
Policy D3 Proposal for non-allocated sites at strategic settlements, larger villages and medium villages
This policy sets out circumstances where development of non-allocated sites will be permitted, listing criteria that need to be fulfilled.
The proposed Main Modifications seek to insert the word 'Exceptionally' at the start of the supporting paragraph relating to 'Larger scale development'. However, it is considered that the insertion of this word is unnecessary - the circumstances under which further development would be permitted on non-allocated sites is confirmed within the text that follows.
We trust that these comments are taken into consideration in the finalising of the VALP.
Yours faithfully
John Smith
Planning Manager

Object

VALP Main Modifications

Representation ID: 3274

Received: 14/12/2019

Respondent: Mr Keith Allison

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

Officer's summary
I would like to comment on two of the issues being proposed in the local plan.

Our first area of great concern is the increase in housing capacity from 'around' to 'at least' on five separate sites.

We feel the road network is straining at present and the extra housing numbers will cause gridlock. We feel this increase in numbers will not only impact on the road network but also on all facilities as schools, hospitals (already at capacity), and surgeries . In short we do not feel the plan seeks to meet development and infra structure requirements.

Change suggested by respondent:

No comment provided

Full text:

I would like to comment on two of the issues being proposed in the local plan.

Our first area of great concern is the increase in housing capacity from 'around' to 'at least' on five separate sites.

We feel the road network is straining at present and the extra housing numbers will cause gridlock. We feel this increase in numbers will not only impact on the road network but also on all facilities as schools, hospitals (already at capacity), and surgeries . In short we do not feel the plan seeks to meet development and infra structure requirements.

The other issue HS2, no decision has been taken on this gigantic costly project although much of the beautiful Buckinghamshire countryside has been devastated. How can this happen when the final agreement is still pending? It is a complete waste of the tax payers money!

We sincerely hope our comments are taken into account on challenging these very important issues.

Object

VALP Main Modifications

Representation ID: 3275

Received: 14/12/2019

Respondent: Mrs Sharine Carter Allison

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

(Officer's summary)
Our first area of great concern is the increase in housing capacity from 'around' to 'at least' on five separate sites.

We feel the road network is straining at present and the extra housing numbers will cause gridlock. We feel this increase in numbers will not only impact on the road network but also on all facilities as schools, hospitals (already at capacity), and surgeries . In short we do not feel the plan seeks to meet development and infra structure requirements.

Change suggested by respondent:

Not stated

Full text:

I would like to comment on two of the issues being proposed in the local plan.

Our first area of great concern is the increase in housing capacity from 'around' to 'at least' on five separate sites.

We feel the road network is straining at present and the extra housing numbers will cause gridlock. We feel this increase in numbers will not only impact on the road network but also on all facilities as schools, hospitals (already at capacity), and surgeries . In short we do not feel the plan seeks to meet development and infra structure requirements.

The other issue HS2, no decision has been taken on this gigantic costly project although much of the beautiful Buckinghamshire countryside has been devastated. How can this happen when the final agreement is still pending? It is a complete waste of the tax payers money!

We sincerely hope our comments are taken into account on challenging these very important issues.

Object

VALP Main Modifications

Representation ID: 3280

Received: 17/12/2019

Respondent: Jones Lang LaSalle

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

The final vacation and disposal date for RAF Halton is 2025.

Full text:

See attached document which is submitted on behalf of the Defence Infrastructure Organisation (DIO)

Attachments:

Object

VALP Main Modifications

Representation ID: 3290

Received: 15/12/2019

Respondent: W K Boxhall

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

Officer's summary
Housing numbers have been either increased or now qualified by 'at least' indicating a desire to build more rather than less or manageable developments.
The proposed elevated road development over the railway line to Stoke Mandeville is dependent on HS2 funding. This suggests a convenient 'grab' at possible funding and not a well thought out solution to the traffic issues and the need for a bypass route.

Change suggested by respondent:

No comment given

Full text:

Once again the views of people directly affected by such large scale housing developments in the Vale of Aylesbury is being totally ignored. For example, . Housing numbers have been either increased or now qualified by 'at least' indicating a desire to build more rather than less or manageable developments.
. No evidence of improvements to road infrastructures which have become increasingly over congested creating queuing throughout the day, particularly at morning peaks and school times leading to delay, frustration and excessive pollution. Any accident, roadwork or similar incident causes major traffic holdups for long periods of time.
. In the context of a 'Garden Town' , the image portrayed by this Plan of large scale house building, heavily congested roads and a polluted environment fails to enthuse me and suggests little consideration has been given to alternative solutions.
. The replacement of roundabouts and the ever increasing traffic lights are not the solution and continue to restrict traffic flows and increase the risk of congestion and associated disruption to day to day travel.
. The proposed elevated road development over the railway line to Stoke Mandeville is dependent on HS2 funding. This suggests a convenient 'grab' at possible funding and not a well thought out solution to the traffic issues and the need for a bypass route around the town. The prospect of this 'rat run' being created horrifies me and would only result in yet more bottlenecks as motorists and emergency services seek alternatives to an already congested road network.

As notified to you in previous correspondence I continue to object to these proposals and do not consider the modifications made adequately matches the need for good infrastructure that would meet the proposed development demands in terms of roads, services and the environment.

Object

VALP Main Modifications

Representation ID: 3296

Received: 16/12/2019

Respondent: Mr & Mrs Chris & Shirley Bull

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

Housing numbers: In the modified Plan, housing numbers for several large developments have been raised:
* D-AGT1 has been modified to raise housing from "around 1,000" to "at least" 1,000.
* D-AGT2 from "around 1,550" to "at least 1,590".
* D-AGT3 from "around 1,660" to "at least 1,757".
* D-AGT4 from "around 3111" to "at least 3358".
* D-HAL003 from "around 1,000" to "at least 1,000".

Change suggested by respondent:

No comment provided

Full text:

VALE OF AYLESBURY LOCAL PLAN CONSULTATION
We have the following comments in response to your consultation:
Oxford - Cambridge Expressway: In the modified Plan, we would have expected the Council to build the Oxford - Cambridge Expressway major road infrastructure project fully into their plan. However, they have deleted reference to it from their Spatial Vision (para 2.4d) and from the list of major infrastructure projects requiring co-operation (para 3.39). And they state (para 3.81) merely that they may potentially consider it at some unspecified point in the future. They have also deleted their declared support for the project (modified policy T3 at paragraph 7.21). There seems to be an absence of strategic thinking and planning here by AVDC and BCC. This is hardly the most appropriate strategy when considered against reasonable alternatives, such as East-West Rail. A considerable amount of housing development is dependent upon the Expressway going ahead.
Housing numbers: In the modified Plan, housing numbers for several large developments have been raised:
* D-AGT1 has been modified to raise housing from "around 1,000" to "at least" 1,000.
* D-AGT2 from "around 1,550" to "at least 1,590".
* D-AGT3 from "around 1,660" to "at least 1,757".
* D-AGT4 from "around 3111" to "at least 3358".
* D-HAL003 from "around 1,000" to "at least 1,000".
The road network in the Aylesbury area is already severely congested, particularly at peak periods and whenever there is an accident or roadworks. Yet the Plan shows no evidence of any updated transport assessment based on these modified figures. In this respect AVDC and BCC are seriously deficient in their ability and desire to plan adequately for the effects on traffic of housing in this area. Therefore, in our view, the Plan fails to meet objectively assessed development and infrastructure requirements.
HS2: The area D-AGT2 is stated as being dependent on the delivery of HS2 (para 4.44 and elsewhere). Yet HS2 is still under review and no decision on this project has been taken. Consequently the Plan clearly cannot be approved until that final decision has been reached. Until it is, AVDC and BCC cannot know the extent to which HS2 will contribute to the funding of their desired road system. In the meantime there is much uncertainty about whether the Plan can seek to meet objectively assessed development and infrastructure requirements.

Object

VALP Main Modifications

Representation ID: 3304

Received: 17/12/2019

Respondent: Mr Roger Green

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

Officer's summary
The numbers of houses intending to be built have now been increased from the original plans. There appear now to be 'at least' an extra 380 houses which would equate to yet further 750 vehicles. How does this equate to a modulation of traffic plan to relieve the dreadful congestion we already experience.

Change suggested by respondent:

Not provided

Full text:

Having seen the plan for the main modifications to the VALP, I am somewhat exasperated by the way that this has been approached.

With specific regard to the traffic plan - something that was heavily criticised in the Inspector's report - the modified report appears to have added to the traffic congestion rather than reduce it. The numbers of houses intending to be built have now been increased from the original plans. There appear now to be 'at least' an extra 380 houses which would equate to yet further 750 vehicles. How does this equate to a modulation of traffic plan to relieve the dreadful congestion we already experience.

In addition the VALP makes the continued supposition that HS2 will be delivered, and so fund part of the 'ring road'. Given that there is fierce debate at Government level and with major political opposition from all Buckinghamshire's MPs this is far from definite and cannot possibly be part of a structured plan for the future. Without the 'ring road' the whole plan fails.

In all how can this show that the modified plan"has been positively prepared, seeking to meet objectively assessed development and infrastructure requirements" ? It sounds much more like a plan that 'hopefully should work' rather than plan which is a positive future vision to create a thriving efficient community attractive to business etc..

Whilst not averse to the increase to housing numbers nationally and our part in its achievement, the goal surely was never intended to be met by bringing the whole of Aylesbury Vale to a standstill. This Modified VALP continues to be flawed.

Object

VALP Main Modifications

Representation ID: 3370

Received: 17/12/2019

Respondent: Ms Julie Williams

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

(Officer's summary)
Secondly, we are very concerned of the potential implications of the increase in housing numbers from 6,771 to approx. 8705 homes on top of the housing projects already underway or completed. leading to the population increasing by at least 40,000 many of whom will be driving - if not immediately then in the foreseeable future- adding additional 35,000 cars to an already congested traffic system( have you tried to drive into/around/through Aylesbury/Stoke Mandiville during normal working hours - it adds additional time and pollution to any journey).

Change suggested by respondent:

Not provided

Full text:

We writing to raise our concerns regarding the proposed Modified Vale of Aylesbury plan.

Firstly the withdrawal of positive support of the Oxford /Cambridge Expressway road. We feel that this is a short sighted move and is this the most appropriate strategy when considered against reasonable alternatives? The new road will reduce congestion on alternative routes and improve not only the lives of those living in the surrounding areas but will open up the job opportunities for those potentially new house buyers/renters in the new houses being built.
An unspecified point in the future is a not a solution to the problem and indeed cause potentially cause more problems/inconvenience in the future.

Secondly, we are very concerned of the potential implications of the increase in housing numbers from 6,771 to approx. 8705 homes on top of the housing projects already underway or completed. leading to the population increasing by at least 40,000 many of whom will be driving - if not immediately then in the foreseeable future- adding additional 35,000 cars to an already congested traffic system( have you tried to drive into/around/through Aylesbury/Stoke Mandiville during normal working hours - it adds additional time and pollution to any journey).
The Planners need to seek to meet the objectively assessed development and infrastructure requirements to build the housing proposed and that already agreed and built.By that I mean schools( both primary and senior),doctors and surgeries, hospital beds, social services, policing ,refuse collection, jobs and bus routes etc.
It is not just Stoke Mandiville that will be affected by this proposal but also the surrounding villages such as Weston Turnville and Aston Clinton, both of which has already had numerous new housing developments built in the last 5 years, which has added to vehicular congestion. David Liddington MP was aware of the issue in Aston Clinton was trying to help to reduce the traffic concerns of local residents prior to the election and hopefully Robert Butler MP will continue to do so.

Thirdly, D-AGT2 is a crucial part of the proposal and is reliant on HS2 being approved .
Have the planners looked at an alternative if HS2 is not approved in regards to current proposed building/planning and how would it meet the current objectively assessed development and infrastructure requirements.

Lastly ,how does the planning of infrastructure and development requirements of the Aylesbury Garden Town proposal impact on Modified Aylesbury Vale Plan?

We are both concerned that Aylesbury Vale is has not looked fully at the impact on their existing residents when undertaking this plan( which we are given to believe includes taking on new housing requirements of neighbouring areas- Chesham) and not building the infrastructure that actually support that development. They are turning it from an area where people chose to live to an area where they don't.

Object

VALP Main Modifications

Representation ID: 3377

Received: 08/01/2020

Respondent: Amarillo Ltd & Scandale Ltd

Agent: Planning Prospects

Legally compliant? Not specified

Sound? No

Representation Summary:

The distribution of housing required throughout the District is unsuitable and unsustainable. There is a substantial over reliance on Aylesbury and less sustainable villages. In comparison, Winslow, a highly sustainable top-tier settlement, is not making a proportionate contribution. As a result, more housing development should be directed towards Winslow. Winslow's contribution should be increased further to reflect its anticipated East West rail station and the expected Ox-Cam Expressway also.

Change suggested by respondent:

Winslow's contribution to the District's housing needs should be substantially increased.

Full text:

Please see attachments.

Object

VALP Main Modifications

Representation ID: 3392

Received: 17/12/2019

Respondent: Turley Associates

Legally compliant? No

Sound? No

Representation Summary:

Whilst we support the housing requirement increase, this should be expressed as a minimum to ensure that the Plan is flexible enough to respond to changing needs. We note that the Council have revisited and upped the capacities for sites at Aylesbury. We support the recognition that sites at Aylesbury are capable of accommodating more growth. We feel that the Main Modifications could have gone further by seeking to make additional allocation(s) in proximity to Aylesbury. In light of this, our clients site 'Land South West of Weston Turville' should be further considered as an additional allocation.

Change suggested by respondent:

See attachment

Full text:

The full text is attached. See attachment.

Object

VALP Main Modifications

Representation ID: 3400

Received: 16/12/2019

Respondent: Melvyn Gibbons

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

(Officer's summary)
In the plan it states that a number of housing developments have had the intended number of dwellings increased or the final total altered from around to read at least. As we already know the traffic in the town at peak times can already be at a standstill, what provision has been made by AVDC or BCC to plan for the increase in traffic created by this additional housing on our already congested local roads. I would have to strongly disagree that this plan seeks to meet objectively the assessed development and infrastructure requirements.

Change suggested by respondent:

Not provided

Full text:

I would like to register my comments on the VALP as follows:-

Housing Numbers
In the plan it states that a number of housing developments have had the intended number of dwellings increased or the final total altered from around to read at least. As we already know the traffic in the town at peak times can already be at a standstill, what provision has been made by AVDC or BCC to plan for the increase in traffic created by this additional housing on our already congested local roads. I would have to strongly disagree that this plan seeks to meet objectively the assessed development and infrastructure requirements. Also that the area labelled D-AGT2 is stated as being dependent upon the delivery of the HS2 project but as this has not yet been approved how can the local plan be approved when the required funding is not in place. This also leads me to question whether AVDC or BCC have the ability to fund their desired road system.

Object

VALP Main Modifications

Representation ID: 3414

Received: 16/12/2019

Respondent: Natural England

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

Several of our points can be applied across all of the site allocation policies;
* We recommend removal of all mentions of 'where practicable' in reference to the retention of existing habitats, woodland and hedgerows, and creation of linkages of surrounding wildlife assets.
* It is Natural England's opinion that the vast majority of the site allocations should require an ecological management plan and subsequent ecological mitigation to be provided.
* All site allocations should require the provision of a measurable net gain in biodiversity, to remain consistent with para. 170 (d) of the NPPF.

Full text:

Planning Consultation: Aylesbury Vale Local Plan - Main Modifications and Sustainability Appraisal Addendum
Thank you for your consultation on the above dated 05 November 2019
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
We would like to thank you for taking many of our comments from previous consultations on board.
Natural England is of the opinion that as it stands this Local Plan does not meet all of the tests of soundness. Natural England's primary concerns centre around Policy NE1 - Biodiversity and Geodiversity, as well as some of the new wording regarding Green Infrastructure.
Once this is addressed we would be happy to review our advice with regards to soundness of the plan.
We have also included some advisory comments, which should constitute best practice. Most are minor changes concerned with wording of certain policies.
QUESTIONS OF SOUNDNESS
Policy NE1 - Biodiversity and Geodiversity
The amalgamation of the biodiversity policies has resulted in a policy and supporting text which is currently unclear and open to interpretation. We are supportive of the Buckinghamshire and Milton Keynes Natural Environment Partnership's (NEP) representations on this policy and supporting text. In particular;
* In (a), clarity needs to be provided that sites of national and international importance are being referred to here, as well as protected species. This section currently only mentions Sites of Special Scientific Interest (SSSIs). Inconsistent with NPPF para. 170.
* In (d), greater clarity on implementation of the Mitigation Hierarchy is required, to ensure on-site avoidance, mitigation and compensation is implemented prior to off-site. Ineffective and inconsistent with NPPF paras. 32, 174.


* In (e), definition of what is meant by 'regional' or 'local sites' - designated Local Wildlife Sites (LWS) and Local Geological Sites (LGS). Inconsistent with NPPF para 171.
* In (g), we require further information about expectation for planning when a development is proposed on a Priority Habitat. When this is the case, any mitigation should not be off-site. Where no Priority Habitat is involved, mitigation is expected to follow the mitigation hierarchy (as outlined in (d)). Several of the site allocations include or are directly adjacent to areas of Priority Habitat, so it is vital that this policy provides greater clarity which is less open to interpretation. NPPF para. 174.
* In (g), Natural England would like to see removal of section detailing where advantages to the local community outweigh adverse impacts to habitats and species. This is inconsistent with the NPPF and plays no role in protecting and enhancing biodiversity and geodiversity. NPPF para 175.

Unsound on the basis that it is ineffective and inconsistent with national policy.
Green Infrastructure (p.256) and Policy I1
In addition to the below comments on Green Infrastructure (GI), we are also supportive of the Buckinghamshire and Milton Keynes NEP's additional representations on reinstating support for the NEP's GI Vision and Principles 2016 document.
Natural England does not agree with the VALP's modified definition of GI to include market squares and other hard surfaced areas as GI. This inclusion is contradictory to national policy and recognised definitions and practice of GI - including but not restricted to Planning Policy Guidance (PPG) definition of GI (July 2019), European GI Strategy, ANGSt guidance of 'natural' greenspace, and local definitions - including the Aylesbury Vale Green Infrastructure Strategy (2011) and the Buckinghamshire and Milton Keynes Natural Environment Partnership's 2016 definitions.
Inclusion of areas of hardstanding as 'green infrastructure' will lead to GI requirements being fulfilled without any sign of real green space. It will allow interpretation of the policy to lead to less green areas being provided, and therefore less ecosystem and natural capital services brought forward.
Further to the above, the inclusion of transport links (in Policy T6) such as existing walking and cycle routes as GI is similarly incompatible with generally accepted definitions of GI. Natural England recognises that these routes could have the potential to provide GI connectivity, through such measures as tree or hedge planting along the route, but are not generally considered GI in their own right.
Unsound on the basis that the modifications are unjustified, ineffective and inconsistent with national policy.
ADVISORY
D-WHA001 Shenley Park
Due to the areas of ancient woodland (irreplaceable habitat), deciduous woodland (priority habitat) and 'no main habitat but additional habitats present' (priority habitat) on the site, we advise wording is put in to ensure habitats are not damaged or destroyed. In addition, we advise removal of 'where practicable' in regards to retention of habitats.
D-HAL003 RAF Halton
Wording should be added to the site specific description to highlight the neighbouring sites of ecological value, and to ensure they are not encroached onto.
The 50% green infrastructure on site should focus on providing a similar experience to the adjacent Ancient Woodland to keep people on-site. Mitigation options for recreational disturbance can include offsite works such as signage, fencing and footpath creation within the protected sites to minimise recreational disturbance such as trampling of vegetation, dog fouling, and disturbance of wildlife.
Policy D1 - Delivering Aylesbury Garden Town
As the main Policy for the Garden Town, we recommend addition to D1 to require all associated development to conserve the biodiversity on site and provide a biodiversity net gain through multifunctional green infrastructure. this is supported within the NPPF (paras. 170, 175 (d). and will bring the Policy in line with Policies NE1-9 and I1.
Site Allocations
Several of our points can be applied across all of the site allocation policies;
* We recommend removal of all mentions of 'where practicable' in reference to the retention of existing habitats, woodland and hedgerows, and creation of linkages of surrounding wildlife assets. In order to comply with the NPPF, para. 175, 'if significant harm to biodiversity resulting from a development cannot be avoided, adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused'. The NPPF also stresses the importance (para 171) of taking a 'strategic approach to maintaining and enhancing networks of habitats and green infrastructure'. By including the words 'where practicable' you allow for the possibly of destruction of priority habitats and the loss of biodiversity.
* It is Natural England's opinion that the vast majority of the site allocations should require an ecological management plan and subsequent ecological mitigation to be provided. Unless you know there is mitigation required, then remove the 'as required'. The discrepancy on how biodiversity is considered between site allocations is currently inconsistent with NPPF para. 170 and Policy NE1.
* All site allocations should require the provision of a measurable net gain in biodiversity, to remain consistent with para. 170 (d) of the NPPF.

Habitats Regulations Assessment
Natural England provided a response on 3rd June 2019 agreeing with the conclusions reached in the HRA and Appropriate Assessment.
We would be happy to comment further should the need arise but if in the meantime you have any queries please do not hesitate to contact us.
For any queries relating to the specific advice in this letter only please contact me at eleanor.sweet-escott@naturalengland.org.uk. For any new consultations, or to provide further information on this consultation please send your correspondences to consultations@naturalengland.org.uk.

Yours Sincerely,
Eleanor Sweet-Escott
Lead Adviser, Sustainable Development
Thames Solent Team

Object

VALP Main Modifications

Representation ID: 3427

Received: 09/01/2020

Respondent: Cllr Roger King

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

1.15 The report says the indicative target for convenience floor space is 6,980 sqm in Aylesbury town centre by 2033. Given the increase in the town's population over the past 10 years, vacant shop floor space has increased. This is particularly true with Vale Retail Park, Friars' Square and Hale Leys. With the increase in on-line shopping I would say that this figure is optimistic

Full text:

Comments with paragraph reference:

Background

I notice that the unit of measurement used throughout the report is metric i.e. Kilometres and sqm
Given that all road signs are in miles and very few of the public reading this document use metric I think it would be useful if distances were given in miles (imperial) as well as metric.

Some of my comments are duplicated as some of the VALP statements overlap.

1.15 The report says the indicative target for convenience floor space is 6,980 sqm in Aylesbury town centre by 2033.
Given the increase in the town's population over the past 10 years, vacant shop floor space has increased. This is particularly true with Vale Retail Park, Friars' Square and Hale Leys. With the increase in on-line shopping I would say that this figure is optimistic.

Strategic Delivery

4.17 The report says 'to continue to grow the town successfully, key transport issues need addressing including tackling congestion, managing demand, enhancing access, increasing active travel and
enhancing public transport in Aylesbury'.
One key issue is the completion of the ring road. This is reliant on HS2 and the developers. Two key parts of the ring road are missing and are unlikely to be built. These are a link road north from A413 to the A418 and west from the A418 to Berryfields on the A41. In addition the ring Roads are not conformal dual carriage way but a mixture of carriageways.

4.18 The Aylesbury Transport Strategy says it wants to -
* Improve transport access and movement to the town centre.
From the south there are only two ways into Aylesbury. One is Tring Road and the other is Walton gyratory. There is no mention on how these two pinch points can be overcome. The chance of widening lower High Street by compulsory purchase has been lost as overdevelopment has taken place right up to the pavement edge.
* Minimise the impact of future growth on traffic levels, congestion and air quality.
This could be contradictory to later statements in the report saying that an increase in the use of the town centre is envisaged to help the economy and help with its vibrancy.
* Make it easier and more accessible through provision of walking and cycling connections and the
use of public transport.
Cycling is decreasing in the town and walking is only possible from homes within less than a mile of the centre. Given that buses are heavily subsidised and most routes stop after 8.00 pm, the car will still be used as the primary means of access to the town centre.

4.21 The report says 'In creating a Garden Town, the Plan must include green spaces and natural environments for local communities. Strategic multi-functional green infrastructure assets should be identified, retained and enhanced, including improving connectivity through the development of green
corridors. Local open spaces should be protected and where possible connected to strategic
multi-functional green infrastructure networks.
With the exception of the Canal, green corridors are not possible into the town centre. If anything any green space in or near to the town centre has been identified elsewhere the report as prime development land i.e. Thame Road, Ardenham Lane and Friarage Road

4.19 Quoting from the report 'The Aylesbury Transport Strategy builds on previous and currently planned improvements to transport infrastructure. The initial work has identified a list of potential transport interventions Proposed Vale of Aylesbury Local Plan as Proposed to be Modified 70 for Aylesbury which will enable growth, influence travel behaviour and meet the strategic objectives'
My comments are as follows on the objectives
* completing a series of outer link roads that will take traffic away from the town centre and allow
public transport priority improvements to take place on the main radial roads closer to the town
centre, improving public transport journey time reliability.
As already mentioned elsewhere in my comments this wish is entirely dependent on developers and HS2. Two big gaps in the scheme look as though they will never be accomplished.
* implementing an overarching strategy to connect new developments, with each other, to key
destinations and to the town centre by active travel and public transport.
Transport for Bucks are already making it difficult to connect communities. I would point out a series of no right turns implemented on major routes into the town. i.e. A4157 Douglas Road into Stocklake, A418 onto Churchill Avenue
* considering new ways to redesign roads within central area of Aylesbury to ensure access for all.
This is difficult with the A41 running through the town centre and no room for widening. The 20 mph speed limit within the inner ring road is not enforced and Bucks CC policies (street parking) allow free movement of traffic in so called pedestrian areas such as the High Street and Market Square. The idea to traffic calm Exchange Street is ludicrous and has been spoken about for at least 20 years but never implemented.

4.30 The report says 'Aylesbury's most valued assets such as the historic old town, conservation areas, the river Thame, the Grand Union Canal and Hartwell House historic park and garden will be protected and enhanced, allowing communities to celebrate their history, their identity and their diversity'. There is no mention of the River Bearbrook which is a great underused asset running through the town centre, most of which cannot be seen. This is probably because the plan is to culvert it for more development.
'The growth will be planned in a way which minimises the need to travel by private car, with more and more people choosing to walk, cycle or use public transport through integrated forward looking and accessible transport options which supports economic prosperity and wellbeing for residents. Traffic growth will be managed to control congestion'.
I have mentioned this elsewhere but will repeat my comments. Cycling is decreasing in the town and walking is only possible from homes within less than a mile of the centre. Given that buses are heavily subsidised and most routes stop after 8.00 pm, the car will still be used as the primary means of access to the town centre.
* All residents will feel a strong sense of distinctive local identity as part of the garden community of Aylesbury Garden Town, including residents and visitors to its attractive and functioning centre.
This is a major task for an incoming council. Over 15% of Aylesbury's population are from other ethnic origins. Very few participate in the leisure activities in the town be it theatre, cinema, restaurants, pubs or the arts centre. This statement is a meaningless just to be politically correct.

4.209 The report makes a number of statements relating to Aylesbury Town Centre. 'Market Square, Walton Street and Friars Square. Make more of the area's presence as a key retail, catering and leisure hub. Town centre policies to support proposals for retail and other main town centre uses, provided they are in accordance with the vision and aims for the town centre Kingsbury (including George Street and Pebble Lane)'.
At present AVDC are not supporting their own policy and are allowing non-retail into key areas. i.e. 10. High Street & new units in Ling Lionel

Create a more attractive environment for residents, visitors and businesses and improve it as the gateway to the Old Town. Town centre policies to support public realm improvements and improving
the quality of the town centre Aylesbury Old Town (the historic quarter). Preserve and enhance this residential area as a key part of the town's heritage and culture offer and improve its links with the rest of the town centre, in keeping with its conservation area status Heritage assets policy to ensure these
are properly considered when assessing development proposals.
I very much support this initiative but it needs to be carried through. The hidden gem of the old town has been neglected for too long. i) Poor surfaces, cobbles and brick sets tarmacked over by utility companies, bad potholes. ii) Poorly placed traffic signage iii) pedestrian areas are not safe and are not policed. Traffic ignore speed restrictions and one way streets.

Gateway South (railway and bus stations) Improve the railway and bus stations as key arrival points and improve their connection with the rest of the town centre. Allocation of area for comprehensive
redevelopment (as shown on the policies map) including co-locating the bus and railway stations to create a public transport interchange.
By far this is the daftest idea in the town centre plan. Firstly the bus station in its present form brings passengers directly into the heart of the town. The new scheme would add a physical barrier in the A41 in order to get to the town centre. Older visitors to the town centre would not want to walk that distance. Morrison's is a much used supermarket particularly for the residents across the Bourg bridge in Southcourt. The demolition of the supermarket would deplete the shopping offer in the town centre, something VALP says it wants to enhance. This idea should be depleted from VALP along with the demolition of the Friars Square car park.

Upper and middle High street Create a more attractive retail environment (especially in middle
High Street), improve connections between upper High Street and Exchange Street, ensure both upper
and middle High Street are part of the retail circuit and flow with the rest of the town centre.
I oppose the demolition of the former Granada cinema/Gals bingo hall. This should be made a central feature of the generation of the High Street

Town centre policies to support public realm improvements and improving the quality of the town centre, including improvements for pedestrian access Cambridge Street, Buckingham Street and New Street. Cambridge Street: Improve the quality and attractiveness of the whole area, the continuity of active frontages along Cambridge Street and the appeal of Cambridge Street to independent shops.
I applaud this idea, although it is not a new ambition. Bucks County Council have introduced parking in Cambridge Street as a money making machine. There has never been a will to have a fully pedestrianized area in the town centre or the will to enforce it. Active frontages would need fair landlords and the enforcement of AVDC's own shop front policy.

Buckingham Street and New Street: Improve the physical environment, reduce dominance of the car and integrate the area more fully into the rest of the town centre and the retail Town centre policies to support proposals for retail, public realm improvements and improving the quality of the town centre, including improvements for pedestrian access.
Buckingham Street once had an avenue of trees. As each one has been felled through one reason or another they have never been replaced. Until Bucks CC or the new Unitary changes its policy of a dislike for trees the town centre will lose more trees. Reasons given by Bucks CC include, leaf fall hazard, cost of clearing up leaves, utility cables and loss of parking spaces.

Break down the concrete barrier of the inner ring road and improve links and accessibility from the rest of the town centre to Aylesbury Waterside Theatre, Aqua Vale Leisure Centre, Vale Park and the retail parks.
Given that the inner ring road are trunk routes, A41, A413 & A418 I don't see how this can be achieved. Traffic is already gridlocked on these roads and adding pedestrians into the mix will only make things worse. The mixed use areas at the top of Great Western Street and at the Bourg bridge crossing of the A41 are an accident waiting to happen.

6.1 & 5 Employment and the Protection of key employment sites
The report says 'The vision for the Plan in relation to employment is to ensure the availability of a diverse and flexible range of employment opportunities for new and existing businesses, which match the expectations for employment growth in the district. To support this, there is a need to maintain
a flexible supply of employment land and premises. This includes making the best use of
existing employment land and premises by retaining the most suitable sites and encouraging
their refurbishment and renovation where necessary.'
Your own published data says the 2011 Census shows that 35,025 residents commute out of the district to work (predominantly to areas just outside the district, but also further afield such as London), yet office space in the town centre has almost disappeared where office blocks have been converted to residential. The Economic Development Team at AVDC have said that there is a shortage of office space in and near to the town centre and supports the growth in office space in the local economy. Yet they did nothing to stop the demolition of Derby House in Wendover Road or the conversion of small and large offices blocks in Walton Street, Buckingham Street and Oxford Road. The loss of employment space not only loses trade for shops in the week-day but also increases car journeys out of town.

Primary shopping frontages

6.22 6.23 The council recognises the importance of the retail role of primary shopping frontages, and of having a mix of uses within Aylesbury town centre, and says it will to ensure that A1 (shops) continue to predominate while allowing some provision of A3 (restaurants and cafes) and A2 uses, provided the overall mix of uses is considered acceptable. Whilst I applaud this approach as I have said previously
at present AVDC are not supporting their own policy and are allowing non-retail into key areas. i.e. 10. High Street & new units in Long Lionel



E7 Tourism development
The plan says 'The council will promote a growing, sustainable tourism sector, and will support
proposals. Proposals for new or expanded tourism, visitor or leisure facilities will be supported
within or adjacent to settlements'. I would suggest reinstating a tourist office in Aylesbury and providing decent stop offs and parking for coaches.

Heritage assets
VALP declares 'The historic environment is an asset of great cultural, social, economic 8.1 and environmental value. It contributes significantly to our quality of life and to the character of the district, representing
a non-renewable resource that once lost is gone forever' Yet in Aylesbury looking after the assets including listed buildings is poor. AVDC have only paid lip service in the pretence of protecting historic areas, conservation areas and listed buildings. Some examples:
i) The civic group of buildings in Market Square including the old courts has been spoilt by adjacent over development of Friars Square with the garish frontage of the Metro bank.
ii) Taxis continue to use Market Square as a rank, hence spoiling the look of the conservation area and the listed civic buildings. . Bucks CC in the pursuit of income do not want to lose valuable meter parking.
iii) The splendid Grade 2 listed Ardenham House in Oxford Road is spoilt by adjacent businesses, parking uncaring tenants and owners and the promise in VALP of future development nearby
iv) The grade 2 listed Walton Mill house continues to rot.

Conservation areas, listed buildings
8.10 VALP says 'Conservation areas are areas of special historic or architectural interest, the special character or appearance of which it is desirable to preserve or enhance. Conservation areas are locally designated heritage assets. Conservation areas are designated by Aylesbury Vale District
Council, according to strategy set out in the AVDC Conservation Areas Supplementary Planning
Document (adopted March 2011)'.
Again just lip service. Aylesbury's 3 conservation areas continue to be spoilt by dustbins on show, poor pavement and road surfaces, temporary signage such as adverts on Byron House railings in Wendover Road and estate agent for sale boards and the abundance of weeds everywhere in the summer.

Registered historic parks and gardens & Scheduled monuments

I note that there I no mention of Quarrendon Leas on periphery of Aylesbury, owned and managed by Buckinghamshire Conservation Trust

Heritage at Risk

8.38 The report says 'Investing in historic buildings can have a direct impact on the quality of life of residents. Many buildings at risk have a rich historic legacy and contribute to local identity. The repair and refurbishment of declining and/or derelict historic buildings can often be a catalyst in
encouraging confidence and investment in an area.
8.39 Wherever practicable the council will support endeavours to repair and reuse
heritage assets in a manner appropriate to their significance and to provide long-term viable
uses for buildings and structures that are vacant and at risk through cooperation with owners
and Historic England.
AVDC's record of protecting assets is poor and again the comments above need to be implemented. We have lost in the past 30 years many historic unlisted buildings. These include Duck Cottages in Green end, Oxford Road Mill, old police station in Walton Street, cattle market auction rings, electricity showrooms in Exchange Street to name just a few.

Biodiversity and Geodiversity Protected sites

9.56 VALP states 'Where tree loss is unavoidable, they should be replaced with suitable new planting, either within the site or in the locality if this is more appropriate. Replacement planting should, as a
minimum, be of commensurate value to that which is lost Development can make a positive
contribution to the tree and hedgerow resource in the locality through new planting or the
restoration and improved management of existing features. New plantings should endeavour
to link up fragmented areas of existing woodland.'
Aylesbury continues to lose trees on important sites and they are not replaced. Where developments have specified that tree planting should be carried out as screening, there is no enforcement id not carried out.


My main interest has been focused on Aylesbury and particularly the town centre. There is much to commend the report but also much is repeated. It seems to me that authors of the report have no empathy with the town and possibly do not live in the town. There is no talk on how any of the plans and schemes will be funded. I await with some enthusiasm.

Cllr Roger King

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