Aylesbury Vale Area

MM041

Showing comments and forms 1 to 24 of 24

Object

VALP Main Modifications

Representation ID: 2750

Received: 03/12/2019

Respondent: National Trust - Waddesdon Estate/Hartwell House

Legally compliant? No

Sound? No

Representation Summary:

Negative impact on Hartwell House Estate as a consequence of housing proposal D-AGT2

Change suggested by respondent:

D-AGT2: South West Aylesbury (AGT2) should be amended to delete housing at its western extent so that it is not visible from the A418 in either direction.

Full text:

Hartwell House Estates / National Trust consider that the proposals would have a negative impact on the setting of Hartwell House Registered Park and Gardens and Hartwell Conservation Area located to the north and north west of the A418 Oxford Road. The proposed housing allocation is not based on a detailed Heritage Statement for Aylesbury Town which has informed the emergent local plan process. This is contrary to Historic England advice set out 'The Historic Environment in Local Plans -Historic Environment Good Practice Advice in Planning: 1' and The Setting of Heritage Assets - Good Practice Advice in Planning Note 3'.

Object

VALP Main Modifications

Representation ID: 2812

Received: 02/12/2019

Respondent: Ms Joanna Shepherd

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

I notice with real concern on reading the Modified Plan that housing numbers for several large developments have been raised. The development south west of Stoke Mandeville has been raised from 1550 to at least 1590. The Plan shows no evidence to any updated transport assessment based on these new figures which I feel is woeful. The congestion is appalling and worsening. To increase the planned housing numbers is utter lunacy. (officer summary)

Full text:

I notice with real concern on reading the Modified Plan that housing numbers for several large developments have been raised. Both Aylesbury Garden Town and RAF Halton have been amended from around 1000 to at least 1000. The development south west of Stoke Mandeville has been raised from 1550 to at least 1590, Woodlands from around 1660 to 1757 and Hampden Fields from around 3111 to at least 3358. The Plan shows no evidence to any updated transport assessment based on these new figures which I feel is woeful. Anyone living in Aylesbury knows how congested the area is. At peak times the roads are virtually gridlocked. Whenever there is an accident anywhere around Aylesbury the whole road network grinds to a halt as witnessed last week when there was an accident by Aylesbury College. To get to the town centre from where I live on Hampden Hall took me 40 minutes. In the same week temporary lights on the Wendover Road and Bedgrove meant that my husband took 45 minutes to get from the Wendover bypass to home, a journey which should take 5 minutes. The congestion is appalling and worsening. I was talking to someone who lives by the police station and works at Elm Farm vetinary practice. She can walk to work in 7 minutes. By car this journey takes her 20 minutes in the morning. Given the current chaos on the roads I fail to see that anyone who actually lives in Aylesbury would feel that the Plan has been positively prepared and seeks to meet objectively assessed development and infrastructure requirements. To increase the planned housing numbers is utter lunacy. Households now invariably have a minimum of 2 cars, often more given that children remain at home much longer. Aylesbury will simply grind to a halt. I beg someone to wake up to this and see that VALP is flawed. I cannot see why anyone would want to live in Aylesbury when the traffic is so bad now. A Plan that shows no evidence of any updated transport assessment yet an increase in housing numbers should not go unchallenged. I challenge those responsible for looking at the Modified Plan to visit Aylesbury at rush hour times. If they did that and then allowed this Modified Plan to be sanctioned when it fails to provide any updated transport assessment I would have to assume that the world has gone made. Aylesbury will have housing but no one will want to live here because the road network will simply collapse under the pressure.

Joanna Shepherd, Weston Turville, (who already cannot get out onto the Wendover Road in the morning unless someone lets her into the stream of solid traffic)

Object

VALP Main Modifications

Representation ID: 2817

Received: 02/12/2019

Respondent: Mr Andrew Burnett

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

In the modified Plan, housing numbers for several large developments have
been raised.
D-AGT2 (south west of Stoke Mandeville) has been modified from "around 1,550" to "at
least 1,590".
I strongly disagree with increasing the housing density in this area. The roads are already over-congested. the continued loss of countryside to housing development
is destroying the rural character of the area, and the distinctness of communities close to Aylesbury is being lost.
Infrastructure is already inadequate to meet the needs of existing housing density and this plan will make it worse. (officer summary)


Full text:

Housing numbers

In the modified Plan, housing numbers for several large developments have
been raised.
.D-AGT1 (Aylesbury Garden Town site 1, south of Stoke Mandeville) has
been modified to raise housing from "around 1,000" to "at least" 1,000.
.D-AGT2 (south west of Stoke Mandeville) from "around 1,550" to "at
least 1,590".
.D-AGT3 (includes Woodlands) from "around 1,660" to "at least 1,757"
.D-AGT4 (includes Hampden Fields) from "around 3111" to "at least
3358"
.D-HAL003 (includes RAF Halton site) from "around 1,000" to "at least
1,000"

I strongly disagree with increasing the housing density in this area. The
roads are already over-congested, and the plans do nothing which will solve
this. In addition, the continued loss of countryside to housing development
is destroying the rural character of the area, and the distinctness of
communities close to Aylesbury is being lost.

I do not agree that this plan, as modified, " seeks to meet objectively
assessed development and infrastructure requirements". Infrastructure is
already inadequate to meet the needs of existing housing density and this
plan will make it worse.

Best Regards
Andrew Burnett



Object

VALP Main Modifications

Representation ID: 2861

Received: 05/12/2019

Respondent: A Daniels

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

HOUSING NO, D-AGT2 no decisions on this project taken as yet, but will probably be more congestion. (officer summary)

Full text:

HOUSING NO,S D-AGT4 in particular
This whole thing is a complete shambles, it has not been objectively assessed for development and infrasructure
requirements, driving out of Bedgrove in a morning and at all busy times is a nightmare and at most other times too.
The whole network in Aylesbury is already congested, and riding a bike is pretty impossible.Our local green
space is almost zero, and we do not need any more building, a noisy HS2 will not help. D-AGT2 no decisions on
this project taken as yet, but will probably be more congestion.

Object

VALP Main Modifications

Representation ID: 2871

Received: 07/12/2019

Respondent: Mr Richard Makepeace

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

D-AGT2 is stated as being dependent on the delivery of HS2. This project is under major review and as such no plan can or should be based on this highly contentious plan.
D-AGT1-4 and D-HAL003 all change housing needs from 'around' a figure to a 'minimum' of the same figure implying that the number of houses is likely to be increased. No alterations have been made to the transport assessment to take account of this likely increase. The transport infrastructure is grossly overloaded and any extra housing will only add to this. (officer summary)

Full text:

Dear Sir,

Having studied the revised Vale of Aylesbury plan I have the following comments

Oxford to Cambridge expressway

The plan appears to have downgraded the plan so as to now take little or no account of this proposal. In particular its effects have been removed from the Spatial Vision and from the list of major infrastructure projects requiring cooperation. It is only considered in a vague manner as possibly being considered in the future.

This strategy does not seem to be one which has taken reasonable consideration of this agains of any other strategies into account.

HS2

D-AGT2 is stated as being dependent on the delivery of HS2. This project is under major review and as such no plan can or should be based on this highly contentious plan going ahead as there is a clear possibility of there being cancellation and in this important respective the plan doesn't meet objectively assessed development and infra structure requirements.


Housing needs

D-AGT1-4 and D-HAL003 all change housing needs from 'around' a figure to a 'minimum' of the same figure implying that the number of houses is likely to be increased. No alterations have been made to the transport assessment to take account of this likely increase. As any resident in Aylesbury and the surrounding area knows from their daily experience that the transport infrastructure is grossly overloaded and any extra housing will only add to this and is unlikely to be ameliorated by any feasible transport infrastructure. Extra housing is in direct contradiction of the frequently expressed views of the residents as opposed to the views imposed by central government.

In this respect I believe the plan does not seek to meet objectively the assessed development and infrastructure requirements.

Yours faithfully

Object

VALP Main Modifications

Representation ID: 2879

Received: 07/12/2019

Respondent: Susan Makepeace

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

D-AGT1-4 and D-HAL003 all change housing needs from 'around' a figure to a 'minimum' of the same figure implying that the number of houses is likely to be increased. No alterations have been made to the transport assessment to take account of this likely increase. The transport infrastructure is grossly overloaded and any extra housing will only add to this.

-AGT2 is stated as being dependent on the delivery of HS2. This project is under major review and as such no plan can or should be based on this highly contentious plan.
(officer summary)

Full text:


Dear Sir,

Having studied the revised Vale of Aylesbury plan I have the following comments

Oxford to Cambridge expressway

The plan now take little or no account of this proposal. It is only considered in a vague manner as possibly being considered in the future.
In particular its effects have been removed from the Spatial Vision and from the list of major infrastructure projects requiring cooperation.

This strategy does not seem to be one which has taken reasonable consideration of this agains of any other strategies into account.


Housing needs

D-AGT1-4 and D-HAL003 all change housing needs from 'around' a figure to a 'minimum' of the same figure implying that the number of houses is likely to be increased. Extra housing is in direct contradiction of the frequently expressed views of the residents as opposed to the views imposed by central government. No alterations have been made to the transport assessment to take account of this likely increase. As any resident in Aylesbury and the surrounding area knows from their daily experience that the transport infrastructure is grossly overloaded and any extra housing will only add to this and is unlikely to be ameliorated by any feasible transport infrastructure.

In this respect I believe the plan does not seek to meet objectively the assessed development and infrastructure requirements.

HS2

D-AGT2 is stated as being dependent on the delivery of HS2. This project is under major review and as such no plan can or should be based on this highly contentious plan going ahead as there is a clear possibility of there being cancellation now or in the future and in this important respective the plan doesn't meet objectively assessed development and infra structure requirements.

Yours faithfully

Object

VALP Main Modifications

Representation ID: 2888

Received: 08/12/2019

Respondent: Mr & Mrs Shirley & Raymond Cox

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

Housing numbers for several large developments have been raised. D-AGT2 from "around 1,550" to "at least 1,590". The road network is already congested, yet the Plan shows no evidence of any updated transport assessment.
The modified Plan fails to address the traffic congestion these new houses would generate. We are also concerned about the level of air pollution that would be generated.
The area D-AGT2 is stated as being dependent on the delivery of HS2 (para 4.44 and elsewhere). Yet no decision as to this project has been taken. The Plan cannot be approved until that final decision.
(officer summary)

Full text:

Dear Sirs
Oxford - Cambridge Expressway

In the modified Plan, the Oxford - Cambridge Expressway is referred to several times. We would have expected the Council to build this major road infrastructure project fully into their plan at this stage. They have deleted the reference 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) only 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).
We do not believe this is the most appropriate strategy when considered against reasonable alternatives.

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 congested, yet the Plan shows no evidence of any updated transport assessment based on these new figures.
The modified Plan fails to address the traffic congestion these new houses would generate. We both have to leave for work for work much earlier to avoid traffic delays. When there are any roadworks, water leaks, accidents etc. Aylesbury literally grinds to a halt. We are also concerned about the level of air pollution that would be generated.
We do not believe AVDC and BCC have planned fairly for the effects of traffic and strongly disagree that this seeks 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 no decision as to this project has been taken. The Plan cannot be approved until that final decision.
We feel work relating HS2 should not commence until the project has been finally approved, thus avoiding unnecessary devastation to the countryside, not to mention wasting vast amounts of money.

If HS2 does not go ahead, AVDC and BCC will not have the ability to fund their desired road system and we strongly disagree that this seeks to meet objectively assessed development and infrastructure requirements.

Yours faithfully

Object

VALP Main Modifications

Representation ID: 2894

Received: 08/12/2019

Respondent: Mr Damian Campbell

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

In the modified Plan, housing numbers for several large developments have been raised. D-AGT2 from "around 1,550" to "at least 1,590".
As was evidenced in the last inspectors report the road network in the Aylesbury area is already congested. Yet the Plan shows no evidence of any updated transport assessment based on these new figures.
AVDC and BCC have stated that much of the funding for the new roads for the VALP would come from HS2. Indeed area D-AGT2 is stated as being dependent on the delivery of HS2 (para 4.44 and elsewhere). Yet as I understand it, no final decision on the HS2 project has been taken.
(officer summary)

Full text:

Attn: The Planning officer for the VALP

Sir / Madam

In addition to my earlier comments about the VALP I would like the following point to the amendments to the VALP to be taken into consideration:

Thank you in advance.

Kind regards




Oxford - Cambridge Expressway

In the modified Plan, the Oxford - Cambridge Expressway is referred to several times. One would have expected the AVDC and BCC to include this major road infrastructure project fully into their plans. However, not only have they have deleted the reference from their Spatial Vision (para 2.4d) and from the list of major infrastructure projects requiring co-operation (para 3.39) but In para 3.81 the Council has seen fit to merely state 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).

I am not only disappointed but truly dismayed at this lack of professionalism. The Vale of Aylesbury Plan is the most important planning document to be worked on for the coming years. For it to have parts deleted and not to include cooperation with the only other infrastructure project in the county beggars belief. The new plans hardly demonstrate the most "Appropriate" strategy when there are other reasonable alternatives available.




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"

As was evidenced in the last inspectors report the road network in the Aylesbury area is already congested. Yet the Plan shows no evidence of any updated transport assessment based on these new figures.

Again this demonstrates shoddy work and a woeful lack of respect for the planning process. It seems that the AVDC and BCC are not taking this process at all seriously. As a concerned resident I would welcome new housing if it's on the basis of a well thought out plan but this demonstrates no respect at all for the existing residents' quality of life, especially as regards increased traffic levels. In fact I would go so far as to say this in no way meets "Objectively assessed development and infrastructure requirements" which I thought was a prerequisite for any plan.


HS2

AVDC and BCC have stated that much of the funding for the new roads for the VALP would come from HS2. Indeed area D-AGT2 is stated as being dependent on the delivery of HS2 (para 4.44 and elsewhere). Yet as I understand it, no final decision on the HS2 project has been taken. Surely the plan cannot be finalised until HS2 has been finally approved? Attempting to push through the plan WITHOUT the funding would show unacceptable disregard regard for the impact this would have on residents who will surely then be expected to fund any shortfall through taxes.

Again this in no way attempts to meet "Objectively assessed development and infrastructure requirements."

Object

VALP Main Modifications

Representation ID: 2900

Received: 09/12/2019

Respondent: Jennifer kruppa

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

The housing numbers have been increased for several large developments (D-AGT2) and also the wording ''at least'' has been used. The road network is Aylesbury is not fit for purpose. Where is the evidence of an updated transport assessment based on the higher 'at least' figures. Infrastructure is needed now before the building of more houses goes ahead.
Part of your planning proposals are dependent on HS2 going ahead. As of today HS2 is under review. I trust that AVDC and BCC can afford to fully fund their own planned developments and are not reliant on HS2 handouts (officer summary)

Full text:

Dear Planning Department

I am writing with regard to the newly modified Vale of Aylesbury Local Plan. I have various comments/concerns, which I have detailed below:

1). I am mystified as to why you state that you may potentially consider the Oxford - Cambridge Expressway at some point in the future. Surely this must be looked at and planned for NOW! The Expressway is a major project for the UK that requires joined up thinking and a large amount of new infrastructure in the Vale of Aylesbury. The Local Plan is an opportunity to lay down plans for this. You have skirted around the issue in your modifications and it looks as if you are unable to plan in a cohesive, forward thinking way. I do not agree that this is justified as the most appropriate strategy when considered against reasonable alternatives.
2). I have noticed that the housing numbers have been increased for several large developments (eg D-AGT1, 2, 3, 4 and D-HAL003) and also the wording ''at least'' has been used which means the Local Plan in these areas actually gives no meaningful figures as they can be increased on a whim. For example the local plan uses the caveat ''at least 3358'' houses for D-AGT4. Does this mean that the planning department do not actually know how many houses they are planning for/building? If so, it cannot be called a 'plan' as the wording leads one to conclude the housing numbers are as yet still unknown and therefore unplanned.


In addition, the road network is Aylesbury is not fit for purpose... at all. Where is the evidence of an updated transport assessment based on the higher 'at least' figures. You have not presented anything that gives me confidence with regard to both future development of the area or the much needed infrastructure. (The latter is needed now before the building of more houses goes ahead).


3). Part of your planning proposals are dependent on HS2 going ahead (e.g. the development S/W of Stoke Mandeville). As of today HS2 is under review. I trust that both AVDC and BCC can afford to fully fund their own planned developments and are not reliant on HS2 handouts.



Kind regards


Object

VALP Main Modifications

Representation ID: 2906

Received: 10/12/2019

Respondent: Mr Brian Tattam

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

Lately in the Aylesbury area, the traffic situations have become intolerable with Aylesbury becoming totally gridlocked.
The AVDC and BCC have no suitable infrastructure plan to cope with the existing traffic, let alone the traffic that will be generated by the building of the original proposed housing numbers, without the proposed increase in those numbers, D-AGTl to 4 and D-HAL003.
Power supplies on limit and drainage overloaded. Building houses on flood plains, "the water run-off has been calculated". That is a nonsense.
The plan for D-AGT2 cannot be decided until HS2 has been delivered
(officer summary)

Full text:

Dear Sir,

Comment on the VALP Main Modifications

In connection with the Oxford to Cambridge expressway, I fail to understand the reasoning behind the AVDC and BCC
deleting their declared support for this project. There would appear NO strategic thinking or planning is behind this
decision. I do not believe this is "justified as the most appropriate strategy when considered against reasonable
alternatives".
Lately in the Aylesbury area, the traffic situations have become intolerable with Aylesbury becoming totally gridlocked.
The AVDC and BCC have no su itable infrastructure plan to cope with the existing traffic, let alone the traffic that will be
generated by the building of the original proposed housing numbers, without the proposed increase in those numbers,
D-AGTl to 4 and D-HAL003.
I totally disagree that this "has been positively prepared, by seeks to meet objectively assessed development and
infrastructure requirements". Until a suitable road infrastructure is place, Aylesbury will cease to function. The AVDC
and BCC appear to have no ability to plan effectively (certainly not up till now) for the traffic impact of housing around
Aylesbury.
Power supplies on limit and drainage overloaded. Building houses on flood plains, "the water run-off has been
calculated". That is a nonsense.
It appears that Transport for Bucks (BCC) leaves the ownership of connecting new estate roads to existing main roads in
the hands of the developers, who have no idea how to manage this, as on the A41 mid-July 2019, bringing Aylesbury to a
standstill for 3 days. AVDC and BCC need to take ownership of t heir planning from beginning to end. Not leave it to
others.
It doesn't work now, and certainly won't in the future!
Finally, HS2. The plan for D-AGT2 cannot be decided until HS2 has been delivered so I totally disagree that this "has been
positively prepared, seeking to meet objectively assessed development and infrastructure requirements" as the AVDC
and BCC cannot possibly know what is going to happen!
Your Faithfully,

Object

VALP Main Modifications

Representation ID: 2912

Received: 07/12/2019

Respondent: Mr David Locke

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

The housing numbers for several of the proposed developments have been changed.
This indicates that the housing numbers cannot possibly have been objectively assessed against infrastructure and development requirements. I cannot see any updated transport assessments.
The developments concerned are:
D-AGT2 from "around 1,550" to "at least 1,590".
D-AGT2 depends on HS2 going ahead (para 4.44 and other mentions as well). A large portion of AVDC's proposed road system is totally dependent on HS2.
HS2 is currently under review. It may be cancelled. The
Oakervee report has not been published and no decision has been taken on HS2 yet. (officer summary)

Full text:

Dear Sirs

Comment on the VALP main Modifications

Having read through the main modifications to the VALP, there are several areas which I think really do not make any sense:

Oxford - Cambridge Expressway

This is a huge government-funded infrastructure project, which we are told will be the catalyst for development of housing between the two cities.
Surely there must be a duty on local authorities to factor such projects into their local plans?
However, the modifications to the VALP have deleted reference to the Expressway from its Spatial Vision (para 2.4d) and from the list of major infrastructure projects requiring co-operation (para 3.39).
The Plan says only that the Expressway may possibly be considered at some point in the future.
The plan no longer declares its support for the Expressway project (modified Policy T3 at paragraph
7.21).
How can this possibly be a sensible attitude to take? A great deal of taxpayers' money will be spent on this project, yet AVDC is turning away from the opportunities that it brings for properly planned development. This demonstrates a complete lack of joined-up strategic thinking.
The modified Plan can't be justified as the most appropriate strategy when you compare it to reasonable alternatives - which must include a consideration of the Expressway.

Housing numbers

In the modified plan, the housing numbers for several of the proposed developments have been changed. This indicates that the housing numbers cannot possibly have been objectively assessed against infrastructure and development requirements. I cannot see any updated transport assessments that I would have thought must required if the housing numbers have increased.
The developments concerned are:
 D-AGT1 (Aylesbury Garden Town site 1, south of Stoke Mandeville) has been modified to raise housing from "around 1,000" to "at least" 1,000.
 D-AGT2 (south west of Stoke Mandeville) from "around 1,550" to "at least 1,590".
 D-AGT3 (includes Woodlands) from "around 1,660" to "at least 1,757"
 D-AGT4 (includes Hampden Fields) from "around 3111" to "at least 3358"
 D-HAL003 (includes RAF Halton site) from "around 1,000" to "at least 1,000"

HS2

Area D-AGT2 depends on HS2 going ahead (para 4.44 and other mentions as well). A large portion of AVDC's proposed road system is totally dependent on HS2.
HS2 is currently under review. It may be cancelled. Where would that leave AVDC's plans? The Oakervee report has not been published and no decision has been taken on HS2 yet.
It cannot be possible to approve the Plan unless and until there is a decision on HS2.

Conclusion

The whole thing just looks as though it has been cobbled together by amateurs in an attempt to get round the Inspector's very valid concerns. It ignores the existence of one major infrastructure project and relies on the delivery of a second one that may yet be cancelled. It's a very poor piece of work. Aylesbury deserves better than this.

Yours faithfully,

Object

VALP Main Modifications

Representation ID: 2993

Received: 13/12/2019

Respondent: National Trust

Legally compliant? No

Sound? Yes

Representation Summary:

This allocation is likely to have a visual impact upon the setting of Hartwell House. Whilst policy criterion (h) is supported as it requires a landscape-led approach to development, we consider that the impact on the setting of this Grade I listed building is not fully accounted for within policy wording contrary to national policy for heritage assets.

Change suggested by respondent:

We therefore require criterion (v) to be amended to 'Protect the setting of Grade I listed Hartwell House, as well as the retention of a suitable setting for Grade II listed Hall End Farm house and Stoke Cottage'.

Full text:

This allocation is likely to have a visual impact upon the setting of Hartwell House. Whilst policy criterion (h) is supported as it requires a landscape-led approach to development, we consider that the impact on the setting of this Grade I listed building is not fully accounted for within policy wording contrary to national policy for heritage assets.

Object

VALP Main Modifications

Representation ID: 3019

Received: 12/12/2019

Respondent: Arnold White Estates

Agent: Arrow Planning Ltd

Legally compliant? Yes

Sound? No

Representation Summary:

It is not clear whether the South West Link Road is an optional extra or whether it is essential
infrastructure that must be available before the development of S-AGT2 South West
Aylesbury can commence. It is not clear whether the Link Road can be delivered as part of
the scheme, thus casting doubt on the site's contribution to housing needs (at least 1,590
dwellings). If the site allocation is proceed then there should be an amendment to the Policy
to ensure that the South West Link Road is available before development commences.

Change suggested by respondent:

AGT2 b. should therefore be worded 'No development shall take place on D-AGT2 until the South
West Link Road is available (the scheme will also enable its delivery), which will relieve traffic
pressures in the town centre and enabling easier vehicular movement around Aylesbury.'

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: 3152

Received: 19/12/2019

Respondent: Mr R H Garside

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

Housing numbers (Ref D-
AGT1 through D-AGT4 and D-HAL003) appear to have been significantly increased
In spite of these increases,
there does not appear to be any updated transport assessment relating to the
new figures. The transport aspect of the VALP has always been in question - now
it just got worse.

Full text:

1)
Housing and Infrastructure; especially road
networks


I am perplexed by the
modifications regarding housing. In particular, the housing numbers (Ref D-
AGT1 through D-AGT4 and D-HAL003) appear to have been significantly increased
or, at the very least, there is now provision for significant increases. (Some,
eg D-AGT4 are actual significant increases.)


In spite of these increases,
there does not appear to be any updated transport assessment relating to the
new figures. The transport aspect of the VALP has always been in question - now
it just got worse.


It is difficult to understand
how this can be regarded as positively prepared planning. What is proposed
seems to demonstrate a complete lack of objective assessment.


2)
Modified Plan Reliant on HS2


It appears that at least some
of the housing development proposals (specifically that defined as D-AGT2) is
contingent upon the HS2 project proceeding, and proceeding to plan in its
present from. This is still far from certain. It is unclear how a key part of
the plan can be dependent on something outside AVDC and BCC control and as such
it does not seem that this aspect of the Plan demonstrates positive preparation
and objective assessment of development and infrastructure.

Object

VALP Main Modifications

Representation ID: 3155

Received: 19/12/2019

Respondent: Mr R H Garside

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

It is unclear how a key part of
the plan D-AGT2 can be dependent on HS2 - something outside AVDC and BCC control and as such
it does not seem that this aspect of the Plan demonstrates positive preparation
and objective assessment of development and infrastructure.

Full text:

1)
Housing and Infrastructure; especially road
networks


I am perplexed by the
modifications regarding housing. In particular, the housing numbers (Ref D-
AGT1 through D-AGT4 and D-HAL003) appear to have been significantly increased
or, at the very least, there is now provision for significant increases. (Some,
eg D-AGT4 are actual significant increases.)


In spite of these increases,
there does not appear to be any updated transport assessment relating to the
new figures. The transport aspect of the VALP has always been in question - now
it just got worse.


It is difficult to understand
how this can be regarded as positively prepared planning. What is proposed
seems to demonstrate a complete lack of objective assessment.


2)
Modified Plan Reliant on HS2


It appears that at least some
of the housing development proposals (specifically that defined as D-AGT2) is
contingent upon the HS2 project proceeding, and proceeding to plan in its
present from. This is still far from certain. It is unclear how a key part of
the plan can be dependent on something outside AVDC and BCC control and as such
it does not seem that this aspect of the Plan demonstrates positive preparation
and objective assessment of development and infrastructure.

Object

VALP Main Modifications

Representation ID: 3215

Received: 13/12/2019

Respondent: Mr Ian Reading

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

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.

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: 3338

Received: 07/12/2019

Respondent: Mr Paul Paul Sypko

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

* D-AGT1 has been modified 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"


Based on my experience of the increasing traffic problems in and around the town, and based on the lack of an updated transport assessment based on the increased housing figures, no confidence that Councils planned effectively for the traffic effects Disagree that the modified plan meets objectively assessed development and infrastructure requirements.

Full text:

1. Inadequacy of plan to meet objectively assessed development and infrastructure requirements

I see that, in the modified Plan, the housing numbers for several large developments have been increased:
* 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"

Despite this, the Plan shows no evidence of any updated transport assessment based on these new figures.

The road network in the Aylesbury area is already heavily congested, and the town centre is prone to gridlock and massive knock-on effects whenever there is a small issue in another nearby area (as recent experiences with burst water mains have shown - see articles at https://www.bucksherald.co.uk/news/updated-thames-water-apologises-after-aylesbury-traffic-gridlock-following-burst-water-main-749861 or https://www.mix96.co.uk/news/local/2159450/burst-water-main-causes-aylesbury-gridlock/ for examples). The A41 Aston Clinton Road in particular now has enormous tailbacks for traffic travelling in an westerly direction virtually every weekday morning. This is not an issue of capacity on the A41 itself; it is indicative of too much traffic reaching bottleneck junctions at they enter the town centre (caused in no small part by all the traffic light controlled junctions that have been added in recent years, which I understand were put in place so as to accommodate heavy traffic from Arla lorries which would have been unable to pass effectively through the otherwise efficiently-functioning roundabouts that had until that point been in place and working well for many years).

Based on my experience of the increasing traffic problems in and around the town, and based on the lack of an updated transport assessment based on the increased housing figures, I do not have confidence that AVDC or BCC have planned effectively for the effects on traffic of housing in this area. I would disagree that the modified plan seeks to meet objectively assessed development and infrastructure requirements.

2. Unreasonable expectations of the public during the consultation process

While I don't doubt that the consultation process itself probably complies with the statutory obligations, I would query whether there really has been a true effort to engage the public in this important local matter. Specifically, there appears to have been very little publicity relating to the revised plan and, speaking personally, had I not heard about it via the Hampden Fields Action Group newsletter this December with 15 days to go until the expiry of the consultation period, I'm not sure I would have heard about it at all.

Out of curiosity, I downloaded the two main consultation documents, converted them to Microsoft Word format, and performed a word count. The results were as follows:
* Local plan (proposed submission): 107,808 words spanning 313 pages.
* Local plan (proposed main modifications): 111,874 words spanning 222 pages.

Object

VALP Main Modifications

Representation ID: 3347

Received: 06/12/2019

Respondent: Keith Ware

Legally compliant? Not specified

Sound? No

Representation Summary:

Housing numbers for developments have been raised.
D-AGT1 has raised 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 congested. Yet the Plan shows no evidence of any updated transport assessment based on these new figures.


Have they been properly considered. Aylesbury is already gridlocked with current traffic, these developments will have a massive negative impact on the roads, congestion, and pollution. Increased demand for Chiltern Railways unmanageable.
Plan cannot be approved until that final decision is made on HS2.

Full text:

In the modified Plan, housing numbers for several large developments have been raised.
* D-AGT1 (Aylesbury Garden Town site 1, south of Stoke Mandeville) has been modified to raise housing from "around 1,000" to "at least" 1,000.
* D-AGT2 (south west of Stoke Mandeville) from "around 1,550" to "at least 1,590".
* D-AGT3 (includes Woodlands) from "around 1,660" to "at least 1,757"
* D-AGT4 (includes Hampden Fields) from "around 3111" to "at least 3358"
* D-HAL003 (includes RAF Halton site) from "around 1,000" to "at least 1,000"

The road network in the Aylesbury area is already congested. Yet the Plan shows no evidence of any updated transport assessment based on these new figures.

What do you make of this?
What are BCC's and AVDC's plans to manage the vast increase in the traffic impact of housing will have in this area? Have they been properly considered. Aylesbury is already gridlocked with current traffic, these developments will have a massive negative impact on the roads, congestion, and pollution. On top of this, the increased demand for Chiltern Railways will be unmanageable. The station car parks are already full and the trains cannot cope with current demand.

I strongly disagree that these plans have been positively prepared, or seek 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 no decision as to this project has been taken. The Plan cannot be approved until that final decision is made.

Again, I strongly disagree that these plans have been positively prepared, or seek to meet objectively assessed development and infrastructure requirements.

I wish for my objections to be recorded and duly considered.

Object

VALP Main Modifications

Representation ID: 3394

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 the attachment

Full text:

The full text is attached. See attachment.

Object

VALP Main Modifications

Representation ID: 3401

Received: 16/12/2019

Respondent: Melvyn Gibbons

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

(Officer's summary)
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.

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: 3496

Received: 17/12/2019

Respondent: Stoke Mandeville Neighbourhood Plan Steering Group

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

The title of this proposed allocation is misleading. There is no recognition that some of the site is located within Stoke Mandeville Parish.
There is also considerable uncertainty regarding the deliverability of the site given its dependence on HS2.
The changed wording of this policy is vague and ineffective and in places factually incorrect and unsound.
The area of the site within Stoke Mandeville should be planned via the SMNP.
r) requires integration with Aylesbury
s) requirement to contribute to 'off site health facilities' is unnecessary
v) unnecessary to specify protection of listed buildings
(officer summary)

Full text:

See attached document which is submitted on behalf of Stoke Mandeville Neighbourhood Plan Group

Object

VALP Main Modifications

Representation ID: 3526

Received: 16/12/2019

Respondent: Gleeson Homes Ltd

Agent: Nexus Planning Ltd

Legally compliant? No

Sound? No

Representation Summary:

The allocation of land at South West Aylesbury for mixed use development is fully supported, however the revised delivery period (2018-2033) is not reflected under 'Implementation Approach'. The requirement to meet ANGST standards was not discussed at the Hearing Sessions, has not been applied consistently and is not necessary in any event. Criterion r should therefore be deleted.

Change suggested by respondent:

Changes Sought
Amend Policy D-AGT2 (as modified) as follows:
i. Amend the section headed 'implementation approach' to make it clear that development will be delivered between 2018 and 2033;
ii. Amend Criterion r to delete references to ANGST standards.

Full text:

See attachments.

Object

VALP Main Modifications

Representation ID: 3533

Received: 15/12/2019

Respondent: Hampden Fields Action Group

Legally compliant? Yes

Sound? No

Representation Summary:

1. The assertion that, "...the delivery of the South West Link Road
[will relieve] traffic pressures in the town centre and enabling
easier vehicular movement around Aylesbury" is heavily contested
given the flaws in the model and therefore it has not been proven.
2. Even the Jacobs report (see above) accepts that significant
mitigation will be required in the Coldharbour area, yet no
mitigation is included or modelled. The requirement for updated
traffic modelling is once again reinforced.

Change suggested by respondent:

Full remedial action to correct the errors and gaps in the transport evidence base and modelling,
followed by a revised set of proposals including funding plans and timetable, with public consultation
on these modifications.

Full text:

see attachments

Support

VALP Main Modifications

Representation ID: 3557

Received: 17/12/2019

Respondent: Buckinghamshire County Council

Representation Summary:

MM041
Highways
- BCC suggest that this point refers to dualing. As this will be determined through modelling and impact assessment, we suggest that this is changed to 'safeguarded for future dualling in the event that is built as a single carriageway.
-Junction improvements may be more than A418 and A413 so suggest this is a separate bullet point.
-Other network improvements as necessary as agreed through the consideration of the transport impacts.
- Include public transport accessibility improvements to cycling and walking links

Full text:

Please find BCC's full technical comments to the VALP Main Modifications below.
MM032
Highways
-Change 'which should' to 'which will'
-Suggest addition of 'no vehicular access to the South East Aylesbury link road will be permitted to serve development sites'
MM035
Highways
- c. - Change to prioritising and safeguarding delivery of...
-d. - suggest addition of ' all development sites shall be designed to provide unhindered vehicular, pedestrian and cycle connections to adjoining sites'
Implementation approach
Change to ... 'once in accordance with an AGT1 masterplan SPD for the entire allocation'.

BCC are responding to a number of elements of the VALP which have been set out into sections below.

MM041

Highways
-BCC suggest that this point refers to dualing. As this will be determined through modelling and impact assessment, we suggest that this is changed to 'safeguarded for future dualling in the event that is built as a single carriageway.
-Junction improvements may be more than A418 and A413 so suggest this is a separate bullet point.
-Other network improvements as necessary as agreed through the consideration of the transport impacts.
- Include public transport accessibility improvements to cycling and walking links
MM048
Highways
-b. - To suggest everything will be delivered within 5 years is not realistic. The ELR is to be delivered by or as soon as after 2021 as possible. Other highway works will be phased beyond that for delivery based on build and need.
-m. -Change to vehicular access to the site shall be from ELR(s)
MM057
Highways
Site specific requirements- this should mention A41PPTC

MM061
Highways
Implementation approach
Design code was submitted for village 3 for the recent reserved matters application and is available to view on the planning portal (18/0115).
MM063
Transport Strategy
- a.- sentence does not finish.
MM076 (pages 134 and 135 of tracked changes)
Rights of way
-h and i- Cover of walking and cycling links connecting the development with outlying communities - both are excellent. A bridleway (WHA/12/2) sits just outside the development edge on the north side of a strip of land called Briary Plantation. This bridleway forms the North Bucks Way and Swans Way, and connects the Tatternhoe Valley Park and Redways with Whaddon in an east to west direction. A bridleway exists north to south in MK borough (Shenley Brook End Bridleway 006) on the eastern edge of the development
- Improvements to Buckinghamshire Bridleway WHA/12/2 and a link onto it from the built development would be advantageous for residents, providing access to green space as well as transport links for walking and cycling between Milton Keynes, the development and Whaddon village. The suggested vision would be for this bridleway to be an extension of the Redways route, with the same or similar bitumen construction (not necessarily red), but also allowing a grass width for horses, if possible.
- g- For the avoidance of doubt should mention '...Redway standard improvements to Bridleway WHA/12/2' specifically as it lies just outside the development edge. Similarly, in para h. could mention '...extensions into the development from Shenley Brook End Bridleway 006, constructed to Redway standard'.
MM101
Transport strategy
This policy states that a cycling and walking strategy is to be agreed by the Council. This is not clear what the cycling and walking strategy would relate to, i.e. is it just for this site or an overall strategy.

MM167
Property
Following the informal publication of the proposed modifications in July 2019, the change of allocation for the WIN020 site became known to BCC and WTC. This created significant concerns around the proposals for the WIN020 site. Since then, BCC, AVDC and Winslow Town Council have engaged in constructive discussions and have reached an alternative agreement to the proposed modification that would not have an impact on an existing project within Winslow that is supported by all parties.

BCC are concerned with the proposed modification MM167 as there would be an impact on an existing scheme proposed for the WIN026 allocation at the Winslow Centre. This scheme consists of a medical centre, community facilities including a new library and up to 90 Extra Care homes. This scheme has gained financial backing from the One Public Estate Board, of which BCC and AVDC are members, along with the NHS and Thames Valley Police. It is based on provisions contained within the existing Winslow Neighbourhood Plan that was adopted in 2014 and is currently the premier planning policy for the Winslow area.
BCC acknowledges that earlier plans and documentation for the WIN026 site included only 30 bed C2 use. This, however, has been revised and the scheme can now achieve over 80 C2 use dwellings (Good practice guidelines for Extra Care developments indicate that 30 units would be too small and a minimum development of 60 units is required to realise the economies of scale benefits of this type of development). The WIN026 site has been allocated in the Winslow Neighbourhood Plan for this purpose. However, in order to achieve the outcomes of this allocation the re-provision of sporting facilities at WIN020 was needed, as also provided for in the Winslow Neighbourhood Plan. WIN026 is a much preferred site for C2 accommodation as it will be adjacent to a new health centre and the library, and is much closer than WIN020 to town centre facilities.
Further detailed design works of the re-provision of the sporting facilities has identified that more land is required than that proposed for the eastern parcel of WIN020 resulting in the need for the whole of the WIN020 allocation to be for sport facilities. Furthermore, the allocation for the remaining parcel of WIN020 for a 100 bed C2 use would be in conflict with the proposal for the Winslow Centre development. BCC as landowner of both allocations would not implement both schemes for C2 use, questioning the deliverability of one or both schemes.
In our discussions we have considered the role of One Public Estate in supporting the Winslow Centre development. It is for these reasons that BCC, AVDC and WTC would seek a revised modification for this allocation. We would wish to see the WIN026 Winslow Centre remain the same with the acknowledgement that it can offer 80+ beds for C2 use and the whole of WIN020 be allocated for sport provision.
BCC, AVDC and Winslow Town Council will be submitting these comments as a joint letter to the Inspector expressing the revised position for the proposed modification of the western part of the site WIN020. We are confident that the agreed changes will be made by AVDC as part of the main modifications consultation.
MM212
Highways
Change text... ' the guidelines set out below which are taken from the ... thresholds for development ...' transport impact assessment change to' transport statement, transport assessment and travel plans'... 'development' this is a guide only and the need should be confirmed through pre application discussions with the council.
MM218
Highways
-a.- suggest houses should have one fast electric vehicle dedicated charging points. At least two parking bays marked for electric vehicles only.
Suggest referring to Surrey's parking guidance to provide up to date info on power sources and changes to installation process.
MM221
Archaeology
Policy BE1 Heritage Assets is not as clear as it could be. The policy is divided between designated heritage assets and non-designated heritage assets; however the requirements for designated are equally valid for undesignated. We would therefore recommend that BE1 includes the following text after the non-designated heritage paragraph:
Heritage statements and / or archaeological evaluations may be required to assess the significance of any heritage assets and the impact on these by the development proposal.
The word 'known' should be removed from the second paragraph relating to possible archaeological sites. This would better fit with NPPF Paragraph 189 which includes, 'Where a site on which development is proposed includes, or has the potential to include, heritage assets with archaeological interest, local planning authorities should require developers to submit an appropriate desk-based assessment and, where necessary, a field evaluation.'
-b. - should probably refer to NPPF February 2019 Paragraph 195 rather than 133.
MM224
Ecology
-The narrative on priority habitats in MM224 (para 9.9) states that;
"Priority habitats and priority species are not always fully protected under UK wildlife laws." but does not refer to their consideration in the National Planning Policy Framework, 2019. It is recommended that text from the NPPF is incorporated in to this section of the Plan, Specifically, paragraph 174 (b) "To protect and enhance biodiversity and geodiversity, plans should: ...promote the conservation, restoration and enhancement of priority habits, ecological networks and the protection and recovery of priority species; and identify and pursue opportunities for securing measureable net gains for biodiversity."
 It is also recommended that the Plan includes the definition of Priority habitats and species in the Plan. NPPF Annex 2 (Glossary) defines Priority habitats and species as: Species and Habitats of Principal Importance included in the England Biodiversity List published by the Secretary of State under section 41 of the Natural Environment and Rural Communities Act 2006.
-Paragraph 9.14 on biometric calculations requires clarity. There is not sufficient emphasis that the mitigation hierarchy should be applied, to avoid, mitigate and compensate, before considering off-site offsetting contributions.
-Paragraph 9.14 also currently says "A negative unit loss would need to be offset". This statement is confusing as it could be interpreted that 'loss' is acceptable. The emphasis should be on achieving net gain (on-site in so far as possible through the mitigation hierarchy).
-Paragraph 170 of NPPF should be included in the text as this refers to net gain (we have moved on from 'no net loss'). It specifically states that: "Planning policies and decisions should contribute to and enhance the natural and local environment by: ... d) minimising impacts on and providing net gains for biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures..." It is recommended that this text from the NPPF is included in the text of the Plan.
-There should be clearer guidance on which biometric calculator is expected (or is acceptable) to be used. The paragraph refers to "Warwickshire's" metric which should be specified as the most recent metric being used by Warwickshire County Council (version 20 is soon to be published). Consideration should also be given to the use of the Defra 2.0 metric, which is currently available as a beta version, and is likely to be finalised in summer 2020.
MM227
Ecology
There is no reference in this section to the statutory protection afforded to Local Nature Reserves. It is recommended that this is included.
MM228 (NE1 Protected Sites)
Ecology
NE1 Protected Sites has been written based on paragraph 175 of the NPPF, which is appropriate. However, paragraphs 176 and 177 of the NPPF also relate to protected sites and it appears these have not been considered in NE1, or at least they are not easily identifiable as having been considered. It is recommended that this wording is incorporated in to the VALP for the avoidance of any doubt as to the definition/protection of a protected site/habitat:
"176. The following should be given the same protection as habitats sites:
a) Potential special protection areas and possible special areas of conservation;
b) Listed of proposed Ramsar sites; and
c) Sites identify or required as compensatory measures for adverse effects on habitats sites, potential special protection areas, possible Special Areas of Conservation, and or proposed Ramsar sites.
Paragraph 177. The presumption in favour of sustainable development does not apply where the plan or project is likely to have a significant effect on a habitats site (either alone or in combination with other plans or projects), unless an appropriate assessment has concluded that the plan or project will not adversely affect the integrity of the habitats site
MM230
Ecology
It would be helpful if this paragraph included examples of which "species have historically been entirely dependent on human habitation for their reproductive success". It should also be specified in this paragraph that planning conditions will be used to ensure these features are installed (in an appropriate way that will benefit wildlife) in the development.
MM231
Ecology
Paragraph 9.17 of the VALP should include reference to the Buckinghamshire and Milton Keynes Natural Environment Partnership (NEP) who is currently preparing the supplementary planning document (SPD) that is the subject of this paragraph. This will raise awareness of the NEP which will become increasingly important as biodiversity accounting/offsetting becomes the 'norm' in development terminology.
MM275
Strategic Flood Management
Policy I4 (page 314 and 315 of tracked changes)
 f. - Wording is unclear in terms of what is expected of an applicant. The Strategic Flood Management team would suggest the wording is amended as follows: Ensure that the proposed drainage system can contain up to the 1 in 30 storm event without flooding. Any onsite flooding between the 1 in 30 and the 1 in 100 plus climate change storm event should be safely contained on site.
- i. - the connectivity between the original bullet point and the additional wording is not clear. It is would advised that guidance is sought from the Environment Agency on the suitability of this wording.
-o. - refers to surface water runoff and then goes onto encompass all sources of flood risk. The focus of this bullet point is SuDS to manage development runoff. It is suggested that where the LPA want to promote SuDS as a measure for mitigating other sources of flood risk this should be included within a separate bullet point.
o. - The Strategic Flood Management disagree with the suggested amendment regarding discharge rates being solely agreed by the sewerage undertaker. There needs to be partnership working between the sewerage undertaker and Lead Local Flood Authority to determine a suitable discharge rate for the site. Therefore, the Strategic Flood Management team would suggest the following amendment: Where the final discharge point is the public sewerage network the runoff rate should be agreed with the sewerage undertaker in consultation with the Lead Local Flood Authority.
Policy I4

Flood risk assessments
- Amend first line to say 'All development proposals must adhere to the advice in the latest version of the SFRA and also the general advice in Section 4 of the groundwater addendum, plus any site-specific advice within the groundwater addendum, and will':
-e- it would be helpful if the policy could define the word 'harm' as this is currently open to interpretation. If not defined, it is suggested this word is removed. Additionally ask that the term 'third parties' is clarified, or propose using alternative wording such as downstream receptors, existing development and/or adjacent land.
-k- insert 'as defined in the Planning Practice Guidance para 041' after 'provide an assessment of residual flood risk'.
i- to include an additional point (L) to say 'include detailed modelling of any ordinary watercourses within or adjacent to the site, where appropriate, to define in detail the area at risk of flooding and model the effect of climate change'.
-l.- include a bullet point (M) to say 'complete site specific ground investigations to gain a more local understanding of groundwater flood risk and inform the design of sustainable drainage components'.
-After title heading Sustainable drainage systems (SuDS) in policy I4, to include the following wording 'All development proposals must adhere to the advice in the latest version of the SFRA and also the general advice in Section 4 of the groundwater addendum, plus any site-specific advice within this groundwater addendum, and will:
The Strategic Flood Management team has no other comments relating to the modifications. It is, however, regretful to note that none of our previous recommended changes to Chapter 11 ('Flood risk' section and Policy I3, now I4) that we set out in BCC's final representation (dated 14th Dec 2017) to the Proposed Submission Version of the VALP were made.

Attachments: