Aylesbury Vale Area

MM070

Showing comments and forms 1 to 20 of 20

Object

VALP Main Modifications

Representation ID: 2795

Received: 02/12/2019

Respondent: Halton Parish Council

Legally compliant? Yes

Sound? No

Representation:

Factually, the houses are in Halton Parish and it will close in 2026

Change suggested by respondent:

In terms of Halton, approximately 1,000 homes will come forward during the Plan period at RAF Halton Camp after its closure in 2026

Full text:

Factually, the houses are in Halton Parish and it will close in 2026

Object

VALP Main Modifications

Representation ID: 2932

Received: 11/12/2019

Respondent: Buckingham Town Council

Legally compliant? No

Sound? No

Representation:

Given the evidence used to justify the removal of BUC051 and other potential future sites, then it is no longer possible to claim that Buckingham is the second most sustainable site, as there is little potential for future growth to sustain services, if sites cannot come forward due to traffic problems. The new evidence does not demonstrate sufficiently why these two sites will not impact on the traffic in Buckingham.
BTC would also refer to previous representations to the original consultation as to the lack of popular support for these sites.

Change suggested by respondent:

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

Full text:

Given the evidence used to justify the removal of BUC051 and other potential future sites, then it is no longer possible to claim that Buckingham is the second most sustainable site, as there is little potential for future growth to sustain services, if sites cannot come forward due to traffic problems. The new evidence does not demonstrate sufficiently why these two sites will not impact on the traffic in Buckingham.
BTC would also refer to previous representations to the original consultation as to the lack of popular support for these sites.

Object

VALP Main Modifications

Representation ID: 2972

Received: 17/12/2019

Respondent: Crevichon Properties Ltd

Agent: Delta Planning

Legally compliant? Yes

Sound? No

Representation:

We support the Proposed Modifications which reallocates site WIN020 for elderly accommodation under new Policy H6b and reduces housing numbers on site WIN001, but would consequently ask the Council and the Inspector to reallocate site WIN003 from employment use to residential use to help towards meeting the District's housing needs.

Change suggested by respondent:

Inclusion of WIN003 land south of Buckingham Road, Winslow as a residential site.

Full text:

We object to new Policy D2 ' Delivering site allocations in the rest of the district' on the basis that site WIN003 Land south of Buckingham Road is not included within the list of residential allocations. WIN003 should be allocated for residential development for the following reasons:

- Contribution to District Housing Needs - The VALP initially proposed to identify land within Winslow for some 585 additional homes, all within one site outside the existing settlement boundary situated at land east of B4033, Great Horwood Road (WIN001). The proposed main modifications seek to reduce this allocation to only 315 additional homes. This is to reflect the capacity the site offers. WIN001 has recently been the subject of an outline planning application for 120 dwellings at Old Brickyard Farm, Great Horwood Road submitted by Land and Partners. Gladman has also submitted two separate outline applications for the reminder of the site for 215/235 houses respectively. The latter application for 235 homes is currently being appealed against non-determination. Given the above, it has become clear that the site capacity (if approved) is much lower than originally thought. Given Winslow is identified as one of the strategic settlements, it is considered that another site should be allocated to make up the shortfall.

- The location of WIN003 is highly sustainable within easy walking distance of Winslow Town Centre and adjacent to a school and proposed new station. Government policy seeks to encourage high density residential development in sustainable locations such as transport hubs.

- Residential use of the subject site is more compatible with other uses namely the school and station.

- The site offers the ability to provide a mix of dwelling types and tenures including a high proportion of affordable/starter homes.

- The land is already an identified development plot (and has been so for 15 years) and is fully serviced and available.

- There is no shortage of employment land in the District. Paragraph 3.13 of the Draft VALP states that the Council currently has an oversupply of over 100ha of employment land. Indeed, Government policy strongly encourages Council's to reallocate land where it is not likely to come forward for its allocated use. Further evidence of the lack of need for employment land in Winslow is demonstrated by the reallocation of WIN020 from employment to housing for the elderly.

- The site has been substantially marketed for 10 years without any success.

- The site has no technical or environmental constraints that would prevent residential development.

In light of the above, we support the Proposed Modifications which reallocates site WIN020 for elderly accommodation under new Policy H6b and reduces housing numbers on site WIN001, but would consequently ask the Council and the Inspector to reallocate site WIN003 from employment use to residential use to help towards meeting the District's housing needs.

Object

VALP Main Modifications

Representation ID: 2988

Received: 12/12/2019

Respondent: Arnold White Estates

Agent: Arrow Planning Ltd

Legally compliant? Yes

Sound? No

Representation:

MM070 There is a new Policy D2 'Delivering site allocations in the rest of the district' on
p124 of the modified Plan. MM080 This refers also to a different Policy D2 which is actually
Policy D3 in the Modified Plan.
The apparent exclusion of 'agricultural buildings' from being converted (or developed) to
residential is contrary to the GDPO Class Q (15.4.15) which allows conversion up to 5 units
in former agricultural buildings.

Change suggested by respondent:

Please view the attached form.

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.

Support

VALP Main Modifications

Representation ID: 3014

Received: 13/12/2019

Respondent: Crest Nicholson

Agent: Mr James Brewer

Representation:

Crest Nicholson fully support the new policy D2 that includes D-WHA001 Shenley Park in the list of major strategic sites that are allocated for development.

Please also see document 32735 Crest Nicholson Section 4 supporting this representation.

Full text:

Crest Nicholson fully support the new policy D2 that includes D-WHA001 Shenley Park in the list of major strategic sites that are allocated for development.

Please also see document 32735 Crest Nicholson Section 4 supporting this representation.

Attachments:

Object

VALP Main Modifications

Representation ID: 3040

Received: 15/12/2019

Respondent: Liz Rawlinson

Legally compliant? Yes

Sound? No

Representation:

We call into question the soundness of proposed sites adjacent to Milton Keynes on grounds of justification, effectiveness and compliance with national policy. We ask that a Public Enquiry be re-opened to examine the evidence used to support development on the Milton Keynes boundary and to consider viable alternatives.

Change suggested by respondent:

Removal of D-WHA001 Shenley Park and D-NLV001 Salden Chase from the Plan.

Full text:

As Chair of The Mill Residents' Association, Water Eaton (350 homes) and representing the Consortium of Bletchley Residents' Associations (COBRA), we wish to object to the new policy and supporting text MM070 re sites adjacent to Milton Keynes - D-NLV001 Salden Chase and D-WHA001 in particular. We to do not consider inclusion of these sites to be sound on the following grounds:
Justification: Inclusion of Shenley Park and Salden Chase cannot be the most appropriate strategy when considered against reasonable alternatives. There is insufficient evidence that reasonable alternatives have been discounted.
Effectiveness and Compliance with National Policy: The Plan for North East Aylesbury Vale is not based on effective joint working on cross-boundary strategic priorities where the burden of infrastructure delivery will be placed almost entirely on Milton Keynes. These modifications fail in their sensitivity to the local character, create an unreasonable additional burden on the neighbouring authority, and do not meet the NPPF requirements for sustainability.
The delegated decision process for Salden Chase has not yet been resolved and it should be excluded from the VALP. Negotiations between Planning Officers between LPAs has demonstrated that AVDC fails to consider the full implications of such developments on its neighbour and has little respect for the unique character and ethos of Milton Keynes. The ability to demonstrate compliance with its Duty to Co-operate is therefore highly questionable.

Object

VALP Main Modifications

Representation ID: 3222

Received: 15/12/2019

Respondent: Miss Marlen Lawrenz

Legally compliant? No

Sound? No

Representation:

I object to MM070, MM071, MM075 and MM076 (in respect of 'Shenley Park') given that:-
1) The modifications were made without due consultation of the affected parties, thereby preventing a proper comparison testing of the three potential sites (Eaton Leys, Salden Chase & Shenley Park).
2) AVDC failed to comply with its 'Duty to Cooperate' with the adjoining local authority MKC in terms of i) local planning aims, and ii) developer's contributions.
3) The Sustainability Appraisal appears to be incomplete, jeopardising the report's soundness and validity of its conclusions.

Change suggested by respondent:

Modifications MM07, MM071, MM075 & MM076 need to be deleted from the VALP before adoption of the VALP occurs. Eaton Leys, Bletchley or Salden Chase, Newton Longville should be considered as a sustainable replacement for Shenley Park. Ideally, alternative sustainable sites should be identified closer to the larger towns within Aylesbury Vale - thereby helping that towns' sustainability and economy rather than that of Milton Keynes.

Full text:

I object to the proposed Main Modifications MM070, MM071, MM075 and, importantly, MM076, which have all been made in respect of 'Shenley Park (WHA001). My objection is based on the following key points:-

1. Shenley Park was only included at this late stage by way of 'modification'. It is, however, evident that AVDC's decision to prefer Shenley Park over the two competing sites (Eaton Leys & Salden Chase) was taken without allowing for a full hearing of the parties affected by the proposed site allocation. This lack of consultation denied Whaddon Parish Council and local residents the opportunity to properly examine, scrutinize and discuss Shenley Park and its impact. Importantly, this also prevented a due & proper comparison testing of the three potential allocation sites. This is unfair and the modifications are not adequately justified. I ask the Inspector to open a further hearing session at the end of the consultation period to rectify this defect, which could otherwise render the final plan unsound and therefore, potentially, unlawful.

2. The proposed modifications were made by AVDC without complying with its 'Duty to Co- operate' with the adjoining authority (being MKC). Whilst AVDC stated that it kept MKC informed, no records or minutes have been provided to evidence effective discussions or proper joint working. It was acknowledged by MKC at the Full Council Meeting on 23 Oct 2019 that a failure to cooperate had occurred. This breach of Government guidelines and national policy may affect the soundness of the plan. I therefore ask the Inspector to re- open the hearing sessions to allow AVDC to adequately respond.

2.1. This failure to cooperate is particularly concerning as the AVDC Local Plan fails to take into account the strategies stated in the MKC Local Plan, in particular in terms of MK's proposed development areas, infrastructure, accessibility and biodiversity aims. This casts serious doubt on the effectiveness of the AVDC Local Plan where it is not aligned with the MKC Local Plan.

2.2. Further issues arise in respect of the proposed distribution of S106 payments, or indeed the complete lack of discussion regarding CIL payments. All three proposed sites are located in immediate proximity of Milton Keynes. As a result, residents will primarily use MK's public services, in particular for healthcare, policing, ambulance, fire services, education etc. This was even acknowledged in the proposed modification MM076. Yet, the AVDC Local Plan fails to address or mitigate the respective strain on MK's infrastructure. In fact, there is a fundamental mismatch between the two local authorities' treatment of developer's contributions: Whilst MKC operates a tariff system under the CIL regime (with a guaranteed amount paid per dwelling), AVDC have not yet started preparing for the adoption of CIL; this is only expected to commence after the Local Plan is adopted. Instead, AVDC rely on the S106 method which is open to developer debate and challenge, therefore potentially delaying the Local Plan's delivery.
And yet, this discrepancy was not remedied by way of 'proper joint working'. I therefore ask the Inspector to re-open the hearing to allow for full discussion of the above points.

3. AVDC uses the Sustainability Appraisal (SA) as main evidence for its decision to favour Shenley Park over suitable alternatives at Eaton Leys and Salden Chase. However, it appears that the SA fails to adequately discuss and appraise some important aspects of Shenley Park in terms of landscape, traffic & highways and biodiversity, therefore casting serious doubt on the completeness and effectiveness of the document. Importantly, the document completely omits the importance of the North Bucks Way (Bridleway). This is not justified. Without duly considering the importance of this ancient landscape boundary, natural habitat and wildlife corridor, the report's soundness is seriously jeopardised, in particular its reasoning and conclusions regarding the sites' landscape and biodiversity aspects. I therefore urge the Inspector to re-open the hearing to be able to adequately discuss and assess the impact of interrupting the North Bucks Way by the proposed grid road extensions.

Object

VALP Main Modifications

Representation ID: 3255

Received: 07/01/2020

Respondent: Jill Mead

Legally compliant? Not specified

Sound? Not specified

Representation:

Further development would mean a reduced quality of life, this isn't progress

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: 3283

Received: 17/12/2019

Respondent: Jones Lang LaSalle

Legally compliant? Not specified

Sound? Not specified

Representation:

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: 3288

Received: 07/01/2020

Respondent: Pete Shaw

Legally compliant? Not specified

Sound? Not specified

Representation:

Firstly, I wish to complain at the "innocent" way in which the housing numbers have been modified. In all instances this has changed from "around" to "at least". This is truly dishonest as if necessary it could be interpreted as changing from "around" to "unlimited" and this is totally unacceptable. No housing plan should have such freedom without continuing reference to other local needs and protections.

Full text:

The Oxford-Cambridge Express Way

Sitting here as a retired engineer I can well understand the concept of an Oxford-Cambridge Expressway. We desperately need to stop the continuing focus on the M25/M4 corridors and transport around London. A belt of new infrastructure joining Oxford, Bicester/Banbury, Milton Keynes, Bedford and Cambridge sitting between London and the Midlands would be an ideal solution. If HS2 goes ahead there will be a new natural centre of communications in the area where it crosses the proposed expressway. Aylesbury, sitting midway between the M25 corridor and the expressway, must have a clear strategy as to how it is to integrate itself into this new concept or it will be left behind. I don't see Aylesbury ever enticing major employers into the area unless things change dramatically. Already we can see the early signs of what an expressway could be by looking at the local growth in the Bicester/Banbury area (M40) and Milton Keynes (M1). Also the recent fast communications between Milton Keynes, Bedford and the A1. With this already happening and the concept of a fully integrated expressway on the horizon, I cannot see Aylesbury benefitting from this with its poor road and rail communications in all directions. The VALP gives no indication of the way forward and this lack of vision is certainly not "justified as the most appropriate strategy when considered against reasonable alternatives". As of its local road system, anything will be just "too little, too late". Our local roads provide little enticement to prospective work creating investors. I hate to say this, but I don't see a future Aylesbury Garden Town but just a massive housing estate in no man's land where most of its workforce travel north, south, east or west on second class roads to places of employment.

Housing Numbers

Firstly, I wish to complain at the "innocent" way in which the housing numbers have been modified. In all instances this has changed from "around" to "at least". This is truly dishonest as if necessary it could be interpreted as changing from "around" to "unlimited" and this is totally unacceptable. No housing plan should have such freedom without continuing reference to other local needs and protections.
Secondly (and here I am sure I'm speaking on behalf of most of Aylesbury's residents) I have no faith in the council's local traffic strategy. With all the proposed house building, a clear strategy is needed but all we get is "too little, too late" tactical solutions. Because there are no strategic funds available (or perhaps no will to fight for them) we are left to resort to a series of S106 agreements which are used to force house developers to pay for a series of linked estate roads which do not constitute a fast efficient route round or in and out of Aylesbury. I accept the need for S106 agreements to supply local benefits but abhor how they are being used to supply strategic solutions. Strategic needs should be borne by the community as a whole, not just by the subset of house on a new housing development. My two eldest grandsons will soon be looking for starter homes in Aylesbury and if the house costs are increased by totally unfair S106 agreements I will not be very happy. In summary, the VALP traffic plan claim to be "positively prepared by seeking to meet objectively assessed development and infrastructure requirements" is a fairy-tale.

HS2 and D-AGT2

Yet again, we have the flamboyant claim "has been positively prepared, seeking to meet objectively assessed development and infrastructure requirements". These claims must come from some official local government handbook of fatuous phrases. If D-AGT2 is it be built it should stand on its own merits with strategic needs borne strategically as outlined above. Even before the recent HS2 delays it was unlikely that the developments would coincide. As it is I fear for the new residents who may find their lives, after nicely settling in for a couple of years, totally disrupted by the construction of HS2.

Object

VALP Main Modifications

Representation ID: 3366

Received: 17/12/2019

Respondent: David Lock Associates

Legally compliant? No

Sound? No

Representation:

1 Hallam Land Management have set out representations in relation to MM082, 083 and 084 in relation to sites BUC043, BUC046, MM006, BUC051 and BUC025.
2 A series of suggested changes are proposed to make the plan sound primarily:
* the deletion of BUC043, BUC046 and MM06 alongside the deletion of BUC051 (MM083); or
* in the alternative the reinstatement of BUC051 and the inclusion also of BUC025 - to maximise developer contributions
3 The adoption of these suggested changes to make the VALP sound will require consequential amendment of the list of sites in policy D2 (MM070).

Change suggested by respondent:

Amendment of sites included in Policy D2 to exclude BUC043, BUC046, MM006
OR
addition to list of sites of BUC051 and BUC025

Full text:

Nick Freer (David Lock) reps for Hallam Land - Buckingham
17 Dec 2019

FULL TEXT
Dear sirs
Further to the ongoing consultation in relation to the VALP Main Modifications please find attached representations on behalf of Hallam Land Management (Buckingham). They relate to five MMs specifically MM70, MM82, MM83, MM84, MM210. I look forward to your further consideration of the representations. Kind regards
Nick Freer
Chairman

REP to MM070

NO SUMMARY PROVIDED.

FULL TEXT

1 Hallam Land Management have set out representations in relation to MM082, 083 and 084 in relation to sites BUC043, BUC046, MM006, BUC051 and BUC025.

2 A series of suggested changes are proposed to make the plan sound primarily:

* the deletion of BUC043, BUC046 and MM06 alongside the deletion of BUC051 (MM083); or

* in the alternative the reinstatement of BUC051 and the inclusion also of BUC025 - to maximise developer contributions towards the delivery of key infrastructure.

3 The adoption of these suggested changes to make the VALP sound will require consequential amendment of the list of sites in policy D2 (MM070).


REP to MM082

SUMMARY


HLM(B) consider that proposed modifications MM082 (BUC043), MM084 (BUC046) - amending policies BUC043 and BUC046 to secure contributions towards unexplained infrastructure are insufficient to make either policy sound, nor MM006. As such the VALP should be further modified by the deletion of all of the Buckingham and Maids Moreton allocations in favour of their allocation through the ongoing Buckingham Neighbourhood Plan revision by which time there would be more prospect of an adequate evidence base in relation to the transport impacts of each allocation. Even if the Inspector is satisfied that the evidence base justifies the allocations, there remains the question of how the identified mitigation strategy - where the WLR is prioritised - will be delivered. In this circumstance, to ensure the effectiveness of the Plan and meet its obligations in respect of infrastructure delivery the VALP should be modified to maximise contributions through further allocations.

FULL TEXT

1 AVDC propose modifications to both BUC043 and BUC046 in relation to the Buckingham Transport Strategy: "A financial contribution will be needed towards finding appropriate elements of the Buckingham Transport Strategy".

2 HLM consider that this is a wholly insufficient response to seek to make the allocations sound.

3 HLM (B) has set out detailed representations on MM083 - the deletion of BUC051. Such representations should be read in conjunction with HLMs objections to MM082 and MM084.

4 Of particular note, HLMs representations on MM083 highlight:
* the conclusions of AVDC's existing evidence base which is that there are significant congestion issues in Buckingham Town Centre already
* the conclusions of the same evidence base that the Western Link Road has been set out as the most effective means of addressing existing issues and mitigating growth in Buckingham;
* the absence of any evidence base to conclude that BUC043 and BUC046, individually or collectively, with or without BUC051 or BUC025, will not also have a significant effect on an existing congested network;
* the absence of reference to the WLR in the MM210 listing mitigation schemes in an amended policy T3; and
* that BUC051 has totally unreasonably been singly and inappropriately ruled out of the Buckingham strategy - despite the positive role that it (or the alternative/additional BUC025) might play

5 Given the above, a requirement for an unspecified contribution towards unspecified works from a development without the benefit of a specific assessment of its impacts on a congested network, fails all tests of soundness. There isn't the evidence to justify.

REP to MM083

SUMMARY

In conclusion, the proposed strategy for Buckingham sites including the deletion of BUC051 (and its non-replacement with BUC025) is unsound because it is completely unsupported by the evidence base. In circumstances where the evidence base says that the Town Centre is already congested and that the most effective means of mitigation is the WLR, the progression of the Main Mods is unsound with no reference to the WLR and the retention of sites BUC043 and BUC046. Moreover, in the absence of modelling, the allocations give every impression of adding to (without mitigating) town centre congestion and town wide journey times.
Not only is the strategy, as proposed to be modified, unsound on the basis of a lack of evidence and justification, the deletion of BUC051, the lack of inclusion of BUC025 and the absence of reference to the WLR in MM210, also results in the Plan being unsound in terms of its failure to plan positively for the infrastructure that has been identified as being necessary.

FULL TEXT


1 Hallam Land Management Buckingham (HLM(B)) controls land owned by New College Oxford to the west and south of Buckingham and including sites BUC025 and BUC051. New College Oxford owns significant additional land to the West of Buckingham, capable of accommodating much of the proposed Western Bypass. The WLR can be delivered within the control of HLM(B) and New College.

2 Both prior, and subsequent, to the publication of the suggested changes to the Plan by AVDC - which addressed BUC051 and the Western bypass - HLM wrote to seek a dialogue to discuss the both of these issues - along with the failings perceived by HLM in the evidence base that was being presented to support what are now MM083 (BUC051), MM082 (BUC043), MM084 (BUC046), MM210 (Policy T3), MM205 (para 7.10) and consequentially MM070 (Policy D1).

3 I enclose a copy of correspondence to AVDC (Appendix 1) which highlighted the strong need for that evidence base to be reinforced prior to the publication of the Proposed Modifications. Otherwise, it was indicated to AVDC, that it will be difficult in the extreme to make representations on the proposed modifications relating to Buckingham - leading to considerable risk of the Mods and hence VALP being unsupported by available evidence and potentially liable to challenge.

4 No response was received, and no such discussions have been entertained by AVDC or BCC. The failings in terms of soundness and/or legal compliance set out in these representations therefore have, regrettably, had to be made without the benefit of such dialogue or additional evidence.

5 The principal additional evidence produced in support of the Proposed Modifications since the Examination is understood to be:
* the Revised County Modelling for Buckingham (Addendum to the Phase 3 Modelling Report) (3 April 2019) (ED214B)
* the Buckingham Town Centre Modelling report (24 May 2019) (ED214A)
* BCC's advice note to AVDC (ED215)

6 Having completed these studies, AVDC propose the deletion of BUC051 (MM083) - the reserve site allocated in the Buckingham Neighbourhood Plan - and retains BUC043 and BUC046 neither of which were allocated in the Buckingham Neighbourhood Plan - albeit with an additional obligation to contribute to transport.

7 Further consideration was given to BUC051 in the light of the Inspectors Initial Findings (IIF) that BUC051 might be considered to be dependent upon the Western Link Road (WLR) in the Buckingham Transport Strategy but that there was no policy seeking to deliver that Link Road. The expectation was that AVDC would - as has been the case in Aylesbury - add in those key elements of infrastructure into T3 through a Main Modification. To be clear the Inspector did NOT consider to what extent other allocations in Buckingham (BUC043 and BUC046) as well as Maids Moreton (MM006) were also dependent on key elements of the Buckingham Transport Strategy (BTS) including the Western Link Road (WLR).

8 Just by way of context, the WLR is identified as necessary for Buckingham as a whole in the Infrastructure Development Plan - an expectation that has not been updated since the Examination hearings.

9 Equally important, in terms of context, the Buckingham Transport Strategy considered the demands of growth at Buckingham as a whole - BUC043, BUC046, BUC051 and BUC025 (although the latter was not allocated in the submission VALP). Para 4.4.2 of the BTS ranked the Western Link Road as being of highest priority followed by the West Street downgrade. Other route upgrades and Left turn slip/junction improvements were given less priority. Funding of the priority schemes was acknowledged to be likely to rely principally on section 106 funding (BTS para 4.5.3).

10 AVDC's justification for deleting BUC051 is set out in Examination Document ED215B published alongside the Proposed Modifications. AVDC argues that it has changed its mind regarding the acceptability of phasing the development of BUC51 to take account of the WLR and now "detailed town centre modelling shows that BUC051 would have an unacceptable impact on the town centre even if the development was phased" (ED214A).

11 Further, AVDC argues that the only way to secure the mitigation of the town centre impacts would be the WLR - but this could not be funded by 300 dwellings (here the County explicitly mooted a much larger allocation to secure the WLR).

12 This conclusion was reached following specific consideration of BUC051 and its specific impacts on the Town Centre in the County Councils addendum to its Phase 3 Modelling report and the Town Centre Modelling Report - work that was not carried out in respect of any of the remaining Buckingham allocations.

13 Apparently as a makeweight, or secondary argument, AVDC argues that there is no need for BUC051 as a reserve site in the manner anticipated in the Buckingham Neighbourhood Plan because the BNP sites had or were coming forward and additional development should be allocated on the edge of MK to reflect the Inspectors Initial Findings. The allocation of 1150 homes at Shenley Park (D0-WHA001, EC125) - well above the gap identified by the Inspector allows AVDC to delete BUC51 but equally makes the point that there would be no harm whatsoever in the allocation of WHA001 and BUC051 or indeed other additional sites at Buckingham to deliver infrastructure (e.g. BUC025). The two locations should not be linked given the scale of need and the consequent undermining of the Buckingham Neighbourhood Plan by the de- allocation of its reserve site.

14 HLM and its transport consultants have considered the additional evidence now produced in support of the deletion of BUC051 and conclude that MM083 is simply not supported by the evidence base that is presented. The deletion of the site - a site already tested and found sound having been examined in a Neighbourhood Plan context - through the VALP is simply not justified by the evidence.

15 The Buckingham Transport Strategy is based on all sites coming forward and puts in place a section 106 contribution-based strategy to deliver what is needed to meet both the demands of the planned growth but also, explicitly, the existing traffic constraints and difficulties in the town - in particular, in the town centre. The key identified requirement is the WLR to facilitate the down-grading of West Street.

16 Perhaps the biggest issue here is the level of congestion in the Town centre. Traffic in Buckingham town centre is highlighted as an existing issue in the adopted Buckingham Neighbourhood Plan and Buckingham Transport Strategy, and indeed the most recent modelling (ED214A). One of the issues is the performance of the two key town centre junctions - the focus of the latest Town centre modelling report (ED214A). ED214A confirms that both junctions will be operating beyond capacity in 2033 - even with no new development in Buckingham. It concludes that each development scenario tested would be unacceptable.

17 It apparently concludes that the traffic effects of the Proposed Modifications, even with no BUC051, would therefore be unacceptable on the town centre.

18 No evidence is presented in the additional modelling that the Proposed modification strategy (BUC43, BUC46 and MM06) has an acceptable impact on the Town Centre. The test has not been done and no evidence prepared to show that the suggested modifications are acceptable in terms of town centre impact.

19 Equally, none of the assessments have considered whether BUC043 or BUCO46 or MM06 - if treated in isolation (as BUC051 has been) - would have more or less of an impact on journey times in Buckingham than BUC025 or BUC051. The evidence is missing.

20 Nor has any testing been undertaken to determine the relative impacts of each of the VALP sites on congestion in the Town Centre which is already an identified problem in the evidence base. Intuitively BUC043 would have a substantial effect on the Moreton Road/Market Square junction. Had assessments been undertaken of individual sites (other than BUC051) in the latest modelling (they have not), it is likely that they would have shown that BUC043/BUC46/MM06 would equally have had unacceptable impact on the town centre.

21 The two sites with the comprehensive evidence base are the two sites omitted from the VALP (BUC025 and BUC051). Those with no substantive evidence are retained in the VALP - at the same time undermining the Buckingham Neighbourhood Plan.

22 Moreover, even if BUC051 were to be deleted from the Plan there is no evidence based reason not to replace BUC051 with BUC025. BCC did consider BUC025 (South of the A421). BCC considers in its advice that:
* it would have less impact on the TC so not unacceptable on highway grounds [i.e is perfectly acceptable];
* but "would not assist reducing traffic through the town centre in that it would not contribute to strategic infrastructure such as the Western Relief Road nor the Buckingham Transport Strategy". This, as a rationale or evidence, is nonsense as any modification to replace BUC051 with BUC025 would have with it a policy obligation to contribute to the BTS - just as is the case in MM82 and 84 - where that financial requirement is now required for sites BUC043 and BUC046.

23 While the Main Mods do not propose to allocate BUC025, notwithstanding the evidence that AVDC assembled, the allocation of BUC025 instead of, or as well as, BUC051 and in addition to BUC043, BUC046 and MM006, would make a strong contribution to delivering transport infrastructure through increased contributions for the Buckingham Transport Strategy. BUC025 was considered entirely suitable for development in the AVDC HELAA with a potential yield, in that assessment, of 360 dwellings.

24 In conclusion, the proposed strategy for Buckingham sites including the deletion of BUC051 (and its non-replacement with BUC025) is unsound because it is completely unsupported by the evidence base. In circumstances where the evidence base says that the Town Centre is already congested and that the most effective means of mitigation is the WLR, the progression of the Main Mods is unsound with no reference to the WLR and the retention of sites BUC043 and BUC046. Moreover, in the absence of modelling, the allocations give every impression of adding to (without mitigating) town centre congestion and town wide journey times.

25 Before there can be any possibility of the strategy, as amended by the PMs, being found sound, additional work must be completed to:
* provide an evidence base on the impact of the remaining allocations (BUC043, BUC046 and MM006) on the town centre individually and collectively - none exists;
* inform whether all allocations (including BUC025 and BUC051), to secure the mitigation strategy, or none, to allow allocations to come through the BNP, should be pursued;
* set out the specific benefits of each mitigation measure and to base the inclusion of schemes on that evidence. In this regard the BTS affords greatest priority to the WLR (above other schemes) as being the most effective means of mitigation for the town - because it frees up the opportunity to downgrade Bridge/West Street and the High Street.

26 Not only is the strategy, as proposed to be modified, unsound on the basis of a lack of evidence and justification, the deletion of BUC051, the lack of inclusion of BUC025 and the absence of reference to the WLR in MM210, also results in the Plan being unsound in terms of its failure to plan positively for the infrastructure that has been identified as being necessary.

27 The best opportunity to deliver the infrastructure that should be included in the Plan - the WLR - is to maximise the contributions from development.

28 The only sound alternative is to not allocate any sites at Buckingham to meet the identified requirement and to devolve the allocation of sites to the next review of the Buckingham NP which is already underway. This is on the basis that there is simply not a sufficient evidence base to proceed with any of the allocations at Buckingham in the VALP. By this means opportunities for positive planning and integrated planning to deliver the WLR etc. could be realised through the NP rather than wasted in the unevidenced and incomplete strategy in the VALP.

29 Critical in this regard is the importance attached to town centre junction issues - and the problems now experienced - and the absence of any comparable assessment of the impact of the BUC43 and BUC46 and MM06 sites on the town centre. Only BUC051 has been assessed. Indeed, ED215A appears to conclude that any development scenario will make matters worse - exponentially - without a proper mitigation strategy.

30 The made Buckingham Neighbourhood Plan (made in October 2015) has proved highly effective in delivering substantial, locally supported, housing numbers. Such a course of action would avert the current need for more evidence prior to the adoption of the VALP. Instead the VALP process could proceed but could divert Buckingham allocations to the NP review, the existing NP having successfully allocated and delivered housing in the absence of an up-to-date Local Plan.

31 That a Neighbourhood Plan is a proper and established and effective route in other places as well as in Buckingham is evident in the experience, in the immediate vicinity at Thame. The Thame Neighbourhood Plan in adjoining South Oxfordshire has likewise successfully allocated sites for some 775 new homes and associated infrastructure - delivering the strategic policies of the District wide plan.

32 Equally the WLR can be delivered within the control of HLM(B) and New College - and can then be included in the VALP or worked through in the update of the Buckingham Neighbourhood Plan that has already commenced.

33 In setting out these observations HLM (B) is very aware that that addendum to the Sustainability Appraisal fails to consider any of the implications of the amended development strategy for Buckingham on the ability to deliver the key infrastructure that the evidence base demands. The SA Addendum simply considers the rather esoteric and immaterial question of whether including scheme details (across the VALP) as words in the VALP is positive or negative.

34 Overall the proposed Main modifications and resultant policies may well be considered to have potential for challenge.


REP TO MMO84

SUMMARY

HLM(B) consider that proposed modifications MM082 (BUC043), MM084 (BUC046) - amending policies BUC043 and BUC046 to secure contributions towards unexplained infrastructure are insufficient to make either policy sound, nor MM006. As such the VALP should be further modified by the deletion of all of the Buckingham and Maids Moreton allocations in favour of their allocation through the ongoing Buckingham Neighbourhood Plan revision by which time there would be more prospect of an adequate evidence base in relation to the transport impacts of each allocation. Even if the Inspector is satisfied that the evidence base justifies the allocations, there remains the question of how the identified mitigation strategy - where the WLR is prioritised - will be delivered. In this circumstance, to ensure the effectiveness of the Plan and meet its obligations in respect of infrastructure delivery the VALP should be modified to maximise contributions through further allocations.

FULL TEXT

1 AVDC propose modifications to both BUC043 and BUC046 in relation to the Buckingham Transport Strategy: "A financial contribution will be needed towards finding appropriate elements of the Buckingham Transport Strategy".

2 HLM consider that this is a wholly insufficient response to seek to make the allocations sound.

3 HLM (B) has set out detailed representations on MM083 - the deletion of BUC051. Such representations should be read in conjunction with HLMs objections to MM082 and MM084.

4 Of particular note, HLMs representations on MM082 and 084 highlight:
* the conclusions of AVDC's existing evidence base which is that there are significant congestion issues in Buckingham Town Centre already
the conclusions of the same evidence base that the Western Link Road has been set out as the most effective means of addressing existing issues and mitigating growth in Buckingham;
* the absence of any evidence base to conclude that BUC043 and BUC046, individually or collectively, with or without BUC051 or BUC025, will not also have a significant effect on an existing congested network;
* the absence of reference to the WLR in the MM210 listing mitigation schemes in an amended policy T3; and
* that BUC051 has totally unreasonably been singly and inappropriately ruled out of the Buckingham strategy - despite the positive role that it (or the alternative/additional BUC025) might play

5 Given the above, a requirement for an unspecified contribution towards unspecified works from a development without the benefit of a specific assessment of its impacts on a congested network, fails all tests of soundness. There isn't the evidence to justify. There isn't an effective mitigation strategy and hence it is neither effective or positively prepared.

REP TO MM0210

SUMMARY

Hallam Land Management (Buckingham) (HLM(B)) do not believe that the Main Modifications are sufficient to make the VALP sound, the Inspector having found this aspect of the Plan to be unsound in his IIF. T3 is therefore fundamentally unsound in failing to respond positively to the planning and delivery of infrastructure and failing to deliver necessary infrastructure accepted in the evidence base.
The infrastructure that must be included in the Plan according to the evidence base is the Western Link Road.

To deliver this - all allocations at Buckingham or Maids Moreton should be deleted to ensure that a comprehensive approach to delivery and allocations comes forward through the neighbourhood Plan OR that all sites including BUC051 and BUC025 are allocated to ensure that there is an effective policy to deliver the contributions to secure the WLR. The WLR can be delivered within the control of HLM(B) and New College.

FULL TEXT

1 The Inspector found that the Transport policies in the Submission Draft of the VALP were significantly lacking. While Policy T1 and T6a required the implementation of the proposals in the Buckinghamshire LTP4 and the Buckingham Transport Strategy "none of these proposals are specified in the Plan" (IIF para 46). This would be unsound because the NPPF requires that the plan "should make clear what is intended to happen in the areas over the life of the plan, where and when this will occur and how it will be delivered. It points out the need to identify the short, medium and long-term transport proposals across all modes as a key issue...".

2 Key within the Inspectors' findings is that "the key infrastructure requirements on which the delivery of the plan depends should be contained in the Local Plan itself. VALP does not do this and so is unsound as it stands".

3 In the first instance, Policy T3 seeks simply to "actively support key transport proposals" and will "support local transport schemes that provide benefits to the District". If the delivery of the listed infrastructure is prejudiced then permission would not be granted.

4 T3, as proposed to be modified, is therefore no more than a safeguarding policy rather than a policy that delivers the infrastructure identified as a requirement of the Plan's development strategy and the Plan's evidence base.

5 The inspector in the IIF noted that policy T1 required developments to implement LTP and BTS proposals. Policy T1 - following its modification by MM206 - will no longer do so. Policy T3 certainly does not do so in its proposed form.

6 Hallam Land Management (Buckingham) (HLM(B)) do not believe that the Main Modifications are sufficient to make the VALP sound, the Inspector having found this aspect of the Plan to be unsound in his IIF. T3 is therefore fundamentally unsound in failing to respond positively to the planning and delivery of infrastructure and failing to deliver necessary infrastructure
accepted in the evidence base and transport policies of the relevant authorities as a requirement.

7 Indeed, in this regard, the VALP as proposed to be modified appears to be vulnerable to challenge.

8 Specifically, MM210 sets out as required works - the Buckingham Town Wide cycle network improvement (short term) and the Buckingham to Silverstone Park cycle route (short term), A413 Buckingham Road improvements (medium term) and Buckingham left turn slip at A422/A413/Stratford Road Roundabout (medium term).

9 There is a considerable evidence base in relation to transport issues and strategy in Buckingham - not least the made Buckingham Neighbourhood Plan and in particular the Buckingham Transport Strategy and VALP IDP. Clear and robust conclusions are drawn.

10 The Western Link Road (WLR) is identified as necessary for Buckingham as a whole in the Infrastructure Development Plan - an expectation that has not been updated since the Examination hearings.

11 Equally important the Buckingham Transport Strategy considered the demands of growth at Buckingham as a whole - BUC043, BUC046, BUC051 and BUC025 (although the latter was not allocated in the submission VALP). Para 4.4.2 of the BTS ranked the Western Link Road as being of highest priority followed by the West Street downgrade. Other route upgrades and Left turn slip/junction improvements were given less priority. Funding of the priority schemes was acknowledged to be likely to rely principally on section 106 funding (4.5.3).

12 The Buckingham Transport Strategy is based on all sites coming forward and puts a section 106 contribution-based strategy in place to deliver what is needed to meet both the demands of the planned growth but also, explicitly, the existing traffic constraints and difficulties in the town - in particular the town centre. The key identified requirement is the WLR to facilitate the down grading of West Street.

13 This is a clear evidence base with a clear strategy for delivery.

14 Since the examination hearings the principal additional evidence produced in support of the Proposed Modifications is understood to be:
* the Revised County Modelling for Buckingham (Addendum to the Phase 3 Modelling Report) (3 April 2019) (ED214B)
* the Buckingham Town Centre Modelling report (24 May 2019) (ED214A)
* BCC's advice note to AVDC (ED215)

15 None of this additional evidence alters the conclusions of the BTS. Indeed, the evidence reinforces it as it concludes that the biggest issue here is the level of congestion in the Town centre. Traffic in Buckingham town centre is highlighted as an existing issue in the adopted Buckingham Neighbourhood Plan and Buckingham Transport Strategy, and indeed the most recent modelling (ED214A). One of the issues is the performance of the two key town centre junctions - the focus of the latest Town centre modelling report (ED214A). ED214A confirms that both junctions will be operating beyond capacity in 2033 - even with no new development in Buckingham. It concludes that each development scenario tested would be unacceptable.

16 One opportunity to deliver the infrastructure that should be included in the Plan - the WLR - is to maximise the contributions from development as is set out in representations made by Hallam in respect of MMs083, 082 and 084. The WLR can be delivered within the control of HLM(B) and New College - and can then be included in the VALP or worked through in the update of the Buckingham Neighbourhood Plan that has already commenced.

17 The only sound alternative is to not allocate any sites at Buckingham to meet the identified requirement and to devolve the allocation of sites to the next review of the Buckingham NP which is already underway. This is on the basis that there is simply not a sufficient evidence base to proceed with any of the allocations at Buckingham in the VALP. By this means opportunities for positive planning and integrated planning to deliver the WLR etc. could be realised through the NP rather than wasted in the unevidenced and incomplete strategy in the VALP.

18 The made Buckingham Neighbourhood Plan (made in October 2015) has proved highly effective in delivering substantial, locally supported, housing numbers. Such a course of action would avert the current need for more evidence prior to the adoption of the VALP. Instead the VALP process could proceed but could divert Buckingham allocations to the NP review, the existing NP having successfully allocated and delivered housing in the absence of an up-to-date Local Plan.

19 That a Neighbourhood Plan is a proper and established and effective route in other places as well as in Buckingham is evident in the experience, in the immediate vicinity at Thame. The Thame Neighbourhood Plan in adjoining South Oxfordshire has likewise successfully allocated sites for some 775 new homes and associated infrastructure - delivering the strategic policies of the District wide plan.

20 In setting out these observations HLM (B) is very aware that that addendum to the Sustainability Appraisal fails to consider any of the implications of the amended development strategy for Buckingham on the ability to deliver the key infrastructure that the evidence base demands. The SA Addendum simply considers the rather esoteric and immaterial question of whether including scheme details (across the VALP) as words in the VALP is positive or negative.

21 Overall the proposed Main modifications and resultant policies may well be considered appropriate for challenge.

NICK FREER - David Lock representing Hallam Land
Reps to AYLESBURY
Rep to MM031
FULL TEXT
1 Hallam Land Management (Aylesbury) controls land to the north east of Aylesbury including site BIE021.

2 To be clear HLM(A) has consistently sought a dialogue to help through its land controls to bring forward the North East Link Road which is the subject of this representation. No such discussions have been entertained by AVDC.

3 HLM has set out detailed representations in relation to MM210 and the changes that it introduces to Policy T3. In particular, substantial objections have been lodged that demonstrate that Policy T3 insofar as it addresses the delivery of key infrastructure at Aylesbury - as set in T3 - continues to fail the tests of soundness.

4 Policy T3 as proposed to be modified by MM210, has not addressed the fundamental issue of delivery of the North East Link Road. The VALP therefore remains unsound on the basis that:
* it is not positively prepared - providing no realistic strategy for the delivery of the North East Link Road;
* it is not justified - without such certainty regarding the North East Link the evidence base suggests that the development strategy for Aylesbury is not adequately mitigated;
* it is not effective given that sound infrastructure delivery planning is necessary to satisfy the test of effectiveness.

5 For the reasons set out in relation to MM210, and by the same token, Policy D1 as proposed to be modified by MM031 also remains unsound as it does not provide the means by which necessary infrastructure - identified in the evidence base as required to support and mitigate the development strategy.

6 Hallam notes that the Council intends to produce the 'AGT Framework and Infrastructure SPD' as stated in point (b) of Policy D1 (Delivering Aylesbury Garden Town). Under the National Planning Policy Framework's (NPPF) Test of Soundness, local plans are required to positively prepare for objectively assessed development and infrastructure. Whilst there is some flexibility in planning for the delivery of strategic matters, planning practice guidance is clear that in the case of a lack of certainty of funding for certain infrastructure, 'strategic policy-making authorities will be expected to demonstrate that there is a reasonable prospect that the proposals can be developed within the timescales envisaged. In addition, the PPG states that plans should assess deficiencies in existing and future infrastructure and set policies for how these deficiencies will be addressed (059 Reference ID: 61-059-20190315). To leave this to an SPD is inadequate and results in the plan not being prepared positively and therefore unsound in respect of planning for infrastructure delivery. The inappropriateness generally of deferring policy to SPD is noted by the Inspector in another context in para 45 (for instance) of the IIF.

7 It is not therefore acceptable or sound that the delivery of key infrastructure such as of the North East Link Road (or for that matter other infrastructure) to be deferred to the proposed AGT Framework and Infrastructure SPD.

SUMMARY

Policy T3 as proposed to be modified by MM210, has not addressed the fundamental issue of delivery of the North East Link Road. The VALP therefore remains unsound on the basis that:
* it is not positively prepared - providing no realistic strategy for delivering the North East Link Road;
* it is not justified - without such certainty regarding the North East Link the evidence base suggests that the development strategy for Aylesbury is not adequately mitigated;
* it is not effective given that sound infrastructure delivery planning is necessary to satisfy the test of effectiveness.

For the reasons set out in relation to MM210, and by the same token, Policy D1 as proposed to be modified by MM031 remains unsound as it does not provide the means by which necessary infrastructure - identified in the evidence base as required to mitigate the development strategy.

REP to MM210

FULL TEXT


1 Hallam Land Management (Aylesbury) controls land to the north east of Aylesbury including site BIE021.

2 To be clear HLM(A) has consistently sought a dialogue to help, through its land controls to bring forward the North East Link Road which is the subject of this representation. No such discussions have been entertained by AVDC or BCC.

3 The Inspectors' Interim Findings (IIF) (28th August 2018), provides the principal context for Main Modification 210 - the amendment of policy T3.

4 The Inspector found that the Transport policies in the Submission Draft of the VALP were significantly lacking. While policy T1 and T6a required the implementation of the proposals in the Buckinghamshire LTP4 and the Aylesbury Transport Strategy "none of these proposals are specified in the Plan" (IIF para 46). This would be unsound because the NPPF requires that the plan "should make clear what is intended to happen in the areas over the life of the plan, where and when this will occur and how it will be delivered. It points out the need to identify the short, medium and long-term transport proposals across all modes as a key issue...".

5 Key within the Inspectors' findings is that "the key infrastructure requirements on which the delivery of the plan depends should be contained in the Local Plan itself. VALP does not do this and so is unsound as it stands" (underlining added for emphasis).

6 Hallam Land Management (Aylesbury) (HLM(A)) welcomes the amendment of the Policy T3 to include those key infrastructure elements from the Aylesbury Transport Strategy (ATS) upon which the Plan depends. Specifically, HLM welcomes the inclusion of the North East Link Road at Aylesbury within T3.

7 This is essential to meet the expectations of the Aylesbury Garden Town Vision which includes "road improvements linking new developments to the town, and creating a series of link roads around the town" (VALP - para 4.30). The Vision specifically includes the North East Link Road between the A413 and A418.

8 It is essential also from the perspective of the need to address current issues in the network. In Examination document EC279, AVDC recognises that the ATS measures (including North East Link Road) also address current issues in relation to the capacity of the Network.

9 More important still, the North East Link Road is essential to mitigate the impacts of the development proposed in the VALP at Aylesbury and, in particular, in Policy D1 of the Plan.

10 Hallam Land Management has consistently made clear through the examination process that the BCC/AVDC evidence base and modelling shows that, without the North East Link Road, the impact of development on the A41, A413 and A418 isn't adequately mitigated. The Technical Note prepared by Markides Associates and appended to Hallam Land Management's Examination Matter 12 Statement was not queried or questioned in the examination hearings and needs to be given substantial weight.

11 The Technical Note draws out the conclusions of the VALP's own evidence base: the BCC Countywide model and, in particular, the Countywide Local Plan Modelling Phase 3 Technical Note.

12 The Markides Technical Note makes two fundamental points. In the first instance, it demonstrates that in either scenario DS1, or DS2, run by the County, there remains significant congestion in the southern quadrant of Aylesbury "particularly on the A418 through Stone and Harcourt" - with all of the link rods provided. We have previously questioned these allocations on this basis.

13 Second, and more directly related to the North East Link Road, the Markides Technical Note highlights the importance of the North East Link Road (which is included in the DS2 model run but not DS1 model run): "Without the provision of the additional link roads [including the North East Link Road] in DS2, there remain issues of congestion on the Stocklake link, A418 and A413 immediately north of Aylesbury and on the A41 to the east of Aylesbury. The North East Link Road offers significant benefits in this area, with scenario DS2 showing much reduced congestion ratios on the A41, A418, A413 and various link roads through the Aylesbury East area over both the DS and DS1 scenarios" [added for clarification].

14 Since the Examination, and the publication of the Inspectors Interim Findings, no new transport modelling appears to have been undertaken by AVDC/BCC in respect of Aylesbury. The ATS Final report 2017 and the Countywide Local Transport Modelling - Phase 3 Tech Note (August 2017) remain the most recent documents forming the evidence base for transport.

15 Little, therefore, appears to have changed since the Examination hearings. The only modelling work available to support the Proposed Modifications relating to Aylesbury shows that the North East Link Road is necessary to mitigate the impact of planned development at Aylesbury (see also para 1.8 of the IDP).

16 HLM(A) therefore considers it essential that the Aylesbury North East Link Road is included in the revised version of policy T3 as amended by Proposed MM210.

17 This is the position of AVDC also. By virtue of its inclusion in T3, it must be regarded by AVDC to be a key measure or intervention, and a requirement to facilitate growth at Aylesbury. Para 7.7 of the VALP - as proposed to be amended by MM203 - is explicit in this regard: "Transport measures and interventions contained in the ATS are required to facilitate growth in Aylesbury Garden Town. The key measures and interventions are set out in Policy [T3] below and supported by the Infrastructure Delivery Plan" [added emphasis].

18 Having been included in Policy T3 by MM210, the North East Link Road also must be included (in indicative layout form- consistent with the Aylesbury Garden Town Proposals and LTP) on the Aylesbury Policies Map.
19 However, Policy T3 as proposed to be modified by MM210, has not addressed the fundamental issue of delivery of the North East Link Road. The VALP therefore remains unsound on the basis that:
* it is not positively prepared - providing no realistic strategy for the delivery of the North East Link Road;
* it is not justified - without such certainty regarding the North East Link the evidence base suggests that the development strategy for Aylesbury is not adequately mitigated;
* it is not effective given that sound infrastructure delivery planning is necessary to satisfy the test of effectiveness.

20 The failings of the proposed policy T3 as proposed to be modified by MM210 are various.

21 In the first instance, Policy T3 seeks simply to "actively support key transport proposals" and will "support local transport schemes that provide benefits to the District". If the delivery of the listed infrastructure is prejudiced then T3 indicates that permission would not be granted.

22 T3, as to be modified, is therefore no more than a safeguarding policy and not a policy that delivers the infrastructure identified as required by the Plan's development strategy and evidence base.

23 The Inspector in the IIF noted that Policy T1 required developments to implement LTP and ATS proposals. Policy T1 - as modified by MM206 - will no longer do so. Policy T3 certainly does not do so - either in respect of strategic developments or globally across the Aylesbury Garden Town.

24 In the second instance, while T3 seeks to set out a delivery mechanism for the North East Link road - this is inadequate, insufficient and inconsistent with the remainder of the Main Modifications. MM210 states that North East Link Road will be delivered "through the Oxford-Cambridge Expressway". Whilst there is not yet a fixed route for the Expressway, Highways England have moved forward a little in terms of identifying route corridors. They have ruled out Corridor A, which would have passed close to Aylesbury and have narrowed it down to Corridors B1 and B3 - the nearest edge of these corridors crossing the A413 in the order of 5 miles north of the centre of Aylesbury, north of Whitchurch. The corridors don't actually reach the A418 north east of Aylesbury. AVDC cannot rely on this means to deliver the North East Link Road.

25 More fundamentally, AVDC has resolved as a Council to not support the Oxford-Cambridge Expressway nor any route in Aylesbury Vale. As a result the second and third sentence of T3 is therefore proposed to be deleted by the Council including the reference to "The scheme is supported by the Council and ...". The scheme is no longer supported by the Council. The Proposed Modifications do not however propose that the Expressway be deleted as the delivery mechanism for the North East Link road. Clearly this represents a very large inconsistency, perhaps oversight, and leaves the delivery of key listed infrastructure in the air and with no strategy.

26 Nor is it acceptable for the delivery of the North East Link Road to be deferred to the 'AGT Framework and Infrastructure SPD' as suggested in point (b) of Policy D1 (Delivering Aylesbury Garden Town). Under the National Planning Policy Framework's (NPPF) Test of Soundness, local plans are required to positively prepare for objectively assessed development and infrastructure. Whilst there is some flexibility in planning for the delivery of strategic matters, planning practice guidance is clear that in the case of a lack of certainty of funding for certain infrastructure, 'strategic policy-making authorities will be expected to demonstrate that there is a reasonable prospect that the proposals can be developed within the timescales envisaged. In addition, the PPG states that plans should assess deficiencies in existing and future infrastructure and set policies for how these deficiencies will be addressed (059 Reference ID: 61-059-20190315). To leave this to an SPD is inadequate and results in the VALP not being prepared positively and therefore unsound also in respect of planning for infrastructure delivery. The inappropriateness generally of deferring policy to SPD is noted by the Inspector in another context in para 45 (for instance) of the IIF.

27 There are also concerns with the claim in T3 that a North East Link Road would cost approximately £35 million to build. Typical construction costs for a 10m wide single carriageway road with 3m footways on either side would be £2050 per linear metre (Spons Civil Engineering Price Book 2017) and at an overall length of 3.2km would be expected to cost approximately £6.5 million. Allowing a further £2 million for junction connections to the A413 and A418 and a generous contingency allowance of 50% increases this to approaching £13 million, less than 40% of the cost that is being claimed in MM210 and more consistent with the IDP estimates for the Western Link, which is a similar length. The lower cost demonstrates that it could be effectively delivered through an appropriate mechanism as set out above.

28 In addition HLM have argued throughout the examination process that a modest high quality allocation on a part of BIE021 would also provide one delivery mechanism for the North East Link Road. This remains an available option and has been spelt out in detail in the examination documentation.

29 Hallam Land Management do not believe that the Main Modifications are sufficient to make the VALP sound, the Inspector having found this aspect of the Plan to be unsound in his IIF. T3 is therefore fundamentally unsound in failing to respond positively to the planning and delivery of infrastructure and failing to deliver necessary infrastructure accepted in the evidence base and transport policies of the relevant authorities as a requirement.

30 Indeed, in this regard, the VALP as proposed to be modified appears to be vulnerable to challenge.

SUMMARY

(HLM(A)) welcomes the amendment of the Policy T3 to include those key infrastructure elements from the Aylesbury Transport Strategy (ATS) upon which the Plan depends, specifically, the North East Link Road at Aylesbury within T3. The North East Link Road is essential to mitigate the impacts of the development proposed in the VALP at Aylesbury and, in particular, in Policy D1 of the Plan.
However, Policy T3 as proposed to be modified by MM210, has not addressed the fundamental issue of delivery of the North East Link Road. The VALP therefore remains unsound on the basis that:
* it is not positively prepared - providing no realistic strategy for delivering the North East Link Road;
* it is not justified - without certainty regarding the North East Link the evidence base suggests that the development strategy for Aylesbury is not adequately mitigated;
* it is not effective sound infrastructure delivery planning is necessary to satisfy the test of effectiveness.



Object

VALP Main Modifications

Representation ID: 3407

Received: 17/12/2019

Respondent: Willis Dawson Holdings Ltd

Agent: Pegasus Plannning Group

Legally compliant? Yes

Sound? No

Representation:

Object to the proposed allocation of Shenley Park to meet needs in the north east of the district.

Object to the site selection process - see reps on MM007

Land West of Newton Leys should be allocated for 400 dwellings (the HELAA fails to take account of new evidence for land west of Newton Leys yet assessments for other sites have been updated).

Transport evidence identifies that there will be significant impact on traffic congestion along the A421 corridor yet AVDC have allocated Salden Chase and Shenley Park, which both access off the A421. The southern transport corridor (Stoke Road and A4146) has a greater capacity to accept additional development.

Change suggested by respondent:

Pegasus seek a change to the proposed modification so that an additional site is included - land west of Newton Leys, Milton Keynes for approximately 400 dwellings.

Policy D2 Delivery site allocations in the rest of the district - should be amended to include land west of Newton Leys (this can be in addition to the other additional sites such as part of Shenley Park or part of Eaton Leys in recognition of the need to provide a range and choice of sites to ensure delivery in the plan period and acknowledging that there are already delays to the Salden Chase strategic allocation following the refusal to grant permission for highway access by Milton Keynes Council).

As a consequence other sites do not have to deliver as many dwellings in the plan period, such an approach reduces the risk of the strategic site not coming forward as soon as anticipated, spreads the risk and supports housing delivery.

Full text:

This representation addresses MM070 and the consequential text to Policy D2 set out in MM071. It should also be read alongside our representations to MM007.

Pegasus object to the proposed allocation of Shenley Park.

Whilst supporting the strategy of concentrating the additional development required in the AVLP around the southern and south western edges of Milton Keynes, an objection is made to the reliance on one site of approximately 1,150 dwellings.

Pegasus have also objected to the Addendum to the Sustainability Appraisal (ED204) and the selection of only three reasonable alternatives to meet the housing shortfall in this location on the edge of Milton Keynes. It is not clear on what basis these three sites were selected, it appears that their choice was because they are of a strategic scale and can contribute to meeting infrastructure requirements.

However, smaller sites may make contributions to infrastructure in accordance with the NPPF para 56.

The objection is justified on the grounds that there are other alternatives which should have been assessed and secondly providing a range and choice of sites in accordance with paragraph 68 of the NPPF will support the 5 year housing land supply. (It should be noted that there are already issues with the delivery of the proposed allocation at Salden Chase - whilst it has a resolution to grant planning permission by AVDC, the issue is that the highway access is required from Milton Keynes roads and MC Council have recently refused access).

Having reviewed the transport evidence in particular ED214C and ED215A it is considered that the transport evidence does not necessarily support the Proposed Modifications to the Plan.

- The "Do Minimum" Scenario, which it is assumed does not include any development allocated around MK e.g. Salden Chase, identifies that there will be significant impact on traffic congestion in both the AM and PM Peaks along the A421 corridor within Aylesbury Vale district. Alternatively the roads further south such as Stoke Road and the A4146 show that there would be either a slight or moderate impact on traffic congestion in the DM scenario.

- Despite this AVDC have not only proposed to allocate 1,855 dwellings at Salden Chase, which is accessed directly off the A421, but now also propose about 1,150 dwellings at Shenley Park, which is also accessed directly off the A421.

- As a result it is perhaps not a great surprise that with the various "Do Something" Scenarios involving further new development along the A421 the traffic congestion gets worse along the A421 and on adjoining roads such as Coddimore Lane, which is the road to Whaddon. Furthermore the increases in traffic congestion extends into the Milton Keynes boundary.

- Alternatively roads to the south such as Stoke Road and the A4146 do not appear to be impacted significantly by traffic congestions under the various Do-Something modelling scenarios and in particular the scenario which includes an additional 1,200 dwellings at Eaton Leys rather than further development adjacent to the A421 such as Salden Chase Extension or Shenley Park. This would seem to suggest that this southern transport corridor has a greater capacity to accept additional development. Furthermore, the attached transport note produced by Buckinghamshire County Council (ED215A) confirms that the scenario "DS4" involving no development at Shenley Park and 1,200 units at Eaton Leys has the least impact on the Buckinghamshire roads of all the scenarios. In addition, the note also confirms that Highways England have informally said that the proposed improvements to the A5 and A5 roundabout (which are of course to the south of MK) should be able to accommodate the additional potential development options around Milton Keynes.

- Lastly the above is all confirmed within section 6.2 of the Summary and Conclusions of ED214C, where is clearly states that of the development options assessed Eaton Leys has the least impact on traffic in the NE of the Aylesbury Vale district.

It is considered that Policy D2 should be amended to include land west of Newton Leys (this can be in addition to the other sites such as part of Shenley Park or part of Eaton Leys in recognition of the need to provide a range and choice of sites to ensure delivery in the plan period and acknowledging that there are already delays to the Salden Chase strategic allocation following the refusal to grant permission for highway access by Milton Keynes Council).

As a consequence other sites do not have to deliver as many dwellings in the plan period. By including land west of Newton Leys the housing requirement can be met and housing delivery can be maintained.

Object

VALP Main Modifications

Representation ID: 3445

Received: 17/12/2019

Respondent: West Bletchley Council

Legally compliant? No

Sound? No

Representation:

The Objectively Assessed Need for the area was determined and used to finalise the housing numbers to be delivered through the Plan:MK period.
The infrastructure needs for the Milton Keynes area are based upon evidence gathered during the Plan:MK preparation, and do not include the needs of allocations on the boundary in adjacent areas.
The allocations of Salden Chase and Shenley Park, on the boundary of Milton Keynes, will unbalance the infrastructure requirements of MKC.
These allocations would be best placed around the key settlements in the VALP area, principally Aylesbury and Buckingham.

Change suggested by respondent:

Delete from new policy D2 "D-NLV001 Salden Chase" and "D-WHA001 Shenley Park"

Full text:

In July 2017, Milton Keynes Council (MKC) adopted Plan:MK, the local plan for the area. As part of the evidence gathering to support to preparation of the plan, a Strategic Housing Market Assessment (SHMA) for the period 2016-2031 was carried out. The Objectively Assessed Need for the area was determined and used to finalise the housing numbers to be delivered through the Plan:MK period.
The infrastructure needs for the Milton Keynes area are based upon evidence gathered during the Plan:MK preparation, and do not include the needs of allocations on the boundary in adjacent areas.
The allocations of Salden Chase and Shenley Park, on the boundary of Milton Keynes, will unbalance the infrastructure requirements of MKC.
These allocations would be best placed around the key settlements in the VALP area, principally Aylesbury and Buckingham.
Consequently, the following main modifications should be amended as follows:

Object

VALP Main Modifications

Representation ID: 3470

Received: 17/12/2019

Respondent: Carter Jonas - Associate SWMK Consortium

Legally compliant? Yes

Sound? No

Representation:

The name 'Salden Chase' related to a much larger urban extension, and as such it is confusing and inaccurate to continue to use it. The Council's response to the Inspector's Question 62 [Doc Ref. ED100] confirmed that all future references to Allocation Ref. NLV001 would be changed to South West Milton Keynes, however that previous response is not reflected in the proposed main modifications.

It is requested that all references to 'Salden Chase' in PSVALP are changed to South West Milton Keynes.

Change suggested by respondent:

It is requested that all references to 'Salden Chase' in PSVALP are changed to South West Milton Keynes.

Full text:

Main Modifications MM070 and MM071 refer to Allocation Ref: NLV001 as 'Salden Chase'. The SWMK Consortium's representations to the Proposed Submission Vale of Aylesbury Plan (PSVALP) requested that the site should be called South West Milton Keynes - see Rep Id. 2289. The site name of South West Milton Keynes is consistent with the planning application for the proposed development. South West Milton Keynes also accurately reflects the location of the site, and is consistent with the name given to the proposed urban extension on the eastern edge of Milton Keynes in Plan:MK i.e. South East Milton Keynes.

The name 'Salden Chase' related to a much larger urban extension, and as such it is confusing and inaccurate to continue to use it. The Council's response to the Inspector's Question 62 [Doc Ref. ED100] confirmed that all future references to Allocation Ref. NLV001 would be changed to South West Milton Keynes, however that previous response is not reflected in the proposed main modifications.

It is requested that all references to 'Salden Chase' in PSVALP are changed to South West Milton Keynes.

Object

VALP Main Modifications

Representation ID: 3497

Received: 09/01/2020

Respondent: Barratt Homes

Agent: Graham Bloomfield

Legally compliant? No

Sound? No

Representation:

The Council's conclusions on the approach to proposed Modifications to Policy D2 do not indicate that a broader assessment of the spatial strategy for North East Aylesbury Vale has been undertaken. Specifically, no account appears to be taken of future infrastructure investment, including the delivery of East-West Rail.
As a result, the proposed spatial strategy for North East Aylesbury Vale cannot be considered the most appropriate strategy, compared against other reasonable alternatives (including our client's strategic opportunity at Park Manor) in accordance with the requirements of Paragraph 182 of the NPPF2012.

Full text:

see attachment

Object

VALP Main Modifications

Representation ID: 3550

Received: 18/11/2019

Respondent: Mr David Vowles

Legally compliant? Not specified

Sound? Yes

Representation:

To avoid possible confusion some of the site descriptions in Policy D2 should be made fuller and consistent.

Change suggested by respondent:

Policy D2
Add "Newton Longville" to description of D-NLV001
Add " Whaddon" to description of D-WHA001
Add "Buckingham" to description of D-BUC046
Add "Haddenham" to description of the D-HAD007
Add "Winslow" to description of D- WIN001
Add "Cuddington" to description of D-CDN001 & D-CDN003
Add "Ickford" to description D-ICK004
Add "Maids Morton" to description of D-MMO006

Full text:

See attachments

Object

VALP Main Modifications

Representation ID: 3554

Received: 18/11/2019

Respondent: Mr David Vowles

Legally compliant? Not specified

Sound? No

Representation:

Provision should be made in the Plan for the identification, by March 2023, of additional sites for development after March 2025 in the rest of the district outside Aylesbury. Each of these sites should be capable of accommodating between 5 & 50 dwellings and yield a total of 1500 dwellings.

Change suggested by respondent:

Insert the following immediately after "D -QUA 014-016 Land at Station Road, Quainton" in the new policy D2:-
"Pending a full review of the Plan further sites of between 5 and 50 dwellings each, totalling 1500 dwellings, will be identified before March 2023 in the rest of the district, including in new or reviewed neighbourhood plans, for development after March 2025.

[Officer addition - see table at end of original submission - form 2]

Full text:

See attachments

Support

VALP Main Modifications

Representation ID: 3570

Received: 17/12/2019

Respondent: Barwood Development Securities Limited

Agent: Turley Associates

Representation:

Barwood welcome the amendments to the VALP and the inclusion of a new paragraph 4.109 which now acknowledges that North East Aylesbury Vale "forms its own category in the settlement hierarchy".

This is a positive step which Barwood consider to reflect the role that this part of AVDC plays (as distinct from the wider District) on the edge of Milton Keynes. Furthermore, this approach also reflects the wider strategic significance of this area, for example its potential role in the CaMKOx corridor and the relationship with the Milton Keynes housing Market Area (as referred to in the Inspector's Interim Findings).

Full text:

See attachment

Object

VALP Main Modifications

Representation ID: 3629

Received: 13/12/2019

Respondent: West Waddy

Legally compliant? Yes

Sound? No

Representation:

(Officer's summary)
The allocation of Shenley Park is unsound. It would extend Milton Keynes beyond a firm landscape ridge and have significant adverse landscape impacts, particularly on the southern parcel where Milton Keynes would effectively coalesce with Whaddon village, adversely impacting upon the character of its Conservation Area. Alternative brownfield land is available on part of the FCC Environment land at Bletchley Road, north of Newton Longville, which was a former Brick Works.
Redevelopment here would have a much lower environmental impact and could help preserve the separateness of Whaddon and Milton Keynes.

Change suggested by respondent:

Allocate previously developed FCC Environment land at the former Brick Works in Bletchley Road, north of Newton Longville for up to 600 dwellings and make a proportionate reduction in the size of proposed allocation at Shenley Park, for the reasons outlined in the full representation.

Full text:

VALP Proposed Main Modifications - Representations on behalf of FCC Environment:
Enter your full representation here:
Fundamental to a plan being justified and sound is that it is based on proportionate and up to date evidence that looks at reasonable alternatives (NPPF, paras 31 & 35). AVDC has singularly ignored this requirement, in allocating land at Shenley Park for at least 1,150 homes, 110-bed care home/extra care and associated
services & infrastructure. This is a large greenfield site, currently in agricultural use, parts of which are highly sensitive in landscape terms. The Council's 'Landscape & Visual Capacity Comparison Assessment,'
(2019), states that "Development within the western part of the northern parcel would be seen as extending
the development edge [of Milton Keynes] to within close proximity of Whaddon Conservation Area, to include
Whaddon Hall. Development within the southern parcel would represent an unacceptable extension of
development into the countryside and visible from the wider landscape," (para 5.1.25 of ED201A). Despite
this negative assessment the Council has nonetheless decided to allocate the whole site for development,
with the north-westernmost corner actually being contiguous with a part of the Whaddon Conservation Area.
The effect of this allocation would therefore, if adopted, be to cause the coalescence of Milton Keynes with
Whaddon and would also involve development crossing the landscape ridge that has hitherto defined the
built-up edge of Milton Keynes. The Final Housing & Economic Land Availability Assessment (HELAA)
version 4 (Jan 2017) also described the Shenley Park site as "highly sensitive in landscape/visual impact
terms so the scale, layout and form of development, will be very important," (Site ref: WHA001 p.253).
Development of Shenley Park would result in the loss of an extensive area of greenfield land (99ha) that
contributes to the character and beauty of the 'Whaddon Chase' countryside and is of some value for its
agricultural use.
Despite the significant detrimental effects that would arise from this proposed allocation, the Council has not
made any assessment of the potential of the FCC Environment land at Bletchley Road, near Newton Longville. This site is located adjacent to the southern edge of Bletchley town and a substantial part was
formerly occupied by the Newton Longville Brickworks. Despite the fact that part of the former Brickworks site is allocated for employment-use redevelopment in the adopted Aylesbury Vale District Local Plan
(AVDLP) (2004) and another part has an extant consent for further employment-use redevelopment, surprisingly, the Council state in their 2017 HELAA that it is: "unsuitable - the site is in the open countryside separate from Newton Longville and Bletchley" and states that "development would be likely to have an adverse landscape & visual impact" (Site ref: NLV029).
That assessment conclusion is unsound on three grounds:
1. The site is adjoined by a ribbon of ten residential properties fronting Bletchley Road, which were originally associated with the former brickworks, and have the character of an urban terrace extending south from the built edge of Bletchley town and the soon to be reopened East-West rail line connecting
Bicester with Milton Keynes;
2. The Council has a long history of identifying the site as suitable for redevelopment. In 1995 the Council approved a Planning Brief for the Newton Longville Brickworks, which identified the former brickworks
as having: "potential for employment development" and also stated that: "this area could also be suitable for some low value/bad neighbour uses, provided they cause no significant nuisance to nearby residents" (p14). Subsequently, in the Local Plan 2004, parts of the former brickworks were allocated for employment use under policy RA.34. Subsequently, the Council granted planning permission for
erection of a single-storey modular office building with associated car parking and landscaping (15/00235/APP) on the southern part of the FCC Environment land; installation and use of a leachate treatment plant (09/20001/AWD); and planning permission has also been granted for the area
adjoining its northern boundary for temporary use for a construction compound incorporating storage area, site offices and car parking (18/04521/APP) associated with the re-opening of East-West rail;
3. The FCC site does not have the character of countryside, as it contains the remains of the former industrial use including access roads & hard standings. It is also very well screened by mature trees, 25 October 2019
so is not visible from the countryside to the south or west and would not therefore have a detrimental landscape impact. The assessment that the site is in the open countryside is therefore wrong. Indeed, this is confirmed by the
Council's own assessment of what it refers to as NLV024 in its 2017 HEELA, which relates to the part of the FCC Environment land furthest from Bletchley and therefore most likely to impact on the character of the countryside. That assessment describes the NLV024 land as suitable for employment and acknowledges that it has granted planning permission for 645m2 of employment in a modular office building in this location.
Unlike Shenley Park, the previously developed FCC Environment land in Bletchley Road is currently unused, so is not being used efficiently or most effectively. Therefore leaving it as it is would not accord with NPPF
advice, which states that planning policies should: "give substantial weight to the value of using suitable brownfield land within settlements for homes and other identified needs, and support appropriate opportunities to remediate despoiled, degraded, derelict, contaminated or unstable land" (para 118 c) and
to "promote and support the development of under-utilised land and buildings, especially if this would help to meet identified needs for housing where land supply is constrained," (para 118 d).
Despite the imperative need to make suitable use of the FCC Environment land opportunities at Bletchley
Road, near Newton Longville, the Council has not undertaken any proper assessment regarding its redevelopment potential and has not been willing to engage with FCC Environment, despite the clear NPPF requirement for early, proportionate and effective engagement. In order to ensure that it was considered as
part of any main modifications, FCC Environment made a site submission to the Council on 1st March 2019 and stated that they would welcome the opportunity to meet the Council to discuss the site. Further follow up letters were sent on 2nd April and 14th August 2019 requesting a meeting, and also enclosing an
illustrative masterplan demonstrating how 600 dwellings could be accommodated on the FCC land. Council Officers have thus far declined to respond positively to FCC's approaches.
Given that FCC Environment had identified the land as available for redevelopment within 5 years and is
ideally placed to meet identified needs in the local area, the site should have been assessed in the sustainability, transport, landscape, flooding, viability, ecology, water supply and heritage assessments that were subsequently undertaken on the Council's behalf in relation to the proposed main modifications and
the Housing and Economic Land Availability Assessment Update 2019 (ED204; ED205; ED206; ED208; ED210; ED211; ED214; RED215; ED216; ED217 & ED222). Regrettably, no consideration was given to the site in any of these documents. It is acknowledged that the majority of the site is currently a Biological
Notification Site. To achieve a net gain in biodiversity a large area would be left undisturbed to protect the
underlying geology and biodiversity enhancement areas are proposed in the south-west and north-east
corners of the site.
We note that the identified delivery of housing at Shenley Park is over the period 2024 - 2033. Over that
period, we consider that there would be potential to deliver up to 600 dwellings at the FCC Environment
Bletchley Road site, which would substantially reduce the amount of development needing to be provided
on greenfield land at Shenley Park. Any such reduction in size of the Shenley Park proposal would help
mitigate its landscape, transport and heritage impacts.
An illustrative masterplan of the potential development layout on FCC's land in Bletchley Road and how this
could be delivered in three phases delivering in total up to 600 dwellings is attached.
It is therefore suggested that the amount of development at Shenley Park should be reduced proportionately
by allocating the FCC Bletchley Road land, as identified on the attached illustrative masterplan, which would
in turn:
- enable a landscape gap to be maintained, thereby preserving the separate identity of Whaddon
and preventing coalescence with Milton Keynes;
- protect the character, appearance and setting of the Whaddon Conservation Area;
- significantly reduce the amount of greenfield development needed on the sensitive southern parcel of the Shenley Park site; and
- enable the unused previously developed FCC Environment land of the former Brick works to be
brought back into active use.
Without these adjustments, we contend that the Plan is unsound as the proposed allocation of Shenley Park
does not constitute "an appropriate strategy, taking into account the reasonable alternatives, based on proportionate evidence", nor is it consistent with the NPPF in terms of making most effective use of land
(para 35).

Object

VALP Main Modifications

Representation ID: 3661

Received: 17/12/2019

Respondent: Jackson Planning Ltd ( Lisa Jackson)

Legally compliant? Yes

Sound? No

Representation:

The new policy D2 must be much less apologetic and cursory about the development proposal to expand MK within AVDC as part of the plan. The plan must embrace the start of the oxford to Cambridge Growth Arc agreed ambitions of MHLG and the local partners (March 2019). The plan must recognise the primacy of MK in the settlement hierarchy and not limit the ambitions of the growth arc for the life of this plan given the aspiration to achieve an additional million homes by 2050.

Change suggested by respondent:

Additional text shown in Blue - text to be removed shown strikethrough
Revise as follows -add this to policy rather than in preamble:
The Local Plan also allocate sites for growth within Aylesbury Vale at the edge as part of the start of the planned growth
of Milton Keynes namely north east Aylesbury Vale and this area forms its own category in the settlement hierarchy in
the Oxford to Cambridge growth arc recognising the primacy of Milton Keynes as a city region. The development
allocations recognise the ability for early delivery of development that supports the Oxford-Milton Keynes - Cambridge
Arc emerging from the revised strategic spatial strategy and government growth agenda to achieve 1 million homes by 2050. The same appraisal process detailed above has been followed to select these sites and Consideration will has also been be given to development beyond the allocations that would assist Milton Keynes' capacity to accommodate further growth consistent with the Oxford-Milton Keynes - Cambridge Arc proposals. Any proposal that would seriously prejudice or jeopardise the longer-term objectives of the Oxford-Milton Keynes - Cambridge Arc

Full text:

Continue onto another page if needed
Please see attached report on the main modifications representations by Chase Consortium.
Whilst the small changes to the policy S2 are welcome, they do not go far enough and do not address the Inspector's criticism that the plan does not reflect the advice that "To be sound, VALP should make contingency plans to accommodate
them, not simply abandon its function to a future review of uncertain timescale". Whilst the references to an early review
have been dropped the plan has not been sufficiently modified with a contingency plan to deal with Cam-MK-Ox growth
arc consistent with MHLG proposals for a million new homes by 2050.
The Inspector accepted that it may not be possible for the Council to identify new settlements (which would account
for less than half of the homes required to support the Cam-MK-Ox arc's future workforce) and these may be left to a
future review of the plan, however, this does not recognise the ability of delivery at pace to serve the strategic needs of
the arc in the near future. An additional 1150 dwellings allocation is simply not sufficient recognition of the strategic
role of the area. This makes the new policy D2 unsound as it is not consistent with National Policy.
The strategic growth of Cam-MK-Ox arc's is totally underplayed in the plan describing it as "a site adjacent to Milton
Keynes."
In terms of NPPF 47 the Council could:
"where possible, identify a supply of specific, developable sites or broad locations for growth for years 6-10"
The Council have simply failed to provide a proper contingency plan for the Cam-MK-Ox growth arc during the life of the plan to 2033. The opportunity to show the wider area of growth that supports AVDC's aspirations has been lost and with it the opportunity to influence the growth arc in a positive way. The plan is therefore not positively prepared.