Aylesbury Vale Area

MM076

Showing comments and forms 1 to 30 of 100

Object

VALP Main Modifications

Representation ID: 2743

Received: 13/11/2019

Respondent: Mr Douglas Cross

Legally compliant? No

Sound? No

Representation:

1. It is unreasonable for Aylesbury Vale to meet its housing needs by unilaterally 'tacking on' an additional 1,800 homes to Milton Keynes.
2. Medical and retail infrastructure in insufficient to support the addition of 4,320 people.
3. The addition of 2,520 cars will increase noise and congestion.
4. The development is not coordinated with the Milton Keynes planning guidelines (past, present and future)

Change suggested by respondent:

Coordination is required between Milton Keynes Council Planning Department and Aylesbury Vale in order to ensure that the development is in line with Milton Keynes planning requirements, including access to medical care, road infrastructure, retail infrastructure, etc.

Full text:

It is unreasonable for Aylesbury Vale to meet its housing needs by unilaterally 'tacking on' an additional 1,800 homes to Milton Keynes.
With an average family size of 2.4 persons (2017 ONS Data), Shenley Park alone will increase the population of Milton Keynes by 4,320 people. Each of whom will require access to a GP, hospital, dentist, supermarket, etc. It has been assumed that these facilities are readily accessible and have sufficient capacity. This is not the case. The nearest GP, Westcroft medical centre, already has long waiting times and queues for appointments. Milton Keynes Hospital Maternity unit has to turn people away at peak times and waiting times at A&E are already three to four hours.
It is unreasonable to expect that Milton Keynes should provide these facilities for the residents of Aylesbury Vale, who will not contribute council tax towards maintaining them.
Further, in the South East, the average number of cars per household is 1.4 (Data from 2018), meaning that an additional 2,520 cars will be present in Shenley Park. These will contribute significantly to background noise (The Western edge of Kingsmead and Oxley Park are currently the only 'quiet' parts of Milton Keynes), and to congestion (the A421 at bottledump roundabout already queues at peak times). Shenley Park will need to be gritted in Winter and this may not be properly coordinated with Milton Keynes, resulting in resident confusion and frustration. Will the council tax paid to Aylesbury Vale cover the gritting, or will this provision be expected of Milton Keynes?
Milton Keynes have their own planning philosophies and requirements, to ensure that the city develops in a measured, controlled way. For example, at inception Milton Keynes did not allow any buildings of more than two storeys high. Has this development been planned according to the latest Milton Keynes planning guidelines? Is the anticipated housing density the same as a typical estate in MK? How will any changes in guidelines over the delivery period be reflected in the Aylesbury Vale plan? Will a planning working group be established to ensure this. None of these points have been identified by the 'plan' document.

Object

VALP Main Modifications

Representation ID: 2758

Received: 20/11/2019

Respondent: Mr Jeremy Bloss

Legally compliant? No

Sound? No

Representation:

It appears this site has been parachuted in at the last minute and I do not believe there has been adequate public consultation, nor with the relevant Parish Council, nor with residents of the adjoining areas of Milton Keynes. This would then appear to be unsound and procedurally unfair.

Change suggested by respondent:

At a minimum there should be Examination hearings to gather the responses of both Whaddon and Milton Keynes

Full text:

It appears this site has been parachuted in at the last minute and I do not believe there has been adequate public consultation, nor with the relevant Parish Council, nor with residents of the adjoining areas of Milton Keynes. This would then appear to be unsound and procedurally unfair.

Object

VALP Main Modifications

Representation ID: 2761

Received: 22/11/2019

Respondent: Mr H Cheema

Legally compliant? No

Sound? No

Representation:

I object to the new site policy relating to the proposed allocation of Shenley Park, Whaddon, MM076 (site reference WHA001), on the grounds that the Local Plan is neither sound nor legally compliant. It is totally unfair that residents have been denied the opportunity to speak at earlier Hearing Sessions. I support the Whaddon Parish Council objection and ask the inspector to reopen the Hearings and listen to and consider Whaddon village concerns in detail.

Change suggested by respondent:

I object to the new site policy relating to the proposed allocation of Shenley Park, Whaddon, MM076 (site reference WHA001), on the grounds that the Local Plan is neither sound nor legally compliant. It is totally unfair that residents have been denied the opportunity to speak at earlier Hearing Sessions. I support the Whaddon Parish Council objection and ask the inspector to reopen the Hearings and listen to and consider Whaddon village concerns in detail.

Full text:

I object to the new site policy relating to the proposed allocation of Shenley Park, Whaddon, MM076 (site reference WHA001), on the grounds that the Local Plan is neither sound nor legally compliant. It is totally unfair that residents have been denied the opportunity to speak at earlier Hearing Sessions. I support the Whaddon Parish Council objection and ask the inspector to reopen the Hearings and listen to and consider Whaddon village concerns in detail.

Support

VALP Main Modifications

Representation ID: 2765

Received: 22/11/2019

Respondent: Mr Paul Griffiths

Representation:

This is the best of the alternatives for a 'site in close proximity to Milton Keynes'. There are other issues with a Salden Chase extension and Eaton Leys (officer summary)

Full text:

This is the best of the alternatives for a 'site in close proximity to Milton Keynes'.

Current concerns about access into/out of Salden Chase and opposition to modifications to Bottle Dump and Tattenhoe roundabouts mean that delays to this phase of development could make Salden Chase extension, west of Whaddon Road and isolated island of development. The development of Eaton Leys is problematic due to regular flooding of the Ouzel River. Also the development is cut off from the rest of Bletchley/Milton Keynes by the River Ouzel and canal and the eats west rail running from Woburn Sands to Fenny Stratford via Bow Brickhill. These natural and man made barriers create limited options for linkage into established developments and already the Brickhill Street level crossing creates probles at peak periods which would only be increased with additional housing at Eaton Leys

Object

VALP Main Modifications

Representation ID: 2773

Received: 26/11/2019

Respondent: Wolverton & Greenleys Town Council

Legally compliant? Not specified

Sound? Not specified

Representation:

"Committee RESOLVED that it was sensible to do extra houses on these pockets of lands but feel that it should follow the Plan:MK of redways and linear parks.Concern that site identified as adjacent to MK, that these actually fall within the boundary of the MK will have a detrimental effect on the infrastructure and services within MK such as schools and medical facilities. If policy SD15 identifies the likelihood of an impact, then Aylesbury Vale should be responsible for providing the funding.
Any impact on the 5YHLS and if building of homes would actually support our housing supply"

Full text:

"The Committee RESOLVED that it was sensible to do extra houses on these pockets of lands but feel that it should follow the Plan:MK of redways and linear parks, there is a concern that whilst the site identified as adjacent to MK, that these actually fall within the boundary of the MK and as such would have a detrimental effect on the infrastructure and service provision within MK such as schools and medical facilities. If policy SD15 identifies the likelihood of an impact, then Aylesbury Vale should be responsible for providing the funding which would have an impact on these services
The committee would like to understand what impact that this would have on the 5YHLS and if it would impact on our figures, or whether the building of homes would actually support our housing supply"

Object

VALP Main Modifications

Representation ID: 2790

Received: 28/11/2019

Respondent: Mr Rhys Collins

Legally compliant? No

Sound? No

Representation:

Whaddon Parish Council (WPC) and residents have been denied the opportunity to properly debate and cross
examine AVDC's decision to choose SP over the other two competing sites. A further hearing session at the
end of the public consultation period, so that this crucial omission can be rectified and some of the hugely
important points that WPC wish to make in terms of a representation can be made.
A failure of co-operation has occurred, and community engagement has been minimal.
The Current plan is probably unlawful

Change suggested by respondent:

Policy MM076 needs to be deleted from the VALP before adoption of the VALP occurs.
Eaton Leys, Bletchley or Sa Iden 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 town's sustainability and economy rather than that of Milton Keynes

Full text:

FIRSTLY
1. Shenley Park, Whaddon (SP) was not included in the November 2017 'Proposed Submission'
version of the Vale of Aylesbury Local Plan (VALP), so Whaddon Parish Council {WPC) and
residents have been completely denied the opportunity to properly debate and cross examine
AVDC's decision to choose SP over the other two competing sites during the public hearing
sessions held by the Inspector in July 2018. The alternative sites are Eaton Leys (EL) and Sa Iden
Chase (SC). This is in breach of NPPF paragraphs 158 and 182 and especially 155.
2. Because of the very late introduction of SP, the Inspector must be strongly encouraged to
reopen a further hearing session at the end of the public consultation period, so that this crucial
omission can be rectified. It is completely UNFAIR (important to use this word in your
response!) and UNJUST not to allow detailed and proper 'comparison testing' between the
three competing sites.
3. To simply accept AVDC's 'preferred choice' of Shenley Park without proper scrutiny and
justification will render the final plan unsound and possibly unlawful.
4. Whaddon residents must be given the opportunity to inform the Inspector of the impact such a
large development will have on their environment, lives & health, road safety, and general wellbeing
etc. Despite the site being mentioned at a much earlier stage (but then deleted) this
consultation is TOO LITTLE, TOO LATE. (and far too complex given the amount of information on
the AVDC website).
SECONDLY
1. Government requires that adjoining Authorities have a 'Duty to Co-operate' - when considering
significant, strategic cross-boundary housing allocations. Such a 'duty' cannot be rectified
during a public consultation period, so failure to do so at a much earlier stage can lead the
Inspector to recommend a non-adoption report. This is contrary to PPG paragraph 3-008 (2014
version)
2. Yes AVDC have paid 'lip-service' to this advice, by indicating to MKC what they were doing, but
they have not addressed this key strategic housing allocation {a minimum of 1150 new homes)
through 'effective discussion' or 'proper joint working', representing a significant failing of 'Duty
to Co-operate' at an early stage ...... especially as MKC are the major town and Lead Authority
which adjoins the three neighbouring and competing sites.
3. MKC discussed this issue at Full Council on 23 October, and members across all parties agreed
that a failure of co-operation has occurred, and that community engagement has been minimal.
4. Non-compliance with such an important issue, especially when MKC have an adopted Local Plan
with meaningful policies, is very concerning. MKC could, and should have helped select the best
and most sustainable site. This lack of engagement renders this part of the plan 'unsound' ..... .
hence further reason to re-open the hearing sessions to ascertain exactly why AVDC chose not
to cooperate and engage more fully with MKC and indeed Whaddon Parish Council, and
residents.
LASTLY
The important North Bucks Way isn't mentioned at all, but a new road access into SP must cut
across this obvious natural boundary that currently forms a strong defensible western edge to the
existing built up area of MK. Its importance as an old established landscaped barrier and existing
habitat and wildlife corridor is overlooked.
Cutting through this ancient North Bucks Way corridor by one, if not two grid road extensions will
unnecessarily harm attractive and as yet unspoilt countryside which does not enjoy any further
logical outer boundary that could be described as a similar long-term and defensible boundary.
I understood that 'biodiversity' and 'natural processes' were placed at the top of MK's agenda, with
ambitions to become the 'Greenest City in the World' with a vision of becoming a 'World-leading
sustainable City', whilst celebrating the rich variety of wildlife by protecting landscapes and habitats
etc". Crossing the hugely important North Bucks Way wildlife corridor into much valued open
countryside and natural habitats would destroy such MKC ideals, especially when less harmful sites
exist and were considered by AVDC during the Site Assessment process.

Object

VALP Main Modifications

Representation ID: 2791

Received: 29/11/2019

Respondent: Mrs Angie Joint

Legally compliant? No

Sound? No

Representation:

I OBJECT to the new site policy relating to Shenley Park, Whaddon, MM076.
Denied the opportunity to examine AVDC's decision - unjust and unfair.
Lack of engagement between MKC and AVDC renders this part of the plan unsound.
Houses will impact landscape and environment - North Bucks Way - historic footpath,
and road-safety due to increased traffic past Whaddon school and playgroup.
Eaton Leys should be the preferred choice as it is a logical infill site and will help
regenerate the area. I urge the inspector to re-open the hearings and listen to and
consider my and Whaddon Village's concerns.

Change suggested by respondent:

Policy MM076 needs 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 town's
sustainability and economy rather than that of Milton Keynes.

Full text:

I wish to strongly OBJECT to the new site policy relating to the proposed allocation of
Shenley Park, Whaddon, MM076 (site reference WHA001).

Shenley Park (SP) was not included in the November 2017 'Proposed Submission'
version of the Vale of Aylesbury Local Plan (VALP), so as a long-standing resident of
Whaddon, I have been denied the opportunity to examine AVDC's decision to choose SP
over Eaton Leys (EL) and Salden Chase (SC) during the public hearing sessions held by
the Inspector in July 2018. Not only is this unjust and unfair, it is in breach of NPPF
paragraphs 158 and 182 and especially 155. The impact such a large development will
have on road safety, my environment, health, and general well-being is huge.

Government requires that adjoining Authorities have a 'Duty to Co-operate' when
considering significant cross-boundary housing allocations. Failure to do so can lead the
Inspector to recommend a non-adoption report. This is contrary to PPG paragraph 3-008
(2014 version). AVDC indicated to MKC (the major town and Lead Authority which adjoins
the three neighbouring and competing sites) what they were doing, but they have not
addressed this key strategic housing allocation (a minimum of 1150 new homes) through
'effective discussion' or 'proper joint working', representing a significant failing of 'Duty to
Co-operate' at an early enough stage. This lack of engagement renders this part of the
plan unsound.

I urge AVDC to re-open the hearing sessions to ascertain exactly why AVDC chose not
to cooperate and engage more fully with MKC - and indeed Whaddon Parish Council, and
me as a resident.

The landscape of the area is an important reason SP should be deleted from the proposed
plans. The North Bucks Way is an ancient and historic footpath. New road access into
SP must cut across this obvious natural boundary that currently forms a strong defensible
western edge to the existing built up area of MK. Its importance as an old established
landscaped barrier and the existing habitat and wildlife corridor has been overlooked.
Cutting through this ancient North Bucks Way corridor by new grid road extensions will
unnecessarily harm attractive and as yet unspoilt countryside.

Through traffic is a major concern as the impact could have devastating consequences for
Whaddon village, particularly on road safety and the immediate environment due to ever
worsening and increasing 'rat-running' through its two Conservation Areas, and past a
school and playgroup. Traffic numbers and higher levels of HGVs worsen year on year.
I believe Eaton Leys should be the preferred choice as it is a logical infill site that would
sensibly round off the eastern side of MK. The total site lies within and is fully contained by
the A4146 Fenny Stratford bypass, meaning that there will be no encroachment into open
countryside beyond. Obvious infill sites should be chosen before despoiling virgin
countryside.

The EL site has close links to Fenny Stratford amenities and Bletchley Railway Station.
New or improved footpath and redway links are planned, or are already being enhanced.
Much has been written or talked about a 'Bletchley Regeneration'. These two sites
together could surely help this ambition and be considered for, and contribute towards, the
ongoing regeneration plan.

I ask the inspector to re-open the hearings and listen to and consider my and
Whaddon Village's concerns in detail.

Object

VALP Main Modifications

Representation ID: 2792

Received: 29/11/2019

Respondent: Mr Vincent Dudley

Legally compliant? Not specified

Sound? No

Representation:

Eaton Leys (B) seems the more obvious choice. It would be filling in a corner of the area with very little little disturbance to the boundary.
Areas (A) and (C) both extend out from natural boundary, and Whaddon in particular would struggle to cope with the increase in traffic should area (A) be developed.

Full text:

Eaton Leys (B) seems the more obvious choice. It would be filling in a corner of the area with very little little disturbance to the boundary.
Areas (A) and (C) both extend out from natural boundary, and Whaddon in particular would struggle to cope with the increase in traffic should area (A) be developed.

Object

VALP Main Modifications

Representation ID: 2793

Received: 27/11/2019

Respondent: Mr Phi Tebbs

Legally compliant? No

Sound? No

Representation:

The VALP Is unsound and unjust because Shenley Park was not originally included, and therefore has not been debated adequately.
'Duty of co - operation with MKC has not been fulfilled.

Change suggested by respondent:

Policy MM076 needs to be deleted from the VALP before adoption of the VALP occurs. Eaton Leys Bletchley should be considered as a sustainable replacement for Shenley Park.

Full text:

Shenley Park, Whaddon (SP) was not included in the Nov 2017 'proposed submission' version of the VALP, so Whaddon residents have been denied the opportunity to properly debate AVDC'S decision to choose SP over the 2 competing sites during the public hearing held by the inspector in July 2018. This is in breach of NPPF paragraphs 158 and 182, and especially 155.

It is completely UNFAIR and UNJUST not to allow detailed and proper 'comparison testing' between the 3 competing sites. Government requires that adjoining authorities have a duty to co-operate when considering significant strategic cross boundary housing allocations. Such a 'Duty' cannot be rectified during a public consultation period, so failure to do at a much earlier stage can lead the inspector to recommend a non-adoption report.

This is contrary to PPG paragraphs 3-008 (2014 version).

Milton Keynes Council has agreed that a failure of co- operation has occurred and this makes this part of the plan 'unsound'.

The development at Shenley Park would cause considerable extra traffic congestion, both in Whaddon and on the A421.

The Eaton Leys site would seem more suitable, as it has good road links - the A4146 and the A5, and has better access to railway stations at Bletchley and Fenny Stratford.

Support

VALP Main Modifications

Representation ID: 2801

Received: 09/12/2019

Respondent: Anglian Water Services Limited

Representation:

We note that an additional site allocation for 1,150 homes and associated uses and infrastructure at Shenley Park is proposed.

Anglian Water is supportive of the requirements for early engagement with Anglian Water in relation to water supply and sewerage network capacity together with the preparation of a foul drainage strategy.

We also fully support the requirement of a surface water drainage strategy based on sustainable drainage principles.

Full text:

We note that an additional site allocation for 1,150 homes and associated uses and infrastructure at Shenley Park is proposed.

Anglian Water is supportive of the requirements for early engagement with Anglian Water in relation to water supply and sewerage network capacity together with the preparation of a foul drainage strategy.

We also fully support the requirement of a surface water drainage strategy based on sustainable drainage principles.

Object

VALP Main Modifications

Representation ID: 2933

Received: 11/12/2019

Respondent: Buckingham Town Council

Legally compliant? Yes

Sound? No

Representation:

Although "existing secondary schools" could be interpreted to include grammar schools, there should be clear provision for the Royal Latin School, (as the site will be in its catchment area for any suitably qualified secondary pupils), should a new secondary school be provided on site as this would seem to negate a financial contribution towards existing secondary schools, and thus with the increased number of houses on this site, there could be a significant number of suitably qualified pupils seeking a place at the local grammar school, but without any financial provision to the school.

Change suggested by respondent:

Provision for financial contribution to the Royal Latin Grammar School in the event that a secondary school is provided on site.

Full text:

Although "existing secondary schools" could be interpreted to include grammar schools, there should be clear provision for the Royal Latin School, (as the site will be in its catchment area for any suitably qualified secondary pupils), should a new secondary school be provided on site as this would seem to negate a financial contribution towards existing secondary schools, and thus with the increased number of houses on this site, there could be a significant number of suitably qualified pupils seeking a place at the local grammar school, but without any financial provision to the school.

Object

VALP Main Modifications

Representation ID: 3020

Received: 13/12/2019

Respondent: Crest Nicholson

Agent: Mr James Brewer

Legally compliant? Not specified

Sound? Not specified

Representation:

(officer changed from support to object as changes are being requested)

Please see attached documents:

32735 Crest Nicholson Section 2
32735 Crest Nicholson Section 3
32735 Crest Nicholson Appendix 1

That set out Crest Nicholson's support, subject to minor proposed changes, to MM076.

Full text:

Please see attached documents:

32735 Crest Nicholson Section 2
32735 Crest Nicholson Section 3
32735 Crest Nicholson Appendix 1

That set out Crest Nicholson's support, subject to minor proposed changes, to MM076.

Object

VALP Main Modifications

Representation ID: 3029

Received: 13/12/2019

Respondent: Mr David Froggatt

Legally compliant? No

Sound? No

Representation:

Shenley Park (SP) was not included in the 2017 proposed submission version of VALP, so Whaddon PC and residents have been completely denied the opportunity to properly debate and cross-examing AVDC's decision to chose SP over the two competing sites. It is unfair and unjust not to allow detailed comparison testing between the three competing sites.
Government requires that adjoining authorities have a duty to co-operates when considering significant strategic cross-boundary housing allocations. AVDC have paid lip service to this, but have not addressed this through effective discussion or joint working.

Change suggested by respondent:

It is illogical and completely unnecessary to expand the MK City boundary into Shenley Park. Why cross a strong defensible bridleway boundary such as the heavily wooded/hedged North Bucks Way into beautiful and much valued open sunspoilt countryside, when there are two more appropriate, and easier to develop, alternative sites available at Salden Chase and particularly Eaton Leys.

Full text:

see attachment

Attachments:

Object

VALP Main Modifications

Representation ID: 3030

Received: 13/12/2019

Respondent: Mrs Dorothy Froggatt

Legally compliant? No

Sound? No

Representation:

Shenley Park (SP) was not included in the 2017 proposed submission version of VALP, so Whaddon PC and residents have been completely denied the opportunity to properly debate and cross-examing AVDC's decision to chose SP over the two competing sites. It is unfair and unjust not to allow detailed comparison testing between the three competing sites.
Government requires that adjoining authorities have a duty to co-operates when considering significant strategic cross-boundary housing allocations. AVDC have paid lip service to this, but have not addressed this through effective discussion or joint working.

Full text:

see attachment

Attachments:

Object

VALP Main Modifications

Representation ID: 3061

Received: 09/12/2019

Respondent: Mr Roy Scott

Legally compliant? No

Sound? No

Representation:

This proposal has not been properly considered/ tested, especially in relation to highways, traffic and local services.

Change suggested by respondent:

The modification should be removed and further consideration given to sustainable sites e.g. Eaton Leys or Salden Chase.

Full text:

It is illogical and completely unnecessary to expand the MK City boundary into Shenley Park at the current time. Why cross a strong, defensible bridleway boundary, such as the heavily wooded/hedged North Bucks Way, into beautiful and much-valued open unspoilt countryside - when there are two more appropriate, and easier-to-develop alternative sites available at Salden Chase and (particularly) Eaton Leys.

Because of the very late introduction of Shenley Park to VALP, the Inspector should open a further hearing session at the end of the public consultation period, so that this crucial change can be rectified. It is completely unfair and unjust not to allow detailed and proper comparison testing between the three competing sites. To simply accept AVDC's preferred choice of Shenley Park without proper scrutiny and justification would render the final plan unsound and possibly unlawful.

AVDC has not addressed this key strategic housing allocation (a minimum of 1150 new homes) through 'effective discussion' or 'proper joint working', representing a significant failing of 'Duty to Co-operate at an early stage' ...... especially as MKC is the major town and Lead Authority adjoining the three neighbouring and competing sites. There is no Concept Plan or Illustrative Layout to examine (unlike some other major sites in the Plan) so how can residents understand what is proposed? Crest Homes in their May 2014 Development Opportunities Plan have demonstrated this dangerous concept by showing future development directional arrows heading further west, towards Coddimoor Lane, well beyond the boundary they currently propose in this version of VALP for the 'at least' 1150 homes.

The traffic and "rat-running" through Whaddon (a Conservation Area!) is already becoming insufferable. AVDC has said that it is not normal to have detailed plans for traffic, for example, in strategic Local Plan allocations, as these will be drawn up later at Detailed and Supplemental Planning stages, at which time there will be further public consultation.......but of course by then the site would be confirmed in the Local Plan! Answers must be provided now before such a major site is confirmed, as the impact could have devastating road safety and environmental consequences for Whaddon village, particularly the High Street where so many properties directly abut the road and the pavements are below accepted modern standards i.e. narrow, damaged, sloping - or non-existent (often with little scope for improvement)!

Object

VALP Main Modifications

Representation ID: 3067

Received: 16/12/2019

Respondent: Milton Keynes Councillor

Legally compliant? No

Sound? No

Representation:

I urge the authority to reconsider the allocation of Shenley Park as a housing site. It is not viable due to the reasons outlined above, and there is no real evidence to suggest why this site has been included again after it was initially ruled out. The decision to include it is rushed, ill conceived and open to challenge. I urge the LPA to either withdraw the site or, as indicted above, re-open the examination hearings to allow full exploration of all possible options.

Change suggested by respondent:

I urge the authority to reconsider the allocation of Shenley Park as a housing site. It is not viable due to the reasons outlined above, and there is no real evidence to suggest why this site has been included again after it was initially ruled out. The decision to include it is rushed, ill conceived and open to challenge. I urge the LPA to either withdraw the site or, as indicted above, re-open the examination hearings to allow full exploration of all possible options. Please allow my residents, and all residents of Milton Keynes who would be affected by development in Aylesbury Vale, a chance to really get across their views and concerns before a final decision is made.

Full text:

On behalf of the residents of Tattenhoe Ward, Milton Keynes, I strongly object to the inclusion of 'Shenley Park' as a new housing allocation in the Vale of Aylesbury Local Plan (VALP) modifications. The inclusion of such a large housing site at this late stage and the drastic change from the original plan raise a number of questions about the suitability, process and sustainability of such a site. It is highly doubtful that an acceptable and policy-compliant development could be delivered at the Shenley Park site. There is no evidence of a robust yet proportionate site selection process underpinning the proposed allocation of Shenley Park, and therefore the proposed allocation is not justified.
As identified by Milton Keynes Council (MKC), the allocation of Shenley Park was initially proposed at Regulation 18 stage of the VALP. However, this was removed from the Regulation 19 version of the VALP and the VALP as submitted for examination. The reappearance of such a strategically significant prospective allocation at Shenley Park via the Examination in Public and the Proposed Main Modifications consultation has, understandably, come as a significant surprise to the communities of Tattenhoe, Kingsmead and Oxley Park within Milton Keynes which I represent. These communities would not have felt it necessary to engage in the Regulation 19 consultation on the VALP as Shenley Park had been removed as proposed allocation, and therefore have not had a voice in the examination proceedings to date. I strongly support Milton Keynes Council's proposal to re-open the examination hearings. This is necessary allow my residents to further explain any written objections and challenge any further submissions or statements made by AVDC in support of the proposed allocation. It is critically important that residents in Milton Keynes are not seen to be disadvantaged through the consideration of such a significant change to the VALP at this late stage of the plan-making process.
The proposed allocation of the Shenley Park is not viable due to 2 main issues, mainly raised by point f in the site-specific requirements: '....the development will use some facilities in Milton Keynes, given its proximity. Milton Keynes also provides an access point into the site'. The first issue being it's difficulty in complying with policy SD15 of Plan:MK (2019) which details the requirements of any development on the Milton Keynes border. It is widely acknowledged that this development is essentially an extension of Milton Keynes and not a stand-alone development in Aylesbury Vale. The impact this will have on the infrastructure and services in Milton Keynes is huge, and the VALP does not address this satisfactorily. Impact on health care, education and services such as libraries and children's centres will be large and this cannot be mitigated through one-off financial contributions such as S106. The lack of council tax revenue for MKC from the residents of Shenley Park means we would be taking on additional burden without sufficient funding. This is not a sustainable proposal.
The second issue is that of highways and access to the site. Point f states, 'Milton Keynes also provides an access point into the site' which I feel presumes a lot. The indicative design with access to the site through the extension of the H6 Child's Way has caused upset and concern amongst my residents and the site cannot be brought forward whilst it is so reliant on a Milton Keynes planning decision to allow extension of the H6 or the H7. The impact on the residential amenity for residents of Harlow Crescent and Saltwood Avenue in Oxley Park and Kingsmead respectively would be sufficient to refuse any application. The site would not be deliverable without this access point and there would be a huge public campaign to ensure this is not granted.
Overall, I urge the authority to reconsider the allocation of Shenley Park as a housing site. It is not viable due to the reasons outlined above, and there is no real evidence to suggest why this site has been included again after it was initially ruled out. The decision to include it is rushed, ill conceived and open to challenge. I urge the LPA to either withdraw the site or, as indicted above, re-open the examination hearings to allow full exploration of all possible options. Please allow my residents, and all residents of Milton Keynes who would be affected by development in Aylesbury Vale, a chance to really get across their views and concerns before a final decision is made.

Object

VALP Main Modifications

Representation ID: 3068

Received: 16/12/2019

Respondent: Mr Adam Stewart

Legally compliant? No

Sound? No

Representation:

MM076 is demonstrably unsound and unlawful. It's rushed and poorly prepared with serious unanswered questions regarding its last-minute inclusion, poor and overly-complex documentation, negative impact on the environment (traffic/road safety) and costs of providing essential public services, especially considering AVDC and MKC's failure to cooperate and work jointly. Further problems are the non-adherence to recognised planning processes (NPPF), lack of consultation/representation, funding/findings of AECOM's Sustainability Appraisal and the dangerous precedent for Buckinghamshire's countryside. Even MKC don't want this AVDC-appendage bolted on to MK. Respect the existing City Boundary and allocate housing in a more appropriate and sustainable location.

Change suggested by respondent:

Policy MM076, including all development at Shenley Park (WHA001) must be deleted from the VALP before adoption of the VALP occurs.

Eaton Leys, Bletchley or Salden Chase should be considered sustainable replacements. Better still, alternative, more-sustainable sites should be identified closer to larger towns in Aylesbury Vale - thereby helping that town's sustainability and economy, rather than that of Milton Keynes.

Full text:

I do not consider modifications MMO75 and MMO76 of AVDC's Local Plan (VALP), specifically the inclusion of the Shenley Park (WHA001) development area, to be sound or justified.

Shenley Park (WHA001) was NOT included in the Vale of Aylesbury Local Plan published in November 2017. Its exclusion meant it was not included in the public hearing held in July 2018, denying local residents the opportunity to scrutinise the plans and AVDC's proposals. This is a serious breach of NPPF guidelines (specifically paragraphs 155, 158 and 182). This is unfair and unjust.

Shenley Park's late inclusion means it has not been subject to the same level of preparation, and investigation as other identified development sites, including Eaton Leys and Salden Chase. Nor have objectors to Shenley Park been afforded the same time or opportunity to investigate, scrutinise and formally object to the suggested development. How can Shenley Park possibly be subject to the same tight deadline? Did AVDC know that Shenley Park is less suitable and that it would meet stiff opposition - and hope that by only including it at the last minute, it would slip through unnoticed and/or unchallenged?

Specifically, in relation to WHA001, there are no concept plans, no illustrative layouts, no indication of highway distribution, no projections of vehicular/traffic impacts, no details of the green barrier between Whaddon village and new housing, no details regarding how essential public services will be paid for and no consideration to how to limit future development and urban sprawl once the natural development barrier of the North Bucks Way has been breached.

Some of these glaring developmental omissions can be explained by the almost total lack of cooperation between AVDC and MKDC - as confirmed by MKDC at their full council meeting on 23rd October 2019 when members across all parties agreed that a 'failure of cooperation' had occurred in contravention of 2014's PPG (paragraph 3-008), risking a non-adoption report. This lack of cooperation has resulted in a disturbing lack of information in certain key development areas - resulting in a VALP that is demonstrably unsound, non-complaint and possibly unlawful.

At this stage I would like to formally record my support for all the points raised in the submission prepared by Whaddon Parish Council, whose knowledge of development matters is second to none given their previous efforts to protect Whaddon village and the rolling countryside of the Whaddon Chase Valley. AVDC would do well to consult with them at the earliest opportunity.

I have decided to focus my detailed representation on the following areas:

TRAFFIC
AVDC is aware that Whaddon Parish Council (WPC) collects detailed traffic volume data - but neither AVDC nor AECOMS consulted with or asked WPC for their traffic data before preparing their proposals. Why not? Where is the local engagement? WPC can statistically demonstrate that weekday traffic levels have increased by over 50% in the last 5 years. Road safety is a serious concern to Whaddon residents, many of whom will testify that both vehicle/vehicle accidents and vehicle/pedestrian accidents have increased over recent years. HGV traffic has also increased, leaving village access roads dangerously potholed - a point AVDC finally acknowledged when they recently agreed to resurface the entire length of Codimoor Lane. When asked by Whaddon Parish Council how a new grid road would address traffic concerns in Whaddon, AVDC revealed they had no plans and no answers! Is AVDC aware of the sound public planning principle (adopted by both Government and Local Authorities nationwide) that 'infrastructure must come before development'? Worryingly, AVDC confirmed that traffic issues would only be resolved at the detailed planning stage. And if they can't be? It would then be too late. Sensible, sustainable planning policy dictates that you resolve issues before committing to considerable expense. It would be foolhardy to start a journey before deciding on the destination. Clearly a proposed development of this scale sited on the border between Aylesbury Vale and Milton Keynes requires traffic impact analysis across both authorities. Not only has this not occurred, but each authority uses a different traffic modelling technique (neither of which consider the impact of major development on the surrounding road network). Given the 'failure of cooperation' between AVDC and MKC, it is clear that cooperation at the traffic impact level has not taken place. Further evidence of this lack of cooperation is evidenced by MKC's refusal to consent to access into Salden Chase from the A421 due to 'insufficient evidence to mitigate traffic'. If development of 1,855 houses is approved at Salden Chase, how will residents access their homes? Via Newton Longville? This would have a devastating effect on Newton Longville. MKC could similarly deny access to Shenley Park (WHA001) from the A421 or along the North Bucks Way, with the resulting traffic through Whaddon destroying the character, environment and safety of Whaddon village. Both authorities should be reminded that their failure to cooperate is a clear contravention of 2014's PPG (paragraph 3-008) and risks a non-adoption report recommendation from the Inspector. These important issues cannot simply be overlooked and must be resolved before identified development sites can be included in the Local Plan.


INFRASTRUCTURE AND ESSENTIAL PUBLIC SERVICES
The failure of AVDC and MKDC to cooperate by engaging in effective discussion and undertaking proper joint-working has also led to serious concerns regarding the provision of and long-term sustainability of essential public services. In summary, Shenley Park residents would reside in Aylesbury Vale, pay taxes to AVDC, but use taxpayer-funded services in Milton Keynes. For example:

* EDUCATION: WHA001 outline plans do not provide for a secondary school as it would 'not be viable'. Where then will children of secondary school age be educated? Especially when you consider that Milton Keynes' secondary schools are already at full capacity (and in any case are intended for MKC residents). More worryingly, how will their education be financed? Due to the lack of cooperation between AVDC and MKDC there has been no discussion (and therefore no agreement) on any transfers of taxes raised from residents of any of the identified development areas to MKDC in order to adequately fund secondary schools.
* EMPLOYMENT: Remarkably, the Main Modifications do not mention employment. It is highly likely that residents of Shenley Park (WHA001) would work in Milton Keynes. Transport infrastructure in Milton Keynes is already at breaking point and Whaddon has evidence of steadily increasing volumes of traffic, with corresponding increases in danger to both motorists and pedestrians. MKC's November 2019 refusal to consent access into Salden Chase from the A421 is a problem that is highly likely to apply to WHA001. Due to a lack of cooperation, insufficient thought has been given to linking future residents to their place of work. Without a sustainable transport plan, VALP, and in particular the inclusion of WHA001, is unsound.
* HEALTHCARE AND AMBULANCE SERVICES: Shenley Park (WHA001) does not provide for healthcare services. Residents will inevitably use health services located in Milton Keynes, especially Milton Keynes Hospital. Limited cooperation on budgeting for residents of Shenley Park's use of Milton Keynes Hospital has taken place and AVDC has only agreed to a single, one-off payment of £2m. There have been no discussions regarding the ongoing and financing of the provision of healthcare and ambulance services. Certainly a £2m one-off fiscal transfer will be a drop in the ocean compared to the ongoing cost of providing hospital services to approximately 2,900 new AVDC residents.
* WASTE SERVICES: Shenley Park (WHA001) does not provide for waste services. Residents will inevitably use waste services, including recycling facilities, located in Milton Keynes.
* POLICE SERVICES: Shenley Park (WHA001) does not provide for police services. Residents in WHA001 will inevitably use and rely on police services located in Milton Keynes.
* FIRE SERVICES: Shenley Park (WHA001) does not provide for fire services. Residents in WHA001 will inevitably use and rely on the fire prevention and extinguishing services located in Milton Keynes.

Milton Keynes Council (MKC) currently uses a tariff system to fund infrastructure and community facilities. Every new dwelling contributes £20,000. If WHA001 were located in Milton Keynes, the 1,150 new homes would raise c. £23m for MKC. As it stands, and due to a complete failure to cooperate, MKC will receive just £2m (nominally earmarked for MK hospital), instead of c. £23m (plus ongoing council tax revenue). Recognising that MKC is being asked to fund significant infrastructure and ongoing public services provision for AVDC residents, MKC members have suggested that a boundary change be considered to allow MKC to align the revenue collection and service provision for any new residents. This was immediately rejected by AVDC - in no small part due to the undeniable fact that WHA001 allows AVDC to collect a significant sum in council taxes whilst letting MKC bear the cost of providing many of their essential public services.

Referring to WHA001, the 'suggested changes' document mentions that 'the development will use some facilities in Milton Keynes, given its proximity' (paragraph f). The reference to 'some' is repeated in the Sustainability Appraisal Report Addendum in Section 9.9.1. 'Some' dependency is unacceptably vague. MM076 mentions a primary school and a small care home - but there is almost no mention of any public service provision for residents between primary school age and those entering a care home. AVDC must more clearly define which public services AVDC is providing and financing and which public services they are expecting MKC to provide and finance. Can AVDC confirm what discussions have taken place between AVDC and MKDC in relation to the provision of and the financing of essential public services? Has an agreement been reached? It is clear that there will be an almost total dependency of residents in WHA001 on public services provided by and paid for by Milton Keynes Council. Is it any wonder the members have serious reservation and are objecting even at this early stage in small but meaningful ways, such as refusing to grant planning permission for access roads from the A421?

The issue arising from the provision of all public services is that AVDC will collect local taxes, but it will be MKC that will bear the cost of providing essential public services - or not. Without cooperation, MKC will either refuse to provide services for residents of AVDC, or these services will be underfunded and deficient. Cooperation - and an agreement on fiscal transfers to fund joint services - must take place and be concluded before any discussion about development should begin. Without agreement on transfers of money to provide for the essential public services - or an agreed boundary change, the VALP is unsustainable, non-complaint and therefore unsound.


MEANINGFUL DEVELOPMENT BARRIER
In 1998, a study by Llewelyn-Davies (at the request of SERPLAN) concluded that the 'Shenley Ridge forms a division between the urbanity of Milton Keynes and the rolling Buckinghamshire
countryside'. The study repeated the earlier recommendations that future development be kept to the East of Shenley Ridge which "forms a logical and obvious boundary to development".

The Public Inspector wrote that he did "not see the logic of regarding the Whaddon Valley as a possible long-term development area. To do so disregards the qualities of the valley landscape and the merits of the Shenley Ridge as a logical and clear long-term boundary.". He concluded by confirming that in his view "the combination of the character of the landscape and the distinctiveness of the ridge dictate that development should not "spill over" the ridge."

https://www.milton-keynes.gov.uk/planning-policy/documents/Part_1.pdf

The North Bucks Way is a natural continuation of the Shenley Ridge and therefore serious consideration should be given to the findings and conclusions of the Planning Inspector's report (dated 7th April 2004). AVDC should conclude - alongside MKC - that the heavily wooded/hedged North Bucks Way should represent 'a logical and obvious boundary to development'. It is illogical and unnecessary to expand the city boundary into WHA001. Milton Keynes' own 'Strategic Development Directions Consultation' document (dated January 2016) identified the development areas in question, including WHA001, to be 'potential strategic green spaces and linear park extensions'. Further evidence that there has been no serious co-ordination or joint strategic planning regarding development sites abutting local authority boundaries.

Even the AECOM Sustainability Appraisal - so heavily relied upon by VALP - confirms that 'significant development would be contrary to a Biodiversity Opportunity Area (BOA) and Bucks Green Infrastructure Plan objectives'. Both Shenley Park (WHA001) and Salden Chase are within a Biodiversity Opportunity Area!

Without defining a natural development barrier, where would encroachment into the open countryside end? Buckingham? AVDC should mirror MKC's ambitions to ensure 'biodiversity' and 'natural processes' are placed at the top of the agenda whilst celebrating the rich variety of wildlife by protecting landscapes and habitats etc. Many objectors to this amendment and development at Shenley Park (WHA001) will consider that AVDC is too easily influenced by profit-hungry developers - many of whom are already racing to secure development rights on tracts of agricultural land reaching as far as Buckingham town. This is evidenced by Crest Homes' 'Development Opportunity Plan (May 2014) showing future development directional arrows pointing even further west than the development proposed at Shenley Park (WHA001). Local Authorities in conjunction with local stakeholders should be defining future development areas based on sound planning practices, not developers with deep pockets and solely economic motives.


CONCLUSION
It is undeniable that AVDC has only included WHA001 at this late stage due to its failure to allocate housing in previously approved sites in Buckingham, Winslow, Haddenham etc. Why should the residents of South-West Milton Keynes - and Whaddon in particular - suffer the consequences of a poorly prepared submission only because AVDC failed to follow due process? Lack of time to prepare sound local area plans should not replace the need for adherence to sensible planning practice and regulations. There are serious and unanswered questions regarding the late inclusion of WHA001, lack of due process and representation, lack of official documents (and the complex manner in which they are presented to the public), environmental concerns (especially in relation to suggested development within a Biodiversity opportunity Area), concerns regarding the initial and ongoing cost of providing essential public services to residents of AVDC, not to mention the funding of and findings of the AECOM Sustainability Appraisal and a demonstrable failure of AVDC and MKC to cooperate and work jointly on even the most basic of issues such as site access.

Although I have focused the attention of my objection on why WHA001 is totally unsuitable for development, resulting in an unsound and legally non-complaint VALP, if development must take place in one or more of the identified sites, there are clearly more acceptable sites than Shenley Park, including Eaton Leys.

AVDC must now answer the following questions:
* Why was Shenley Park (WHA001) not considered suitable for the 2017 VALP?
* Why was it suddenly (and unexpectedly) included in the October 2019 modifications document?
* Does AVDC accept the inclusion of WHA001 at such a late stage is in breach of NPPF guidelines?
* Will AVDC publish the results of the research that led it to conclude there would only be 'some' dependence of residents, when even a brief glance through the published documents reveal that there would be an almost total dependence.
* Will AVDC publish the results of their discussions and cooperation with MKC - especially in relation to capacity building and ongoing financial sustainability of essential public services, including details of ongoing transfers AVDC will make to MKC.
* What degree of influence does the landowner and potential developer of WHA001 have on AVDC?
* In reaching their conclusions, AVDC appears to place disproportionate weight on the findings of the AECOM Sustainability Appraisal. Why? Can all parties be reassured that the AECOM findings are truly 100% impartial? And, in particular, free from any developer influence or bias?
* Will AVDC reopen the Inspector's Hearing Sessions? If not, why not?

Local residents, particularly those who in the historic Domesday village of Whaddon must be given the opportunity to formally object to the very serious and negative impacts such a large development will have on their village - especially on the environment and road safety. A re-opening of the Inspector's Hearing Sessions (with both AVDC and MKC present) is the only acceptable way forward. This would allow previous objectors and Whaddon residents who have been denied the opportunity to speak and object at a hearing to seek satisfactory answers to genuine concerns, including crucial transport, landscape and social issues.

Policy MM076, including all development at Shenley Park (WHA001) must be deleted from the VALP before adoption of the VALP occurs. Eaton Leys, Bletchley or Salden Chase should be considered sustainable replacements. Better still, alternative, more-sustainable sites should be identified closer to larger towns in Aylesbury Vale - thereby helping that town's sustainability and economy, rather than that of Milton Keynes.

[I am also attaching a pdf copy of my objection to MM076]

Support

VALP Main Modifications

Representation ID: 3069

Received: 16/12/2019

Respondent: Mrs Olive Sturridge

Representation:

I am in favour of the proposed allocation of 1150 new houses .

Full text:

I am in favor of the proposed allocation of 1150 new houses .

Object

VALP Main Modifications

Representation ID: 3076

Received: 17/12/2019

Respondent: Clifton Kirstie (Bovis Homes Limited)

Agent: Define Planning & Design

Legally compliant? Yes

Sound? No

Representation:

It is evident that AVDC's suggested phasing and delivery trajectory for this allocation is unrealistic and not substantiated by reasonable assumptions, with the Housing Trajectory suggesting that 50 dwellings will be delivered in 2024/25. This assumes first dwellings would be delivered within a four year timescale. This is unrealistic, given the Shenley Park FAQs document requires a Supplementary Planning Document to be be prepared and approved, plus the site's deliverability has been put into question following the highway constraints identified in relation to Salden Chase (as noted in response to MM074).

Change suggested by respondent:

Amend delivery assumptions for D-WHA001 to appropriately reflect delivery risks.

Full text:

Whilst the addition of a further site within North East Aylesbury Vale, Shenley Park, would provide a further 1,150 homes to meet the District's housing requirement to 2033, Bovis Homes notes particular concerns regarding the allocation of the site through MM075 and MM076. Notably, it is evident that AVDC's suggested phasing and delivery trajectory for this allocation is unrealistic and not substantiated by reasonable assumptions.

In particular, MM076 notes that "the site is expected to be delivered between 2024 and 2033", with the Housing Trajectory (as amended by MM023) suggesting that 50 dwellings will be delivered in 2024/25. This would suggest that housing delivery would begin within 4 years of the plan's adoption, which is assumed to be mid-2020 (as is reasonable). Based upon the Shenley Park FAQs document that supports this consultation, that is, a Supplementary Planning Document would be prepared and approved, an application would be submitted, determined, a Section 106 Agreement would be agreed, conditions would be discharged, Reserved Matters would be prepared and determined (if an outline application route is proposed initially), pre-commencement conditions would be discharged, site remediation and preparation would be carried out, supporting infrastructure would be developed, and first dwellings would be delivered within a four year timescale.

By contrast, assumptions put forth by the Planning Matters report suggest that the average Total Development site (from the submission of the first application to the delivery of the first dwelling on site) for sites of 1,000 to 1,999 dwellings is around 7 years. Thus, should an application be submitted immediately upon the anticipated adoption of the VALP in mid-2020, it would be reasonable to suggest that delivery may start around mid-2027; three years later than anticipated by AVDC in MM076. This would result in the reduction of the District's housing supply and, if coupled with any delay within the six strategic allocations surrounding Aylesbury Garden Town, would result in a significant shortfall in housing supply. Furthermore, Planning Matters assumes a build out rate of 100dpa for sites between 1,000 and 1,999 dwellings. Given that there is no clarity relating to the developers involved with the development, the peak build out rate as set out within the housing trajectory should be capped to 100dpa.

Taking into consideration these reasonable alterations, 600 dwellings would be removed from AVDC's purported housing supply in the plan period to 2033. Combining the reasonable assumptions for both Salden Chase and Shenley Park, 1,505 dwellings would be removed from AVDC's supply of housing to 2033. Therefore, AVDC's supply from 2013 to 2033 would reduce from 30,233 to 28,728; falling below the 28,600-dwelling housing requirement set out in the VALP.

However, the site's deliverability has been put into question following the highway constraints with relation to the capacity of Standing Way / the A421 running along the site's southern boundary. It is anticipated that the development would include the provision of access from this road. As discussed above, the refusal of a full planning application relating to Highways and Access at Salden Chase suggests that the highway network would be unable to accommodate the increased traffic flow, particularly relating to the Bottledump roundabouts of Standing Way / A421.

Thus, the deliverability of Shenley Park is also put into doubt, given that any application must demonstrate that there would not be an unacceptable impact on the highway network. In this light, should the site not come forward, AVDC would lose 1,150 dwellings from its purported supply of housing. Should both sites be unable to deliver as a result of the evident highways impacts, 3,005 dwellings would be lost, reducing AVDC's housing supply from 30,233 to 27,228 dwellings. In this event, the VALP would be unable to demonstrably meet its housing requirement of 28,600 dwellings.

Even if the site is able to deliver in its entirety during the plan period (which is unrealistic), it appears that the addition of the site is utilised to justify modification MM008 (as discussed), which states that a new settlement is no longer part of the VALP as a result of "a reduction in our housing figures." The reliance on a site of 1,150 dwellings that is extremely unlikely to deliver in accordance to the trajectory set out is questionable and unlikely to replace the housing supply that would have been delivered from a new settlement (previously indicated capacity of c. 4,000 dwellings).

For these reasons, and to ensure flexibility in the District's housing supply, further development should be supported on medium sites within large and medium villages. Specifically, development could be intensified at those sites that can demonstrate an ability to accommodate further residential development, such as Land South of Creslow Way, Stone (as discussed in response to MM094) in order to provide flexibility in the light of the uncertainty relating to Shenley Park and Salden Chase.

Object

VALP Main Modifications

Representation ID: 3102

Received: 17/12/2019

Respondent: Kingsmead Residents Group

Agent: Mr Robert Wilson

Legally compliant? No

Sound? No

Representation:

Object to Shenley Park Allocation in Main Modification MM076

Change suggested by respondent:

Delete Shenley Park and replace with Eaton Leys

Full text:

Representation to the Vale of Aylesbury Local Plan Main Modifications consultation

Shenley Park additional allocation

17th December 2019
LPA Ref:
Our Ref: KRG 001
Impact Planning Services Ltd:
Unit 1, The Court Yard
Copse farm,
Lancaster Place
South Marston Park,
Swindon,
Wiltshire,
SN3 4UQ
Tel: 01793 820158


Contents
1.0 Introduction 2
2.0 Background to the VALP......................................................2
3.0 Duty to Co-operate..............................................................4
4.0 Sustainability appraisal reports & related evidence.................6
5.0 Details of the site proposed, including constraints................13
6.0 Alternative approach.........................................................14

Appendix...............................................................................................16
Plan 1..............................................................................................................20
Plan 2..............................................................................................................21



1.0 Introduction

1.1 This representation is submitted by Impact Planning Services Limited (IPS) on behalf of the Kingsmead Residents Group (KRG), who comprise a non-elected community group of people who live in the Kingsmead area in the west side of Milton Keynes.
1.2 The structure of this representation is as follows:
 Background to the Vale of Aylesbury Local Plan (VALP),
 Duty to Co-operate,
 Sustainability Appraisal Reports & related evidence,
 Details of the site proposed, including constraints,
 Alternative approach and sites to assist the VALP in meeting its additional housing need.
1.3 As this representation makes clear there is no justification for the selection of the additional allocation for housing at Shenley Park (Main Modifications 070 New Policy 'D2 Delivering site allocations in the rest of the district' and accompanying pre amble' and MM071,075 and 076 New Site Policy D-WHA001 Shenley Park' for at least 1,150 dwellings) and the decision to allocate it is unfounded. It is also contrary to the Aylesbury Vale District Council's own evidence base. The site should be removed from the Plan for a second time. Given this substantive change to the Plan at a very late stage in the process then at the very least, it is respectfully requested that the Examination hearings are re-opened to enable all parties, including KRG, the opportunity to make and augment their case directly to the Inspector.


2.0 Background to the VALP

2.1 Aylesbury Vale District Council (AVDC) has a poor record of plan making. It failed to adopt a Core Strategy in 2010 when the Secretary of State announced that Regional Spatial Strategies (the South East Plan for Aylesbury Vale) were revoked. In a report dated 8th September 2010 to the Council it was advised that the Core Strategy did not address in sufficient detail: sustainable development, employment targets nor energy. In addition, the report suggested that with the revocation of housing figures from the South East Plan, the Council could plan for a reduced number of new dwellings. On the 5th October 2010, the Secretary of State issued a Direction withdrawing this Plan.
2.2 Following this AVDC embarked on another plan- the Vale of Aylesbury Strategy which was submitted to the Secretary of State for examination in August 2013. On 7th January 2014 the Inspector, Kevin Ward wrote to the AVDC and in paragraph 27 of that letter he states 'There are particular issues concerning the relationship of Aylesbury Vale to Milton Keynes and its future growth. These issues have been left unresolved. The Council has been aware of these issues from early in the plan preparation process, if not before'.
2.3 The Inspector concluded that AVDC had failed to comply with the Duty to Co-operate. This together with other failings including the insufficient overall provision for housing and jobs, the fact that the Plan had not been positively prepared, the fact that it was not justified nor effective and it was not consistent with national policy, led the AVDC to withdraw this Plan on 5th February 2014.
2.4 The Vale of Aylesbury Local Plan is the third attempt by AVDC to prepare a sound plan. Previous Local Plan Inspectors have made reference to development in this location and these are highlighted later. The sequence of events and timeline associated with this latest Plan is convoluted to say the least.
2.5 The Scoping for the Plan was carried out in the Spring of 2014 together with a Call for Sites. This was followed by the Issues and Options stage in October 2015 (which included 'extension to Milton Keynes/Bletchley' in five of the nine options but no plans in chapter 5), with accompanying evidence studies. The Consultation Plan was publicised in the Summer of 2016. The July 2016 VALP had the Shenley Park site depicted on a map and was the subject of an allocation together with Salden Chase. Subsequently, there was consultation on the Proposed Submission Plan from 2nd November 2017 to 14th December 2017. The November 2017 Submission VALP omitted the Shenley Park site.
2.6 The rationale for making changes to the Plan has not been always been clear and this matter is explained in more detail later in this representation.


3.0 Duty to Co-operate

3.1 As explained above AVDC has failed to meet this legal duty previously and although the information considered to date on the current emerging VALP may satisfy the duty up to that stage, it is clear that there has been no outcome from any co-operation between AVDC and Milton Keynes Council (MKC) regarding the edge of Milton Keynes strategic locations, other than for Salden Chase. There is no Memorandum of Understanding (MOU) between the two authorities concerning Shenley Park and this was confirmed at an informal meeting with the Development Plans Manager at MKC on 21ST November 2019. The only MOU between AVDC and MKC is dated February 2018 (reference CD.DTC. 008) and it just addresses the Salden Chase development.
3.2 The Planning Practice Guidance states at paragraph:022 Reference ID: 61-022-20190315: 'Inspectors will expect to see that strategic policy making authorities have addressed key strategic matters through effective joint working, and not deferred them to subsequent plan updates or are not relying on the inspector to direct them. Where a strategic policy-making authority claims it has reasonably done all that it can to deal with matters but has been unable to secure the cooperation necessary, for example if another authority will not cooperate, or agreements cannot be reached, this should not prevent the authority from submitting a plan for examination. However, the authority will need to submit comprehensive and robust evidence of the efforts it has made to cooperate and any outcomes achieved; this will be thoroughly tested at the plan examination'.
3.3 At the MKC meeting held on 23rd October 2019 under item 5 b (ii) the Shenley Park Development Proposals were discussed. It was resolved by the Council that it:
'(a) expresses concern that Shenley Park, or any of the other possible allocations may have a negative potential impact on Milton Keynes;
(b) expresses concern that the allocations have been brought up only towards the end of the plan-making process, meaning that community engagement on these sites has been minimal;
(c) expresses concern that ward councillors and parish councils were unaware of these proposals and asks the Cabinet to look at their protocol for informing and consulting ward and parish councillors when neighbouring authorities come forward with development proposals;
(d) believes that the development could place unacceptable strain on the infrastructure and services in Milton Keynes including on highways and transport infrastructure, quality public open space, GP services and school provision;
(e) notes that the development proposals lack any conformity or integration with the surrounding and adjoining infrastructure of Milton Keynes; and
(f) notes that as Shenley Park would likely be regarded informally and geographically as part of Milton Keynes, but falls outside the administrative boundaries of Milton Keynes Council so any planning decisions and future income would not fall to Milton Keynes Council'.
3.4 Further evidence of the co-operation difficulties is provided by the decision of MKC to refuse planning permission for the access to Salden Chase on 7th November 2019 (ref:15/00619/FUL) and on 16th December a Delegated Decision by the Cabinet Member for Planning and Transport will be made by MKC to formerly object to the VALP and the selection of the Shenley Park Allocation.
3.5 This all clearly demonstrates that AVDC has failed to meet the Duty to Co-operate on this most obvious cross authority matter and so the proposal fails on this legal requirement. This can be rectified by full engagement between the two authorities with all meetings outcomes recorded in writing and addressing all of the potential cross boundary sites and issues, not just Salden Chase.


4.0 The Sustainability Appraisal Reports & related evidence

Sustainability Appraisal
4.1 Section 19 of the Planning and Compulsory Purchase Act 2004 requires a local planning authority to carry out a sustainability appraisal (SA) of each of the proposals in a plan at each stage during its preparation.
4.2 Furthermore, the SA should provide conclusions on the reasons the rejected options are not being taken forward and the reasons for selecting the preferred approach in light of the alternatives.
4.3 The non- technical summary on page 3 of the SA Addendum report October 2019 (ED204),states in the conclusions to table B:
...'it does not necessarily follow that this site (Shenley Park*) is the most suitable or sustainable overall, as the various objectives are not assigned any weighting. For example, the appraisal serves to highlight Shenley Park as performing relatively poorly in respect of heritage objectives, and the Council - as decision-makers - might assign particular weight to this matter. Equally, Shenley Park is judged to perform less well than Salden Chase Extension in respect of 'Communities' objectives, due to uncertainties in respect of secondary school delivery, and the Council might assign particular weight to this'. * Impact Services Ltd addition for clarity
4.4 The SA Addendum October 2019 in Appendix 1 states on biodiversity issues that in conclusion Salden Chase is the less preferable site on balance (but it does have a favourable recommendation to grant planning permission). Eaton Leys and Shenley Park have pros and cons, however on balance it is considered appropriate to differentiate in accordance with the Ecology Headlines Study. As explained below under the sub heading 'Related Evidence', that leads to Eaton Leys being more suitable to allocate ahead of Shenley Park, not the other way around so this part of the SA 2016 is an error. The conclusion at 9.2.2.is restricted to the proposed allocation at Shenley Park and does not provide any comparison with the other two sites.
4.5 Under the community heading this SA recognises that Shenley Park performs less well and although Eaton Leys is described as performing poorly it is important to emphasise there is no certainty that Eaton Leys needs to deliver a new secondary school on the site. Furthermore, as explained above under the Duty to Co-operate the consequences for education provision in Milton Keynes must be taken into account. That information has seemingly not been sought nor analysed and it is clearly lacking within the SA reports.
4.6 In terms of landscape the 2019 SA in the main report at paragraph 9.9.1,states that only 35% of the Shenley Park site is likely to be suitable for development. In the Appendix 1 the SA states that Shenley Park has low capacity in the north west and that it is considered inappropriate to highlight Shenley Park ahead of Salden Chase. Eaton Leys is described as having low capacity but this ignores the clear separation of this site from the open countryside beyond the dominant boundary formed by the A5 and the A4146 roads and associated developments. This separation from the wider landscape is acknowledged in paragraph 3.1.8 of the Landscape and Visual Capacity Comparison Assessment (ED210A).
4.7 In terms of the economy all three of the sites are described as being along the emerging growth corridor and there is no potential to differentiate the alternatives with any confidence.
4.8 Under the heritage topic Shenley Park is 'considered to present more constraints to development than the other two sites'. This is confirmed in the document ED222, the Heritage Appraisal at paragraph 5.6 of that document.
4.9 Importantly the October 2019 SA refers to the justification for the Council supporting the preferred option can be seen in section 7. It refers to the HELAA as the assessment process which came out in support of Shenley Park as the preferred site. This ignores the advice from Government in the NPPG, which as explained above, states that the SA should provide conclusions on the reasons for the rejected options not being taken forward and together with the reasons for selecting the preferred approach in light of the alternatives. The October 2019 SA does not perform this function and is therefore flawed. The HELAA is addressed later.
4.10 Prior to this version of the SA, in July 2016 AVDC published the SA of the Reasonable Alternatives produced by Lepus Consulting. In that report Whaddon (WHA001) which is the reference given to Shenley Park, is considered with approximately 110 other sites and is one of only 13 sites to have just one minor positive score. All of the other sites (some 97 sites) had two or more positive scores. On page 106 of that document at paragraph 3.42.4 it states that with regard to the landscape at Shenley Park: 'This LCA is recorded as being in very good condition, with high sensitivity. The HELAA states that a large landscape buffer to Whaddon village will be included within the development of the site. Site WHA001 is likely to be visible from all sides except the east, which is lined with trees, limiting visual impact on Kingsmead'.
4.11 The following paragraph refers to the predominant agricultural fields with linear patches of woodland lining the site to the north and east. It continues: 'These patches of woodland may be high in biodiversity and are likely to serve as a habitat corridor for a number of species, including birds and bats. Development could result adverse impacts on biodiversity (SA Objective 3)'. In addition to these comments there is a well-established mature belt of deciduous woodland running along the southern boundary of the site with the A421 road and the mature tree and hedgerow boundary of the North Buckinghamshire P R of Way on the current western edge of Milton Keynes.
4.12 At paragraphs 3.42.6 the 2016 SA states: 'WHA001 is located within Flood Zone 1, which is at low risk of flooding. To the south of the site there is an area at high risk of surface water flooding. Development in this part of the site may therefore be at high risk of flooding (SA Objective 5)'.
4.13 This in effect sterilises a significant area in the south of the Shenley Park site. When this is combined with the SA comments on the landscape in the north west of the site summarised in paragraph 4.6 above, very little land remains which may be suitable for development. The 35% figure of the total site at Shenley Park will be further reduced.
4.14 In the next paragraph of the 2016 SA it states:
'Sustainable transport servicing WHA001 is lacking. There are no train stations within 1km and the bus service that runs through the village is infrequent, running on a Wednesday only. As such, accessibility to and from Whaddon by public transport is limited and residents are likely to rely on travel by car, thus increasing the carbon footprint of the area (SA Objectives 4 and 9).'.
4.15 This highlights the fact that the site is too far from the East-West rail line and even further from any rail station. As the Inspector makes reference to the Oxford to Cambridge Arc in paragraphs 5 to 9 in the document ED166 Interim Findings 29 August 2018, it is important to provide an update regarding the current circumstances of this corridor or arc.
4.16 On 18th September 2019 AVDC resolved to object to the Oxford to Cambridge Expressway and this decision has been incorporated into the Main Modification 210 which revises Policy T3 to delete the reference to this proposed road.
4.17 The proposed Oxford to Cambridge Expressway will be reviewed should the Conservative Party form the next Government, following the previous announcement by the Rt Hon Grant Shapps (Secretary of State for Transport) on 21st November 2019. This means that the rail improvements are considered the more likely at this point in time and the findings made in August 2018 may require review dependent upon the outcome of the General Election. Irrespective of any decision about major transport improvements the main transport connections for Shenley Park, Salden Chase and Eaton Leys should be with Milton Keynes and as will be explained later Eaton Leys is clearly the more suitable location when this factor is considered.
4.18 All of this must be reviewed by the Inspector because this is a significant change since he wrote his Interim Findings. The strategic transport situation is far less clear now than when the Findings were published and given the ADVC decision to oppose the Expressway this throws even more uncertainty into the case for proposing Shenley Park because of the transport impacts.

Related Evidence
4.19 As the 2016 SA explains there are biodiversity issues with the Shenley Park proposal and the evidence contained in the Eco Headlines documents (refs ED205F Shenley Park, ED205D Salden Chase Extension and ED205B Eaton Leys) indicates that of the three strategic sites only Shenley Park has a range of Priority Habitats identified: Deciduous woodland, lowland meadows, Traditional orchard wood, pasture and parkland BAP. By contrast, Salden Chase under this heading lies adjacent to some priority habitats and Eaton Leys has only lowland meadows and Deciduous woodland. This indicates that Eaton Leys is the more suitable location for development.
4.20 The whole of the Shenley Park area is contained within the Whaddon Chase Biodiversity Opportunity Area (see Plan 1). Whilst this is defined as a regional priority area for the restoration and creation of Biodiversity Action Plan (BAP) habitats, it is not an area of constraint. However, it is a significant planning consideration.
4.21 The Housing and Employment Land Availability Assessment (HELAA) May 2019 update, which is document ED 208 in the Examination Library, mentioned at paragraph 4.9 above, the three potential strategic sites adjacent to Milton Keynes are referenced. For Eaton Leys (site GRB002) the HELAA claims it is unsuitable because of the 'harmful landscape and visual impact' and also the settlement pattern on this side of Bletchley. The HELAA continues to mention the fact that planning permission had been granted by MKC and explains this is a change to the original HELAA in regard to the built development to the north, but it then concludes for landscape reasons there should be no change.
4.22 This ignores the AVDC document ED 210A, evidence contained in the Landscape and Visual Capacity Comparison Assessment by BMD dated 11th June 2019. In paragraph 3.1.8 of that document it states about Eaton Leys: 'the existing green edge of Waterhall Park, to the west, and MK housing allocation to the north, result in the site being partial contained from the wider landscape'.
4.23 This point is reinforced in the June 2017 Development Control Committee report by MKC on the planning application 15/01533/OUTEIS for Eaton Leys. The report makes clear in 5.57 that 'the LCA that 'the site' forms part of does provide a visually important setting'. In paragraph 5.59 of the Committee report further states: 'The Milton Keynes Landscape Character Assessment (2015) identified the presence of the A5 within this setting as detracting from the area; the application would provide an opportunity to mitigate the impact of the road through the improvements scheme. Milton Keynes Council would welcome further involvements in these works to ensure earthworks are designed and planted to effectively screen residential properties and the road'.
4.24 This development to the north is introducing an urban context to the area but the clear defensible boundaries of the A5 and the A4146 provide an obvious opportunity to deliver further improvements to mitigate the impact of both roads on the wider landscape setting.
4.25 The Eaton Leys site in AVDC is enclosed by these two major roads to the east and south together with the canal corridor to the west and the new housing under construction to the north. It can offer significant mitigation on the same principle as the planning permission to the north and consequently enhance and protect the wider landscape setting to the east and south beyond the A5 and A4146. The land is contained from the wider landscape as confirmed and explained in the AVDC'S own evidence in document ED210A.
4.26 Shenley Park has no such defensible boundaries, other than the very clear and well-established existing boundary with Milton Keynes which will be destroyed should the proposal be confirmed. Shenley Park and has a landscape setting which is as important if not more important than Eaton Leys given the heritage, bio-diversity and ecological values mentioned above. The Strategic Landscape and Visual Capacity Study August 2017, ENV04 in Appendix A describes Shenley Park LCA condition as 'very good', which in that part of the table equates to Mentmore Ridge. Salden Chase is described as 'moderate' and there is no reference to the Eaton Leys site.
4.27 One of the most important factors in the selection of another strategic site recognised by the AVDC evidence is the issue of transport.
4.28 MKC responded to the July 2016 VALP and stressed the need to co-ordinate the Plan. It referred to the Bucks and River Ouzel Internal Drainage Board's call for coordination. The MKC response also called for AVDC to assess the impacts and mitigation for Milton Keynes and raised the traffic impacts as particularly concerning. Highway concerns were raised in many responses to the July 2016 consultation.
4.29 In the SA from July 2016 paragraph 3.15.8 states that the A421 is a key road in the strategic highway network defined in the Bucks Local Transport Plan 2011-2016. Later in that SA at paragraph 3.42.7 is clearly states: 'Sustainable transport serving WHA001 is lacking'. However, in the October 2019 SA Addendum there is a sudden change on page 5 of that report. Nevertheless, in Table 7.1 Eaton Leys scores the highest in transport terms ahead of Shenley Park and Salden Chase.
4.30 The 2019 SA Addendum continues to highlight transport concerns and greenhouse gas emissions for the Shenley Park site at 9.4.1 and at 9.4.4 it refers to emissions from transport as a separate matter. Associated transport emissions are mentioned again at 9.11.1 where the report states: 'The allocation of WHA001 at the Milton Keynes edge will introduce new road users and associated transport emissions; however, there are no AQMAs in Milton Keynes, nor at Buckingham or Winslow. Site specific policy notably requires that: "An air quality and noise assessment shall be submitted to and approved in writing by the Council prior to development commencing."
4.31 In the preparation of the Plan MK by MKC transport modelling of the A421 and the whole MK road network was undertaken. This work is independent of the Buckinghamshire modelling. The report: Milton Keynes Multi-Modal Model Update November 2017 (produced by AECOM), confirms at paragraph 1.6.9 that the A421 junctions are more overloaded at the 2016 reference case. The situation is forecast to become more severe as illustrated in the figure 33 in that report which shows the growth in delays for the 2031 reference case junction delay (MK wider area).
4.32 In the AVDC document ED 214C page 50-100, Jacobs in section 6.2, table 6.4 identifies Eaton Leys with three green ratings which means the transport impacts from this site are slight. Shenley Park however has three amber ratings which are described as moderate impacts on transport.
4.33 When the Buckinghamshire modelling is taken into account the Eaton Leys site is most suitable to allocate. If the MKC data is added then the case is made significantly stronger for Eaton Leys.
4.34 Whilst there may not be Air Quality Monitoring in MKC, the junctions of the A421 are already experiencing serious peak time congestion and the length of delay is increasing meaning more vehicles will be standing with engines running and air pollution increasing. This affects a number or routes including the V1, and most of the east- west routes like the H6, especially in the morning rush hour.
4.35 One specific junction (of many) on the A421 in Milton Keynes, is with Watling Street. It has serious delays now. It is physically constrained by the A5 bridge and then the West Coast Mainline railway bridge, so it has limited scope for increased capacity. This suggests that people living close to this junction will see a worsening of their air quality in the immediate future. The addition of Salden Chase will make this more severe, but the Shenley Park proposal would add even more pressure and pollution onto these roads and junctions.
4.36 It is also important to recognise the significant open green space in the Kingsmead area adjacent to the proposed allocation. A new grid road here would introduce noise, disturbance, pollution and destroy this valuable visual and social amenity. In addition, wherever the link or links are planned they will 'punch through' the North Bucks Way and the bridleway to the south which has well-established belts of mature deciduous woodland. This long-distance path runs 34 miles from the Ridgeway at Chequers Nature Reserve to the county boundary at Pulpit Hill Nature Reserve. It links to the bridleway along the western boundary of Milton Keynes and these rights of way are an important amenity for people along the Milton Keynes boundary. It should not be surrounded by new development.
4.37 In the Viability Report (ED 216) the transport costs have been excluded and this is a fundamental omission. It means that the selection process of the strategic sites on the edge of Milton Keynes has not been fully addressed.
4.38 A final comment on the transport issues is that Shenley Park is a long way from the centre of Milton Keynes where the shopping and cultural facilities tend to congregate. Eaton Leys is closer and has the dual benefit of being much closer to Bletchley which requires more footfall to improve its town centre.
4.39 In previous Plans the emphasis has been on strategic extensions to the south east and south west of Milton Keynes. This was clear in the now revoked South East Plan and the accompanying Panel Report. The Salden Chase development accords with this regional strategy and Eaton Leys lies to the south east of Milton Keynes. Shenley Park is west of Milton Keynes and is not in accordance with this strategy although it is acknowledged it has been revoked.


5.0 Details of the site proposed and constraints

5.1 As explained above Shenley Park has a high quality of landscape being within the Whaddon Chase Biodiversity Opportunity Area and it has significant heritage and ecological qualities. The eastern boundary is an historic long-distance route now safeguarded as the North Bucks Way. It consists of hedgerows and trees and it clearly provides a defensible boundary in this part of the western edge of Milton Keynes.
5.2 Furthermore, the layout of open space roads and footpaths in Milton Keynes relates well to the open countryside beyond and provides valuable open space which has visual as well as physical and social benefits for the people who live here.
5.3 Within the site itself there are ancient woodlands, hedgerows and other remnants from the historic parkland. As the AVDC evidence shows the area of the site to the north west is highly sensitive because of the topography as well as the conservation importance of the nearby Whaddon village. Snelshall Priory earthworks lie just to the north of the site.
5.4 The southern part of the site has surface water flooding and there is a tributary to the Little Ousel which flows westwards. A well-established line of mature deciduous woodland runs along the southern boundary of the site with the A421.
5.5 There are several historic buildings within the site and Shenley Road runs through the site.
5.6 In addition, there is the Kingsbury to Buncefield Oil Pipeline (see Plan 2), which runs in a general north to south alignment on the east part of the Shenley Park site. It runs close to the North Bucks Way in the north east corner of the site and then follows the bridleway and right of way to the south before turning south - eastwards. Information provided from deeds and conveyance and supplemental deed documents shows parallel pipelines. Entry and use in exercise of the easements and rights granted by the Original Deed and the New Deed (can be supplied if required) provide for so much of the land as lies within a lateral distance of 3.048 metres (10 feet) from a point vertically above or below a part of the parallel pipe-lines or either of them and to obtain access to and egress from shall be agreed.
5.7 This adds a further constraint to the woodland and hedgerow belt which runs along the entire eastern boundary of the site,



6.0 Alternative approach and sites to assist the VALP in meeting its additional housing need

6.1 It has been made clear in the preceding paragraphs of this representation that despite AVDC claiming that there is little to choose between the three strategic sites on the edge of Milton Keynes which are being considered at this very late stage in the Plan preparation process, there is a clear justification for selecting Eaton Leys. This is based on transport, landscape, ecology and heritage grounds.
6.2 The fact that Salden Chase has a resolution to grant permission means that this has moved forward as a more realistic option. The fact that the northern part of Eaton Leys has permission and more importantly is under construction means that in planning terms this location has moved forward even further than Salden Chase. It is clear that the planning evidence points to Eaton Leys ahead of Shenley Park.
6.3 In the Inspector's Interim Findings dated 29th August 2018 he explained that he had sufficient concerns to recommend AVDC that the VALP required some further work before it could be found sound. This representation establishes that insufficient further work has been undertaken by AVDC.
6.4 Firstly, AVDC has not engaged with MKC and has failed to demonstrate that it has met the legal Duty to Co-operate in these Main Modifications.
6.5 Secondly AVDC has 'jumped' to allocate Shenley Park, and then retrospectively commissioned evidence to try and justify the decision to allocate it. It produced a set of Frequently Asked Questions in an attempt to assist people responding to the consultation. Unfortunately as inadequate as it is, it was unsupported by comprehensive information and was therefore somewhat misleading. A copy of this document is attached in Appendix 1 with notes highlighting the errors.
6.6 Thirdly, AVDC has published the main modifications without a full explanation about why a larger allocation or allocations were not investigated more fully in Buckingham to help deliver the Western By Pass. It has also failed to revisit any prospect of some development adjacent to Leighton Buzzard. They have also failed to fully address the Inspector's finding that there was a disproportionately small role of villages.
6.7 Notwithstanding the above comments, KRG strongly believe that the major change to the VALP at such a late stage in the process warrants a re-opening of the Examination hearings if the AVDC decides to disregard or challenge the matters raised in this representation.
6.8 Should the AVDC agree and delete the Shenley Park allocation and replace it with an allocation at Eaton Leys then the KRG would support the Plan. This will require more work but in the interests of fairness the hearings should be subject to a re-opened examination hearing in either scenario.










Appendix 1
Frequently Asked Questions AVDC (Nb. Impact P S Ltd comments in red font)
Vale of Aylesbury Local Plan(VALP) Proposed Allocation of Shenley Park
FAQs September 2019

These questions and answers are intended to clarify technical and procedural matters relating to the new proposed allocation at Shenley Park (WHA001), including information about how to make comments during the Main Modifications consultation that ends at 5.15pm on Tuesday 17 December 2019. This document should be read in conjunction with the other consultation material.
Why has this site been allocated at this stage?
The Inspector's Interim Findings (ED166) which were issued in August 2018 following the examination hearing sessions set out that a modification to the Plan was required to redress the balance of housing development across Aylesbury Vale by increasing allocations in close proximity to Milton Keynes. The Inspector's instruction in document The Inspector also finds the lack of allocation adjacent to Leighton Buzzard 'remarkable'.
ED181 Inspector's reply to AVDC's response to his Discussion Document D5 (4 March 2019), which we have no option to ignore or disagree with, said that the increased growth being met entirely by an allocation in the Milton Keynes area "would adequately address the specific recommendation of paragraph 37 of my Interim Findings". The choice of the site to be allocated was left to the council's discretion.
What sites did the council consider?
The housing requirement was also revised following comments from the Inspector. A significant factor leading the Inspector to propose this is the Oxford Cambridge arc with the new rail link and the Expressway. The Expressway remains uncertain at the moment and there are more suitable sites which could be much closer to the rail and proposed road if it happens. This should be clarified when we then know the precise route, but as AVDC now oppose the Expressway and there have been calls for a review the future of this road is significantly less certain. This led to the need for a site for over 1100 houses to be found on the edge of Milton Keynes. Three sites were identified and examined in more detail:
* Shenley Park;
* Extension to the existing Salden Chase Allocation; and * Eaton Leys (area within Aylesbury Vale).
A site analysis was undertaken on the three alternative allocations during spring/summer 2019 and the evidence was published as examination documents in June and July 2019 https://www.aylesburyvaledc.gov.uk/examination-documents On the basis of the evidence, AVDC concluded despite their own evidence which raised concerns (transport, landscape and biodiversity, heritage & the SA) about the site.it was concluded that, on balance, Shenley Park was the preferred site.
Did this site feature in any earlier versions of the Plan?
Shenley Park has figured in previous versions of the VALP. In October 2015, the VALP Issues and Options consultation identified nine alternative development scenarios, of which five related to an extension to Milton Keynes/Bletchley but these did not identify sites. In July 2016 the Draft VALP included potential housing allocations at Salden Chase and Shenley Park with a specific consultation event being held in Whaddon. Shenley Park was then removed from the Submission Plan.
Following debate of the site at the Examination hearings, the publication of the Interim Findings and initial preparation of the Proposed Modifications, the council then held a briefing for parish and town councils in July 2019.
Outside of the VALP Milton Keynes Council, as part of the preparation of Plan MK, consulted on Strategic Development Directions (SDD) in January 2016 which included "Direction of Growth 1 - Development to the west, south west and/or south east of the city". That document said:
"The growth envisaged in this direction takes the form of extensions to the existing urban area. This form of development has advantages in that it could be relatively straightforward to strengthen connections to the existing transport corridors and services within Milton Keynes whilst still being large enough to provide the additional facilities and infrastructure to meet the needs of residents."
A Plan MK consultation event about the SDDs was held in Whaddon on 23 March 2016 which an AVDC officer attended.
The MK Futures 2050 Commission Report This is not a statutory plan and should not carry weight. states that "we see some of the preferred locations for growth as beyond the boundaries of the Milton Keynes Council area in adjacent local authorities".

Is there a detailed concept plan for what the development will look like as there are for other sites in the plan?
No there isn't at this stage. Yes there is. AVDC do not do comprehensive research. There are two schemes prepared by Scott Brownrigg for Crest Nicholson in 2014 & 2016. There is no requirement for detailed concept plans of local plan allocations as they are strategic in nature. but they do assist in setting out the strategic issues and most importantly the ownership and control over the site.
A similar sized allocation at RAF Halton does not have a concept plan. Those sites with concept plans are those where planning consent has been granted or detailed plans have been submitted as part of a planning application. This site has not yet reached this stage.
The Shenley Park allocation should it progress requires the preparation of a Supplementary Planning Document which will include a concept/masterplan plan. Public consultation will be an integral part of the process of progressing Shenley Park, through both the production of the SPD and the planning application process.
What discussions have you had with Milton Keynes Council about this site?
We have talked to Milton Keynes Council. Discussions between AVDC and MKC officers took place following the publication of the Interim Findings and during the site analysis process. Meetings were held in December 2018, May 2019 and September 2019 and dialogue continues between officers what was the outcome, why were no councillors involved and where are the records of these meetings?
Milton Keynes Council is being formally consulted about the proposal as part of the Main Modifications consultation process. Milton Keynes Council has been kept informed throughout the preparation of VALP and they made representations about the Shenley Park site at the draft plan stage which raised concerns about traffic impacts, the need for mitigation of other impacts on MK & raised objection to the wording of the draft policy and disputed the Housing Market Areas.
Notably, MKC has consulted Duty to co-operate is not just consultation about the option of housing development within AVDC during the preparation of their Plan MK.
Why do you need so many houses?
As well as needing to satisfy a higher housing figure for the district that the Inspector has imposed, a major site at Buckingham which is shown as a reserve housing site in the 'made' Neighbourhood Plan. has been deleted because it is not deliverable and planning applications have been made for other site allocations with lower amounts of housing than the plan envisaged. We are also concentrating development on one site, rather than splitting provision over a number of sites, to ensure the delivery of infrastructure and community facilities.
What provision will be made for infrastructure and community facilities?
The VALP's overall approach to infrastructure is set out in Policy S5 (page 51 of the Proposed Submission VALP as proposed to be Modified). The specific policy for Shenley Park includes, amongst other requirements:
* the need to provide primary school education; a new local centre; contribution to health facilities;
* a new link road from the A421 through the site to connect into the existing MK grid road network;
* high quality walking and pedestrian links throughout the site also linking up to the existing networks and;
* contributions to the public transport network.
What control does AVDC have on the countryside/green buffer to Whaddon, how big that will be and what form it will take?
The policy for Shenley Park incudes criteria to conserve the setting of Whaddon village and Conservation Area by establishing a substantial and well designed countryside buffer. The buffer is within the site boundary shown on the policies map but more detail and the exact amount of land for the buffer will be determined in considering the Supplementary Planning Document (SPD) or in any future planning application.
Will this be part of Milton Keynes?
No, there are no plans to change the district boundary Not as simple.... should this go ahead it will need to be designed to the MK standards and integrate with the grid road system. This is one of the issues which is not straightforward and involves agreement between AVDC and MKC. This needs to be addressed and so far it has not been done.
Why can't you just put this housing somewhere else in the district?
The Inspector has been very clear that a new site must be identified in close proximity to Milton Keynes.
How can you go ahead with this consultation when there is a general election?
The decision to proceed with the consultation was taken before the election was announced so there is no legal justification to delay the consultation and the council is aiming to have an up to date, adopted local plan in place as soon as possible.
How can I see the documents if I have no access to the internet?
There are deposit locations at Westcroft Library, Wimborne Crescent, Westcroft; Bletchley Library, Westfield Road, Bletchley and 11 other deposit locations throughout Aylesbury Vale where paper copies of the main consultation material can be viewed. Whaddon Parish Council has been supplied with a printed copy of the Main Modifications and submission VALP as proposed to be modified which will be made available for inspection.
Where are the documents on the internet?
The Statement of Availability sets out the relevant consultation documents and where they can be accessed online (as well as providing details of the deposit point locations where all the documents can be seen). A USB stick containing the documentation is available if required.
There is so much information, how do I know what to look at?
In the Proposed Main Modifications document, Also highlight the SA of the Modifications. Most will not want to wade through this but it shows the other sites are as good and, in some cases, better than Shenley Park. the proposed allocation at Shenley Park can be found on pages 44 - 46. The policy title is D-WHA001 Shenley Park and the modification reference is MM076. A location plan is also included in the Policies Maps at the back of the document (reference MM289) under the heading Northeast Aylesbury Vale.
In the Proposed Submission Plan as proposed to be modified, the Shenley Park allocation can be found on pages 133 - 135.
How can I comment if I can't access the internet? Can I just write in?
Yes, you can write in to Planning Policy, AVDC, The Gateway, Gatehouse Road, Aylesbury, HP19 8FF. You do not need to use the representation form, a letter will do. However you must give us your name, address and email (if you have one) so we can contact you if necessary. Without these details, we can't accept a representation. Where possible your representation should state whether you support or object to the modifications and if and how the plan should be changed.
Can you accept my comments if I just add my name to a list or petition?
We cannot accept a representation with just a name. As above, you must give us your name, address and email if you have one so we can contact you if necessary. Without these details we cannot accept a representation.
Can I just write in to say that I support the Parish Council's response
We need more information than this. If you wish to support the Parish Council's response, you would need to reproduce this in your comments so that we can be sure what your comment is. You can make additional comments if you wish.
Can residents in the Milton Keynes Council area make representations?
Yes - representations are not limited to residents of Aylesbury Vale.

Plan 1
Whaddon Chase Biodiversity Opportunity Area

Plan 2
Kingsbury to Buncefield Oil Pipeline

Object

VALP Main Modifications

Representation ID: 3112

Received: 17/12/2019

Respondent: Mr Graham Stewart

Legally compliant? No

Sound? No

Representation:

Shenley Park is an inappropriate site for inclusion within VALP, because the Sustainability Appraisal is unsound, and more thought needs to be given to both deliverability issues and the historical context of providing a permanent and defensible western edge/boundary to Milton Keynes, which would protect the historically important countryside, biodiversity and highway/traffic concerns

Change suggested by respondent:

Shenley Park (WHA001) should be deleted from the VALP, and should be replaced with Eaton Leys, or a combination of Eaton Leys and other appropriate sites, such as an extension to Newton Leys.

Full text:

I have lived in Whaddon Village for 40 years, was born locally, and have worked and lived in and around Milton Keynes for my entire life. I consider that I know the area particularly well. I have read the full submission by Whaddon Parish Council and fully agree with all the points raised within it. I do not intend to repeat those arguments here, apart from one very important issue which appertains to the re-opening of the hearing sessions. It is essential for 'fairness' reasons that residents of Whaddon have the opportunity to express their concerns about the Shenley Park (WHA001) site and the Main Modification MM076, because it is clear to me and many others that the proper process has not been followed by our Local Authority - AVDC, and there are huge 'question marks' over the validity and accuracy of the AECOM Sustainability Appraisal, which although coming out 'just' in favour of Shenley Park fails to make a proper case of testing the three appraised sites against one another, and has a definite bias when it comes to favouring the Whaddon site. I hope the Inspector uses his discretion and reopens the Inquiry Hearing, and gives all parties plenty of notice so that they may prepare accordingly. This timetable should not be influenced by the imminent demise of AVDC, because the new single Unitary Authority for Bucks should be able to seamlessly continue the VALP progress.

This is a new point that I do not believe was adequately covered in the Whaddon Parish response, so I ask the Inspector to consider it :-

"Policy D2 Delivery site allocations in the rest of the district - should be amended to exclude the proposed allocation at Shenley Park (WHA001) and instead include land at Eaton Leys, if it is decided only one strategic site should replace Shenley Park. However, I believe that given the delays and uncertainty associated with the delivery of the Salden Chase allocation, and the possible slippage of the RAF Halton Camp site in delivery timescales, consideration should be given to the allocation of a combination of sites to deliver the c.1150 plus additional dwellings. For example this could include that part of Eaton Leys within the AVDC district and also land around Newton Leys (as opposed to Salden Chase), which I understand is available and has been promoted to AVDC during the VALP process. This would represent a simple and easy to achieve extension to a new and thriving Milton Keynes community that has brand new facilities such as a new primary school, bus services and community facilities. This site is also conveniently located at the head of the A4146 and Stoke Hammond bypass, meaning that the additional traffic generated by these new homes would not impact on the A421 which is the subject of so many well founded and accurate capacity and safety concerns. Such an approach reduces the risk of the strategic site not coming forward as soon as anticipated, spreads the risk and supports housing delivery. As mentioned earlier, I believe that the Sustainability Appraisal Addendum is already seriously flawed, but another failing is that it did not consider the reasonable alternative of meeting the housing numbers adjacent to Milton Keynes through a combination of sites rather than just relying on one strategic site."

This is the second point that I believe was not adequately covered in the Whaddon Parish response, and it relates, in my opinion, to the important point of 'consistency' within the planning process, which surely should not be overlooked or ignored, when considering previous studies by eminent companies, and those comments made by previous Inspectors, in relation to the landscape to the west of Milton keynes beyond the Shenley Ridge and the continuation thereof being the long distance bridleway (North Bucks Way or Milton Keynes Boundary Walk). In essence, this established edge to Milton Keynes has been recognised over many, many years as being worth protecting, and until such time as this well-founded principle has to be broken (and that time has not yet come), it is much more sensible, and good planning logic to identify less sensitive sites that will not have such a damaging impact on the landscape, biodiversity opportunities and those communities living in the areas to the west of Milton Keynes.

I do not believe that this Public Consultation period is the appropriate time or place to spread 50 years of planning and landscape decisions and opinions before you, as you have much else to consider. However, if you would be prepared to, at least inspect and take account of these 'previous opinions' at a further hearing - in order that you may better understand the original 'setting up' and 'growth pattern' of Milton Keynes, and thereafter consider the shared views of your predecessors (when they have had to reach similar difficult expansion decisions), then these can be prepared and submitted at that time. Such background documents were submitted during the September 2003 'A Ridge too Far' campaign during an earlier Milton Keynes Local Plan Inquiry, where a large strategic site within Milton Keynes, on the opposite side of Whaddon Village was contested on similar grounds. On that occasion the landscape and traffic arguments submitted by the village were upheld and the village preserved that part of the historic Whaddon Chase. The documents, if allowed, would include pertinent extracts and comments from, amongst others :-

1966 - In the 'report of the Inquiry' into 'The Draft of the North Buckinghamshire New Town', recommendations of Inspector Mr. G C Godber CBE.

1967 - Ministry of Housing and Local Government, Mr. J. Palmer (Assistant Secretary), when confirming the New Town Designation Order.

1992 - M.K. Expansion Study. The Llewelyn-Davies report, commissioned by MKC.

1994 - PPG - Planning and the Historical Environment (addendum 8)

1998 - The later Update of the 1992 M.K. Expansion Study .... Which follows the general theme throughout and excluded the further expansion west beyond the North Bucks Way, as this would encroach into the very high quality landscape containing extensive and attractive views and destroy the historic nature of the area.

2002 - Public Inquiry into Objections to the Deposit Draft of the Aylesbury Vale District Plan : Inspectors report Part 2. By, Peter Beasley Dip TP. Dip ld. MRTPI, Inspector.

2004 - Milton Keynes Local Plan Inquiry, Interim (Part 1) Report by, Keith Holland, Inspector

Thank you for considering these points.

Object

VALP Main Modifications

Representation ID: 3115

Received: 17/12/2019

Respondent: Mrs Naomi Artus

Legally compliant? No

Sound? No

Representation:

I object on the basis the plan is:
- Not legally compliant
- Not sound
- Not positively prepared, consistent, justified or consistent with National Policy.
- Insufficient opportunities have been given for debate on the impact given the timing of these
modifications.
- There has been insufficient discussion with Milton Keynes Council and so AVDC has failed to
fulfil its 'Duty to Co-operate'.
- The proposed development would have significantly detrimental impacts on traffic, local
infrastructure, boundaries and the environment.
- Inadequate support and plans have been provided e.g. no Concept Plan or Illustrative Layout
has been provided.

Change suggested by respondent:

Policy MM076 needs to be deleted from the VALP before adoption of the VALP occurs. Alternative
sites such as 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 town's sustainability and
economy rather than that of Milton Keynes.

Full text:

I believe the local plan, particularly in respect of the proposed Shenley Park development, is not legally
compliant for a number of reasons.
1) The proposed Shenley Park development was not included in the November 2017 Proposed
Submission version of the Vale of Aylesbury Local Plan, so local and impacted councils and
residents such as Whaddon Parish Council and Nash Parish Council have not been given an
opportunity to properly take part in appropriate discussions around AVDC's decision to choose
Shenley Park over the two alternative sites of Eaton Leys and Salden Chase, nor has there been
the opportunity to question AVDC on this decision. This breaches NPPF paragraphs 158 and 182
and especially 155.
As the Shenley Park proposal was introduced so late, it is completely unfair and unjust not to
allow detailed and proper comparison testing between the proposed Shenley Park, Eaton Leys
and Salden Chase sites. It is important to reopen a further hearing session at the end of this
consultation period so that this can be rectified. The final plan would be unsound and possibly
unlawful if there is no opportunity afforded for proper scrutiny and justification of AVDC's
preferred choice of Shenley Park.
It is crucial that local residents such as those in Whaddon and Nash be given the opportunity to
voice their views of the impact this extremely large development will have on their lives e.g. the
impact on road safety, environment, and general well-being. The current consultation is not
sufficient and comes too late in the process to be acceptable.
2) It is a government requirement that Authorities have a 'Duty to Co-operate' when considering
significant, strategic cross-boundary housing allocations. This duty cannot be corrected and fulfilled
during a public consultation period, so failure to do so at a much earlier stage can lead the Inspector
to recommend a non-adoption report. This is contrary to PPG paragraph 3-008 (2014 version).
AVDC have failed to fulfil this duty as they have notified Milton Keynes Council of their plans, but
there has not been adequate discussion and co-operation. This is partly evidenced by Milton Keynes
Council's discussion of this issue at Full Council on 23 October, where members across all parties
agreed that a failure of co-operation had occurred and community engagement had been minimal.
Non-compliance on this important issue is extremely concerning, particularly as Milton Keynes
Council have developed and adopted a Local Plan with meaningful policies. Milton Keynes Council
should have contributed to the process of deciding the most appropriate and sustainable site. The
lack of co-operation and engagement between the councils therefore renders the Shenley Park
proposal part of the plan unsound. It is therefore necessary to re-open the hearing sessions to
ascertain why ADVC chose not to co-operate and engage adequately with Milton Keynes Council
and other impacted parties, such as Whaddon Parish Council, and residents.
Significant Concerns
In addition to the above comments with respect to the legality of the local plan, I have significant
concerns as to the impact and viability of the Shenley Park proposal.
- I believe there has not been sufficient consideration given to the impact on the local transport
infrastructure. There have been no answers given by AVDC in respect of how the local transport
infrastructure and particularly the roads will cope with the increase in vehicles as a result of the
development. AVDC say there is potential for a new grid road but no details or plans have been
provided as to what this would entail. Whaddon in particular has already experienced a significant
increase in traffic numbers each year and a development on the scale of the Shenley Park
development would increase this further drastically, having an extremely detrimental impact on
the road safety, noise and the immediate environment of the area. A particular concern would be
that one of the main impacted roads has a school and playgroup on it. The A421 is already
extremely busy and it is very likely that Whaddon and the surrounding areas would become a
much more used rat-run by drivers seeking to avoid the congestion on the A421. Also, there is no
evidence that any new access to the A421 would be created, particularly given Milton Keynes
Council have recently refused planning consent for access from other proposed developments to
the A421 on the grounds that there was 'insufficient evidence to mitigate traffic'. There are
extremely important questions that need to be answered by AVDC and Milton Keynes Council in
respect of traffic, particularly given the impact on local residents, and these need to have been
addressed much earlier, making the plan very unsound.
- No 'Concept Plan' or 'Illustrative Layout' as been provided. Given the scale of the development
this is an extremely important and necessary piece of documentation that should have been
prepared. If no detailed plans are drawn up until the later Detailed and Supplemental Planning
stages when there would be further consultation, this would be too late to allow proper informed
analysis and debate by affected parties given the site would already have been confirmed in the
Local Plan.
- The change in wording regarding housing numbers from the originally drafted AVDC Main
Modifications wording of 'up to 1,150 new houses' to the wording in the revised wording of 'at
least 1,150 new homes' has a huge effect on the impact on local residents of the proposed new
development given there would be space to potentially provide up to 2,000 new houses. Thus it is
even more important that adequate opportunity to discuss and debate the proposal is given.
- The proposed development would have a severely detrimental impact on the local environment
and landscape. The AECOM Sustainability Appraisal mentions several times within it that "...a
new strategic site at Shenley Park gives rise to certain tensions in respect of the landscape
objectives....these matters will be addressed at the detailed planning stage". However, at such
point that these tensions are addressed it will be after the site is allocated in the Plan and may
well be too late to remedy. A key point is also that the Sustainability Appraisal also says 'Perhaps
more likely is that significant development would be contrary to a Biodiversity Opportunity Area
and Bucks Green Infrastructure Plan objectives'. Also, a new road access into Shenley Park
would have to cut across the important North Bucks Way. The North Bucks Way is a clear
western boundary to the existing suburban area of Milton Keynes. It is an old established
landscaped barrier and an existing habitat and wildlife corridor. A road access across this would
unnecessarily harm attractive and unspoilt countryside, and notably virgin land. The current clear
defensible land boundary provided by the North Bucks Way would be broken down, with no
further clear boundary in place to the west of this, thus providing significant opportunities for
developers to cause further damage to the existing landscape, environment and wildlife.

Object

VALP Main Modifications

Representation ID: 3118

Received: 17/12/2019

Respondent: Mr Tim Welch

Legally compliant? Yes

Sound? No

Representation:

Given the existing pressure on local transport and social infrastructure I am concerned that Shenley Park would put extra load on nearby public services. Already stretched capacity at local GP and hospital health care services are significant concerns.
However transport is another concern. It is especially irrational to fail to replace policy RA.35 of the District Local Plan in the VALP and then put extra pressure on the rural roads that are the rat run between the A421 at Bottledump Roundabout and the A4146 at Newton Leys. A suitable replacement policy for RA.35 is essential particularly if Shenley Park proceeds.

Change suggested by respondent:

Greater commitment to strengthening existing infrastucture before laying more pressure on top is needed.

Full text:

Given the existing pressure on local transport and social infrastructure I am concerned that Shenley Park would put extra load on nearby public services. Already stretched capacity at local GP and hospital health care services are significant concerns.
However transport is another concern. It is especially irrational to fail to replace policy RA.35 of the District Local Plan in the VALP and then put extra pressure on the rural roads that are the rat run between the A421 at Bottledump Roundabout and the A4146 at Newton Leys. A suitable replacement policy for RA.35 is essential particularly if Shenley Park proceeds.

Object

VALP Main Modifications

Representation ID: 3121

Received: 17/12/2019

Respondent: Mr Andrew Bennett

Legally compliant? No

Sound? No

Representation:

Shenley Park Whaddon (SP) was not included in the November 2017 version of the VALP. SP
has been put into the plan late without proper consultation which is unfair and unjust which
could result in an unsound plan and possibly unlawful.
* There has been no Duty of Co-Operation with the adjoining authority.
* Inadequate thought has been giver to traffic congestion within the local area.
* Little prevision for education of upper school student or doctor's surgery.
* Why build on Shenley park when Eaton Leys is ready to go

Full text:

The Shenley Park Whaddon (SP) was not included in the November 2017 version of the Vale of
Aylesbury Local Plan (VALP) and as such this has denied us the opportunity to properly debate and
cross examine the decision of AVDC's to choose SP over the other two competing sites of Eaton
Leys (EL) and Salden Chase (SC). This is in breach of NPPF paras 158, 182 and 155.
The SP is a late introduction to the AVLP and as such I strongly encourage that you reopen a further
hearing session at the end of the consultation period so that this crucial omission can be rectified.
This is not only unfair but unjust that we have not been allowed to have a proper comparison testing
between the three sites.
To accept AVDC's preferred choice of Shenley Park without proper justification would render the final
plan unsound and possibly unlawful.
As a resident of Whaddon I should have the opportunity to inform the inspector as to the impact of
such a large development would have on our environment, lives and health, road safety and
wellbeing. This site was in the original plan but was the removed and this consultation is too little, too
late.
* Before such development can occur, the Government requires that the adjoining authorities have a
"Duty of Co-Operation" when considering significant cross boundary housing allocations. At a Milton
Keynes full council meeting on the 23 October members across all parties agreed that a failure of cooperation
has occurred, and that community engagement had been minimal. Non-compliance with
such an important issue, especially when MKC have an adopted Local Plan with meaningful policies,
is very concerning. This lack of engagement renders this part of the plan 'unsound' hence further
reason to re-open the hearing sessions to ascertain exactly why AVDC chose not to cooperate and
engage more fully with MKC - and indeed Whaddon Parish Council, and residents.
* If houses were built an SP has there been sufficient consideration to how the extra traffic would affect
the surrounding area and how road safety would be affected. As I understand it the Bedfordshire
county council (BCC) and MKC traffic modelling methods only apply to main roads, and they have not tested
the impact of the traffic from such a large number of new houses on the rural road network such as the
traffic through Whaddon. The A421 into Milton Keynes is already over loaded at peak times and
making this road a dual carriage way would only move the bottle necks to the next roundabout so not
improving the traffic flow.
* What consideration have been made for education and doctor's surgery. This development may be
able to support a primary school as shown on initial plans by Crest but where do all the upper school
student go to. There are no provisions made for a doctor's surgery.
* In summary it is illogical and completely unnecessary to expand the Milton Keynes City boundary into
Shenley Park at the current time. Why cross a strong defensible bridleway boundary such as the
heavily wooded/hedged North Bucks Way into beautiful and much valued open unspoilt countryside -
when there are two more appropriate, and easier to develop alternative sites available at Salden
Chase and particularly Eaton Leys. The Eaton Leys has planning history and is almost ready to go
giving delivery certainly within this local plan period.

Object

VALP Main Modifications

Representation ID: 3123

Received: 17/12/2019

Respondent: Mrs Ann Bennett

Legally compliant? No

Sound? No

Representation:

Shenley Park Whaddon (SP) was not included in the November 2017 version of the VALP. SP
has been put into the plan late without proper consultation which is unfair and unjust which
could result in an unsound plan and possibly unlawful.
* There has been no Duty of Co-Operation with the adjoining authority.
* Inadequate thought has been giver to traffic congestion within the local area.
* Little prevision for education of upper school student or doctor's surgery.
* Why build on Shenley park when Eaton Leys is ready to go.

Full text:

The Shenley Park Whaddon (SP) was not included in the November 2017 version of the Vale of
Aylesbury Local Plan (VALP) and as such this has denied us the opportunity to properly debate and
cross examine the decision of AVDC's to choose SP over the other two competing sites of Eaton
Leys (EL) and Salden Chase (SC). This is in breach of NPPF paras 158, 182 and 155.
The SP is a late introduction to the AVLP and as such I strongly encourage that you reopen a further
hearing session at the end of the consultation period so that this crucial omission can be rectified.
This is not only unfair but unjust that we have not been allowed to have a proper comparison testing
between the three sites.
To accept AVDC's preferred choice of Shenley Park without proper justification would render the final
plan unsound and possibly unlawful.
As a resident of Whaddon I should have the opportunity to inform the inspector as to the impact of
such a large development would have on our environment, lives and health, road safety and
wellbeing. This site was in the original plan but was the removed and this consultation is too little, too
late.
* Before such development can occur, the Government requires that the adjoining authorities have a
"Duty of Co-Operation" when considering significant cross boundary housing allocations. At a Milton
Keynes full council meeting on the 23 October members across all parties agreed that a failure of cooperation
has occurred, and that community engagement had been minimal. Non-compliance with
such an important issue, especially when MKC have an adopted Local Plan with meaningful policies,
is very concerning. This lack of engagement renders this part of the plan 'unsound' hence further
reason to re-open the hearing sessions to ascertain exactly why AVDC chose not to cooperate and
engage more fully with MKC - and indeed Whaddon Parish Council, and residents.
* If houses were built an SP has there been sufficient consideration to how the extra traffic would affect
the surrounding area and how road safety would be affected. As I understand it the Bedfordshire
county council (BCC) and MKC traffic modelling methods only apply to main roads, and they have not tested
the impact of the traffic from such a large number of new houses on the rural road network such as the
traffic through Whaddon. The A421 into Milton Keynes is already over loaded at peak times and
making this road a dual carriage way would only move the bottle necks to the next roundabout so not
improving the traffic flow.
* What consideration have been made for education and doctor's surgery. This development may be
able to support a primary school as shown on initial plans by Crest but where do all the upper school
student go to. There are no provisions made for a doctor's surgery.
* In summary it is illogical and completely unnecessary to expand the Milton Keynes City boundary into
Shenley Park at the current time. Why cross a strong defensible bridleway boundary such as the
heavily wooded/hedged North Bucks Way into beautiful and much valued open unspoilt countryside -
when there are two more appropriate, and easier to develop alternative sites available at Salden
Chase and particularly Eaton Leys. The Eaton Leys has planning history and is almost ready to go
giving delivery certainly within this local plan period.

Object

VALP Main Modifications

Representation ID: 3143

Received: 19/12/2019

Respondent: Mr Robert Barnes

Legally compliant? No

Sound? No

Representation:

Denied opportunity to debate allocation at Shenley park; significant increase in traffic and accident danger; develop Eaton Leys

Full text:

Shenley Park was not included in the Nov17 Proposed Submission and we have been denied the opportunity to debate and cross examine AVDC decision. The road structure in and around Whaddon are becoming dangerous and it's only a matter of time before a serious accident happens. The new housing development will multiply the risk of this happening ten fold.
Surely developing Eaton Leys would be a far better site as it would support Bletchley and Fenny Stratford which is badly needed.

Object

VALP Main Modifications

Representation ID: 3145

Received: 19/12/2019

Respondent: Mr David Froggatt

Legally compliant? No

Sound? No

Representation:

Shenley Park, Whaddon (SP) was not included in the 2017 proposed submission version of VALP,so Whaddon PC and residents have been completely denied the opportunity to properly debate and cross examine AVDC's decision to choose SP over the other two competing sites. It is completely unfair and unjust not to allow detailed and proper comparison testing between the three competing sites. Government requires that adjoining authorities have a "duty to co -operate when considering significant strategic cross-boundary housing allocations. AVDC have paid lip-service to this, but have not addressed this through effective discussion or proper joint working,

Change suggested by respondent:

It is illegal and completely unnecessary to expand the MK city boundary into Shenley Park. Why cross a strong defensible bridleway boundary and much valued open unspoilt countryside, when there are two more appropriate, and easier to develop, alternative sites available at Salden Chase and particularly Eaton Leys.

Full text:

Shenley Park, Whaddon (SP) was not included in the 2017 proposed submission version of VALP,so Whaddon PC and residents have been completely denied the opportunity to properly debate and cross examine AVDC's decision to choose SP over the other two competing sites during the public learning sessions held by the inspector on July 2018. Because of the very late introduction of SP the inspectors must be strongly encouraged to open a further hearing session at the end of the public consultation period, so that this critical omission can be rectified. It is completely unfair and unjust not to allow detailed and proper comparison testing between the three competing sites.
Whaddon residents must be given the opportunity to inform the inspectors of the impact such a large development will have on their environment, lives and health, road safety and general well-being of particular concern is the expected substantial increase in traffic bringing with it additional pollution and noise, within the village of Whaddon and surrounding country roads. The A421 is already a bottleneck and the delays and pollution will be made much worse by adding this many vehicles to it. Very surprisingly, the SA does not mention the SA does not mention the important North Bucks Way at all, but a new road access into SP must out across this natural boundary that currently forms a strong definable western edge to the existing built-up area of MK. Its importance as an old established landscaped barrier and existing habitat and wildlife corridor is overlooked Cutting through this ancient corridor by one if not two, grid road extensions will unnecessarily harm attractive and as yet unspoilt countryside. "Virgin" land which does not enjoy any further outer boundary that could be described as a similar long-term and defensible boundary. en the three competing sites.
Government requires that adjoining authorities have a "duty to co -operate when considering significant strategic cross-boundary housing allocations. Such a duty cannot be rectified during a public consultation period. AVDC have paid lip-service to this, but they have not addressed this key strategic housing allocation through effective discussion or proper joint working, representing a significant failure of "duty tot co -operate" at an early stage. Shenley Park (SP) was not included in the 2017 proposed submission version of VALP, so Whaddon PC residents have been completely denied the opportunity to properly debate and cross-examine AVDC'S decision to choose SP over the two competing sites. Government requires that adjoining authorities have a duty to co-operate when considering significant cross-boundary housing allocations. AVDC have paid Lip Service, but have not addressed this through effective discussion or joint working. It is illegal and completely unnecessary to expand the MK city boundary into Shenley Park. Why cross a strong defensible bridleway boundary and much valued open unspoilt countryside, when there are two more appropriate, and easier to develop, alternative sites available at Salden Chase and particularly Eaton Leys.

Object

VALP Main Modifications

Representation ID: 3146

Received: 19/12/2019

Respondent: Mrs Dorothy Froggatt

Legally compliant? No

Sound? No

Representation:

Shenley Park (sp) was not included in the 2017 pro proposal and submission version of VALP, so Whaddon PC and residents have been completely denied the opportunity to properly debate and cross examine AVDC's decision to choose SP over the two competing sites. Government requires that adjoining authorities have audit to co-operate when considering sufficient strategic cross-boundary housing allocations. AVDC have paid lip-services to this, It is illogical and completely unnecessary to expand the MK city boundaries into Shenley Park. There are two more appropriate, and easier to develop alternative sites available at Salden Chase and particularly Eaton Leys.

Full text:

Shenley Park (sp) was not included in the 2017 pro proposal and submission version of VALP, so Whaddon PC and residents have been completely denied the opportunity to properly debate and cross examine AVDC's decision to choose SP over the two competing sites. It's unfair and unjust not to allow detailed comparison testing between the three competing sites. Government requires that adjoining authorities have audit to co-operate when considering sufficient strategic cross-boundary housing allocations. AVDC have paid lip-services to this, but have not addressed this through effective decisions or joint working. It is illogical and completely unnecessary to expand the MK city boundaries into Shenley Park. Why cross a strong definable bridleway boundary and much valued heavily wooded/hedged north Bucks way into beautiful and much valued open unspoilt countryside, when there are two more appropriate, and easier to develop alternative sites available at Salden Chase and particularly Eaton Leys.

Object

VALP Main Modifications

Representation ID: 3163

Received: 19/12/2019

Respondent: Mr Baird McClellann

Legally compliant? No

Sound? No

Representation:

The Shenley Park, Whaddon Site cannot and does not offer the opportunities available at the two alternative sites. The inherent constraints not least the known and unknown traffic implications and education issues, plus the inexplicable landscape and biodiversity concerns suggests that it is the least favourable of the sites when closely examined

Change suggested by respondent:

Based on the points raised and elements referred to in my case I would suggest that Eaton Leys be moved to preference 1 and Salden Chase be considered as 2nd choice, or reserve.

Full text:

Lack of opportunity to debate AVDC's decision set alongside the other 2 sites i.e. Eaton Leys and Salden Chase
Basis for request that the Inspector re-open a further hearing session
Duty to co-operate
Landscape and biodiversity, including ref to the North Bucks Way
Housing numbers and change of wording
concept plan
transport and highways with specific ref to Codimoor Lane, Shenley Road & the A421
Education a major concern especially Upper School provision
Employment
Funding/Monies
Not included in Nov. 2017 "Proposed Submission"-VALP
* We were denied the opportunity to debate & cross examine AVDC's decision to choose
Shenley Park over the other 2 sites (Eaton Leys and Salden Chase) This is in breach of NPPF
paragraphs 158 & 182 and especially 155
* The Inspector should reopen a further Hearing Session, it is Unfair if not and Unjust not to
allow comparison testing on all 3 sites.
* It is Unsound and possibly Unlawful to accept AVDC's preferred choice without proper
scrutiny & justification
* Whaddon residents must be given the opportunity to inform the Inspector of the impact of
such a large development on their lives, environment, education, health, road safety and
general well-being, etc.
* "Duty to co-operate" -see PPG paragraph 3-008 (2014 version)
* AVDC appears to be paying lip service to this advice and failed to comply
* MKC - 23rd October - members agreed that a failure of co-operation has occurred
* MKC- lack of engagement renders this part of the plan "Unsound" and this should lead
to the reopening of the Hearing session.
Landscape & Biodiversity
* North Bucks Way not mentioned and its protection
* Due consideration should be made to Public Open Space, Countryside and Natural
habitats
Housing Numbers
* A major change was introduced in the wording- in July "up to 1150"
* Revised version - now "at least 1150"
Transport, Traffic and Highways
* No answers to explain Bucks CC statement regarding addressing "rat-running'' through
Whaddon
* Devastating consequences for Whaddon Village- route past school and playgroup sites
* More HGVs - this issue has worsened year on year- to consider the impact on the village
as a result of the high number of proposed houses and facilities
* MKC - th November refused planning consent for the access into Salden Chase despite
knowledge of AVDC planning for 1855 houses to mitigate traffic- where is the cross
boundary discussion and cooperation?
Shenley Road uncertain-additional problems for traffic and access to Westcroft
and MK
* Coddimoor Lane - major issues with many accidents over the past few years and huge
impact on A421 roundabout already. Increased traffic will exacerbate these problems
and has treat implications that will impact on the School and Playgroup.
* A421 is already over capacity and causes concern
* Shenley Park provides no direct/ easy access to rail and major road links
All these points make the choice of Shenley Park "Unsound"
Education
* Shenley Park numbers would not enable provision for ALL age pupils i.e. Upper School,
although a 2 form entry primary school is on the plans. This is unacceptable, especially
when the alternative sites (Eaton Leys and Salden Chase) would be able to.
* These other two sites would not require pupils/ parents crossing a main road (A421) in
order to access the school, but movement/ walking within one site would be possible.
This surely is the approach to be strongly supported, especially with today's awareness
of the environmental problems and concerns.
* Numbers to justify a new Upper School would require building alongside the A421.
Would this mean an underpass, level crossing, over bridge? Has this situation even been
considered?
* Pollution and its effects is something to bear in mind when evidence shows the damage
this can do to people and the environment. There seems to be a lack of information/
planning to address this situation and the negative and damaging implications for the
Health and Safety of pupils and residents
* Local schools, including the selective Grammar School -Royal Latin School-Upper Schools
Employment
* Access to MK though Whaddon is of great concern. This cut- through will, as now,
become a favoured route plus the increase in traffic.
Funding / Monies
This appears to be under dispute between AVDC and MK for several aspects

Object

VALP Main Modifications

Representation ID: 3168

Received: 17/12/2019

Respondent: Mrs Zoe Ryder

Legally compliant? No

Sound? No

Representation:

The impact on Whaddon village has not been properly assessed, particularly in respect of traffic on the A421 and through the village. Infrastructure, Environmental and Landscape issues make the proposal unrealistic.

Change suggested by respondent:

Shenley Park should be removed and consideration given to other more suitable sites, possibly close to larger towns in AV with better infrastructure and positive economic advantage.

Full text:

The sudden, recent inclusion of Shenley Park in VALP is inexplicable, bearing in mind the obvious associated problems, particularly in regard to traffic. I was born and brought up in Whaddon, am a frequent visitor and still live in Aylesbury Vale so Iam constantly aware of the congestion problems both on the A421 and through the village (particularly at rush hours and school arrival/departure times, when there can be gridlock). Whaddon, is a historic village within conservation area and I am staggered at the environmental and hazardous impact this wiwilly-nilly, ill-considered plan proposes. Surely infrastructure issues should be clear be clear before lines are drawn on maps.