Aylesbury Vale Area

MM076

Showing comments and forms 61 to 90 of 100

Object

VALP Main Modifications

Representation ID: 3300

Received: 17/12/2019

Respondent: Ken Goodman M.B.E.

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

Transport needs for Shenley Park, Whaddon have not been properly considered.

Health Service provision, the extra strain on emergency services caused by new developments and the disposal of waste do not seem to have been properly considered.

All the burden will be placed on MK rather than Aylesbury Vale and thus expansion actually achieves diminished sustainability and a reduced quality of life for those in the north.

The expansion policy for Shenley Park refers to "at least 1,150" houses. This conceals the fact that the site promoters are pushing for 1,800 houses on the site.

No provision has been made for a secondary school in compliance with BCC policy.

The lack of co-operation by AVDC with MKC can be seen in the absence in AVDC policy to comply with the adopted policies in Plan:MK.

Full text:

I am writing to register my objections to the VALP Main Modifications which require further review. The letters 'MM' and numbers refer to the appropriate modifications. I believe the public examination (PE) should be re-opened for the following reasons.

Transport needs for Shenley Park, Whaddon have not been properly considered. The long traffic jams at rush-hour on inter alia the A421 prove the roads on the west of MK are already at capacity, and this is before the new builds at Tattenhoe Park and Kingsmead have been built. You must understand these traffic jams are only going to get longer. Traffic analysis must be done first, not as an afterthought. Infrastructure before expansion would be a sensible course of action. Unfortunately, it seems not be a consideration in this case and that must be addressed. (MM007, 010, 076)

The question of the necessary and significant uplift for Health Service provision, the extra strain on emergency services caused by new developments and the disposal of waste do not seem to have been properly considered. (MM007, 010,076) Coalescence has similarly not been correctly considered, and there is a very obvious double standard being applied between the protection of villages around Aylesbury and the lack of protection for villages around Milton Keynes. This protectionism appears to have been driven by politics rather than any other consideration and is manifestly unfair to those living in the north of Aylesbury Vale. Northern villages must be offered the same protection from coalescence as the south. (MM013, 014, 031)

AVDC seems to think that simply being close to Milton Keynes makes a development sustainable. That is not the case for the above reasons. All the burden will be placed on MK rather than Aylesbury Vale and thus expansion actually achieves diminished sustainability and a reduced quality of life for those in the north. This cannot be seen as progress. (MM070, 076)

The expansion policy for Shenley Park refers to "at least 1,150" houses. This conceals the fact that the site promoters are pushing for 1,800 houses on the site. This will further diminish sustainability and furthermore no provision has been made for a secondary school in compliance with BCC policy as is made clear in the Sustainability Appraisal Addendum. (MM076)

Further evidence of the lack of active and real co-operation by AVDC with MKC can be seen in the absence in AVDC policy to comply with the adopted policies in the adopted Plan:MK for such a proposed development. Further, the motions passed by the full council of Milton Keynes Council in relation to both Salden Chase and "Shenley Park" at Whaddon also raise serious questions over AVDC's real appetite, or otherwise, to comply with the 'Duty to Cooperate.' (MM072 to 076)

For all the above reasons I reconfirm my objection to the VALP Main Modifications in respect of Newton Longville and ask that the PE be reopened.

Object

VALP Main Modifications

Representation ID: 3326

Received: 17/12/2019

Respondent: David Massey

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

Transport needs for Shenley Park, Whaddon have not been properly considered.

Health Service provision and the increased strain on emergency services caused by new developments, have also not been properly considered.

The expansion policy for Shenley Park refers to "at least 1,150" houses. This conceals the fact that the site promoters are pushing for 1,800 houses on the site.

No provision has been made for a secondary school.

The lack of active and real co-operation by AVDC with MKC can be seen in the absence in AVDC policy to comply with the adopted policies in the adopted Plan:MK.

Full text:

I am writing to register my objections to the VALP Main Modifications which require further review.

The letters 'MM' and numbers refer to the appropriate modifications. I believe the public examination (PE) should be re-opened for the reasons set out below.

Transport needs for Shenley Park, Whaddon have not been properly considered. The roads on the west of MK are already very busy and there are regular jams at rush-hour on the A421. Increased building is likely to worsen this problem. Traffic analysis must be done as a priority before decisions are made. (MM007, 010, 076)

Health Service provision and the increased strain on emergency services caused by new developments, have also not been properly considered. (MM007, 010,076)

Coalescence has similarly not been properly considered, and there is a very obvious double standard being applied between the protection of villages around Aylesbury and the lack of protection for villages around Milton Keynes. This protectionism appears to have been driven by politics rather than any other consideration and is manifestly unfair to those living in the north of Aylesbury Vale. Northern villages must be offered the same protection from coalescence as the south. (MM013, 014, 031)

The expansion policy for Shenley Park refers to "at least 1,150" houses. This conceals the fact that the site promoters are pushing for 1,800 houses on the site. This will further diminish sustainability and furthermore no provision has been made for a secondary school in compliance with BCC policy as is made clear in the Sustainability Appraisal Addendum. (MM076).

Further evidence of the lack of active and real co-operation by AVDC with MKC can be seen in the absence in AVDC policy to comply with the adopted policies in the adopted Plan:MK for such a proposed development. Further, the motions passed by the full council of Milton Keynes Council in relation to both Salden Chase and "Shenley Park" at Whaddon also raise serious questions over AVDC's real appetite, or otherwise, to comply with the 'Duty to Cooperate.' (MM072 to 076)

For all the above reasons I reconfirm my objection to the VALP Main Modifications in respect of Newton Longville and ask that the PE be reopened.

Object

VALP Main Modifications

Representation ID: 3330

Received: 14/12/2019

Respondent: Mr James Lodge

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

The A421 and the roads in our village are already very congested and this is before the new houses at Tattenhoe Park and Kingsmead have been built. Traffic analysis needs to be done before more housing is allocated. Infrastructure should be placed prior to development.
Healthcare, waste disposal and emergency services are going to be stretched to breaking point.
MK will have to shoulder the burden rather than Aylesbury Vale
The site promoters are angling for 1,800 , 1,150 is dishonest
No provision has been made for a secondary school
Evidence of the absence of active and real co-operation by AVDC with MKC. (Officer summary)

Full text:

Dear Sir,
I would like to make my objections known and registered in respect to VALP Main Modifications, these need further review. Letters 'MM' and nos. refer to appropriate modifications.
It is my belief that the public examination should be reopened for the following reasons.

Volume of traffic caused by Shenley Park, Whaddon !! At rush hour the A421 is already very congested with long queues and this is before the new houses at Tattenhoe Park and Kingsmead have been built. The traffic jams will get worse. The roads west of MK simply cannot cope now, traffic analysis should be a priority BEFORE not after allocating more housing. This has not been the case. (MM007, 010,076)

Healthcare, waste disposal and emergency services are going to be stretched to breaking point but again this does not appear to have been taken into consideration. (MM007,010, 076)

I would feel more comfortable if infrastructure was placed prior to development.
The Roads in our village and about are overloaded I hate to think hoe our village roads will cope with the additional 2-3 thousand vehicles - I appreciate
AVDC feel the majority of traffic will use the 421 and away from our village but I assure you the vehicles that will pass into our village will be vast.
We are already a shortcut to the new M1 junction going south so our roads are full and larger HGV are destroying our paths and road surface.
Also whilst build is scheduled the increased HGV movements will be unacceptable.


MK will have to shoulder the burden rather than Aylesbury Vale actually reducing sustainability and quality of life due to ill conceived expansion.
This is not Progress. (MM070, 076)
With reference to numbers of houses at Shenley Park, the expansion policy refers to 'at least 1,150 houses'.
Why the dishonesty when it is known the site promoters are angling for 1,800 properties?? No provision has been made for a secondary school in compliance with BBC policy, and these additional 'secret houses' will further lessen sustainability, add to traffic chaos and adversely affect quality of life for people living in the area. (MM076)

Evidence of the absence of active and real co-operation by AVDC with MKC can be seen in the failure of AVDC policy to comply with the adopted policies in the adopted Plan:MK for such a proposed development. Additionally the motions passed by the full council of MK Council regarding both Salden Chase and Shenley Park makes one question whether AVDC has any intention of complying with the 'Duty to Cooperate'. (MM072 to 076)
I again therefore impress on you for the above reasons my objection to the VALP Main Modifications in respect of Newton Longville and request that the public examination be reopened.
Yours sincerely,

James Lodge

Object

VALP Main Modifications

Representation ID: 3332

Received: 16/12/2019

Respondent: J Brownrigg

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

The transport needs for Shenley Park, Whaddon in my opinion have not been properly considered. There also seems to be a double standard being applied between the protection of villages around Aylesbury and a lack of protection for those villages around Milton Keynes. Site location is not sutainable. No provision for secondary school. No cooperation between AVDC and MKC.

Full text:

Dear Sir/Madam
I would like to register my objections to the Main Modifications of the VALP. I feel they need further review and the MM letters and numbers refer to the particular modification.
The public examination should be reopened for the following reasons:-
The transport needs for Shenley Park, Whaddon in my opinion have not been properly considered. There are very long traffic jams at rush hour on the A421 near the bottledump rounderbout. This proves that the roads on the west side of Milton Keynes are already full to capacity. Any new builds at Tattenhoe Park and Kingsmead will only compound this. I believe traffic analysis should be done first. Infrastructure should always be done first to avoid future problems. Unfortunately it seems not to have been a consideration and must be addressed. (MM007, 010, 076)

There also seems to be a double standard being applied between the protection of villages around Aylesbury and a lack of protection for those villages around Milton Keynes. This seems to be driven by politics rather than any other consideration and is unfair to those of us living in the north of Aylesbury Vale. It is only fair that the villages to the north be offered the same protection as the south. (MM013, 014, 031)
It seems that AVDC think that being close to Milton Keynes makes a development sustainable. This is not the case for the above reasons. Milton Keynes rather than ADVC takes all the burden and therefore actually achieves diminished sustainability and quality of life. This does not seem like progress at all. (MM070, 076)
The Shenley Park expansion policy refers to at least 1,150 houses but it hides the fact that the site promoters want 1,800 houses on this site. This can only further diminish sustainability. Neither has any provision been made for a secondary school in compliance with BCC policy as is made very clear in the Sustainability Appraisal Addendum. (MM076)
The lack of real cooperation by AVDC with Milton Keynes Council can be further seen in the absence in ADVC's policy to comply with the adopted policies in the adopted Plan:MK for such a proposed development. More evidence in the motions passed by the full council of Milton Keynes in relation to both Salden Chase and Shenley Park at Whaddon also raise serious questions over ADVC's real appite to comply with the Duty to Cooperate. (MM072 to 076).
Because of the above reasons I object to the VALP Main Modifications in respect of Newton Longville and ask that the Public Examination be reopened.

Yours faithfully

Mrs J Brownrigg

Object

VALP Main Modifications

Representation ID: 3333

Received: 14/12/2019

Respondent: Mrs Jane Franks

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

Milton Keynes is set to expand according to its own plans and these do not include the VALP modifications.
Will Burden MK hospitals, health services, emergyencey services schools, waste disposal. Excisting services are at capacity.
The policy says 'at least 1,150 houses' - which is considerably different to the 1,800 houses that the site promoters talk about. Either is not sustainable.
Transport and traffic volume seem not to have been assessed at all. There is congestion and gridlock and no room for further traffic.
Coalescence with MK is another aspect which seems to have been given little thought. It seems that AVDC do not wish to co-operate with MKC by complying with the policies of Plan:MK. (officer summary)

Full text:

Dear Sir,

I am a resident of Newton Longville and I am writing to you in respect of the VALP Main Modifications, which do not seem to have been thought through very carefully and for that reason I ask that the Public Examination should be re-opened.

I would like to register my objections as follows ;

(MM 007 010 076 070)
Currently Milton Keynes is set to expand according to its own plans and these do not include the extra number of residents that the current VALP main modifications recommend.

The burden that so much building in the extreme north of AV will put upon MK hospitals and other health services, the emergency services, schools (there is no provision for a senior school to cater for what will likely be a young community), and waste disposal, is ridiculous. Our services in this area are already at full capacity. Further development on this scale will reduce the quality of life for those of us already living here, and will be unacceptably low for a new community moving in. (And whom will presumably be expecting a good standard of living in a newly built area).

There also seems to be a certain amount of mealy mouthed description of the extent of expansion. The policy for Shenley Park says 'at least 1,150 houses' - which is considerably different to to the 1,800 houses that the site promoters are talking about. Frankly either way it is too much to be sustainable anyway.

(MM 007010 076)
Transport and traffic volume seem not to have been assessed at all. Anyone living in this area who is obliged travel at rush hour will know that there are considerable tailbacks on the A421, and gridlock in other areas in the west side of MK. Villages on this side of the town are becoming rat-runs, and in some instances very dangerous - where rush hour traffic cuts through roads with no footpaths when trying to avoid the queues. And rushing. Current adopted and approved expansion is already going to push this problem to the limit and there is no room for further volume of traffic. Therefore this needs some proper in depth analysis by a credible independent and reliable third party before anything is decided. Which appears not to have happened yet.

(MM 072 through 076)
Coalescence with MK is another aspect which seems to have been given little thought. It seems that AVDC do not wish to co-operate with MKC by complying with the policies of Plan:MK. Nor do they seem to have the same consideration for residents here in the north of their own District as they do for those 'closer to home' in the south. Villages near Aylesbury are protected from coalescence with the town, whereas the suggested expansion close to our villages already in close proximity to MK are not being offered the same courtesy of protection. Should these proposed VALP expansions go ahead we will be exposed to 'filling in' in a very short time as the developers close in for the kill.

It seems that AVDC do not wish to fulfil the 'Duty to Co-operate'. They are intending to offload the problems of expansion onto those of us at the extreme edge of the district, and accept none of the responsibilities.

For these reasons I am objecting strongly to the VALP Main Modifications, and wish to be on the record, that there is a necessity for a further and more thorough review.

Yours faithfully

Mrs Jane Franks.

Object

VALP Main Modifications

Representation ID: 3334

Received: 08/01/2020

Respondent: Mrs & Mr Janet & C M Pickup

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

The transport needs for Shenley Park, Whaddon in my opinion have not been properly considered. There also seems to be a double standard being applied between the protection of villages around Aylesbury and a lack of protection for those villages around Milton Keynes. Site location is not sutainable. No provision for secondary school. No cooperation between AVDC and MKC.

Full text:

We are writing to register my objections to the VALP Main Modifications which in my opinion require further review. The letters 'MM' and numbers included in this letter refer to the appropriate modifications.
Having reviewed the information it is my belief that the public examination should be re-opened for the following reasons.
The transport requirements in relation to Shenley Park, Whaddon have not been properly considered. There are already long traffic jams at rush-hour on inter alia the A421 which prove the roads on the west of MK are already at capacity, and this is before the new builds at Tattenhoe Park and Kingsmead have been built. We are of the opinion that the traffic jams are only going to get longer and that a traffic analysis must be done first, not as an afterthought. This village already sees a constant flow of traffic during rush hours and that infrastructure before expansion would be a sensible course of action. Unfortunately, it seems not be a consideration in this case and that must be addressed. (MM007, 010, 076).
There is also the question of the necessary and significant uplift for Health Service provision, the extra strain on emergency services caused by new developments and the disposal of waste have not been properly considered. (MM007, 010,076).
We believe that coalescence has not been properly considered, and it would appear that there is a very obvious double standard being applied between the protection of villages around Aylesbury and the lack of protection for villages around Milton Keynes. This protectionism seems to have been driven by politics rather than any other consideration and is manifestly unfair to those living in the north of Aylesbury Vale. Northern villages must be offered the same protection from coalescence as the south. (MM013, 014, 031)
AVDC appears to think that simply being close to Milton Keynes makes a development sustainable. This is certainly not the case for the above reasons. Milton Keynes will have all the burden placed on them rather than Aylesbury Vale and therefore what expansion actually achieves is diminished sustainability and a reduced quality of life. This cannot be seen as progress. (MM070, 076).
The expansion policy for Shenley Park refers to "at least 1,150" houses. This hides the fact that the site promoters are pushing for 1,800 houses on the site. This will further diminish sustainability and in addition no provision has been made for a secondary school in compliance with BCC policy as is made clear in the Sustainability Appraisal Addendum. (MM076). Further evidence of the lack of active and real co-operation by AVDC with MKC can be seen in the absence in AVDC policy to comply with the adopted policies in the adopted Plan:MK for such a proposed development.
In addition, the motions passed by the full council of Milton Keynes Council in relation to both Salden Chase and "Shenley Park" at Whaddon also raise serious questions over AVDC's real appetite, or otherwise, to comply with the 'Duty to Cooperate.' (MM072 to 076).
For all the above reasons we reconfirm our objections to the VALP Main Modifications in respect of Newton Longville and ask that the Public Examination be reopened.

Object

VALP Main Modifications

Representation ID: 3353

Received: 17/12/2019

Respondent: North Bucks Parishes Planning Consortium

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

3 sites were initially under consideration. AVDC's proposed modifications registered on the website in July 2019. NBPPC notes that the evidence base at that time did not include those most important Assessments for Sustainability and Transport for any of the three sites. Should a decision only be made when all the necessary evidence is available. The inspector is urged to arrange a hearing sessions so this matter is properly aired in public. (officer summary)

Full text:

See attached document.

Attachments:

Object

VALP Main Modifications

Representation ID: 3357

Received: 15/12/2019

Respondent: Mr Peter Lemagnen

Legally compliant? No

Sound? No

Representation Summary:

Whaddon residents have been denied the opportunity to properly debate AVDC's
decision to choose SP over the other sites. It is completely UNFAIR and UNJUST not
to allow detailed and proper 'comparison testing' between the sites.
Authorities have a 'Duty to Co-operate' when considering significant cross-boundary
housing allocations; there has been a significant failing of 'Duty to Co-operate' at an
early stage. Community engagement has also been minimal.

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:

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 select 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 Salden Chase (SC). This is in breach of NPPF paragraphs 158
and 182, and especially 155.
● 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 and UNJUST not to allow detailed and proper 'comparison testing'
between the three competing sites.
● Simply to accept AVDC's 'preferred choice' of Shenley Park without proper scrutiny and justification will
render the final plan unsound, and possibly unlawful.
● 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 well-being 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).
● 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 nonadoption
report. This is contrary to PPG paragraph 3-008 (2014 version)
● 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 are the major town and Lead Authority, adjoining the three neighbouring and competing sites.
MKC discussed this issue at Full Council on 23 October 2019, and members across all parties agreed that
a failure of co-operation has occurred, and that community engagement has been minimal.
● Non-compliance with such an important issue, especially when MKC has 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.
HOUSING NUMBERS
● The originally drafted AVDC Main Modifications, first seen at the end of July, stated 'up to 1150 new
houses', but following discussion with the Inspector, the revised version states 'at least 1150 new homes'. A minor
change in writing, but with potentially devastating consequences bearing in mind that the promoted site may have
the capacity to provide up to 2000 houses...... and that is before the 'future development direction' arrows,
suggested by Crest Homes in May 2014 come into play!
TRANSPORT, TRAFFIC AND HIGHWAYS ISSUES
● Bucks CC has said "The advantage of the SP development is that it has the potential to provide a new grid
road which would address rat-running through Whaddon". When asked to explain "how?" AVDC had no plans or
answers, only to say that this will be resolved following further traffic investigations at the detailed planning stage!
Answers must be provided now before such a major site is confirmed in a Local Plan, 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.
● Through-traffic numbers and higher levels of HGVs have worsened year on year since MK began, despite
a traffic calming scheme costing approximately £110,000, being installed some six years ago. Since the MVAS
flashing speed signs were installed average weekday traffic levels (in both directions) have increased from about
2024 vehicles (December 2014 MVAS traffic data) to approximately 3098 (November 2019 data) ... or just over a
50% increase in just 5 years. Just imagine what impact a further minimum 3,000 new homes (say 4-5000 cars) at
Shenley Park (at least 1150 houses) and Salden Chase, Newton Longville (circa 1855 houses) will have?
● On 7 November 2019, MKC refused planning consent for the 'access' into Salden Chase off the A421, due
to 'insufficient evidence to mitigate traffic'. This was despite knowing that AVDC have granted planning (in
principle) for the 1855 houses, school etc. What does this say about 'cross boundary discussion?' The developers
must now appeal that decision, which could take six months or more - with no certainty of success. Where does
this leave VALP, if almost 1900 houses are suddenly lost?
● What is the future of Shenley Road, and will it be closed completely? If not, we can expect a longer and
much more tortuous journey to Morrisons through an even bigger housing estate ... and much higher levels of
traffic heading towards Stony Stratford, Wolverton and North MK. (Kiln Farm and Stacey Bushes industrial estates
etc.)?
● Alternatively, perhaps closing Shenley Road, making it 'cycles only', would mean Coddimoor Lane
becoming the only way into Whaddon from the A421? ...... but surely that would worsen by far the rat-running?
● Coddimoor Lane currently joins the A421 at a very busy roundabout. Traffic congestion into MK is a major
problem at peak travel times and during bad weather. Many accidents have occurred in this vicinity (both on the
A421 and along Coddimoor Lane) in recent years. The roundabout is already hard to access at peak times during
the day. Parents will find it increasingly difficult when delivering to, and collecting their children from the Primary
School and Playgroup.
● SP has no easy access to rail stations. Both MK and Bletchley stations would be 6km away.
● These are all hugely important questions to Whaddon residents, who have endured 30-plus years of 'year
on year' increases of traffic through two conservation areas, and past the village primary school and play group.
WPC believe these are critical questions that should have been addressed by both AVDC and MKC at an earlier
stage - but they have not. This makes the plan very 'unsound' especially as the two authorities use different traffic
modelling techniques - neither of which look at the impact of major growth on the surrounding rural road network.

Object

VALP Main Modifications

Representation ID: 3362

Received: 16/12/2019

Respondent: Mrs Justine Smith

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

There seems to absolutely no provision for any extra road
infrastructure. The main roads through Milton Keynes eg. the 421 are
already seriously congested at rush hour. Commuters take short cuts
through Newton Longville to the Stoke Hammond bypass and all day heavy
goods vehicles move through unsuitable village roads
Thus any future traffic from the proposed developments will
be funnelled through the Village.
pressure on the local health services, there seems to be absolutely no
regard taken to the future health needs of any more residents in the
area.

Full text:

With respect to the VALPED plans for North Bucks. As a resident of
Newton Longville, I am asking that the public examination should be
re-opened.

MM007.10,076

There seems to absolutely no provision for any extra road
infrastructure. The main roads through Milton Keynes eg. the 421 are
already seriously congested at rush hour. Commuters take short cuts
through Newton Longville to the Stoke Hammond bypass and all day heavy
goods vehicles move through unsuitable village roads, causing potholes
and making the roads generally more dangerous for pedestrians crossing.
The link from the Stoke Hammond bypass to the A421 seems to have been
forgotten. Thus any future traffic from the proposed developments will
be funnelled through the Village.

Having had the misfortune to spend some time in Milton Keynes Hospital
this year and having personal experience of the severe overcrowding and
pressure on the local health services, there seems to be absolutely no
regard taken to the future health needs of any more residents in the
area.

Object

VALP Main Modifications

Representation ID: 3365

Received: 08/01/2020

Respondent: Mr Andrew Devlin

Legally compliant? No

Sound? No

Representation Summary:

The Shenley Park location will place massive strain on the local roads/area, including having an
adverse affect on local amenities (doctors, school opportunities for families/ children already in the
area). AVDC haven't engaged the local community or MKC correctly to discuss the location and many
decisions to date seem in conflict with NPPF/ PPG paragaphs (specified in box 1). AVDC conduct to
date may render the plan unlawful. Choosing Shenley Park conflicts with local biodiversity
agreements, especially as it is in a BOA area. Eaton Leys is not in a BOA area and seems a more
suitable choice.

Change suggested by respondent:

The Shenley Park site cannot and does not offer the opportunities available at the two alternative
sites. The inherent constraints, not least the unknown traffic implications and inexplicable landscape
and biodiversity concerns, suggests that in fact it is the least favourable of the three sites when
closely examined. As a result I don't think there are any changes that could make the modification
work for the Shenley Park site. Bucks County Council, in response to an AVDC request, have stated
"The DS4 scenario - with Shenley Park removed and 1200 dwellings at Eaton Leys has the least
impact on the Buckinghamshire highway network". Eaton Leys is a more logical choice as an infill site
that would round off the eastern side of MK. There would be no encroachment into open countryside
beyond the A4146 Fenny Stratford bypass as all housing would lie within this area.
X

Full text:

We moved to Nash to have access to village schools for our children, with small classes so they would have more focused
teaching. These houses add huge risk to classroom size and greater competition for places in the school system - and other
local services in the area such as doctors - which carry a serious threat to our childrens' education and quality of life.
Additionally, Shenley Park Whaddon wasn't included in the Nov 2017 Proposed Submission version of the VALP so the local
parish council and residents have been denied any chance to debate and discuss AVDC's decision to choose this location over
the other options during the public hearing sessions in July 2018. This seems in breach of NPPF paragraphs 155, 158 and 182.
As a result of the late introduction of Shenley Park to the process the locals have been treated with disrespect and in an entirely
unfair manner. As a result the inspector must open a further hearing session at the end of the consultation period, so proper
comparison testing can be done across the different site options. To accept AVDC's 'preferred choice' of Shenley Park without
proper scrutiny and justification could render the plan unlawful. Local residents must be given the chance to inform the
Inspector of the impact such a development would have on our lives and the local environment, such as my above point about
my childrens' education.
Government requires that adjoining authorities have a duty to cooperate when considering housing allocation such as this. This
'duty' cannot be rectified during a public consultation period and failure to do so much earlier in the process can lead the
Inspector to recommend a non-adoption report. This is very much contrary to PPG paragraph 3-008 (2014 version). AVDC
seem to have paid lip service to this advice, indicating to MKC what they were doing but at no point have they addressed this
key strategic housing allocation through effective discussion or proper joint working, signalling a significant failure to meet the
definition of 'duty to cooperate' at an early stage. MKC discussed this issue at Full Council on 23 October and members across
all parties agreed that a failure of cooperation has occurred and that community engagement has been minimal. This is all very
concerning as MKC could and should have helped select the best, most sustainable site. As a result the plans should be
deemed 'unsound' to date and hearing sessions need to be re-opened to understand why AVDC chose not to cooperate with
MKC or the local community throughout the process.
The A421 is already an incredibly busy road which has frequent accidents on it and this number of houses will be completely
unsustainable for the area, causing a huge amount of extra traffic which will cause massive disruption and negatively impact to
the local area. AVDC have provided no plans or answers to solving traffic issues that have been raised to date. This plan is also
in conflict with the October 2019 Full Council cross-party agreement to 'ensure biodiversity and natural processes are at the top
of the agenda with ambitions to [make MK] the Greenest City in the World'. Crossing the important North Bucks Way wildlife
corridor into much valued countryside and natural habitats directly destroys such MKC ideals. The AECOM Sustainability
Appraisal also states 'significant development would be contrary to a Biodiversity Opportunity Area (BOA) and Bucks Green
Infrastructure Plan objectives' and the Eaton Leys alternative location option is not in a BOA area, while Shenley Park is.
Overall Shenley Park does not offer the same opportunities as the alternative sites, especially Eaton Leys.

Object

VALP Main Modifications

Representation ID: 3385

Received: 16/12/2019

Respondent: Shenley Church End Parish Council

Legally compliant? Not specified

Sound? Not specified

Representation Summary:


* Lack of consultation with areas of MK that will be affected.
* Conclusions from the Landscape and Visual Capacity Comparison Assessment suggests an alternative site (Newton Leys)
* The development will have a negative impact on residents in Oxley Park and Kingsmead
* No details have been provided to show how the Shenley Park site was chosen as the more viable option,
* concerning to note that there is no reference to any infrastructure costs within Milton Keynes
* Highway modelling does not satisfactorily represent the impact of the development on traffic flow into and around MK.
* Proposals for a link road should ensure that this is a grid road The proposals should also ensure that a 'Redway' is developed
* . Pupil demand form the development should be accommodated by onsite provision, or by provision elsewhere within Bucks
* The development will fall into Aylesbury Vale CCG which has no healthcare provision in the area.
* The naming of the development is also cause for concern.

Full text:

The Parish Council object to the proposal for the following reasons:
* Lack of consultation with areas of MK that will be affected. It is stated that a briefing was held for parish and town councils in July 2019. This parish council has no record of such an invitation
* Conclusions from the Landscape and Visual Capacity Comparison Assessment from June 19 suggests an alternative site (Newton Leys) has the capacity to accommodate 1,000 dwellings but this has not been reflected in the updated Housing and Economic Land Availability Assessment. This raises a question over the viability of the comparisons between the 3 MK edge sites (Eaton Leys, Shenley Park & extension to Salden Chase allocation)
* The development will have a negative impact on residents in Oxley Park and Kingsmead with the potential for at least 1150 properties being built on their doorstep
* No details have been provided to show how the Shenley Park site was chosen as the more viable option, what evidence base has informed the decision or what weighting has been given to the matters under consideration
* Highways costs from BCC have not been included and it is significantly concerning to note that there is no reference to any infrastructure costs within Milton Keynes being taken into consideration or information sourced
* Highway modelling does not satisfactorily represent the impact of the development on traffic flow into and around MK. The traffic will impact unacceptably on the existing highways infrastructure and increase pollution around the area
* Proposals for a link road should ensure that this is a grid road as per Policy SD15 of Plan:MK. The proposals should also ensure that a 'Redway' is developed providing a link for cyclists and pedestrians to the existing Redway network within MK
* Schools in MK within the vicinity of the development do not have capacity to accommodate out of area children. Pupil demand form the development should be accommodated by onsite provision, or by provision elsewhere within Bucks
* The development will fall into Aylesbury Vale CCG which has no healthcare provision in the area. It is essential that specific healthcare provision is provided for residents and that no additional demand be placed on the over stretched facilities within MK
* The naming of the development is also cause for concern. The 'Shenleys' are part of MK and to name a new development in this way will only add to confusion. It should be noted that within Shenley Church End there is already an area named Shenley Park

Object

VALP Main Modifications

Representation ID: 3388

Received: 17/12/2019

Respondent: Mr Peter Hosier

Legally compliant? No

Sound? No

Representation Summary:

lack of opportunity as resident to comment
availability of at least two other more appropriate sites
destruction of ancient countryside
increase of traffic
lack of sustainable infrastructure

Change suggested by respondent:

Policy MMO76 needs to be deleted from the VALP before the adoption of the VALP occurs. Eaton Leys Bletchley or Salden Chase Newton Longville, should be considered as sustainable replacements for Shenley park. Ideally alternative sustainable sites should be identified closer to the larger towns iin Aylesbury Vale - thereby helping that town's sustainability and economy, rather than that of Milton Keynes.e

Full text:

As Whaddon residents my wife and I entirely object to the proposed Shenley Park Development based on:
being denied the opportunity to debate the decision to choose Shenley park over two other sites and the lack of the sites inclusion in Nov 2017 proposed submission version of VALP
it is unfair and unjust not to allow comparison testing between the three competing sites. To simply accept AVDC's prefered choice will render the plan unsound, possibly unlawful
how much of our countryside must we chop up when other sites are more resdy and suited to development? Cutting through the ancient North Bucks Way will be unnecessarily spoil and harm countryside and nature
the plans are already growing from up to 1150 homes to at least 1150
Traffic through Whaddon onto the A421, via Kingsmead etc is already at braking point. AVDC apparently have no answer or plans for how traffic will be managed - hugely concerning
Infrastructure, education, employment and hospital capacity have been grossly under estimated or not considered. There is no upper school provision and AVDC's offer of £2m to MK Hospital is insulting.

Object

VALP Main Modifications

Representation ID: 3389

Received: 16/12/2019

Respondent: Mr James Brownrigg

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

Their needs to be serious consideration to the traffic issues at rush hour around the bottledump roundabout on the A421
Extra homes will always mean extra strain on our emergency services
There's a double standard being applied between the protection of villages in Aylesbury and villages around Milton Keynes
Simply being close to MK doesn't make a development sustainable.
The policy for Shenley Park refers to at least 1150 houses. The site promoters are pushing for 1800 houses.
No provision has been made for a secondary school. (officer summary)

Full text:

Dear Sir/Madam
I am writing to you to voice my objections to the VALP Modifications which require further review.

I believe the Public examination should be reopened for the following reasons.

Their needs to be some serious consideration to the traffic issues at rush hour around the bottledump roundabout on the A421. There are already significant queues at rush hour even now before extra houses at Tattenhoe Park and Kingsmead are built.
(MM007, 010,076)

Extra homes will always mean extra strain on our emergency services (MM007,010,076)

There seems to be a double standard being applied between the protection of villages in Aylesbury and villages around Milton Keynes.(MM013,014,031)

AVDC seems to think that simply being close to Milton Keynes makes a development sustainable,this is not the case for the reasons I have stated above.(MM070,076)

The expansion policy for Shenley Park refers to at least1150 houses however there is reason to believe that the site promotors are pushing for 1800 houses. this will further diminish the sustainability and furthermore no provision has been made for a secondary school in compliance with BCC policy as is made clear in the sustainability appraisal Addendum.(MM076)

Yours Faithfully

Mr James Brownrigg

Object

VALP Main Modifications

Representation ID: 3390

Received: 16/12/2019

Respondent: Whaddon Parish Council

Legally compliant? No

Sound? No

Representation Summary:

Whaddon PC strongly object to MMo76 Shenley Park Whaddon which did not feature in the November 2019 proposed submission VALP. Whaddon requires the the Inspector to reopen the inquiry hearing sessions on fairness grounds having been denied the opportunity in July 2019. AVDC have not complied with their lehgal duty to cooperate obligations with MKC and Whaddon PC regarding this omission sit. Whaddon has significant concerns regarding the AECOM sustainability appraisal which is unsound and fails to follow government and NPPF guidance especially on landscape transport and bidiversity grounds. This submission explains Whaddon genuine concerns.

Change suggested by respondent:

MMO76 Shenley Park Whaddon (WHA001) should be deleted from the VALP on the grounds that it is fundamentally unsuitable and seriously flawed on landscape transport/highway and biodiversity grounds lacks clarity and detail to make qualified judgement and may prove undeliverable before 2033. WPC believe that the minimum 1150 dwellings should be allocated at Eaton Leys, one of the two alternative site appraised by AVDC

Full text:

Please see attachment.

Object

VALP Main Modifications

Representation ID: 3397

Received: 17/12/2019

Respondent: Christopher Leech

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

AVDC seems to have paid 'lip-service' to this advice, by indicating to Milton Keynes Council (MKC) what they were doing, but they have not addressed this key strategic housing allocation through 'effective discussion' or 'proper joint working', representing a significant failing of 'Duty to Cooperate' at an early stage ...... especially as MKC are the major town and Lead Authority which adjoins the three neighbouring and competing sites, non of which have sustainable connectivity with Milton Keynes
reason to re-open the hearing sessions to ascertain exactly why AVDC chose not to cooperate and engage more fully with MKC

Full text:

Comments from: Great Brickhill Parish Council
The 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)
● AVDC seems to have paid 'lip-service' to this advice, by indicating to Milton Keynes Council (MKC) what they were doing, but they have not addressed this key strategic housing allocation through 'effective discussion' or 'proper joint working', representing a significant failing of 'Duty to Cooperate' at an early stage ...... especially as MKC are the major town and Lead Authority which adjoins the three neighbouring and competing sites, non of which have sustainable connectivity with Milton Keynes
● 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.
● 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

Object

VALP Main Modifications

Representation ID: 3402

Received: 04/12/2019

Respondent: Mr David Froggatt

Legally compliant? No

Sound? No

Representation Summary:

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, 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 crossa 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

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 id 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 Wayt 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.
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 to co -operate" at an early stage. Shenley Park (SP) was not included in the 2017 proposed submission version of VALP, so WhaddonPC residents have been complet4ly 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: 3403

Received: 04/12/2019

Respondent: Mrs Dorothy Froggatt

Legally compliant? No

Sound? No

Representation Summary:

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 sufficientstrategic cross-boundary housing allocations. AVDC have paid lip-services to this, but have not addressed this through effective decisions or joint working. 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 sufficientstrategic 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: 3404

Received: 17/12/2019

Respondent: Bletchley and Fenny Stratford Town Council

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

concerns both about the reliability of the
evidence on which the proposed site allocations have been determined and about
the conclusions drawn from the Viability Report published alongside the Main
Modifications consultation. The lack of a clear site selection methodology and
process for selecting further strategic allocations on the edge of Milton Keynes is
particularly worrying.
chief objection to the VALP has always been that it does not
fully recognise or adequately acknowledge the infrastructure implications for Milton
Keynes and specifically for the community of Bletchley and Fenny Stratford which
will arise from the MK edge developments. The transport and highways
infrastructure demand on our area is of particular concern to our community

Full text:

The Town Council shares the concerns of Milton Keynes Council that the
conclusions drawn in the updated Housing and Economic Land Availability
Assessment relating to Eaton Leys are not fully justified and therefore that the
proposed allocation of Shenley Park may be unsound. (Policy D-WHA001 ).
As a parish which will be directly impacted by two of the three "MK edge" site options
in the plan, the Town Council has significant concerns both about the reliability of the
evidence on which the proposed site allocations have been determined and about
the conclusions drawn from the Viability Report published alongside the Main
Modifications consultation. The lack of a clear site selection methodology and
process for selecting further strategic allocations on the edge of Milton Keynes is
particularly worrying.
The Town Council's chief objection to the VALP has always been that it does not
fully recognise or adequately acknowledge the infrastructure implications for Milton
Keynes and specifically for the community of Bletchley and Fenny Stratford which
will arise from the MK edge developments. The transport and highways
infrastructure demand on our area is of particular concern to our community. For
example, Policy D-WHA001 indicates that the A421 may need to be dualled near the
Bottledump Roundabout and more detailed traffic modelling will be required to inform
the necessary decision making. The Town Council believes that robust and detailed
modelling should have been conducted already and that the policy should at least be
made more explicit in defining how sustainable and acceptable development can be
achieved. Another worry concerns the accuracy of modelling that the Bucks
Country Transport Model affords when calculating likely traffic effects of specific
developments.
Our Local Planning authority is better placed to make the technical planning
arguments which support our objections to the VALP as modified. However the
Town Council hopes that you will recognise the genuine concerns of many "ordinary"
residents of our community ie that any developments on or near LPA borders should
be fully and robustly examined before growth sites are allocated because the impact
of such developments on our community will be profound

Object

VALP Main Modifications

Representation ID: 3410

Received: 16/12/2019

Respondent: Natural England

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

ADVISORY
D-WHA001 Shenley Park
Due to the areas of ancient woodland (irreplaceable habitat), deciduous woodland (priority habitat) and 'no main habitat but additional habitats present' (priority habitat) on the site, we advise wording is put in to ensure habitats are not damaged or destroyed. In addition, we advise removal of 'where practicable' in regards to retention of habitats.

Full text:

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


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

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

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

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

Object

VALP Main Modifications

Representation ID: 3425

Received: 17/12/2019

Respondent: Mr Pierre Hibble

Legally compliant? No

Sound? No

Representation Summary:

The Local Plan is not sound, not legally compliant, UNFAIR and UNJUST.
AVDC is in breach of the Government's 'Duty to Co-operate'.
The Sustainability Appriasail identifies Shenley Park (SP) as within a Biodiversity Opportunity Area and contrary to Green Infrastructure Plan objectives. It fails to consider crossing the North Bucks Way, a defensible boundary into countryside.
SP proposed access is via a new A421 roundabout, which is over capacity. AVDC has no proposals for the rural access roads to/from Whaddon.
AVDC fails to recognise Eaton Leys is the more logical and ideal 'infill site' to the eastern side of MK.

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 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 demonstrably neither sound nor legally compliant. Shenley Park, Whaddon (SP) was not included in the November 2017 'Proposed Submission'
version of the Vale of Aylesbury Local Plan (VALP) and in breach of NPPF paragraphs 158 and 182 and specifically paragraph 155. As such Whaddon residents have been unlawfully denied the opportunity, at the public hearing sessions held by the Inspector in July 2018, to review and question the AVDC decision
to select SP over the more suitable site at Eaton Leys (EL) or possibly that at Salden Chase (SC). The AVDC proposal for SP has multiple deficiencies making it UNSOUND. Not least is the abject failure of
AVDC to put forward a credible plan for road access. To suggest access to SP via the A421 indicates a total lack of knowledge, verging on incompetence or the cynical disregard of inconvenient facts including the Milton Keynes refusal to allow A421 access for SC. Notwithstanding the catalogue of failures in the
AVDC proposal for SP it must be rejected on this issue of road access alone.
AVDC has stated the strategic flood risk and landscape comparison assessments guided them to select SP. AVDC has failed to explain exactly how they came to their conclusion. The Inspector has an obligation to reopen a further hearing session so that crucial issues such as this can be fully discussed. The acceptance
of the AVDC statement and 'preferred choice' of SP without proper scrutiny and justification is completely
UNFAIR and UNJUST and will render the final plan UNSOUND and UNLAWFUL with legal repercussions.
The SP site was referenced earlier in the planning process but then deleted. Whaddon residents have not
been given the opportunity to present their concerns and the impact of such a large development on their
environment, health and road safety. It should be noted that the AVDC website and information
pertaining to the SP and other sites is complex and difficult to navigate. There has been no attempt to
MM076
x
x x x x
simplify the documentation, especially that relating to 'highway/traffic' and 'landscape' issues which are
crucial for Whaddon residents. Additionally the Representation Form and the online portal methods of
submitting acceptance or objections are not consistent, another legal failing. This is a blatant policy of
complying with statutory obligations in name but not spirit. One can only assume it is intended to
obfuscate residents in their efforts to make a balanced assessment of proposals.
Additional to the failure to comply with the legal requirement of proper consultation with Whaddon
residents, AVDC is in breach of the Government's 'Duty to Co-operate', the requirement for adjoining
Authorities when considering significant, strategic cross-boundary housing allocations. This is contrary to
PPG paragraph 3-008 (2014 version). AVDC has sought to by-pass its obligations by indicating proposals
to MKC while failing to address the key strategic issues through 'effective discussion' or 'proper joint
working'. Milton Keynes Council (MKC) discussed this issue and members across all parties agreed that a
failure of co-operation has occurred and that community engagement has been minimal. The AVDC action
is nothing short of a significant failing of its 'Duty to Co-operate' obligations.
In respect of the AVDC failures to engage with either residents or MKC it should be noted that AVDC has sought to justify its decisions based upon the Inspector's requirements for new allocations in close
proximity to Milton Keynes. This is disingenuous in that the Inspector agreed with AVDC that 500 new homes were necessary 'close to MK'. Subsequently AVDC realised that three of their allocated sites could
not, due to infrastructure deficiencies, be depended on to produce the number of homes required. Rather than reconsider AVDC took the easiest path of increasing the homes adjacent to MK. There was a loss of some 621 planned homes and as a result the agreed 500 homes was increased by AVDC, not the Inspector,
to 1117 and rounded up to 1150 for the Local Plan. As AVDC appears unable to plan proper sustainable growth within their own, established district then the viability of an uncharted development at SP, especially without the required dialogue with MKC, must be considered UNSOUND. Interestingly, the
originally allocated sites proved unsuitable due to infrastructure deficiencies. The same issues apply to SP but AVDC has chosen to deny and ignore or, more plausibly and again through inadequate performance,
not yet identified these deficiencies.
Apart form the legal and communication failings there are numerous deficiencies within the AVDC
proposal for SP. Generally this is the result of the failure to adequately consider issues and to assume that a solution will be found in the future. That is not planning. Examples are (i) education and how schooling
will be provided considering that children will probably have to cross the A421 and (ii) employment with no definition of where new residents are supposed to work or, more importantly, how they are supposed to travel without exacerbating an already congested road system. In my opinion however the two most
glaring faults with the AVDC Local Plan are the omissions from the Landscape and Biodiversity plans plus the failure to comprehend, let alone address, the traffic issues and specifically the impact on not just the already over congested A421 but the increasingly inadequate rural roads.
To quote the AECOM Sustainability Appraisal (SA): '...a new strategic site at Shenley Park gives rise to
certain tensions in respect of landscape objectives.' and 'these matters will be addressed at the detailed
planning stage'. While a second quote is: 'Perhaps more likely is that significant development would be
contrary to a Biodiversity Opportunity Area (BOA) and Bucks Green Infrastructure Plan objectives'. To
defer critical considerations is not planning but wishful thinking that leaves the issue open to abuse, i.e. at
some future date the ignoring of the environmental damage since "the development is so far advanced we
cannot turn back". As for environmental policy, the SP site is within a BOA area (as is the Salton Chase
alternative site but not the Eaton Leys alternative site). So AVDC has a policy that it has no scruples about
conveniently ignoring when it does not fit with its own preconceived strategy. Hardly the basis for
ensuring the future development addresses all the deferred issues appropriately or diligently.
A bemusing fact is the total failure of the SA to identify the requirement to cut through the ancient North
Bucks Way corridor by grid road extensions. North Bucks Way as an established landscaped barrier (and
existing habitat and wildlife corridor), is a natural boundary that forms a strong defensible western edge to
the existing built up area of MK. The SP development will irrevocably destroy unspoilt countryside and
remove a logical outer boundary against yet further expansion developments, some of which are already
identified by future development directional arrows beyond the boundary in the current proposal for the
'at least' 1150 homes. One can only assume that the SA failure to address the North Bucks Way is an
omission of convenience since it undermines the AVDC proposals. One may further surmise AVDC failed to
engage with MKC since it recognised the problems of the North Bucks Way are contrary to MKC stated
policy.
In respect of my second major concern, traffic and highways, the AVDC Local plan shows a complete
disregard for reality and need to face facts. Whaddon through traffic, "rat-running", increases month-onmonth
and presents major safety concerns for the village play group, school and general residents. The
environmental degradation in a conservation area is a further issue. Bucks CC has stated that "The
advantage of the SP development is that it has the potential to provide a new grid road which would
address rat-running through Whaddon". A glib statement without any basis or thought. There are no plans
or proposals for such a road and no idea as to how or when such a new grid road would be funded or
constructed. Yet again this is not planning but the use of throwaway lines to act as sops for those impacted.
Equally AVDC has no proposals for the access roads to/from Whaddon. It has singularly failed to consider
how the roads should be modified through closure or otherwise and no concept of (or chooses to ignore)
what volume of traffic increases will result from the SP development.
The critical consideration is how, when and where the SP site will be accessed. SP has no easy access to
facilities such as rail stations and is totally subject to raid transport. It was suggested by AVDC that there
would be a new roundabout along the A421 and that a length of the A421 would be dualled but further
traffic analysis is required before this can be confirmed. It would appear AVDC has been in denial (or yet
again chosen to ignore reality) regarding the A421 congestion. As a matter of indisputable fact the A421 is
already over capacity, even more so at peak times. The simple installation of a new roundabout solves
nothing. Dualling may help, provided it covers sufficient distance to mitigate congestion. It should be
noted that MKC has refused planning consent for the 'access' into SC off the A421, due to 'insufficient
evidence to mitigate traffic'. AVDC appears oblivious to this point and lack the common sense to recognise
that before significant numbers of new homes can be built, the existing roads must be improved. We
return yet again to the AVDC failure to engage with MKC. It somewhat beggars belief that traffic issues and
the mitigation of a major problem has not been fully discussed, modelled and agreed prior to
recommending the SP development. Again, this is not planning but the blatant disregarding of reality.
This single fact alone makes the AVDC Local Plan totally UNSOUND.
While objecting to the SP development, it is appreciated that homes must be built. Of the three alternative
sites (EL, SC and SP) considered by AVDC, EL is demonstrably the most logical and best choice. It is
difficult to comprehend the AVDC failure to recognise that EL is an ideal 'infill site' to the eastern side of
MK. The total site is contained by the A4146 Fenny Stratford bypass, precluding encroachment into open
countryside. Yet again the AVDC Local Plan chooses to ignore common sense and that infill sites should be
chosen over virgin countryside. Further, Bucks CC, in response to an AVDC request, has stated "The DS4
scenario - with Shenley Park removed and 1200 dwellings at Eaton Leys has the least impact on the
Buckinghamshire highway network". (enquiry document no:- ED215A). The obvious question to be
answered is why AVDC ignored this advice?
In respect of AVDC not selecting EL the following questions, among many, have not been answered and
deserve consideration:
● The MKC/AVDC administrative boundary cuts the full EL site roughly in half. MKC has granted
planning consent for their half of the site adjacent to the AVDC half, the Brickhills Area of attractive
Landscape (AAL). Why will AVDC not remove their half of the overall site from the Landscape
Designation and consider this site for 1150 new homes as there would be minimal impact on the
remaining Brickhill Local Landscape Area due to the site containment of the A4146 road?
● Much has been written or talked about 'Bletchley Regeneration'. The whole EL site has close links
to Fenny Stratford amenities and Bletchley Railway Station.
● AVDC reference 'Strategic Flood Risk' as part of their overall site appraisal. The exploratory
planning application 4 years ago (MKC ref : 15/01533/OUTEIS), raised a 'no objection' response
from the Environment Agency and the Lead Local Flood Authority. Why does AVDC continue to raise such a concern?

In conclusion, the AVDC proposals for SP fail to consider multiple critical issues and which AVDC appear intent on ignoring, for the present, since it undermines their case. AVDC has not acted professionally or
openly with residents. AVDC has not engaged with MKC. AS such the AVDC proposals are UNSOUND, UNFAIR and LEGALLY NON-COMPLIANT

Object

VALP Main Modifications

Representation ID: 3429

Received: 17/12/2019

Respondent: Willis Dawson Holdings Ltd

Agent: Pegasus Plannning Group

Legally compliant? Yes

Sound? No

Representation Summary:

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

Object to the site selection process - see reps on MM007

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

Change suggested by respondent:

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

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

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

Full text:

This representation addresses MM076, but should be read in conjunction with our representations to MM070 and the consequential text to Policy D2 set out in MM071; and also our representations to MM007.

Pegasus object to the proposed allocation of Shenley Park.

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

In addition to the representations to MM070, one of the key requirements in the policy wording relating to Shenley Park within the revised Local Plan, is the provision of "a new link road between the A421 Buckingham Road and H6 and or H7 Childs Way/Chaffron Way". However, it is not clear whether any traffic impact assessment been undertaken to assess the impact of this road connection on the existing MK residential areas of Oxley Park, Kingsmead and Tattenhoe.

The modelling work demonstrates that there will be a significant amount of traffic congestion on the A421 in the future and whilst this proposed link road could help alleviate the situation this traffic will be re-routed through existing residential areas.

ED215A states the DS3 Scenario with both Shenley Park and Salden Chase appears to perform worse in terms of impact on the highway network. ED215A states "The only advantage of the Shenley Park development is that it has the potential to provide a new grid road which would address the rat running through Whaddon."

Given the environmental constraints to the site,{ED210A} (Development within the western part of the northern parcel would be seen as extending the development edge to within close proximity of Whaddon Conservation Area, to include Whaddon Hall. Development within the southern parcel would represent an unacceptable extension of development into the countryside and visible from the wider landscape.) It is not clear why this site has been included in the proposed modifications, given the highways and other evidence.

Whereas development to the south of Milton Keynes such as around Newton Leys and also Eaton Leys would seem to have less impact on both Buckinghamshire CC roads and also MK roads and existing MK residential areas.

Object

VALP Main Modifications

Representation ID: 3448

Received: 17/12/2019

Respondent: Mrs Wendy Hibble

Legally compliant? No

Sound? No

Representation Summary:

The Local Plan is not sound, not legally compliant, UNFAIR and UNJUST.
AVDC is in breach of the Government's 'Duty to Co-operate'.
The Sustainability Appriasail identifies Shenley Park (SP) as within a Biodiversity Opportunity Area
and contrary to Green Infrastructure Plan objectives. It fails to consider crossing the North Bucks Way, a defensible boundary into countryside.
SP proposed access is via a new A421 roundabout, which is over capacity. AVDC has no proposals for the rural access roads to/from Whaddon.
AVDC fails to recognise Eaton Leys is the more logical and ideal 'infill site' to the eastern side of MK.

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 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 demonstrably neither sound nor legally compliant. Shenley Park, Whaddon (SP) was not included in the November 2017 'Proposed Submission' version of the Vale of Aylesbury Local Plan (VALP) and in breach of NPPF paragraphs 158 and 182 and specifically paragraph 155. As such Whaddon residents have been unlawfully denied the opportunity, at the public hearing sessions held by the Inspector in July 2018, to review and question the AVDC decision to select SP over the more suitable site at
Eaton Leys (EL) or possibly that at Salden Chase (SC). The AVDC proposal for SP has multiple deficiencies making it UNSOUND.
AVDC has stated the strategic flood risk and landscape comparison assessments guided them to select SP. AVDC has failed to explain exactly how they came to their conclusion. The Inspector has an obligation to reopen a further hearing session so that crucial issues such as this can be fully discussed. The acceptance of the AVDC
statement and 'preferred choice' of SP without
proper scrutiny and justification is completely UNFAIR and UNJUST and will render the final plan UNSOUND and UNLAWFUL with legal repercussions. The SP site was referenced earlier in the planning process but then deleted. Whaddon residents have not been given the opportunity to present their concerns and the impact of such a large development on their environment, health and road safety. It should be noted that the AVDC website and information pertaining to the SP and other sites is complex and difficult to navigate thereby frustrating residents.
Additional to the failure to comply with the legal requirement of proper consultation with Whaddon residents, AVDC is in breach of the Government's 'Duty to Co-operate', the requirement for adjoining Authorities when considering significant, strategic cross-boundary housing allocations. This is contrary to PPG paragraph 3-008 (2014 version).
MM076
x
x x x x
AVDC has sought to by-pass its obligations by indicating proposals to MKC while failing to address the key strategic issues through 'effective discussion' or 'proper joint working'. Milton Keynes Council (MKC) discussed this issue and members across all parties agreed that a failure of cooperation
has occurred and that community engagement has been minimal. The AVDC action is nothing short of a significant failing of its 'Duty to Co-operate' obligations.
The AVDC Local plan shows a disregard for reality and need to face facts. Whaddon through traffic,
"rat-running", increases month-on-month and presents major safety concerns for the village play group, school and general residents. The environmental degradation in a conservation area is a further issue. Bucks CC has stated that "The advantage of the SP development is that it has the potential to provide a new grid road which would address rat-running through Whaddon". A glib statement without any basis or thought. There are no plans or proposals for such a road and no idea as to how or when such a new grid road would be funded or constructed. Yet again this is not
planning but the use of throwaway lines to act as sops for those impacted. Equally AVDC has no proposals for the access roads to/from Whaddon. It has singularly failed to consider how the roads should be modified through closure or otherwise and no concept of (or chooses to ignore) what volume of traffic increases will result from the SP development.
While objecting to the SP development, it is appreciated that homes must be built. Of the three alternative sites (EL, SC and SP) considered by AVDC, EL is demonstrably the most logical and best choice. It is difficult to comprehend the AVDC failure to recognise that EL is an ideal 'infill site' to
the eastern side of MK. The total site is contained by the A4146 Fenny Stratford bypass, precluding encroachment into open countryside. Yet again the AVDC Local Plan chooses to ignore common sense and that infill sites should be chosen over virgin countryside. Further, Bucks CC, in response to an AVDC request, has stated "The DS4 scenario - with Shenley Park removed and 1200 dwellings
at Eaton Leys has the least impact on the Buckinghamshire highway network". (enquiry document no:- ED215A). The obvious question to be answered is why AVDC ignored this advice?

Object

VALP Main Modifications

Representation ID: 3450

Received: 17/12/2019

Respondent: Miss Lucy Stewart

Legally compliant? No

Sound? No

Representation Summary:

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.

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 STRONGLY OBJECT to the proposed development at Shenley Park

VALP & AVDC FAILINGS

* Shenley Park has been included, last minute, in the latest VALP to make up for a housing shortfall as a result of infrastructure deficiencies in previously approved locations (Buckingham, Winslow and Haddenham). The fact that Shenley Park was not included in the 2017 VALP proves this!

* Shenley Park has been swiftly identified, pushed through and approved as the 'preferred site'. Meanwhile, Whaddon residents have not been informed of this devastating proposition until now. It will have a catastrophic impact on our rural living conditions - the very reason we chose to live in a small village outside of Milton Keynes and within the Aylesbury Vale district. It is completely unfair and unjust that we have been prevented from commenting until now!

* The 'Modifications' document is vast. Information regarding Shenley Park is hidden away on page 44 of 222 and written in language which is vague and inaccessible to most. If people were not aware of this late addition to the VALP it would be very difficult to find out the details for yourself! The AVDC website and online portal is complicated and hard to navigate, even for the more technologically minded amongst us! The process to comment during the consultation period has been made incredibly difficult and confusing - presumably to put people off commenting?! The online portal form is not compliant as it is missing two key questions which appear on the physical form version (which, itself, was extremely difficult to locate!):
Do you consider the Local Plan to be legally compliant? And do you consider the Local Plan to be sound?
My response to both of these key questions is, 'NO'!.

*Due to the late inclusion of Shenley Park and lack of opportunity to examine all options during the public hearing sessions in July 2018, I strongly urge the Inspector to re-open a further hearing session so that legitimate comparison testing can take place.

DUTY TO CO-OPERATE FAILINGS

* With any cross-boundary development, adjoining authorities have a duty to co-operate. This has simply not been the case, evidenced by its inclusion at such a late stage. When county boundaries are crossed, authorities have an obligation to consult at length to ensure sensible and strategic planning occurs which is beneficial to both districts.

* Shenley Park is a nonsensical option - it adds zero value to Aylesbury Vale other than in achieving its housing quota. Milton Keynes may benefit from additional growth, however the longer-term provision of thousands of new residents (multiple occupants of the 'in-excess of' 1150 new homes) has not been carefully considered; a one-off contribution towards the Milton Keynes University Hospital is grossly inadequate!
This 'bolt-on' estate is not the answer - there are better, much more suitable infill sites at Eaton Leys and Salden Chase which would not have such a negative impact on the local environment and its rural communities.
(My arguments FOR an alternative site will follow all of my objections to Shenley Park).

* MKC discussed this issue at Full Council on 23 October, and all cross-party members agreed that a failure had occurred. This clear admission of primary level failings simply cannot be ignored.

* This clear failure of 'duty to co-operate', has led to retrospective planning and poorly formulated proposals.
This much-needed collaborative planning cannot be rectified during a consultation period.
As such, I strongly urge the Inspector to immediately withdraw Shenley Park from examination.

OTHER CONSIDERATIONS forming my OBJECTION

* With the future spread of Milton Keynes now set to expand over the M1 towards Bedford, why be ignorant of sound planning advice and common sense by dumping in excess of 1150 houses in a location which:
- Already suffers from traffic congestion, both in 'rat-running' through Whaddon village and when trying to join the MK grid-road network and the A421.
- Has poor transport links not only into Milton Keynes but to other outlying towns and cities where people would need to travel for employment and conveniences.
- Offers limited employment opportunities in the locality.
- Has insufficient provision for schooling.
- Lies within beautiful, unspoilt countryside - landscape considerations were highlighted but not addressed in the Sustainability Appraisal document.
- Has historical significance (Whaddon was the Headquarters of Section VIII, the Communications Division of MI6, which was linked to Bletchley Park during WWII).

* The North Bucks Way, and Swans Way footpaths and bridleways, form a strong, defensible, natural boundary between the urban city of Milton Keynes and the unspoilt countryside of north-eastern Aylesbury Vale. Those that have lived in Whaddon as long as I have (all of my 38 years) will remember the 'City Boundary' sign which used to be in-situ just past the corner of Tattenhoe Bare Farm, up to which which the Kingsmead estate is nearing completion. Surely such boundaries should be respected and upheld, especially as once breached, the floodgates open to potentially unlimited development.

* Salden Chase a previously approved site for almost 2000 new homes, has recently been halted by MKC in proceeding to development stage as a result of insufficient transport infrastructure (an already congested and bottle-necked section of the A421). This highlights and proves prior failings of cross-boundary discussions!

Where should this housing go?

As I strongly oppose development at Shenley Park, I want to highlight the benefits of an alternative site:-
Eaton Leys is the most suitable site for development because:
- It is a much more logical 'infill' site being nicely rounded-off by prior development and a major road.
- This site would enable traffic to be dispersed much more effectively across a better developed and more extensive road network.
- Three railway stations are within close proximity so people can travel further and wider to their place of employment
- It is a more strategic and sustainable location for development with the other half of the whole site (which falls within Milton Keynes as opposed to Aylesbury Vale) approved and already being developed.
- The Eaton Leys site is near an area of Bletchley (Water Eaton) which would benefit greatly from regeneration.
- There is provision for secondary school aged children at existing schools.
- Eaton Leys is not in a Biodiversity Opportunity Area, unlike Shenley Park and Salden Chase.


Object

VALP Main Modifications

Representation ID: 3455

Received: 17/12/2019

Respondent: Ms Sylvie Eames

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

SUSTAINABILITY; putting another 1,800 houses close to Milton Keynes does not make sense as the services (Health, hospitals, dentists, fire, schools, churches, nurseries) are already at break point . This diminishes sustainability and reduces quality of life and thus is not progress. (MM070, 076)No provision has been made for a Secondary School in compliance with BCC policy as is made clear in the Sustainability Appraisal Addendum (MM076).

Likewise, Coalescence has similarly not been properly considered and double standards are being applied between protection of villages around Aylesbury and the lack of protection for villages around Milton Keynes.

Change suggested by respondent:

Not provided

Full text:

Having read the Main Modifications to VALP, I am writing to object and request that the Public Examination be re-opened.

My reasons are:
TRANSPORT requirement for Shenley Park near Whaddon have not been thoroughly considered. As resident of Newton Longville (46 Berry Way) travelling daily to Buckingham I can confirm the A421 is a traffic jam at rush hour and getting out onto it from the Bottledump roundabout be it at 6.30am, 7am 8am and even 9am can take up to fifteen minutes.
Everyday in both directions emergency vehicles try to get through and drivers are having to go up verges to make room for the emergency vehicles. Putting more houses in the area means more cars and not just traffic jams but just impossible congestion. Traffic Analysis should have already proven this point. Infrastructure before expansion is the sensible course of action to address (MM007, 010 076)

SUSTAINABILITY; putting another 1,800 houses close to Milton Keynes does not make sense as the services (Health, hospitals, dentists, fire, schools, churches, nurseries) are already at break point . This diminishes sustainability and reduces quality of life and thus is not progress. (MM070, 076)No provision has been made for a Secondary School in compliance with BCC policy as is made clear in the Sustainability Appraisal Addendum (MM076)

Likewise, Coalescence has similarly not been properly considered and double standards are being applied between protection of villages around Aylesbury and the lack of protection for villages around Milton Keynes.

Finally, evidence of lack of active and real co-operation by AVDC and MKC is seen in the absence in AVDC policy to comply with the adopted policies in the adopted Plan : MK for such a proposed development(MM072-076) The Duty to Co-operate is a serious consideration.

Object

VALP Main Modifications

Representation ID: 3461

Received: 17/12/2019

Respondent: Carter Jonas - Associate SWMK Consortium

Legally compliant? Yes

Sound? No

Representation Summary:

It is considered that there are anomalies between the technical work completed to inform the transport assessment of the site options for additional development on the edge of Milton Keynes and the decision to select Shenley Park as the most suitable site allocation. In summary, the transport modelling has not included a new grid road proposed as part of Shenley Park and has not included mitigation measures that relate to the dualling of the A421.

It is considered that there are limited differences in landscape terms between the preferred site allocation at Shenley Park and the SWMK Consortium's site Ref. NLV020 at South West Milton Keynes. In summary, there are no differences in terms of landscape value and both sites would have a similar relationship with the existing and emerging edge of Milton Keynes.

Overall it is concluded that the transport and landscape evidence to support an allocation at Shenley Park is not robust.

Change suggested by respondent:

It is requested that the transport modelling should be updated to provide an accurate distribution of traffic and impacts of the proposed grid road within the site allocation at Shenley Park. It is requested that the transport modelling is updated to include all potential mitigation schemes to determine and compare impacts of the potential site allocation options.

It is requested that the landscape value of the Shenley Park and NLV020 sites are reassessed. It is requested that the landscape assessment process reassesses the existing and emerging relationship of the sites with the edge of Milton Keynes.

It is requested that an additional allocation is needed at North East Aylesbury Vale. The SWMK Consortium's representations requested an additional allocation at South West Milton Keynes at Site Ref. NLV020.

Full text:

Main Modification MM076 allocates an additional site at Shenley Park, located on the edge of Milton Keynes, for 1,150 dwellings. The SWMK Consortium has instructed consultants to assess the transport and landscape evidence used to support the decision to allocate Shenley Park. In summary it is concluded that the evidence is not robust.

In terms of transport, it is considered that there are anomalies between the technical work completed to inform the assessment of the site options for additional development on the edge of Milton Keynes and the decision to select Shenley Park as the most suitable site allocation. In summary, the transport modelling has not included a new grid road proposed as part of Shenley Park and has not included mitigation measures that relate to the dualling of the A421. The proposed development at Shenley Park includes a proposed grid road from the A421 to Kingsmead, but this road has been omitted from the transport modelling which it is considered would potentially underestimate the impact on the A421 and other local roads in Milton Keynes. It is requested that the transport modelling should be updated to provide an accurate distribution of traffic and impacts of the proposed grid road. The modelling has also not assessed a mitigation scheme involving the dualling of the A421 between Buckingham and Milton Keynes, or the impact of dualling of the A421 in combination with a Bletchley Bypass. It is requested that the transport modelling is updated to include all potential mitigation schemes to determine and compare impacts of the potential site allocation options.

In terms of landscape, it is considered that there are limited differences between the preferred site allocation at Shenley Park and the SWMK Consortium's site Ref. NLV020 at South West Milton Keynes (referred to in the assessment as Salden Chase extension). There are two factors that are used to justify the decision to allocate Shenley Park, but it is considered that the assessment of these factors is not robust. Firstly, the Shenley Park site is wholly located within a Landscape Character Areas which is assessed as being in 'very good' condition with a 'high' sensitivity. However the landscape assessment process has downgraded these factors and concluded that the value of the landscape at the Shenley Park site is 'low', which is an anomaly in the assessment process. The agricultural character of the NLV020 site is also typical of the wider area and ordinary, and as such the landscape value of the site should have been identical to that of Shenley Park. It is requested that the landscape value of the Shenley Park and NLV020 sites are reassessed. Secondly, the Shenley Park site is preferred because it is concluded that it is better located to the existing and emerging edge of Milton Keynes. In comparison, the assessment process occasionally refers to the NLV020 site as detached from the existing settlement, when in fact it would be immediately adjacent to Site Allocation NLV001 located on the edge of Milton Keynes and adjacent to existing residential areas. Site Allocation NLV001 includes strategic landscaping and green infrastructure to connect the urban area with the surrounding area. There are no differences between the sites in terms of their relationship with the edge of Milton Keynes. It is requested that the assessment process reassesses the existing and emerging relationship of the sites with the edge of Milton Keynes.

Overall it is concluded that the transport and landscape evidence to support an allocation at Shenley Park is not robust.

In addition, as set out in the SWMK Consortium's representations to Main Modification MM088, it is considered that development at RAF Halton will not be completed during the plan period.

For both these reasons, it is requested that an additional allocation is made at North East Aylesbury Vale. The SWMK Consortium's representations requested an additional allocation at South West Milton Keynes at Site Ref. NLV020 [see Rep Id. 2336].

In summary, Site Ref. NLV020 was assessed in the Housing and Economic Land Availability Assessment (January 2017) and a number of technical studies have been prepared to support development at the site including a concept masterplan; those supporting documents were submitted with the SWMK Consortium's representations.

It is considered that development could be accommodated at Site Ref. NLV020 without resulting in significant landscape and visual effects. Site Ref. NLV020 is well placed to provide a variety of options for sustainable travel, including extensions to the bus service, and connections to the existing pedestrian and cycle network in the surrounding area. It is also considered that subject to reaching agreement on an appropriate transport mitigation package, Site Ref. NLV020 is deliverable in transport and highway terms and offers an opportunity to enhance strategic and local transport infrastructure and thereby create a highly sustainable integrated new community.

As set out in the SWMK Consortium's representations, it is requested that Site Ref. NLV020 is allocated for a mixed use residential-led development, comprising the following uses:
* Residential 31.26 Ha - 1,095 dwellings (including affordable)
* Care Village 1.66 Ha
* Employment 0.51 Ha
* Education 9 Ha
* Neighbourhood Centre 0.7 Ha (plus an additional 30 dwellings)
* Community Centre 0.5 Ha
* Allotments 1.0 Ha
* Cemetery 1.2 Ha
* Green Infrastructure 50.01 Ha

If it is decided that, despite the above, the site should not be allocated as a strategic allocation, then as an alternative it is considered that Site Ref. NLV020 should be identified as a reserve site to provide flexibility and allow for any change in circumstances, e.g. an anticipated shortfall in housing land supply, to meet jobs growth or the planned provision of new strategic infrastructure. A reserve site approach at Site Ref. NLV020 would be in accordance with the existing development strategy of directing development to the larger and more sustainable settlements, including to the edge of Milton Keynes.

Object

VALP Main Modifications

Representation ID: 3473

Received: 16/12/2019

Respondent: Mr & Mrs Ronald & Jenny Hudson

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

(Officer's summary)
Further detailed consideration of transport needs for the proposed Shenley Park and Whaddon must be investigated. The traffic problems and jams on the A421 are bad enough now at times and these are only going to get worse. Traffic analysis must be done first, not as an Infrastructure before expansion would be a sensible course of action.
The site promoters are pushing for 1,800 houses on the site. This will further diminish sustainability and furthermore no provision been made for a new secondary school.

Full text:

I am writing to register my objections to the VALP Main Modifications which require further review. The letters 'MM' and numbers refer to the appropriate modifications.
I believe the public examination (PE) should be re-opened for the following reasons.
Further detailed consideration of transport needs for the proposed Shenley Park and Whaddon must be investigated. The traffic problems and jams on the A421 are bad enough now at times and these are only going to get worse. Traffic analysis must be done first, not as an afterthought. Infrastructure before expansion would be a sensible course of action. Unfortunately, it seems not be a consideration in this case and that must be addressed. (MM007, 010, 076). The impact of extra traffic through Newton Longville and the road being used as a rat run is a real possibility.
The question of the necessary and significant uplift for Health Service provision, the extra strain on emergency services caused by new developments and the disposal of waste have not been properly considered. (MM007, 010,076) are all matters that need further consideration.
There is a very obvious double standard being applied between the protection of villages around Aylesbury and the lack of protection for villages around Milton Keynes. This protectionism appears to have been driven by politics rather than any other consideration and is manifestly unfair to those living in the north of Aylesbury Vale. Northern villages must be offered the same protection from coalescence as the south. (MM013, 014, 031). This is a very important and significant consideration.
AVDC seems to think that simply being close to Milton Keynes makes a development sustainable. That is not the case for the above reasons. All the burden will be placed on MK rather than Aylesbury Vale and thus expansion actually achieves diminished sustainability and a reduced quality of life. This cannot be seen as progress. (MM070,
The site promoters are pushing for 1,800 houses on the site. This will further diminish sustainability and furthermore no provision has been made for a new secondary school in compliance with BCC policy as is made clear in the Sustainability Appraisal Addendum. (MM076)
There is no evidence of active co-operation by AVDC with MKC can be seen in the absence in AVDC policy to comply with the adopted policies in the adopted Plan:MK for such a proposed development. Further, the motions passed by the full council of Milton Keynes Council in relation to both Salden Chase and "Shenley Park" at Whaddon also raise serious questions over AVDC's real appetite, or otherwise, to comply with the 'Duty to Cooperate.' (MM072 to 076)
It appears that AVDC are not showing active co-operation with MK to bring a satisfactory outcome to the problems that have arisen and is is for the above reasons I reconfirm my objection to the VALP Main Modifications in respect of Newton Longville and ask that the PE be reopened.

Object

VALP Main Modifications

Representation ID: 3494

Received: 17/12/2019

Respondent: L&Q Estates

Agent: Barton Willmore

Legally compliant? No

Sound? No

Representation Summary:

Considers that the SA Report Addendum's appraisal findings are deficient and should be revised. It is deficient in its assessment of Eaton Leys vs the other two sites on grounds of - HEELA update flawed assessing Eaton Leys to take account of adjoining development; more nuanced approach on landscape & AAL needed; biodiversity conclusions not accepted; conclusions of SFRA Addendum not accepted - green infrastructure will contribute to Climate Change Adaption; could provide a secondary school if required; highway transport impacts slight sustainable transport initiatives not properly considered.

The revised appraisal demonstrates that Eaton Leys performs well against the majority of
objectives and is ranked ahead of the Shenley Park and Salden Chase Extension. Should recommend Eaton Leys as the preferred option.

Change suggested by respondent:

A further update to AVDC's HELAA which identifies Eaton Leys as 'suitable for
housing'.

Having regard to the wide-ranging flaws in AVDC's site selection process, the
proposed allocation of Shenley Park through Policy D-WHA001 is it is demonstrably
unjustified and therefore unsound. Additional hearings are required to consider
the procedural and evidential concerns which are set out above

Full text:

see attachment

Object

VALP Main Modifications

Representation ID: 3522

Received: 17/12/2019

Respondent: Milton Keynes Council

Legally compliant? Yes

Sound? No

Representation Summary:

The Council requests certain changes are made to Policy D-WHA001 to ensure that the policy
wording, in isolation, is effective. However, the Council wishes to make it clear that the proposed
changes to Policy D-WHA001 would not remedy the more fundamental issues of soundness
associated with the selection of Shenley Park as an additional allocation in the VALP.

Change suggested by respondent:

see attachment

Full text:

see attachment

Support

VALP Main Modifications

Representation ID: 3562

Received: 17/12/2019

Respondent: Buckinghamshire County Council

Representation Summary:

Officer's summary
MM076 (pages 134 and 135 of tracked changes)
Rights of way
- h and i- Cover of walking and cycling links connecting the development with outlying communities - both are excellent. A bridleway (WHA/12/2) sits just outside the development edge on the north side of a strip of land called Briary Plantation. This bridleway forms the North Bucks Way and Swans Way, and connects the Tatternhoe Valley Park and Redways with Whaddon in an east to west direction.

Full text:

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

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

MM041

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

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

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

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

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

Attachments:

Object

VALP Main Modifications

Representation ID: 3565

Received: 16/12/2019

Respondent: Thames Water

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

Revised policy states:
"w. An updated assessment of sewerage capacity and water supply network shall be carried out, working with Anglian Water, to identify the need for infrastructure upgrades and how and when these will be carried out to inform site delivery."
For consistency the same wording should be included in all allocation referencing Anglian Water, or Thames Water.

In addition part v. should read:
"v. A foul water strategy is required to be submitted to and approved in writing by the Council in conjunction with the water and Sewerage undertaker. "
This should also be included for every allocation.

Change suggested by respondent:

Revised policy states:
"w. An updated assessment of sewerage capacity and water supply network shall be carried out, working with Anglian Water, to identify the need for infrastructure upgrades and how and when these will be carried out to inform site delivery."
For consistency the same wording should be included in all allocation referencing Anglian Water, or Thames Water.

In addition part v. should read:
"v. A foul water strategy is required to be submitted to and approved in writing by the Council in conjunction with the water and Sewerage undertaker. "
This should also be included for every allocation.

Full text:

See attachment