Aylesbury Vale Area

MM076

Showing comments and forms 91 to 100 of 100

Object

VALP Main Modifications

Representation ID: 3627

Received: 17/12/2019

Respondent: Mrs Pauline Welch

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

(Officer's summary)
The long traffic jams at rush-hour on the A421 prove the roads on the west of MK are already at capacity. This will get worse as other new builds within Milton Keynes itself come into play. Transport needs for Shenley Park, Whaddon have not even been properly considered.
Weight, tonnage and speed of traffic along Whaddon Road from the Bottledump Roundabout (A421) to the crossroads in Newton Longville is already dangerous and intolerable from the point of view of noise and pollution; but the situation is seriously aggravated by the impatience demonstrated at rush hour times.

Change suggested by respondent:

Not provided

Full text:

Please note my objections to the VALP Main Modifications which require
further review. The letters 'MM' and numbers refer to the appropriate modifications.

1.The long traffic jams at rush-hour on the A421 prove the roads on the west of MK are already at capacity. This will get worse as other new builds within Milton Keynes itself come into play. Transport needs for Shenley Park, Whaddon have not even been properly considered.

Weight, tonnage and speed of traffic along Whaddon Road from the Bottledump Roundabout (A421) to the crossroads in Newton Longville is already dangerous and intolerable from the point of view of noise and pollution; but the situation is seriously aggravated by the impatience demonstrated at rush hour times. It would make sense to assume the persistent traffic jams are a causative factor.

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)

2.None of the extra strain on the emergency services caused by new developments and the disposal of waste have been properly considered. Sustainability will not be possible (MM007, 010,076)

3.It is wrong for AVDC to assume that Newton Longville's infrastructure needs will be met by Milton Keynes. It doesn't happen now. Why would it in future?
(MM070, 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: 3628

Received: 13/12/2019

Respondent: West Waddy

Legally compliant? Yes

Sound? No

Representation Summary:

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

Change suggested by respondent:

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

Full text:

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

Object

VALP Main Modifications

Representation ID: 3631

Received: 17/12/2019

Respondent: Newton Longville Parish Council

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

The Inspector should re-open the public examination. The allocation of Shenley Park should be removed from the plan. Discussions between AVDC and MK do not satisfy the legal duty. Referring to 1,150 conceals the site promoter pushing for 1,800 houses. No provision for employment. No references to policy SD15 in Plan:MK. Transport needs for Shenley Park have not been properly considered. Shenley Park should include construction (not just safeguarding) of a bypass from the A421 to the A4146 Detailed policies for sites should be within VALP, not left to be in an SPD.
Not clear how evidence led to the decision of site. The SA appears to have been produced after decision on which site. (officer summary)

Full text:

See attachment for full comments and all issues raised

Object

VALP Main Modifications

Representation ID: 3655

Received: 13/12/2019

Respondent: Mr Neil Barnfather

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

strain on MK infrastructure with no financial restitution from development - particularly, traffic impacts, stretch/overload existing local shopping facilities - parking at shops and railway station overloaded; impact of traffic on Shenley Road mixing with existing heavy traffic from Kingsmead/Oxley Park and require Grid Road widening. Loss of open farmland which currently forms a natural boundary.
Encourage development at Newton Longville of Eaton Leys.

Change suggested by respondent:

Encourage development at Newton Longville of Eaton Leys.

Full text:

Having had the opportunity of considering documentation, plans and indicative maps relating to the VALP; specifically though the proposal for Shenley Park. I would like my commentary to be recorded as follows:

In the first instance I recognise the need for more housing, this is an inescapable fact and all. authorities must continue to consider options for available land for development.

In the broadest terms I have no substantive observations nor concerns regarding VALP as a document outlining growth, the need for dwellings and alike.

Where my concerns begin to arise is in the location of where to build future developments, how this need ought to be managed and facilitated where it adjoins neighbouring LA's etc.

As a resident living on the boundary of Aylesbury Vale authority within the Kingsmead estate;; the preposed site development branded as Shenley Park gravely concerns me.

In the first instance, the councils inspector has already noted, in the rational behind opting for a site so close to MK, that a substantial portion of residents/traffic shall be passing into MK. With this in mind, MK citizens would bear the brunt of increased usage patterns on all aspects of infrastructure and local resource, without any financial restitution; yet would be almost entirely impacted by the development.

This is to say; the preposed estate residents would be Aylesbury tax payers, yet the inspector readily accepts that much of their impact will be upon the infrastructure, thus residents of, MK.

I am gravely concerned as to the choice of the land development so named Shenley Park;

Extending Childs Way (H6) and connecting to Standing Way (H8) will add a substantive volume of traffic to roads that already are often experiencing practical grid lock at rush hours. Further are dangerously busy at other times; which maybe an issue for MKLA to resolve/investigate in terms of speed restrictions and other traffic calming measures.

Local facilities such as shops at Oxley Park and Westcroft would be considered destinations of these residents, these facilities are already stretched and maximised all but to full capacity. There is often no parking at either site which would be Exacerbated were this development to proceed.

Infrastructure such as the mainline railway station (MKC) has substantive parking and congestion problems at peak usage times, again referring to the inspectors findings, the implication being that part of the appeal to the majority of residents of SP would be destinations such as MKC.

A secondary issue would be traffic movements along the old Shenley Road, how to protect residents living adjacent to this and safeguard against "rat-runs" and other undesirable usage practices.

I am also concerned as to how it is envisaged that this bulk of traffic leaving the SP development into MK would intermingle with the already dense traffic leaving Kingsmead and Oxley Park, later Westcroft, SBE, SCE etc as Childs Way would need to be expanded, yet, is already heavily used. In my view it could not support the changes needed to facilitate what the inspector reports as being predominantly residents passing into MK from SP.

Finally, the environmental impact of loosing the open area of farm land to the south west of MK which currently serves as a natural boundary and void for citizens of both MK and AV to enjoy and pass through.

My personal stance is that AVDC and MKLA need to resolve any complexity surrounding the expansion of the already developing Eaton Leys to include the land within AVDV which a-joins Eaton Leys MK development. Infrastructure is already in place here and capacity has already been factored by both authorities.

Further, consideration ought to be made as to the usage of land at Newton Longville, as this to would stand to impact MK residents far less so were it to have appropriate infrastructure to be self-contained more so than the proposed SP development.

In conclusion I appose the development at SP for the reasons set out above and believe that MK council needs to work with AVDC to encourage development of Eaton Leys and Newton Longville.

Object

VALP Main Modifications

Representation ID: 3656

Received: 03/12/2019

Respondent: Mr Paul Logan

Legally compliant? No

Sound? No

Representation Summary:

Shenley Park (SP) was not included in the November 2017 'Proposed Submission' version of the Vale of Aylesbury Local Plan (VALP), so Whaddon Parish Council and residents have been completely denied the opportunity to properly debate and cross examine AVDC's decision to choose SP. The proposed expansion provides for no natural/effective barrier to continued eastward expansion around Whaddon. There are serious concerns over impacts on biodiversity and landscape amenity as well potentially very serious safety concerns arising from the likely increase in traffic through Whaddon village. AVDC has not explained the inadequate consideration given to development at Eaton Leys.

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 choose SP over the other two competing sites during the public hearing sessions held by the Inspector in July 2018. The alternative sites are Eaton Leys (EL) and 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.
To simply 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)
Furthermore, 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 have paid 'lip-service' to this advice, by indicating to MKC what they were doing, but they have not addressed this key strategic housing allocation (a minimum of 1150 new homes) through 'effective discussion' or 'proper joint working', representing a significant failing of 'Duty to Co-operate' at an early stage ...... especially as MKC are the major town and Lead Authority which adjoins the three neighbouring and competing sites.
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' ...... and is hence a further reason to re-open the hearing sessions to ascertain exactly why AVDC chose not to cooperate and engage more fully with MKC - or indeed with Whaddon Parish Council, residents and other stake-holders.
In considering impacts on landscape and biodiversity, the AECOM Sustainability Appraisal (SA) states in the introduction, and several times within it, that '...a new strategic site at Shenley Park gives rise to certain tensions in respect of landscape objectives.' but goes on to say that 'these matters will be addressed at the detailed planning stage'. This will of course be after the site is allocated in the Plan, and perhaps too late to remedy! These 'tensions' are not discussed further, but 'biodiversity gains' will be by 'extending remnant woodland blocks and targeting new habitat creation' . However, one 'telling' sentence states:- 'Perhaps more likely is that significant development would be contrary to a Biodiversity Opportunity Area (BOA) and Bucks Green Infrastructure Plan objectives'. Both SP and SC are within a BOA area whilst EL is not.
Somewhat surprisingly, the SA does not mention the important North Bucks Way at all, but a new road access into SP must cut across this obvious natural boundary that currently forms a strong defensible western edge to the existing built up area of MK. Its importance as an old established landscaped barrier and existing habitat and wildlife corridor is overlooked. Cutting through this ancient North Bucks Way corridor by one, if not two grid road extensions will unnecessarily harm attractive and as yet unspoilt countryside - 'virgin' land which does not enjoy any further logical outer boundary that could be described as a similar long-term and defensible boundary. Crest Homes in their May 2014 'Development Opportunities Plan' have demonstrated this dangerous concept by showing future development directional arrows heading further west, towards Coddimoor Lane, well beyond the boundary they currently propose in this version of VALP for the 'at least' 1150 homes.

At their Full Council meeting on 23 October 2019, elected members across all political parties of MK Council agreed "to ensure 'biodiversity' and 'natural processes' were placed at the top of MK's agenda, with ambitions to become the 'Greenest City in the World' with a vision of becoming a 'World-leading sustainable City', whilst celebrating the rich variety of wildlife by protecting landscapes and habitats etc". Crossing the hugely important North Bucks Way wildlife corridor into much valued open countryside and natural habitats would destroy such MKC ideals, especially when less harmful sites exist and were considered by AVDC during the Site Assessment process.
It is also highly unlikely that the Public Open Space, especially on the edges of the development would be passed, with a suitable financial endowment, to the recognised expert in this field, namely MK Parks Trust, thereby ensuring its future care and maintenance in perpetuity. A long term 'defensible edge' to a development, would only be in existence until the Local Plan is next reviewed, so we can expect the developers to maintain control over any 'edge land', with perhaps a management company being formed whereby new residents contribute to the cost of future maintenance?

Major concerns also exist around traffic and highways provision. Bucks CC have 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 HGV's have worsened year on year since MK began, despite a traffic calming scheme costing approx £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 2,024 vehicles (December 2014 MVAS traffic data) to approximately 3,098 (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 4-5,000 cars) at Shenley Park - (at least 1,150 houses) and Salden Chase, Newton Longville (circa 1,855 houses) will have? Traffic levels through Whaddon during morning and evening peak periods are already at levels which are a very real threat to the safety of residents. Living near the junction of the High Street with Stock Lane, it is almost impossible at these times to safely exit our driveway without causing a speeding driver to swerve or brake sharply to avoid a collision. In the past seven days, temporary traffic lights sited near this junction, resulted in queues of up to 40 minutes to pass through the lights, such was the volume of traffic with parents also dropping children at the village school.

MKC on 7th November 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 1,855 houses, school etc. What does this say about 'cross boundary discussion?' The developers must now appeal that decision, which could take 6 months or more - with no certainty of success. Where does this leave VALP, if almost 1,900 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.). Access to Whaddon needs to be considered in its entirety. A possible closure of Coddimoor Lane could mean that everybody uses the tortuous new SP route into MK or to gain access to the A421. Without data on such possible impacts, how can residents be expected to fully participate in a public consultation exercise?
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? Now is the time to think about this! This is a 'serious concern' and the Inspector should insist on 'someone having to provide sensible answers to a really difficult problem,
and undertake the detailed traffic analysis to justify if mitigation can indeed work'. 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. There is almost universal agreement (at least by Whaddon and MK residents) that the A421 is already over capacity - especially during peak times. It cannot be right that developers do not have to concern themselves with this problem, because all they need to do is demonstrate that their new homes will 'consume their own smoke', and provide improvements that will deal only with their extra generated traffic levels. Government and Local Authorities have long argued and insisted that 'Infrastructure must come before development'. Surely, common sense dictates that before new homes of this number can be built, the existing roads must be improved.
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.

Whaddon residents also need to know exactly how, when and from where the new site will be accessed. It was originally suggested by AVDC in late July 2019, that there would be a new roundabout along the A421 by Wood Pond Farm, and that the length of the A421 between there and the Bottledump roundabout would be dualled. It now appears that further traffic analysis is required before this can be confirmed - and indeed if dualling is needed at all. Whatever happens there will be major disruption/closures on the A421, so how will any diversions impact on Whaddon? The A421 is already heavily overloaded at peak times, and it is clear to many that any dualling (if considered necessary) must extend at least to the existing Whaddon roundabout (and possibly beyond towards Buckingham) to avoid further 'backing up' of traffic, which inevitably leads to impatient drivers joining the rat-running traffic through Whaddon village. These major decisions and 'further traffic investigations' must be undertaken and resolved BEFORE the site is allocated in the Local Plan, and MUST NOT be allowed to wait until the later Supplemental and Detailed planning stages. It is not just at peak travel times when the traffic queues up on entering and exiting MK at Bottledump roundabout, it is becoming an 'all day' event especially on wet, frosty, and misty days. If the Oxford - Cambridge Expressway does not go ahead or is seriously delayed (as some predict), then without major improvements (or full dualling between MK and Buckingham) the extra 3000 houses proposed can only exacerbate the current and very serious capacity and safety problems on the A421. WPC believes that no more houses should be allowed onto the A421 until all these concerns are fully investigated, resolved and the necessary improvement works fully completed. It is worth repeating that developers overcome 'existing capacity' problems, because their housing estates need only show necessary improvements that will overcome the extra traffic problems that their houses generate (i.e. they must 'consume their own smoke'). It must be wrong that they can simply ignore existing problems and current congestion. WPC repeats, "What has happened to the much proclaimed Government mantra that says 'I before E' (Infrastructure before expansion)?
If SP is not to be developed, then the additional housing should go to Eaton Leys (EL).
Bucks CC, 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". (enquiry document no:- ED215A) Why then, have AVDC chosen to ignore this advice?
EL, even to an untrained eye, is a totally obvious and logical 'infill site' that would sensibly 'round off' the eastern side of MK. The total site lies within and is fully contained by the A4146 Fenny Stratford bypass, meaning that there will be no encroachment into open countryside beyond. The A4146 will then clearly define a long lasting and permanent edge to the east of Milton Keynes.
The MKC/AVDC administrative boundary cuts the full EL site roughly in half. Just under half the total site lies in the MKC district, but the larger part stands within AVDC. The AVDC half of the site stands within the Brickhills Area of attractive Landscape (AAL), despite the A4146 being constructed through it some years ago, but for some reason - and this can only be based on historic district boundary lines, the MKC part was never covered by the same designation, despite there being little or no difference on the ground in visual or landscape terms. Given that MKC have recently granted planning consent for some 600 new homes on their half of the site, despite it now abutting the Brickhills AAL, and having little or no different landscape from the AVDC half of the site, why will AVDC not remove their half of the overall site from the Landscape Designation and consider this site for 1150 new homes? It is after all, contained within the A4146 Fenny Stratford bypass, and the original AAL Landscape Designation was defined only by a district boundary and an outer road boundary, being that of the old A4146 to Leighton Buzzard.
Building work has very recently commenced on the MKC half of the site by Barratt Homes, with a new access currently being constructed on the A4146. An earlier planning application to build homes on the AVDC half of the site in 2015 was withdrawn due to lack of AVDC support, despite indications (WPC believe) that no physical obstacles to development existed. Surely, following the MKC decision and with the Barratt Homes development proceeding, there would be minimal impact on the remaining Brickhill Local Landscape Area due to the site containment of the A4146 road.
Common sense dictates that obvious infill sites should be chosen before despoiling virgin countryside, especially when the alternative SP site would mean crossing the North Bucks Way - a strong and defensible landscape barrier.
The entire EL site has close links to Fenny Stratford amenities and Bletchley Railway Station. New or improved footpath and redway links are planned, or are already being enhanced. Much has been written or talked about 'Bletchley Regeneration'. These two sites together could surely help this ambition and be considered for, and contribute towards, the ongoing 'Overall Regeneration Plan'. Areas of regeneration are often favourably regarded for financial support?
There are excellent traffic routes to CMK (10km), the A4146 Stoke Hammond/Leighton Buzzard bypass (1.5km), M1 (10km), A5 (1.5km) and Bletchley (3.5km). Compare these with Shenley Park!
Railway stations are easily accessible with Bletchley just 3.5km away and Bow Brickhill 3km. whilst Leighton Buzzard and MK Central are within easy driving distance. A primary school site would be made available, with secondary stage students attending existing schools where there are free places. Obviously housing numbers at this site are too low for a new upper school to be included, but a new school will be provided in the proposed MK Eastern Expansion area, and financial contributions could possibly make accommodation available there? For the first time public access would be gained to the eastern bank of the River Ouzel, with this very important public open space being passed to Parks Trust to extend their existing interests in this area.
This major resource together with extended green corridors through the site would greatly improve biodiversity and guarantee its future as an important wildlife and recreational area, subject to proper development funding arrangements, securing long term maintenance of this valuable area.
AVDC's reference to 'Strategic Flood Risk' as part of their overall site appraisals would appear to relate to this site, being the only one with river frontage. 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, so perhaps AVDC should explain their 'concern'.
THEREFORE, why was an extension to Eaton Leys not considered the most suitable site?


Object

VALP Main Modifications

Representation ID: 3657

Received: 17/12/2019

Respondent: Joy Arnold

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

(Officer's summary)
Traffic in the area is already well over what the roads can take, with long traffic jams on the A421 at rush hour. Building large new developments without carrying out volume of traffic studies and analysis will lead to further chaos on the already busy roads. I feel that I am having to state the obvious!

Change suggested by respondent:

Not Provided

Full text:

I am writing to register my views on the VALP Main Modifications. I think the public examination should be re-opened for reasons set out below.

Traffic in the area is already well over what the roads can take, with long traffic jams on the A421 at rush hour. Building large new developments without carrying out volume of traffic studies and analysis will lead to further chaos on the already busy roads. I feel that I am having to state the obvious! (MM007, 010, 076)

I live in Newton Longville which is a village mentioned in the Domesday Book, so think it only proper and right that this ancient village should not be engulfed by mass building. I understand that there is a protection policy in place for villages around Aylesbury, but it appears there is no protection for villages situated in the north of Aylesbury Vale, this is just not fair.(MM013, 014,031)

The extra strain put on Health Service provision does not appear to have been remotely addressed. It is already very difficult to get a doctor's appointment, a normal waiting period for routine appointments is 3 - 5 weeks, and there has been no mention of opening any new GP surgeries. Any visit or admittance to Milton Keynes Hospital shows the enormous pressure their resources are already under without further influx of people. There will be extra strain put on all the emergency services and waste disposal. (MM007, 010, 076)

AVDC appears not to care that all the strain of sustaining the above mentioned services will fall on MKC due to the proximity of the new developments to Milton Keynes. The system here is already under enormous pressure and will not be able to uphold services to an acceptable level and quality of life will be diminished for residents - a backward step.(MM070, 076)

It appears that AVDC allows planning consent for huge developments in our area because they can wash their hands of providing the services needed to sustain such vast developments.

Object

VALP Main Modifications

Representation ID: 3658

Received: 17/12/2019

Respondent: Miss Marlen Lawrent

Legally compliant? No

Sound? No

Representation Summary:

I object to MM70, MM071, MM075 and MM076 in respect of Shenley Park given that:
1) The modification were made without due consultation of the affected parties
thereby preventing a proper comparison testing of the three potential sites(E.Leys, Saldon Chase and Shenley Park).
2. AVDC failed to comply with its duty to cooperate with the adjoining authority MKC in interest of i)local planning aims and ii) developer's contributions
3. The SA appears to be incomplete, jeopardising the report soundness and validity of its consultation.

Change suggested by respondent:

Modifications MM070,MM071, MM075 and MM076 need to be deleted from the VALP before adoption of VALP occurs. Eaton Leys, Bletchley or Solden Chase, Newton L.should be considered as to sustainability replacement for Shenley Park. Ideally, alternative sustainable sites should be identified closer to the larger towns within Aylesbury Vale. Thereby helping that towns sustainability and economy rather than that of Milton Keynes.

Full text:


1. Shenley Park was only included at this late stage by way of 'modification'. It is, however, evident that AVDC's decision to prefer Shenley Park over the two competing sites (Eaton Leys & SaIden Chase) was taken without allowing for a full hearing of the parties affected by the proposed site allocation. This lack of consultation denied Whaddon Parish Council and local residents the opportunity to properly examine, scrutinize and discuss Shenley Park and its impact. Importantly, thi? also prevented a due & proper comparison testing of the three potential allocation sites. This is unfair and the modifications are not adequately
justified. I ask the Inspector to open a further hearing session at the end of the consultation period to rectify this defect, which could otherwise render the final plan unsound and therefore, potentially, unlawful.
2. The proposed modifications were made by AVDC without complying with its 'Duty to Cooperate' with the adjoining authority (being MKC). Whilst AVDC stated that it kept MKC informed, no records or minutes have been provided to evidence effective discussions or proper joint working. It was acknowledged by MKC at the Full Council Meeting on 23 Oct 2019 that a failure to cooperate had occurred. This breach of Government guidelines and national policy may affect the soundness of the plan. I therefore ask the Inspector to reopen the hearing sessions to allow AVDC to adequately respond.
2.1. This failure to cooperate is particularly concerning as the AVDC Local Plan fails to take into account the strategies stated in the MKC Local Plan, in particular in terms of MK's proposed development areas, infrastructure, accessibility and biodiversity aims.
This casts serious doubt on the effectiveness of the AVDC Local Plan where it is not
aligned with the MKC Local Plan.
2.2. Further issues arise in respect of the proposed distribution of S 106 payments, or indeed the complete lack of discussion regarding CIL payments. All three proposed sites are located in immediate proximity of Milton Keynes. As a result, residents will primarily use MK's public services, in particular for healthcare, policing, ambulance, fire services, education etc. This was even acknowledged in the proposed modification MM076. Yet, the AVDC Local Plan fails to address or mitigate the respective strain on MK's infrastructure. In fact, there is a fundamental mismatch between the two local authorities' treatment of developer's contributions: Whilst MKC operates a tariff system under the CIL regime (with a guaranteed amount paid per dwelling), AVDC have not yet started preparing for the adoption of CIL; this is only expected to commence .afm[ the Local Plan is adopted. Instead, AVDC rely on the S106 method which is open to
developer debate and challenge, therefore potentially delaying the Local Plan's delivery.
And yet, this discrepancy was not remedied by way of 'proper joint working'. I therefore ask the Inspector to re-open the hearing to allow for full discussion of the above points.
3. AVDC uses the Sustainability Appraisal (SA) as main evidence for its decision to favour Shenley Park over suitable alternatives at Eaton Leys and Salden Chase. However, it
appears that the SA fails to adequately discuss and appraise some important aspects of Shenley Park in terms of landscape, traffic & highways and biodiversity, therefore casting serious doubt on the completeness and effectiveness of the document. Importantly, the document completely omits the importance of the North Bucks Way (Bridleway). This is not justified. Without duly considering the importance of this ancient landscape boundary,
natural habitat and wildlife corridor, the report's soundness is seriously jeopardised, in particular its reasoning and conclusions regarding the sites' landscape and biodiversity aspects. I therefore urge the Inspector to re-open the hearing to be able to adequately discuss and assess the impact of interrupting the North Bucks Way by the proposed grid road extensions.

Object

VALP Main Modifications

Representation ID: 3659

Received: 17/12/2019

Respondent: Mr John Collinge

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

Officer's summary
The recently agreed development at Shenley Park refers to "at least 1,150" houses. The site promoters are planning for 1,800 houses. I cannot see any provision for a secondary school in compliance with Bucks County Council policy. See the Sustainability Appraisal Addendum. (MM076)
I think there is a legal requirement to have consulted and co-operated with adjacent planning bodies.

Change suggested by respondent:

Not stated

Full text:

I would like to record my objections with you on the Main Modifications to VALP. I've included the 'MM' numbers to make the match easier to various modifications. It is a complex document.
I think the public examination should be formally re-opened. There are many reasons; these are detailed below.
The effect of Transport for Shenley Park, Whaddon have not been properly modelled or considered, if they are estimated in a similar method to Salden Chase. Each morning and evening, the long traffic jams along or near the A421 show that the roads near west MK are full. This is before Tattenhoe Park and Kingsmead have been completed. If there is any new build at Salden Chase, or Whaddon, it will just get much worse. The traffic jams will get longer. A proper defendable traffic analysis must be completed before an approval is given. Infrastructure before expansion would be the only way considered way forward. Unfortunately, this does not seem to be part of the process and plan. It must be addressed. (MM007, 010, 076)
There does not seem to be a proper review and assessment of the provision of public services such as Health Services. The increased demand on NHS, emergency services and waste disposal have not been properly considered. (MM007, 010, 076)
How to avoid Coalescence does not appear to have been clearly defined for Mursley, Newton Longville or Far Bletchley. There needs to be proper detail on how this will be avoided. There is only a brief mention that it will be avoided, but not how. (MM013, 014, 031)
As we know from the rejection of Salden Chase by Milton Keynes Council, simply being close to Milton Keynes makes not make a development sustainable. All the social and infrastructure burden will be on MK rather than Aylesbury Vale. These proposed expansions do not detail how they will be made sustainable so currently reduce sustainability and reduces quality of life. (MM070, 076)
The recently agreed development at Shenley Park refers to "at least 1,150" houses. The site promoters are planning for 1,800 houses. I cannot see any provision for a secondary school in compliance with Bucks County Council policy. See the Sustainability Appraisal Addendum. (MM076)
I think there is a legal requirement to have consulted and co-operated with adjacent planning bodies. It does not looks like this happened as there does not seem to be compliance with the adopted policies in the Plan:MK for development. As mentioned above, the motions passed by the full council of Milton Keynes Council about both Salden Chase and "Shenley Park" at Whaddon raise serious questions about AVDC's compliance with the 'Duty to Cooperate.' (MM072 to 076)
For all the above reasons I wish to object to the VALP Main Modifications, especially about Newton Longville and ask that the public examination be reopened.

Object

VALP Main Modifications

Representation ID: 3663

Received: 17/12/2019

Respondent: Jackson Planning Ltd ( Lisa Jackson)

Legally compliant? Yes

Sound? No

Representation Summary:







This site allocation is not effective and not justified by evidence as the evidence was flawed and partial, it is not positively prepared, and it is inconsistent with National Policy. The sustainability appraisal carried out to look at the three sites concluded that Shenley Park did not necessarily follow as the most suitable or sustainable overall. Shenley Park performed poorly in respect of community objectives.
The choice of sites for assessment in the sustainability appraisal is not justified. Yet it was selected in preference to a more extensive allocation at Salden Chase.

Change suggested by respondent:

Revisit the allocations for Milton Keynes to reflect MK Future 2050 and aspirations for EW rail and the NIC growth arc
aspirations. However, it is difficult to see, given the clear direction by the Inspector from the interim findings, how a fair
and reasonable assessment of the site options can proceed. The lack of consultation about the additional work and
evidence presented has denied the representor's legitimate interests and involvement in the plan preparation. It is not
clear why the comparative landscape assessment chose the three sites and their boundaries. This should have been subject to public consultation. This makes the evidence base questionable and any recommendations that flow from it flawed and challengeable. What is required is a move away from the piecemeal planning that has dogged MK for the last decade and return to strategic thinking and planning. At the very least the broad direction of growth needs to be identified for any allocated
site to fit within to meet the National Planning Policy Framework

Full text:

The Council modification to add the new site D-WHA001 is not properly justified by evidence.
The selection of this site over the more extensive allocation at Salden Chase is not justified by sound evidence. The landscape appraisal (Landscape and Visual Appraisal Capacity Comparison Assessment) considered a different parcel of
land with significantly more mitigation than that allocated. It is not the correct or proportionate evidence base. The SA disagreed with the conclusion of the landscape assessment.
In addition, the landscape appraisal did not consider the more logical development at Salden Chase, promoted by this objector keeping all development north of the natural ridge of Weasle Lane that avoided the higher land with extensive
views south of the and they chose an irregular parcel shape, that does not reflect the grid pattern of MK.
The new policy again shows the flawed thinking that fails to embrace the transformational growth agenda. The new areas of the city should not be considered as extensions or 'bolt-ons' but properly integrated neighbourhoods designed to work with the original masterplan concept. The AVDC plan modifications do not do this, this site D-WHA001 is a poorly planned 'bolt on' rather than part of the strategic vision for the city in an expanded arc of development.
This is yet again an example of piecemeal planning that has dogged the proper planning of the area for the past decade since the demise of the South East Plan.c

Object

VALP Main Modifications

Representation ID: 3666

Received: 03/12/2019

Respondent: Mrs Jill Aitken

Legally compliant? No

Sound? No

Representation Summary:

Protect Whaddon and surrounding area and wildlife.
MM076 - area not appropriate for development as the village of Whaddon would not cope. It already has over 2,000 cars travelling through daily. No infrastructure, damage to landscape, biodiversity. Should be near a railway station.

Change suggested by respondent:

Other areas should be considered e.g. Eaton Leys, Bletchley. Salden Chase or Newton Longville but preferably another area where the infrastructure can cope & town benefit therefore MM076 must be deleted from VALP and must not be allowed to ruin this outstanding area of natural beauty.

Full text:

MM076 must be deleted from the VALP before adoption. This is not a appropriate area as it will destroy the village of Whaddon. This has not been discussed appropriately.
We already have over 2,000 cars passing through the village daily and our small village cannnot cope.
Shenley Park wasn't included in Nov 2017 Plan (VALP) therefore a breach of NPPF paragraphs 158 & 182. Unfair and unjust to introduce Shenley Park late in discussions therefore hearing should be re-opened at the end. Damage to landscape & biodiversity. No infrastructure to support such a big development. Insufficient consultation.
Wildlife must be protected/open spaces protected, Whaddon protected.