Aylesbury Vale Area

MM210

Showing comments and forms 1 to 18 of 18

Object

VALP Main Modifications

Representation ID: 2870

Received: 07/12/2019

Respondent: Mr Richard Makepeace

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

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

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

Full text:

Dear Sir,

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

Oxford to Cambridge expressway

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

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

HS2

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


Housing needs

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

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

Yours faithfully

Object

VALP Main Modifications

Representation ID: 2877

Received: 07/12/2019

Respondent: Susan Makepeace

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

Oxford to Cambridge expressway

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

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

Full text:


Dear Sir,

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

Oxford to Cambridge expressway

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

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


Housing needs

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

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

HS2

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

Yours faithfully

Object

VALP Main Modifications

Representation ID: 2886

Received: 08/12/2019

Respondent: Mr & Mrs Shirley & Raymond Cox

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

In the modified Plan, the Oxford - Cambridge Expressway is referred to several times. We would have expected the Council to build this major road infrastructure project fully into their plan at this stage. They have deleted the reference from their Spatial Vision (para 2.4d) and from the list of major infrastructure projects requiring co-operation (para 3.39) and they state (para 3.81) only that they may potentially consider it at some unspecified point in the future. They have also deleted their declared support for the project (modified policy T3 at paragraph 7.21).
We do not believe this is the most appropriate strategy when considered against reasonable alternatives.

Full text:

Dear Sirs
Oxford - Cambridge Expressway

In the modified Plan, the Oxford - Cambridge Expressway is referred to several times. We would have expected the Council to build this major road infrastructure project fully into their plan at this stage. They have deleted the reference from their Spatial Vision (para 2.4d) and from the list of major infrastructure projects requiring co-operation (para 3.39) and they state (para 3.81) only that they may potentially consider it at some unspecified point in the future. They have also deleted their declared support for the project (modified policy T3 at paragraph 7.21).
We do not believe this is the most appropriate strategy when considered against reasonable alternatives.

Housing numbers

In the modified Plan, housing numbers for several large developments have been raised.
* D-AGT1 has been modified to raise housing from "around 1,000" to "at least" 1,000.
* D-AGT2 from "around 1,550" to "at least 1,590".
* D-AGT3 from "around 1,660" to "at least 1,757"
* D-AGT4 from "around 3111" to "at least 3358"
* D-HAL003 from "around 1,000" to "at least 1,000"

The road network in the Aylesbury area is already congested, yet the Plan shows no evidence of any updated transport assessment based on these new figures.
The modified Plan fails to address the traffic congestion these new houses would generate. We both have to leave for work for work much earlier to avoid traffic delays. When there are any roadworks, water leaks, accidents etc. Aylesbury literally grinds to a halt. We are also concerned about the level of air pollution that would be generated.
We do not believe AVDC and BCC have planned fairly for the effects of traffic and strongly disagree that this seeks to meet objectively assessed development and infrastructure requirements.

HS2

The area D-AGT2 is stated as being dependent on the delivery of HS2 (para 4.44 and elsewhere). Yet no decision as to this project has been taken. The Plan cannot be approved until that final decision.
We feel work relating HS2 should not commence until the project has been finally approved, thus avoiding unnecessary devastation to the countryside, not to mention wasting vast amounts of money.

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

Yours faithfully

Object

VALP Main Modifications

Representation ID: 2892

Received: 08/12/2019

Respondent: Mr Damian Campbell

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

Oxford - Cambridge expressway reference is deleted from their Spatial Vision (para 2.4d) and from the list of major infrastructure projects requiring co-operation (para 3.39) but In para 3.81 the Council has seen fit to merely state that they may "Potentially consider it at some unspecified point in the future". They have also deleted their declared support for the project (modified policy T3 ).
The new plans hardly demonstrate the most "Appropriate" strategy when there are other reasonable alternatives available. (officer summary)

Full text:

Attn: The Planning officer for the VALP

Sir / Madam

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

Thank you in advance.

Kind regards




Oxford - Cambridge Expressway

In the modified Plan, the Oxford - Cambridge Expressway is referred to several times. One would have expected the AVDC and BCC to include this major road infrastructure project fully into their plans. However, not only have they have deleted the reference from their Spatial Vision (para 2.4d) and from the list of major infrastructure projects requiring co-operation (para 3.39) but In para 3.81 the Council has seen fit to merely state that they may "Potentially consider it at some unspecified point in the future". They have also deleted their declared support for the project (modified policy T3 at paragraph 7.21).

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




Housing numbers

In the modified Plan, housing numbers for several large developments have been raised.
D-AGT1 has been modified to raise housing from "around 1,000" to "at least" 1,000.
D-AGT2 from "around 1,550" to "at least 1,590".
D-AGT3 from "around 1,660" to "at least 1,757"
D-AGT4 from "around 3111" to "at least 3358"
D-HAL003 from "around 1,000" to "at least 1,000"

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

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


HS2

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

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

Object

VALP Main Modifications

Representation ID: 2898

Received: 09/12/2019

Respondent: Jennifer kruppa

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

I am mystified as to why you state that you may potentially consider the Oxford - Cambridge Expressway at some point in the future. Surely this must be looked at and planned for NOW! The Expressway is a major project for the UK that requires joined up thinking and a large amount of new infrastructure in the Vale of Aylesbury. The Local Plan is an opportunity to lay down plans for this. You have skirted around the issue in your modifications and it looks as if you are unable to plan in a cohesive, forward thinking way. I do not agree that this is justified as the most appropriate strategy when considered against reasonable alternatives.

Full text:

Dear Planning Department

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

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


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


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



Kind regards


Object

VALP Main Modifications

Representation ID: 2904

Received: 10/12/2019

Respondent: Mr Brian Tattam

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

In connection with the Oxford to Cambridge expressway, I fail to understand the reasoning behind the AVDC and BCC
deleting their declared support for this project. There would appear NO strategic thinking or planning is behind this
decision. I do not believe this is "justified as the most appropriate strategy when considered against reasonable
alternatives".

Full text:

Dear Sir,

Comment on the VALP Main Modifications

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

Object

VALP Main Modifications

Representation ID: 2910

Received: 07/12/2019

Respondent: Mr David Locke

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

The modifications to the VALP have deleted reference to the Expressway from its Spatial Vision (para 2.4d) and from the list of major infrastructure projects requiring co-operation (para 3.39).
The Plan says only that the Expressway may possibly be considered at some point in the future.
The plan no longer declares its support for the Expressway project (modified Policy T3 at paragraph 7.21).
How can this possibly be a sensible attitude to take? (officer summary)

Full text:

Dear Sirs

Comment on the VALP main Modifications

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

Oxford - Cambridge Expressway

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

Housing numbers

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

HS2

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

Conclusion

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

Yours faithfully,

Object

VALP Main Modifications

Representation ID: 2947

Received: 11/12/2019

Respondent: Buckingham Town Council

Legally compliant? No

Sound? No

Representation Summary:

Key transport strategies from BTS are identified for medium term as A413 road improvements and the A422 left hand slip road. The cost of A413 improvements is "tbc" in T3 so there is no available evidence to suggest that this will be deliverable by developer contributions any more so than the Western Relief Road which has not been included in T3 schemes here - presumably on non deliverability grounds - otherwise it is the highest scoring mitigation in BTS. This is not consistent.

Change suggested by respondent:

Status of the Buckingham Transport Strategy is not clear and treated inconsistently throughout the plan. Revised transport modelling and a changed approach is required.

Full text:

Key transport strategies from BTS are identified for medium term as A413 road improvements and the A422 left hand slip road. The cost of A413 improvements is "tbc" in T3 so there is no available evidence to suggest that this will be deliverable by developer contributions any more so than the Western Relief Road which has not been included in T3 schemes here - presumably on non deliverability grounds - otherwise it is the highest scoring mitigation in BTS. This is not consistent.

Object

VALP Main Modifications

Representation ID: 3090

Received: 17/12/2019

Respondent: AVDC Councillor

Legally compliant? Yes

Sound? No

Representation Summary:

The Buckingham Transport Strategy has some very useful proposals which I see are included in this updated paragraph, but two key items are missing: The A421/A422 link road and the west street/town centre environmental improvements.

Change suggested by respondent:

Add these elements of the BTS to this paragraph.

Full text:

The Buckingham Transport Strategy has some very useful proposals which I see are included in this updated paragraph, but two key items are missing: The A421/A422 link road and the west street/town centre environmental improvements.

Support

VALP Main Modifications

Representation ID: 3208

Received: 11/12/2019

Respondent: South Oxfordshire District Council

Representation Summary:

South Oxfordshire District Council notes that Aylesbury Vale District Council's
position in relation the Oxford to Cambridge Expressway has subsequently changed
since the submission of the plan. Aylesbury Vale no longer supports the proposal
which has resulted in modifications to Policies T2 and T3. South Oxfordshire District
Council recognises that these changes may be necessary to reflect the updated
political position of the council. However, we would like to ensure the council
continues to engage and work collaboratively with neighbouring authorities and
statutory bodies under the requirement of duty to co-operate to understand the
impact and required mitigation associated with the Oxford to Cambridge Expressway.

Full text:

Dear Sir/Madam
South Oxfordshire District Council response to the Aylesbury Vale Local Plan Main Modifications Consultation.
Thank you for giving South Oxfordshire District Council (SODC) the opportunity to comment on the Main Modifications Consultation documents. Having reviewed the modified Local Plan and supporting documents, SODC can confirm that we are satisfied the modified plan is sound, legally compliant and justified.
We acknowledge that the housing requirement has increased from 27,400 to 28,600 in addition with the number of homes to be delivered in the plan period which includes an increased buffer of 5.7% to account for under delivery. Overall, this results in 30,233 homes planned for in the modified plan. Further to this, the increased housing requirement of the modified plan is largely to be met on one additional site in the north east of the district on the edge of Milton Keynes and with amendments to site capacities.
SODC does not consider that changes to the housing requirement for the Aylesbury Vale Local Plan or additional allocations will have any significant negative effect on South Oxfordshire.
South Oxfordshire District Council supports the modification of the plan to remove reference to the need for an early review as this plan appropriately deals with the issues at hand. Additionally, the council supports the deletion from the supporting text in paragraph 3.15 which states 'We expect a new settlement to form part of that Local Plan'. While we acknowledge this may be necessary in the future to account for any changes in national policy and the impact of nationally important infrastructure projects, we believe the approach to distributing growth cannot be predetermined and must follow due process based on the most up to date evidence base.
South Oxfordshire District Council, 135 Eastern Avenue, Milton Park, Abingdon, Oxfordshire
OX14 4SB www.southoxon.gov.uk
South Oxfordshire District Council notes that Aylesbury Vale District Council's
position in relation the Oxford to Cambridge Expressway has subsequently changed
since the submission of the plan. Aylesbury Vale no longer supports the proposal
which has resulted in modifications to Policies T2 and T3. South Oxfordshire District
Council recognises that these changes may be necessary to reflect the updated
political position of the council. However, we would like to ensure the council
continues to engage and work collaboratively with neighbouring authorities and
statutory bodies under the requirement of duty to co-operate to understand the
impact and required mitigation associated with the Oxford to Cambridge Expressway.
Kind Regards
Ryan Hunt
Planning Officer

Object

VALP Main Modifications

Representation ID: 3363

Received: 17/12/2019

Respondent: Ms Julie Williams

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

(Officer's summary)
Firstly the withdrawal of positive support of the Oxford /Cambridge Expressway road.
We feel that this is a short sighted move and is this the most appropriate strategy when considered against reasonable alternatives? The new road will reduce congestion on alternative routes and improve not only the lives of those living in the surrounding areas but will open up the job opportunities for those potentially new house buyers/renters in the new houses being built.

Change suggested by respondent:

No comment provided

Full text:

We writing to raise our concerns regarding the proposed Modified Vale of Aylesbury plan.

Firstly the withdrawal of positive support of the Oxford /Cambridge Expressway road. We feel that this is a short sighted move and is this the most appropriate strategy when considered against reasonable alternatives? The new road will reduce congestion on alternative routes and improve not only the lives of those living in the surrounding areas but will open up the job opportunities for those potentially new house buyers/renters in the new houses being built.
An unspecified point in the future is a not a solution to the problem and indeed cause potentially cause more problems/inconvenience in the future.

Secondly, we are very concerned of the potential implications of the increase in housing numbers from 6,771 to approx. 8705 homes on top of the housing projects already underway or completed. leading to the population increasing by at least 40,000 many of whom will be driving - if not immediately then in the foreseeable future- adding additional 35,000 cars to an already congested traffic system( have you tried to drive into/around/through Aylesbury/Stoke Mandiville during normal working hours - it adds additional time and pollution to any journey).
The Planners need to seek to meet the objectively assessed development and infrastructure requirements to build the housing proposed and that already agreed and built.By that I mean schools( both primary and senior),doctors and surgeries, hospital beds, social services, policing ,refuse collection, jobs and bus routes etc.
It is not just Stoke Mandiville that will be affected by this proposal but also the surrounding villages such as Weston Turnville and Aston Clinton, both of which has already had numerous new housing developments built in the last 5 years, which has added to vehicular congestion. David Liddington MP was aware of the issue in Aston Clinton was trying to help to reduce the traffic concerns of local residents prior to the election and hopefully Robert Butler MP will continue to do so.

Thirdly, D-AGT2 is a crucial part of the proposal and is reliant on HS2 being approved .
Have the planners looked at an alternative if HS2 is not approved in regards to current proposed building/planning and how would it meet the current objectively assessed development and infrastructure requirements.

Lastly ,how does the planning of infrastructure and development requirements of the Aylesbury Garden Town proposal impact on Modified Aylesbury Vale Plan?

We are both concerned that Aylesbury Vale is has not looked fully at the impact on their existing residents when undertaking this plan( which we are given to believe includes taking on new housing requirements of neighbouring areas- Chesham) and not building the infrastructure that actually support that development. They are turning it from an area where people chose to live to an area where they don't.

Object

VALP Main Modifications

Representation ID: 3378

Received: 17/12/2019

Respondent: David Lock Associates

Legally compliant? No

Sound? No

Representation Summary:

Policy T3 is unsound in failing to respond positively to the planning and delivery of infrastructure and failing to deliver necessary infrastructure accepted in the evidence base.
The infrastructure that must be included in the Plan according to the evidence base is the Western Link Road.
To deliver this - all allocations at Buckingham or Maids Moreton should be deleted and allocations comes forward through the neighbourhood Plan OR that all sites including BUC051 and BUC025 are allocated. The WLR can be delivered within the control of HLM(B) and New College.

Change suggested by respondent:

In Buckingham contributions to the Buckingham Transport Strategy are required of the allocated sites.
Policy T3 as amended by MM270 is insufficient to demonstrate that the plan will be effective in planning for and delivering key infrastructure.
It lists/picks the simplest elements of the BTS. However, it fails to make reference to the key element of the strategy - the WLR - which is set out in the evidence base and IDP as necessary to relieve existing traffic issues and to address growth in any location at Buckingham. The WLR can be delivered within the control of HLM(B) and New College - and can then be included in the VALP or worked through in the update of the Buckingham Neighbourhood Plan that has already commenced.
In the absence of any such reference and mechanism to most effectively realise the WLR Policy T3 should not be found
Main modification 270 should be extended by the inclusion of the WLR to be delivered through developer contributions - requiring specific contributions from all allocations. Failure to include the WLR which benefits and mitigates ALL Buckingham developments will leave a high level of risk that no progress will be made to delivering the key infrastructure in Buckingham.
Additional amendments to the modification should:
* require the delivery of the key infrastructure measures listed in T3
* to confirm that the WLR road will need to be funded by developer contributions;
* seek to stress that delivery will require through co-operation and enabling development with and in respect of land associated with the delivery of the WLR
* include an indicative route for the WLR in a modification to the Policies Map for Buckingham.

Full text:

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

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

REP to MM070

NO SUMMARY PROVIDED.

FULL TEXT

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

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

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

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

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


REP to MM082

SUMMARY


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

FULL TEXT

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

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

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

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

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

REP to MM083

SUMMARY

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

FULL TEXT


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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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


REP TO MMO84

SUMMARY

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

FULL TEXT

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

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

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

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

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

REP TO MM0210

SUMMARY

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

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

FULL TEXT

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

SUMMARY

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

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

REP to MM210

FULL TEXT


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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

SUMMARY

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



Object

VALP Main Modifications

Representation ID: 3399

Received: 17/12/2019

Respondent: David Lock Associates

Legally compliant? No

Sound? No

Representation Summary:

(HLM(A)) welcomes the amendment of the Policy T3 to include those key infrastructure elements from the Aylesbury Transport Strategy (ATS) upon which the Plan depends, specifically, the North East Link Road at Aylesbury within T3. The North East Link Road is essential to mitigate the impacts of the development proposed in the VALP at Aylesbury and, in particular, in Policy D1 of the Plan.
However, Policy T3 as proposed to be modified by MM210, has not addressed the fundamental issue of delivery of the North East Link Road.

Change suggested by respondent:

In virtually all other respects the remaining elements of planned infrastructure in T3, at Aylesbury, are to be secured through developer contributions. In the absence of any reliance on funds being placed or even welcomed from the Cambridge-Oxford Expressway, an alternative mechanism for the delivery of the North East Link must be set out in the Local Plan.
This will require an amendment to the modification:
* to require the delivery of the key infrastructure measures listed in T3
* to confirm that the North East Link road will need to be funded by developer contributions;
* that such developer contributions will be required to be secured from existing allocations and through co-operation and enabling development with and in respect of land associated with the delivery of the North East Link Road (including for instance site BIE021 - in respect of which extensive representations have been made throughout the Examination process).
A modest high quality allocation on a part of BIE021 would provide a delivery mechanism for the North East Link Road.
A modification to the Policies Map for Aylesbury to include an indicative route for the North East Link - along with the other 9 links listed in T3 and shown on the Policies Map.

Full text:

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

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

REP to MM070

NO SUMMARY PROVIDED.

FULL TEXT

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

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

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

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

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


REP to MM082

SUMMARY


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

FULL TEXT

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

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

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

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

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

REP to MM083

SUMMARY

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

FULL TEXT


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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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


REP TO MMO84

SUMMARY

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

FULL TEXT

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

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

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

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

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

REP TO MM0210

SUMMARY

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

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

FULL TEXT

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

SUMMARY

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

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

REP to MM210

FULL TEXT


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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

SUMMARY

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



Object

VALP Main Modifications

Representation ID: 3458

Received: 16/12/2019

Respondent: Mr Andrew Smith

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

Oxford - Cambridge Expressway:
More effort should have been put into assessing the strategic implications of the Expressway and planning ahead for a number of realistic alternatives to ensure a sound result.
HS2:
Like most people in this part of Bucks, given the changes in costs and benefits of HS2, I am waiting on the decision as to whether this project will go ahead, in what form and on what timescale.

Full text:

The following are my comments on the VALP Main Modifications:

Oxford - Cambridge Expressway:
I am disappointed that this has not had more focus so that we can begin to understand exactly how the impact of this is being assessed since it appears to be one of the major investments promised by the new government. More effort should have been put into assessing the strategic implications of the Expressway and planning ahead for a number of realistic alternatives to ensure a sound result.

Housing Numbers:
The increase in housing numbers for large developments raises the question of the modifications required in Aylesbury's over-congested road network to cope with these. I can see no evidence of these. In the case of Hampden Fields development this has moved from an initial 3,000 to "around 3,111" and now to "at least 3,358". I find the process and result confusing - on the one hand we use words such as "around" and "at least" indicating a degree of approximation and on the other hand precise numbers such as 1,757 / 3,358. Net result I must question the soundness of the process. In the case of Hampden Fields, I worry that this creep from the original 3,000 to 3,358 affects the value of the traffic analysis used in the Hampden Fields proposals and the capability of the proposed infrastructure to cope with these increases.

HS2:
Like most people in this part of Bucks, given the changes in costs and benefits of HS2, I am waiting on the decision as to whether this project will go ahead, in what form and on what timescale.
Given the significance of this, I maintain that it will be unsound to proceed with the present VLAP until this decision has been made and the impacts have been assessed and incorporated.

If cancelled or radically changed then without the funds for our local road system included in the HS2 proposal I believe that AVDC/BCC will be unable to fund their plans. i.e the VLAP as it stands has not been prepared to meet objectively assessed development and infrastructure requirements under these differing conditions.

Object

VALP Main Modifications

Representation ID: 3480

Received: 15/12/2019

Respondent: Susan & Rex Horton

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

Oxford to Cambridge Expressway

The Modified Plan make reference to this project several times, but fails to link any road infrastructure projects into the plan. They have also deleted reference to any major infrastructure projects that require co-operation (para 3.39) and state they may (para 3.81) consider them at some unspecified time in the future. It would also appear that they no longer support the project.
This does not give a very good account of the AVDC and BCC strategic thinking and planning. How does this make you feel and what do you make of it?

Full text:

We feel that this Modified Local Plan has a number of major flaws and should not be submitted to the Inspector in it's current form.

Housing Numbers

It shows an increase in the number of New Home planned for the larger developments D-AGT1, D-AGT2, D-AGT3 and D-AGT4 and fails to take into account the number of new homes currently being constructed on a large number of developments in Aylesbury, Stoke Mandeville, Bishopstone, Aston Clinton, Weston Turville, Bierton and Marsworth. These current development are considerably adding to the strain being put on the local infrastructure, eg. roads, trains, education, doctors and hospitals etc. The new increased numbers of new homes shown in the modified plan, will only reduce the quality of life in the area.
All major routes in and out of Aylesbury are already heavily congested now, with vehicles often travelling at walking pace at peak times. This plan offers no change to the current situation and vehicle movements will only get worse.
What does this say about AVDC and BCC's strategic thinking and planning? How does this make you feel? Could you agree or disagree that this is the best strategy when there are reasonable alternatives to be considered, what are your thoughts ?
HS2
The Plan relise heavily on funds being made available from HS2 (para 4.44) to construct the area D-AGT2. However this project is under threat and no final decision has been made on whether it will scrapped or goes ahead. The Plan cannot be approved until there is a final decision on HS2.
Surely this is not the best strategy when there are reasonable alternatives to be considered, what does it say about AVDC and BCC's strategic thinking and planning? What do you make of this?

Oxford to Cambridge Expressway

The Modified Plan make reference to this project several times, but fails to link any road infrastructure projects into the plan. They have also deleted reference to any major infrastructure projects that require co-operation (para 3.39) and state they may (para 3.81) consider them at some unspecified time in the future. It would also appear that they no longer support the project.
This does not give a very good account of the AVDC and BCC strategic thinking and planning. How does this make you feel and what do you make of it?

Earlier Planning applications have been rejected by the government Inspector on the basis of the Aylesbury Road Network will not cope with the increase of traffic flow. However this plan shows there will be a considerable increase in the number of vehicles on our roads but fails to produce an update of any transport assessment based of the new homes to be built.

Object

VALP Main Modifications

Representation ID: 3548

Received: 15/12/2019

Respondent: Hampden Fields Action Group

Legally compliant? Yes

Sound? No

Representation Summary:

1. The modified Plan references the Buckinghamshire County Model
and the Aylesbury Transport Study as its evidence base for many
schemes. Both the Model and the Study are unsound. Therefore, neither of the key components of the modified Plan's
transport evidence base provide objectively-assessed
requirements nor proportionate evidence.
2. These issues also mean that the strategy already lacks "integrity"
3.A confident BCC £200m bid to
the Housing Infrastructure Fund for these 'critical' roads was
expected to have succeeded by May 2019 but has still not done so
six months later.
4. Further comments on specific schemes made
(officer summary)

Change suggested by respondent:

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

Full text:

see attachments

Support

VALP Main Modifications

Representation ID: 3573

Received: 17/12/2019

Respondent: Barwood Development Securities Limited

Agent: Turley Associates

Representation Summary:

Barwood support the fact that Policy T3 of the VALP continues to support key transport proposals including those identified in both the Aylesbury Transport Strategy and Buckingham Transport Strategy. In addition, the table to be
included within Policy T3 is to be supported as a matter of principle insofar as it also identifies wider transport schemes which are to be protected and supported. In particular, Barwood welcome the specific references to the 'Aylesbury Vale wide' measures including the 'East West Rail - Bicester, to Winslow, MK and Aylesbury - Includes new station'.

Full text:

See attachment

Object

VALP Main Modifications

Representation ID: 3665

Received: 17/12/2019

Respondent: Jackson Planning Ltd ( Lisa Jackson)

Legally compliant? Yes

Sound? No

Representation Summary:

T2 and T3 - Oxford Cambridge Expressway
The plan is not positively prepared if it fails to prepare for the Oxford Cambridge Expressway by removing reference to it from the plan. The Council's resolution to oppose the route is not consistent with National Policy and on this basis the plan is unsound.
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 and the failure of AVDC to grasp the transformational change that is planne

Change suggested by respondent:

Recognise the aspirations EW rail, the Oxford to Cambridge expressway and the NIC growth arc aspirations.

Full text:

T2 and T3 - Oxford Cambridge Expressway
The plan is not positively prepared if it fails to prepare for the Oxford Cambridge Expressway by removing reference to it from the plan. The Council's resolution to oppose the route is not consistent with National Policy and on this basis
the plan is unsound. 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 and the failure of AVDC to grasp the transformational change that is planned for the area.