Aylesbury Vale Area

FMM089

Showing comments and forms 1 to 8 of 8

Object

VALP Further Main Modifications

Representation ID: 3714

Received: 23/01/2021

Respondent: Mr John Oliver

Legally compliant? Yes

Sound? No

Representation Summary:

The status of ELR(S) and SLR has been reduced from critical to required in Policy T3 at FMM089.
Meanwhile, other planning applications affecting A41 traffic have been approved or recommended contingent on mitigation works to be secured from ELR(S) and SLR.
Kingsbrook has produced unacceptably increased rat-running on Broughton Lane, the remedy for which now depends on those two schemes.
Therefore, they remain critical for reducing that and A41 congestion, which is a Highway Authority statutory duty.

Change suggested by respondent:

In particular, ELR(S) must remain critical to existing and further development in East Aylesbury.

Full text:

The status of ELR(S) and SLR has been reduced from critical to required in Policy T3 at FMM089.
Meanwhile, other planning applications affecting A41 traffic have been approved or recommended contingent on mitigation works to be secured from ELR(S) and SLR.
Kingsbrook has produced unacceptably increased rat-running on Broughton Lane, the remedy for which now depends on those two schemes.
Therefore, they remain critical for reducing that and A41 congestion, which is a Highway Authority statutory duty.

Object

VALP Further Main Modifications

Representation ID: 3726

Received: 04/02/2021

Respondent: Mr John Oliver

Legally compliant? No

Sound? No

Representation Summary:

Officer note - rep was submitted against FMM001 but changed to FMM089.

As a Chartered Civil Engineer and Fellow of CIHT I consider the plan fails to recognise the duty of the Highway Authority to provide and maintain a safe, effective and efficient strategic highway network for Aylesbury and its environs. That duty is a statutory obligation and must not be constrained by planning needs or aspirations on individual sites.

Change suggested by respondent:

Recognise the urgent need to reduce the network susceptibility to traffic congestion and to increase highway capacity in line with already committed development.

Full text:

As a Chartered Civil Engineer and Fellow of CIHT I consider the plan fails to recognise the duty of the Highway Authority to provide and maintain a safe, effective and efficient strategic highway network for Aylesbury and its environs. That duty is a statutory obligation and must not be constrained by planning needs or aspirations on individual sites.

Object

VALP Further Main Modifications

Representation ID: 3761

Received: 09/02/2021

Respondent: Mr Phil Yerby

Legally compliant? Yes

Sound? No

Representation Summary:

1) The Traffic modelling/evidence base is inadequate & non compliant with NPPG, based on outdated 2013 data.
2) The, mainly roads-based, transport strategy does not address through commuting/cross-town commuting.
3) It is not effective because It encourages more/longer car journeys, generating more CO2 producing miles, those entering the town should be encouraged to use public transport/park and ride.
4) It does not address the existing congestion in Aylesbury but creates new congestion hotspots where new roads meet the existing network.
5) It is inconsistent with National Policy, counter to NPPF para 103 and fails to take into account TCPA guidance.

Change suggested by respondent:

The countywide model needs updating, as we have argued for many years, to reflect national guidance where significant new road infrastructure is involved.
Rather than start with fixed roads which the council have been promoting for years, options should be considered to reduce existing congestion in Aylesbury for example by considering moving of key infrastructure out of the existing town centre and considering many more model shift options than currently have been.
A new settlement may need to be considered if growth cannot be adequately accommodated at Aylesbury town.

Full text:

This submission is on behalf of the Hampden Fields Action Group. The following is a summary only. It must be read in conjunction with the full attached report from our transport consultants, Transport Planning Practice.

1) The Traffic modelling and evidence base are outdated and non compliant with NPPG. As major transport infrastructure is being proposed, the failure to comply with WebTAG guidelines is unacceptable. The VALP - in an area of huge proposed land-use changes which is also designated as a Garden Town - requires a more focussed modelling exercise and Transport Assessment than that so far undertaken. The data is now 8 years out of date. A new 2020 Aylesbury Transport Model has been released but not used in VALP while the Countywide Model remains outdated. As highlighted in the TPP report, the councils own consultants clearly caveat is limitations and use. Thus, proposed policy T3 not been positively prepared based on objectively assessed evidence.

2) The, mainly roads-based, transport strategy being proposed for Aylesbury is not justified.
In Appendix C, we include extracts from a report produced by Buckinghamshire County Council (BCC) in 2009. Whilst the report was based on travel surveys from 2005, it gives a good summary of local traffic patterns. BC have not offered any more recent comparative traffic analysis to the Local Plan Examination, although they have suggested to the Examination Hearings that such data might be available.

From the 2005 surveys, it was estimated that only 12% of traffic on Aylesbury’s roads was “through” traffic (external-external). This 12% would have been split between a range of permutations of cross-town movements between the seven main radial routes approaching the town.

3) We note that the largest concentrations of employment in the town are in the central area and along the A41 Bicester Road corridor. The A41 corridor is where the major business parks are located. This is shown very powerfully in the map attached on page 12 of the report, which is taken from page 20 of the Aylesbury Transport Strategy 2017 itself (located under VALP Transport supporting evidence). During the weekday morning peak period, many commuters are destined for the dark blue areas shown on the map. However, the proposed orbital road schemes will not improve access to these zones.

4) In planning a Garden Town, people making relatively local short distance internal-internal car journeys (i.e. with both origin and destination within the town) should be encouraged to switch to more sustainable modes. Otherwise, the proposed new orbital road system will, in many cases, result in longer car journeys than those that are currently made. This behaviour will increase vehicle kilometres travelled and will generate additional air pollution and carbon dioxide. Drivers coming into the town from outside (external-internal trips) should be encouraged to use public transport and park and ride facilities.
For these reasons, building a ring road to remove “through traffic” and cross-town traffic from central Aylesbury is not justified.

5) We conclude that on the basis of the available evidence, the proposed orbital road links will not function as a bypass. If they are designed to be used by local traffic, this runs counter to Garden Town principles to reduce vehicle kilometres travelled and encourage use of more sustainable modes. The roads are being proposed, mainly, as a means to “unlock” various development sites around the edge of the built-up area.
We note that the earlier versions of VALP, based on the Aylesbury Transport Strategy, envisaged virtually a complete ring road around Aylesbury. The FMMs contain half of the ring road to the east of the town. This major change is not adequately explained and justified by BC in the FMM background papers.

6) The proposed new T3 is not Effective
Setting aside our reservations about CSTM, our analysis based on the Do-Something Scenario 1A (with mitigation) modelling shows that many of the proposed junctions on the ring road links will be over-capacity in 2033. In the 2033 Do-Something 1A scenario (with mitigation) a driver approaching Aylesbury on the A418 north east, near Bierton, will have to navigate about 12 junctions to traverse the town on the “ring road” and reach the A418 to the south west. BC’s own traffic modelling shows that the driver would encounter congestion at many of the junctions in AM and PM peak periods. So, in practice, the small volumes of “through traffic”, and the cross town internal-internal trips, might well stay on the existing roads through the centre of the town.
Therefore, the effectiveness of the proposed transport mitigation has not been adequately demonstrated.

7) Proposed policy T3 (FMM089) is Inconsistent with National Policy
The proposed transport improvements are heavily focussed on road solutions with more sustainable modes - walking, cycling and use of public transport - receiving a very low priority. This is counter to NPPF Chapter 9 on promoting sustainable transport. NPPF Paragraph 103 states
“Significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. This can help to reduce congestion and emissions, and improve air quality and public health.”
Furthermore, the transport proposals in the VALP take no account of the principles that would be expected for a Garden Town, as embodied in the TCPA guidance.

Conclusion
It has not been adequately demonstrated that Policy T3 and the associated transport strategy for Aylesbury is:
• effective in mitigating the impacts of the proposed development; or
• consistent with National Policy in terms of enabling the delivery of sustainable development in Aylesbury.
Furthermore, the transport strategy, as presented, fails to address the priorities that would be expected for a Garden Town, as outlined in TCPA guidance.

Object

VALP Further Main Modifications

Representation ID: 3821

Received: 09/02/2021

Respondent: David Lock Associates

Legally compliant? Yes

Sound? No

Representation Summary:

The Plan (with FMM089) insofar as it relates to Buckingham is not positively planned and prepared or justified.
HLM is convinced of the need:
• for a comprehensive transport strategy founded upon or evolved from the BTS – and fully evidenced as being effective;
• for each allocation to be demonstrably capable of being mitigated
• to be crystal clear what allocations are specifically contributing towards in terms of highway and transport infrastructure.
Equally, HLM are convinced that the VALP with MM210 and FMM089 – plus the relevant site allocations – do not meet these tests which are at the heart of the NPPF soundness tests.

Change suggested by respondent:

(Officer addition - see attachment for formatting strike through and deleted text)
HLM has set out previously the changes required to address the failings of Policy T3 as proposed to be modified by MM210. These include requiring the delivery of key infrastructure and confirmation that the policy – and hence the contributions – should explicitly refer to, and be linked to, the Western Link Road. FMM089 changes T3 again yet do not assists with the overarching requirement that:
a) There should be certainty regarding the package of improvements required to address the identified transport issues in the town (including Town Centre congestion) and to mitigate the impact of new allocations
b) No planning permission will be issued unless a financial contribution is made towards this common package or measures on a fair and equitable basis
c) The measures proposed are specific costed and deliverable and consistent with the objectives of the BTS
d) That such a mechanism for delivering infrastructure should require developments or allocations to come forward, best planned through the forthcoming Buckingham Neighbourhood Plan review (noting that the costing of the measures required may necessitate additional allocations).
Specifically the third para of T3 as proposed to be modified by MM210 and FMM089 should be amended to reflect the above requirements and the specific circumstances of Buckingham. The first sentence of para 3 should be amended as follows: “Planning permission will not be granted for development that would not make a proportionate contribution to a comprehensive package of measures and transport measures prejudice or diminish the integrity of the Implementation of existing or protected and supported required transport schemes identified in the list below or as otherwise set out in settlement wide transport strategies”
Add to third para: “In the case of Buckingham, a comprehensive package of measures, including necessary supporting allocations should be set out in the review of the Buckingham Neighbourhood Plan”

Full text:

BUCKINGHAM SUBMISSION:

Sirs

Please find enclosed representations on the Further Main Modifications to the VALP – submitted on behalf of Hallam Land Management (Buckingham)

1 Hallam Land Management (Buckingham) [HLM(B)] has set out a number of objections to the policies of the submitted VALP, and also to the Main Modifications, insofar as the Plan and the Main Modifications relate to Buckingham and the planning and transportation strategy being set out therein.
2 Those objections to the submission version of the VALP were set out in some detail and heard at previous sessions of the Examination prompting, in part, the Inspector to set out a preliminary finding that the VALP in it is initial form was unsound in failing to include, in the VALP, the key infrastructure requirements upon which the delivery of the plan depends. This conclusion was drawn, by the Inspector, notwithstanding the generic references in the VALP to the Buckingham Transport Strategy (BTS) and the VALP IDP (which includes a broad range of infrastructure projects to be implemented in Buckingham - including the Buckingham Western Link Road (WLR) and West Street/High Street Route downgrade). HLM(B) is not aware that the IDP or Buckingham Transport Strategy has been updated since the earlier sessions of the examination. Therefore, they are intended to continue to underpin the Plan.
3 AVDC sought to address the Inspectors concerns, in Main Modification 210 (August 2019) by setting out, in Policy T3, the transport projects it would support in each location of the District. In Buckingham a number of schemes from the Buckingham Transport Strategy and the VALP IDP were included in Policy T3, through MM210, albeit not the WLR nor the High Street/West Street works.
4 MM082 and 084 also amended the policies relating to allocated sites BUC043 and BUC046 to insist that “a financial contribution will be required towards funding appropriate elements of the Buckingham Transport Strategy”. MM083 deleted allocation BUC051 to the west of Buckingham in part, because, it was said to rely upon the WLR which could not be delivered by site BUC051 alone (albeit that the necessary land controls were in place).
5 Detailed objections were raised to each of these Main Modifications by HLM(Buckingham), in timely fashion and recognised by the Inspector in his Discussion Document No 8 (ED265) as meriting a further hearing session in relation to the Buckingham sites and Buckingham Transport Strategy. This is to be arranged once the Inspector has been able to consider representations on these Further Proposed Modifications to the VALP, including those set out here.
6 FMM089 proposes a further modification(s) of Policy T3 and compounds the concerns raised by HLM (Buckingham) at MM stage. Specifically, at Buckingham, FMM089 proposes that the transport strategy for Buckingham be further modified from that set out in the BTS and indeed in MM210. Specifically T3, as proposed to be further modified, now appears to require specific listed transport schemes. Moreover, that list has been further amended: i) the A421/413 is now to be upgraded to dual standard over a length now specified, ii) the BTS scheme for Improvement of the A413 Buckingham Road is now to be deleted from the Plan.
7 Hallam seeks not to repeat its objections to the MMs which were set out in full last year and which the Inspector is to consider at a further session of the examination.
8 The gist of the previous and outstanding concerns is summarised below as context for this objection to FMM089. In summary such concerns were that:
• Policy T3 sought simply to “actively support key transport proposals” not require them and hence was little more than a safeguarding policy;
• The transport schemes added into T3 in Buckingham – did not reflect the evidence base, and in particular did not reflect the Buckingham Transport Strategy;
• The absence of an adequate evidence base to enable a conclusion that allocations BUC043 or BUC046 or MM06 can be adequately accommodated on the highway network or can be satisfactorily mitigated.
9 The importance of the Buckingham Transport Strategy was that it provided a comprehensive analysis of the transport issues in the town and set out a comprehensive package of measures to address those Transport issues. Prominent among the issues raised was the scale of congestion in the town centre in particular – a conclusion endorsed by the additional evidence published alongside the Main Modifications:
• The Revised County Modelling for Buckingham (3 April 2019) (ED214B)
• The Buckingham Town Centre Modelling Report (24 May 2019) (ED214A)
• BCC’s advice Note (ED215)
10 Whilst AVDC and BCC argued that site BUC051 could no longer be supported because of the impact of its development on the town centre (in the absence of the WLR), HLM (Buckingham) argued strongly that there simply was not the evidence to demonstrate that ANY of the proposed allocations could be mitigated in the absence of a wholehearted policy to deliver the Buckingham Transport Strategy (either as proposed or refined).
11 The remedy suggested by HLM(Buckingham) comprised one or more of the following:
• The removal of proposed allocations at Buckingham and the devolution of such allocations to the ongoing review of the Buckingham Neighbourhood plan;
• The alternative of the inclusion of additional allocations such as BUC025, to support the delivery of the Buckingham Transport Strategy – the BTS having been prepared and assessed having regard to sites such as BUC025 ad BCC in its evidence base noting the acceptability of BUC025 in its updated evidence base;
• The inclusion in T3 of each element of the Buckingham Transport Strategy (including the WLR), rather than a selection of elements
• A stronger commitment to allocations funding all rather than selected elements of the BTS – as drafted MM082 and 084 seek simply a financial contribution – failing to be precise as to what is required in development sites
12 FMM089 sets out different remedies which are unsatisfactory and objected to.
13 First FMM089 proposes that T3 be further modified by deleting the reference to critical and necessary infrastructure and instead should refer to “required” infrastructure. At face value this is helpful yet it sits within a policy that remains “to actively support key transport proposals including those identified in both the Aylesbury Transport Strategy and Buckingham Transport Strategy”. Any intention to require the delivery of the listed elements of infrastructure appears to be contradicted by an overall intention only to actively encourage the key transport proposals in the opening line of the policy.
14 Moreover, the amended wording is far from clear and leaves developers unclear of their obligations. As per FMM089 the policy now seeks to resist planning permission for development “that would prejudice or diminish the integrity of the implementation of existing or protected and supported required transport schemes identified in the list below”. The convoluted wording of the policy is very confusing. Is the test that development proposals should be resisted if they physically compromise the implementation of transport schemes? Or is it that proposals should be resisted if they do not properly fund and ensure the delivery of the listed transport schemes – presumably the schemes necessary to mitigate the development (including town wide strategies such as at Buckingham).
15 Second, FMM089 proposes substantial changes to the required transport infrastructure at Buckingham: i) the A421/413 is now to be upgraded to dual standard over a length now specified, ii) the BTS scheme for Improvement of the A413 Buckingham Road is now to be deleted from the plan and T3 as had been set out in MM210. In essence this appears to be a different mitigation strategy again.
16 HLM (Buckingham) do not believe that the further (apparently ad hoc) changes to the required Transport strategy for Buckingham are supported by appropriate evidence or are justified.
17 HLM (Buckingham) acknowledge that yet further evidence has been published (since the publication of the MM) by Buckinghamshire Council in relation to Transport at Buckingham notably:
• Buckingham VALP Allocations - Statement on Highway Matters (ED257)
• VALP Modelling – Buckingham Additional Modelling Report (ED255) (October 2020)
• RES002 Response to Representations made by Hallam Land Management by Buckinghamshire Council in relation to Highways and Transportation Matters
18 Much of the additional evidence appears to be a defence of the position set out in MM083 and MM210 and a response to previous objections made by HLM(Buckingham). It seeks retrospectively to seek to plug some of the gaps in the evidence base previously identified by HLM. It does little more than seek to compare the merits of the individual sites at Buckingham and how the deleted BUC051 performs relative to the others. It is a justification for MM083 (the deletion of BUC051) rather than an evidence base that supports the overall transport strategy for Buckingham and the policy set out in T3– as now proposed to be further modified in FMM089.
19 Technically the additional evidence is flawed in a number of respects (See Appendix 1 – Technical Note 4 prepared by Brookbanks):
• The assessments made have a very narrow focus on the allocations and no reconsideration of which elements of the BTS are required to address transport issues in Buckingham and/or mitigated the impacts of the proposed developments
• The assessments were very limited being based on a static Arcady model rather than County Strategic Transport Model;
• The assessments did not consider the impacts of developments, only the on congestion at two town centre junctions
• The latest assessments included no additional modelling to assess the effectiveness of the BTS or elements thereof.
20 In addition, while the latest evidence is said to conclude that the allocation of BUC051 would have a greater impact on the highway network than of other sites, it is apparent that all other sites will have highway impacts and that no conclusion is set that demonstrates that impact and the effects of the mitigation measures set out in T3 and FMM089.
21 Of greater significance there is no attempt to justify, or evidence, the additional FMM089 changes to the Transport Strategy for the town. HLM is unaware of any evidence to support the deletion in FMM089 of the A413 improvements from the schedule of required schemes in T3.
22 Originally the preparation of the Buckingham Transport Strategy was a laudable attempt to establish a comprehensive and coherent basis for delivering both development and transport improvements in the town – recognising existing and new congestion and journey time issues. It provided clarity and it was on this basis that HLM (Buckingham) in securing consent for 400 dwellings on land to the west of the town (15/01218/AOP) contributed some £800,000 as a Strategic Transport Contribution
23 Although still referenced in T3, the BTS appears to have been watered down, or broken up into individual elements – in a manner unsupported by any new evidence base. HLM(B) is of the firm view that far from providing certainty for the community and developers, there is no settled comprehensive transport strategy for the town. There is therefore no settled basis for contributions (as are now required by MM82 and MM084). The latest adjustment of the strategy – deletion of reference to the A413 improvements is not supported anywhere by evidence (it seems).
24 For all of these reasons, the Plan (with FMM089) insofar as it relates to Buckingham is not positively planned and prepared or justified.
25 HLM (Buckingham) do not hold unwaveringly to the need to provide the WLR as part of that comprehensive strategy. It is possible that there are alternatives and that development should be focussed on the south side of town (BUC025) to ensure the delivery of those options). However HLM is convinced of the need:
• for comprehensive transport strategy founded upon or evolved from the BTS – and fully evidenced as being effective;
• for each allocation to be demonstrably capable of being mitigated (and not simply retained because of a perceived lesser impact that BUC051, and merely deleting others.)
• to be crystal clear what allocations are specifically contributing towards in terms of highway and transport infrastructure.
26 Equally, HLM are convinced that the VALP with MM210 and FMM089 – plus the relevant site allocations – do not meet these tests which are at the heart of the NPPF soundness tests.

AYLESBURY SUBMISSION:

Dear Sir/ Madam,

Please find enclosed representations on the Further Main Modifications to the VALP – submitted on behalf of Hallam Land Management (Aylesbury).

We would be grateful if you could acknowledge receipt of the representations.

1 Hallam Land Management (Aylesbury) controls land to the north east of Aylesbury including site BIE021.
2 As our previous representations have outlined, HLM (A) have 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 Following the Inspector’s Interim Findings (IIF) (28th August 2018), the Council amended Policy T3 (via MM210) to include the key infrastructure elements from the Aylesbury Transport Strategy (ATS) upon which the Plan depends.
4 The North East Link road was included within the amended Policy T3, as a ‘necessary’ piece of infrastructure upon which the VALP depends.
5 Policy T3 is proposed to be further modified by FMM089, removing reference to both the North East Link Road and Western Link road (between A418 and A41). This directly contradicts the amendment made in MM210 to explicitly include – as critical and necessary – the North East Link Road in the VALP. It does so without any additional basis in evidence or clear justification.
6 The North East Link Road was included in T3 at MM stage for clear and obvious reasons.
7 As noted in reps at Main Modifications stage:
• it was 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 included the North East Link Road between the A413 and A418.
• it is essential also from the perspective of the need to address current issues in the network. In Examination document EC279, AVDC had recognised that the ATS measures (including North East Link Road) also address current issues in relation to the capacity of the Network.
• more important still, the North East Link Road was essential to mitigate the impacts of the development proposed in the VALP at Aylesbury and, in particular, in Policy D1 of the Plan.
8 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.
9 The Technical Note drew 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. The Markides Technical Note highlighted 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].
10 The publication of MM210 reflected the contribution of the NE Link Road including its provision of critical and necessary.
11 Since the publication of the MM, additional modelling has been published by Buckingham Council – explicitly the VALP Modelling Countywide Local Plan Modelling Report Phase 4 (ED254). It is dated May 2020.
12 Hallam Land Management has reviewed the further modelling work that was carried out last year, including in the note prepared by Markides Associates on its behalf (attached as appendix 1). HLM note that this latest assessment work includes a new mitigation scenario which excludes the North East Link Road (along with the Western Link Road). It is a further iteration from the 2017 Phase 3 modelling report employing virtually the same development allocation.
13 Hallam Land Management continues to have significant concerns arising from the work technically and in terms of the results. There are concerns with the validation of the model and how heavily the subsequent forecasts can be relied on. It appears that some of the Do Something model results are unexpectedly inconsistent with the previous Phase 3 modelling when they have been reproduced in the Phase 4 report, despite there being very little change in the development assumptions. Moreover the mitigation model runs show a deterioration in congestion levels and journey times on highway routes in the eastern part of the, indicating that the omission of the North East Link Road may result in impacts of the Local Plan development being severe.
14 FMM089, and its deletion of the North East Link Road, is “explained” in Buckinghamshire Council’s response to Hallam Land Management (HLM) Aylesbury’s representations to the VALP Main Modifications in Examination Document ED263 (Schedule of Councils responses to representations made on the Proposed Main Modifications consultation). Buckinghamshire Council argues that ‘Policy T3 now refers to ‘required’ infrastructure which is essential to enable or unlock strategic housing or employment floorspace.’ It is on this basis that the North Eastern Link Road (NELR) has been removed from Table 16 (within Policy T3), as Buckinghamshire Council state that it has been removed as the ‘NELR is not considered to be required to enable or unlock strategic housing or employment space proposed within the VALP’.
15 Neither the previous (Phase 3), nor the latest (Phase 4), modelling appears to provide the evidence that this is the case or that T3 (without the NELR and WLR) would not result in serious or severe transport impacts.
16 Independent from the technical transport evidence, the North East Link Road, remains a commitment in the up to date strategic planning and investment context for the town of Aylesbury and funding obtained for the town on the basis of an overarching Garden Town Strategy that included the NELR.
17 Specifically:
• the Aylesbury Garden Town Masterplan, dated July 2020, includes a North East Link Road Feasibility Study update as a ‘Medium term (2024-2028)’ action which commits the Council to undertake work described as an “update to the route alignment study for proposed section of orbital link road, considering longer term development potential and relationships to Garden Town proposals.” Furthermore the “North East Link Road Route design and potential delivery” is basis of comprehensive delivery strategy to transform Aylesbury into a Garden Town over the coming decades” (Minutes of Buckinghamshire Council Meeting 15th July 2020). included as a long-term (2029-2033) action. Such actions are clearly within the Vale of Aylesbury Local Plan period (2013-2033). The Aylesbury Garden Town Masterplan was approved by Buckinghamshire Council on 15th July 2020 and clearly demonstrates the Council’s commitment to the Masterplan as “the basis of comprehensive delivery strategy to transform Aylesbury into a Garden Town over the coming decades” (Minutes of Buckinghamshire Council Meeting 15th July 2020).
• Aylesbury Garden Town is included as a key ‘growth and development’ opportunity within Buckinghamshire Growth Board’s Buckinghamshire Recovery and Growth Proposal, submitted to the Government. The Buckinghamshire Recovery and Growth Proposal includes a priority to “front load the delivery of 50,000 homes by 2036, regenerating and reviving towns, and consolidating the opportunity presented by major innovative developments such as Aylesbury Garden Town…”. A proposed project as part of the application for the Single Pot investment Fund is “Aylesbury Transport Improvements”.
• the North East Link road is referred to in the Pre Submission Version of the Bierton with Broughton Neighbourhood Plan (October 2020 version). The aspiration section of the proposed Plan states “it is recognised that, during the life of the plan, there may be Strategy Developments outside of the current Development Boundaries, including but not limited to the Northern Link Road to complete the outer ring road around Aylesbury”.
18 It is therefore clear that the North Eastern Link Road is a long standing commitment and future requirement associated with Aylesbury Garden Town and Buckinghamshire Council’s ambitions for growth within the Plan period and further to 2050.
19 HLM (A) question whether FMM089 omits the North East Link Road simply because of uncertainty regarding deliverability – particularly in the light of a reconsideration of the Oxfordshire Cambridgeshire Expressway proposals of which it once might have formed a small part. In reality, development can of course assist with delivery.
20 Specifically, HLM(A) requests that a reference to the North East Link Road, in the context of Buckinghamshire Council / Aylesbury Garden Town’s long standing commitment to the Aylesbury Transport Strategy, be retained within policy T3 of the VALP to ensure that it is recognised as a future Plan requirement – a matter for the Buckinghamshire Plan, required to be adopted by 2025 (five years since vesting day of Buckinghamshire Council).

See attachment Markides Associates
Review of Updated Aylesbury Countywide
Model Prepared for: Hallam Land Management
9 February 2021

Object

VALP Further Main Modifications

Representation ID: 3822

Received: 09/02/2021

Respondent: David Lock Associates

Legally compliant? Yes

Sound? No

Representation Summary:

HLM(A) objects to the removal of the North East Link Road from amended Policy T3. The North East Link Road is clearly an important component of the Aylesbury Transport Strategy and Aylesbury Garden Town. The North East Link Road should be included as a requirement for future growth in the Aylesbury area, if not within this plan should the Inspector find the impact upon the existing road network is ‘severe’ without it.

Change suggested by respondent:

(Officer Note - See attachment for formatting strike through and underlined text)

It is apparent to HLM(A), in the light of the above and all previous evidence and submissions, that the North East Link Road should be recognised in the VALP as a fundamental element of the Strategic Plan for Aylesbury. Such recognition will ensure consistency with the evidence base, the Garden Town Strategy, the Aylesbury Transport Strategy.
Option 1 is simply to ensure that the North East Link Road is retained in the list of required schemes (ie. that FMM089 – insofar as it relates to the Link Road – is rejected as a modification to the Plan).
Option 2, should it be determined that the NELR is not required to be delivered prior to the early phases of Delivering Aylesbury Garden Town (VALP policy D1) (Hallam has not seen the evidence that this is the case) then alternative recognition be given to its nevertheless ongoing strategic importance. The consequential requirement of the deletion of the North East Link Road from the list of required schemes would be an explicit reference in the preamble to the list of schemes in T3 in one of the following forms:
• First line amended as follows: “The council will actively support key transport proposals including these identified in both the Aylesbury Transport Strategy and Buckingham Transport Strategy – such schemes to include identified priorities not listed in Table 16 below and including the North East and Western Link Roads at Aylesbury”; or
• Third para amended as follows: “These required transport schemes are also shown on the Policies Map. In addition to these required schemes, the Council will seek to bring forward other strategic transport priorities set out in the AGTS, ATS and BTS – including explicitly the Aylesbury North East Link Road”.

Full text:

BUCKINGHAM SUBMISSION:

Sirs

Please find enclosed representations on the Further Main Modifications to the VALP – submitted on behalf of Hallam Land Management (Buckingham)

1 Hallam Land Management (Buckingham) [HLM(B)] has set out a number of objections to the policies of the submitted VALP, and also to the Main Modifications, insofar as the Plan and the Main Modifications relate to Buckingham and the planning and transportation strategy being set out therein.
2 Those objections to the submission version of the VALP were set out in some detail and heard at previous sessions of the Examination prompting, in part, the Inspector to set out a preliminary finding that the VALP in it is initial form was unsound in failing to include, in the VALP, the key infrastructure requirements upon which the delivery of the plan depends. This conclusion was drawn, by the Inspector, notwithstanding the generic references in the VALP to the Buckingham Transport Strategy (BTS) and the VALP IDP (which includes a broad range of infrastructure projects to be implemented in Buckingham - including the Buckingham Western Link Road (WLR) and West Street/High Street Route downgrade). HLM(B) is not aware that the IDP or Buckingham Transport Strategy has been updated since the earlier sessions of the examination. Therefore, they are intended to continue to underpin the Plan.
3 AVDC sought to address the Inspectors concerns, in Main Modification 210 (August 2019) by setting out, in Policy T3, the transport projects it would support in each location of the District. In Buckingham a number of schemes from the Buckingham Transport Strategy and the VALP IDP were included in Policy T3, through MM210, albeit not the WLR nor the High Street/West Street works.
4 MM082 and 084 also amended the policies relating to allocated sites BUC043 and BUC046 to insist that “a financial contribution will be required towards funding appropriate elements of the Buckingham Transport Strategy”. MM083 deleted allocation BUC051 to the west of Buckingham in part, because, it was said to rely upon the WLR which could not be delivered by site BUC051 alone (albeit that the necessary land controls were in place).
5 Detailed objections were raised to each of these Main Modifications by HLM(Buckingham), in timely fashion and recognised by the Inspector in his Discussion Document No 8 (ED265) as meriting a further hearing session in relation to the Buckingham sites and Buckingham Transport Strategy. This is to be arranged once the Inspector has been able to consider representations on these Further Proposed Modifications to the VALP, including those set out here.
6 FMM089 proposes a further modification(s) of Policy T3 and compounds the concerns raised by HLM (Buckingham) at MM stage. Specifically, at Buckingham, FMM089 proposes that the transport strategy for Buckingham be further modified from that set out in the BTS and indeed in MM210. Specifically T3, as proposed to be further modified, now appears to require specific listed transport schemes. Moreover, that list has been further amended: i) the A421/413 is now to be upgraded to dual standard over a length now specified, ii) the BTS scheme for Improvement of the A413 Buckingham Road is now to be deleted from the Plan.
7 Hallam seeks not to repeat its objections to the MMs which were set out in full last year and which the Inspector is to consider at a further session of the examination.
8 The gist of the previous and outstanding concerns is summarised below as context for this objection to FMM089. In summary such concerns were that:
• Policy T3 sought simply to “actively support key transport proposals” not require them and hence was little more than a safeguarding policy;
• The transport schemes added into T3 in Buckingham – did not reflect the evidence base, and in particular did not reflect the Buckingham Transport Strategy;
• The absence of an adequate evidence base to enable a conclusion that allocations BUC043 or BUC046 or MM06 can be adequately accommodated on the highway network or can be satisfactorily mitigated.
9 The importance of the Buckingham Transport Strategy was that it provided a comprehensive analysis of the transport issues in the town and set out a comprehensive package of measures to address those Transport issues. Prominent among the issues raised was the scale of congestion in the town centre in particular – a conclusion endorsed by the additional evidence published alongside the Main Modifications:
• The Revised County Modelling for Buckingham (3 April 2019) (ED214B)
• The Buckingham Town Centre Modelling Report (24 May 2019) (ED214A)
• BCC’s advice Note (ED215)
10 Whilst AVDC and BCC argued that site BUC051 could no longer be supported because of the impact of its development on the town centre (in the absence of the WLR), HLM (Buckingham) argued strongly that there simply was not the evidence to demonstrate that ANY of the proposed allocations could be mitigated in the absence of a wholehearted policy to deliver the Buckingham Transport Strategy (either as proposed or refined).
11 The remedy suggested by HLM(Buckingham) comprised one or more of the following:
• The removal of proposed allocations at Buckingham and the devolution of such allocations to the ongoing review of the Buckingham Neighbourhood plan;
• The alternative of the inclusion of additional allocations such as BUC025, to support the delivery of the Buckingham Transport Strategy – the BTS having been prepared and assessed having regard to sites such as BUC025 ad BCC in its evidence base noting the acceptability of BUC025 in its updated evidence base;
• The inclusion in T3 of each element of the Buckingham Transport Strategy (including the WLR), rather than a selection of elements
• A stronger commitment to allocations funding all rather than selected elements of the BTS – as drafted MM082 and 084 seek simply a financial contribution – failing to be precise as to what is required in development sites
12 FMM089 sets out different remedies which are unsatisfactory and objected to.
13 First FMM089 proposes that T3 be further modified by deleting the reference to critical and necessary infrastructure and instead should refer to “required” infrastructure. At face value this is helpful yet it sits within a policy that remains “to actively support key transport proposals including those identified in both the Aylesbury Transport Strategy and Buckingham Transport Strategy”. Any intention to require the delivery of the listed elements of infrastructure appears to be contradicted by an overall intention only to actively encourage the key transport proposals in the opening line of the policy.
14 Moreover, the amended wording is far from clear and leaves developers unclear of their obligations. As per FMM089 the policy now seeks to resist planning permission for development “that would prejudice or diminish the integrity of the implementation of existing or protected and supported required transport schemes identified in the list below”. The convoluted wording of the policy is very confusing. Is the test that development proposals should be resisted if they physically compromise the implementation of transport schemes? Or is it that proposals should be resisted if they do not properly fund and ensure the delivery of the listed transport schemes – presumably the schemes necessary to mitigate the development (including town wide strategies such as at Buckingham).
15 Second, FMM089 proposes substantial changes to the required transport infrastructure at Buckingham: i) the A421/413 is now to be upgraded to dual standard over a length now specified, ii) the BTS scheme for Improvement of the A413 Buckingham Road is now to be deleted from the plan and T3 as had been set out in MM210. In essence this appears to be a different mitigation strategy again.
16 HLM (Buckingham) do not believe that the further (apparently ad hoc) changes to the required Transport strategy for Buckingham are supported by appropriate evidence or are justified.
17 HLM (Buckingham) acknowledge that yet further evidence has been published (since the publication of the MM) by Buckinghamshire Council in relation to Transport at Buckingham notably:
• Buckingham VALP Allocations - Statement on Highway Matters (ED257)
• VALP Modelling – Buckingham Additional Modelling Report (ED255) (October 2020)
• RES002 Response to Representations made by Hallam Land Management by Buckinghamshire Council in relation to Highways and Transportation Matters
18 Much of the additional evidence appears to be a defence of the position set out in MM083 and MM210 and a response to previous objections made by HLM(Buckingham). It seeks retrospectively to seek to plug some of the gaps in the evidence base previously identified by HLM. It does little more than seek to compare the merits of the individual sites at Buckingham and how the deleted BUC051 performs relative to the others. It is a justification for MM083 (the deletion of BUC051) rather than an evidence base that supports the overall transport strategy for Buckingham and the policy set out in T3– as now proposed to be further modified in FMM089.
19 Technically the additional evidence is flawed in a number of respects (See Appendix 1 – Technical Note 4 prepared by Brookbanks):
• The assessments made have a very narrow focus on the allocations and no reconsideration of which elements of the BTS are required to address transport issues in Buckingham and/or mitigated the impacts of the proposed developments
• The assessments were very limited being based on a static Arcady model rather than County Strategic Transport Model;
• The assessments did not consider the impacts of developments, only the on congestion at two town centre junctions
• The latest assessments included no additional modelling to assess the effectiveness of the BTS or elements thereof.
20 In addition, while the latest evidence is said to conclude that the allocation of BUC051 would have a greater impact on the highway network than of other sites, it is apparent that all other sites will have highway impacts and that no conclusion is set that demonstrates that impact and the effects of the mitigation measures set out in T3 and FMM089.
21 Of greater significance there is no attempt to justify, or evidence, the additional FMM089 changes to the Transport Strategy for the town. HLM is unaware of any evidence to support the deletion in FMM089 of the A413 improvements from the schedule of required schemes in T3.
22 Originally the preparation of the Buckingham Transport Strategy was a laudable attempt to establish a comprehensive and coherent basis for delivering both development and transport improvements in the town – recognising existing and new congestion and journey time issues. It provided clarity and it was on this basis that HLM (Buckingham) in securing consent for 400 dwellings on land to the west of the town (15/01218/AOP) contributed some £800,000 as a Strategic Transport Contribution
23 Although still referenced in T3, the BTS appears to have been watered down, or broken up into individual elements – in a manner unsupported by any new evidence base. HLM(B) is of the firm view that far from providing certainty for the community and developers, there is no settled comprehensive transport strategy for the town. There is therefore no settled basis for contributions (as are now required by MM82 and MM084). The latest adjustment of the strategy – deletion of reference to the A413 improvements is not supported anywhere by evidence (it seems).
24 For all of these reasons, the Plan (with FMM089) insofar as it relates to Buckingham is not positively planned and prepared or justified.
25 HLM (Buckingham) do not hold unwaveringly to the need to provide the WLR as part of that comprehensive strategy. It is possible that there are alternatives and that development should be focussed on the south side of town (BUC025) to ensure the delivery of those options). However HLM is convinced of the need:
• for comprehensive transport strategy founded upon or evolved from the BTS – and fully evidenced as being effective;
• for each allocation to be demonstrably capable of being mitigated (and not simply retained because of a perceived lesser impact that BUC051, and merely deleting others.)
• to be crystal clear what allocations are specifically contributing towards in terms of highway and transport infrastructure.
26 Equally, HLM are convinced that the VALP with MM210 and FMM089 – plus the relevant site allocations – do not meet these tests which are at the heart of the NPPF soundness tests.

AYLESBURY SUBMISSION:

Dear Sir/ Madam,

Please find enclosed representations on the Further Main Modifications to the VALP – submitted on behalf of Hallam Land Management (Aylesbury).

We would be grateful if you could acknowledge receipt of the representations.

1 Hallam Land Management (Aylesbury) controls land to the north east of Aylesbury including site BIE021.
2 As our previous representations have outlined, HLM (A) have 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 Following the Inspector’s Interim Findings (IIF) (28th August 2018), the Council amended Policy T3 (via MM210) to include the key infrastructure elements from the Aylesbury Transport Strategy (ATS) upon which the Plan depends.
4 The North East Link road was included within the amended Policy T3, as a ‘necessary’ piece of infrastructure upon which the VALP depends.
5 Policy T3 is proposed to be further modified by FMM089, removing reference to both the North East Link Road and Western Link road (between A418 and A41). This directly contradicts the amendment made in MM210 to explicitly include – as critical and necessary – the North East Link Road in the VALP. It does so without any additional basis in evidence or clear justification.
6 The North East Link Road was included in T3 at MM stage for clear and obvious reasons.
7 As noted in reps at Main Modifications stage:
• it was 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 included the North East Link Road between the A413 and A418.
• it is essential also from the perspective of the need to address current issues in the network. In Examination document EC279, AVDC had recognised that the ATS measures (including North East Link Road) also address current issues in relation to the capacity of the Network.
• more important still, the North East Link Road was essential to mitigate the impacts of the development proposed in the VALP at Aylesbury and, in particular, in Policy D1 of the Plan.
8 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.
9 The Technical Note drew 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. The Markides Technical Note highlighted 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].
10 The publication of MM210 reflected the contribution of the NE Link Road including its provision of critical and necessary.
11 Since the publication of the MM, additional modelling has been published by Buckingham Council – explicitly the VALP Modelling Countywide Local Plan Modelling Report Phase 4 (ED254). It is dated May 2020.
12 Hallam Land Management has reviewed the further modelling work that was carried out last year, including in the note prepared by Markides Associates on its behalf (attached as appendix 1). HLM note that this latest assessment work includes a new mitigation scenario which excludes the North East Link Road (along with the Western Link Road). It is a further iteration from the 2017 Phase 3 modelling report employing virtually the same development allocation.
13 Hallam Land Management continues to have significant concerns arising from the work technically and in terms of the results. There are concerns with the validation of the model and how heavily the subsequent forecasts can be relied on. It appears that some of the Do Something model results are unexpectedly inconsistent with the previous Phase 3 modelling when they have been reproduced in the Phase 4 report, despite there being very little change in the development assumptions. Moreover the mitigation model runs show a deterioration in congestion levels and journey times on highway routes in the eastern part of the, indicating that the omission of the North East Link Road may result in impacts of the Local Plan development being severe.
14 FMM089, and its deletion of the North East Link Road, is “explained” in Buckinghamshire Council’s response to Hallam Land Management (HLM) Aylesbury’s representations to the VALP Main Modifications in Examination Document ED263 (Schedule of Councils responses to representations made on the Proposed Main Modifications consultation). Buckinghamshire Council argues that ‘Policy T3 now refers to ‘required’ infrastructure which is essential to enable or unlock strategic housing or employment floorspace.’ It is on this basis that the North Eastern Link Road (NELR) has been removed from Table 16 (within Policy T3), as Buckinghamshire Council state that it has been removed as the ‘NELR is not considered to be required to enable or unlock strategic housing or employment space proposed within the VALP’.
15 Neither the previous (Phase 3), nor the latest (Phase 4), modelling appears to provide the evidence that this is the case or that T3 (without the NELR and WLR) would not result in serious or severe transport impacts.
16 Independent from the technical transport evidence, the North East Link Road, remains a commitment in the up to date strategic planning and investment context for the town of Aylesbury and funding obtained for the town on the basis of an overarching Garden Town Strategy that included the NELR.
17 Specifically:
• the Aylesbury Garden Town Masterplan, dated July 2020, includes a North East Link Road Feasibility Study update as a ‘Medium term (2024-2028)’ action which commits the Council to undertake work described as an “update to the route alignment study for proposed section of orbital link road, considering longer term development potential and relationships to Garden Town proposals.” Furthermore the “North East Link Road Route design and potential delivery” is basis of comprehensive delivery strategy to transform Aylesbury into a Garden Town over the coming decades” (Minutes of Buckinghamshire Council Meeting 15th July 2020). included as a long-term (2029-2033) action. Such actions are clearly within the Vale of Aylesbury Local Plan period (2013-2033). The Aylesbury Garden Town Masterplan was approved by Buckinghamshire Council on 15th July 2020 and clearly demonstrates the Council’s commitment to the Masterplan as “the basis of comprehensive delivery strategy to transform Aylesbury into a Garden Town over the coming decades” (Minutes of Buckinghamshire Council Meeting 15th July 2020).
• Aylesbury Garden Town is included as a key ‘growth and development’ opportunity within Buckinghamshire Growth Board’s Buckinghamshire Recovery and Growth Proposal, submitted to the Government. The Buckinghamshire Recovery and Growth Proposal includes a priority to “front load the delivery of 50,000 homes by 2036, regenerating and reviving towns, and consolidating the opportunity presented by major innovative developments such as Aylesbury Garden Town…”. A proposed project as part of the application for the Single Pot investment Fund is “Aylesbury Transport Improvements”.
• the North East Link road is referred to in the Pre Submission Version of the Bierton with Broughton Neighbourhood Plan (October 2020 version). The aspiration section of the proposed Plan states “it is recognised that, during the life of the plan, there may be Strategy Developments outside of the current Development Boundaries, including but not limited to the Northern Link Road to complete the outer ring road around Aylesbury”.
18 It is therefore clear that the North Eastern Link Road is a long standing commitment and future requirement associated with Aylesbury Garden Town and Buckinghamshire Council’s ambitions for growth within the Plan period and further to 2050.
19 HLM (A) question whether FMM089 omits the North East Link Road simply because of uncertainty regarding deliverability – particularly in the light of a reconsideration of the Oxfordshire Cambridgeshire Expressway proposals of which it once might have formed a small part. In reality, development can of course assist with delivery.
20 Specifically, HLM(A) requests that a reference to the North East Link Road, in the context of Buckinghamshire Council / Aylesbury Garden Town’s long standing commitment to the Aylesbury Transport Strategy, be retained within policy T3 of the VALP to ensure that it is recognised as a future Plan requirement – a matter for the Buckinghamshire Plan, required to be adopted by 2025 (five years since vesting day of Buckinghamshire Council).

See attachment Markides Associates
Review of Updated Aylesbury Countywide
Model Prepared for: Hallam Land Management
9 February 2021

Object

VALP Further Main Modifications

Representation ID: 3850

Received: 10/02/2021

Respondent: Boyer Planning

Legally compliant? Yes

Sound? Yes

Representation Summary:

We consider that FMM089, as relevant to Buckingham, would not represent a sound modification to the Plan. This is because there is no compelling evidence to justify the proposed route upgrade on the A421 and A413.

Full text:

Response to Proposed Further Main Modifications Consultation
Representation on behalf of Wates Developments Ltd.
Wates Developments Ltd (‘Wates’) is seeking to bring forward Land off Osier Way, Buckingham,
which is proposed for allocation in the Vale of Aylesbury Local Plan (‘VALP’) at Policy D-BUC046.
An application for outline planning permission (ref. 19/00148/AOP) was submitted on 15th January
2019, and is currently being considered by the Council in its capacity as Local Planning Authority
(‘LPA’). The application seeks consent for up to 420 dwellings, together with supporting
infrastructure.
Whilst Wates supports and endorses the VALP in general, our client’s seek to raise a number of
specific concerns and comments, particularly in respect of further proposed main modifications
FMM089 and FMM091.
FMM089 – Proposed Modifications to Policy T3 ‘Supporting Local Transport Schemes’
The proposals associated with modification FMM089, seek to make various adjustments to VALP
Policy T3. Within Buckingham, the proposed modification would introduce a requirement for a route
upgrade on the A421 and A413, to dual carriageway status, between the Radclive Road roundabout
and A421/A413 roundabout (east).
We do not consider that the proposal for this new infrastructure is necessary, nor is any substantive
evidence put forward (by the Council) to justify its introduction or demonstrate its deliverability. Our
reasoning is fully explained in the accompanying Technical Note (prepared by iTransport). This is
provided at Appendix 1.
However, in summary, the transport modelling undertaken by the Council indicates that the scale of
new development envisaged at Buckingham (in conjunction with existing commitments) is limited
and will not give rise to impacts that merit mitigation in the form of a dual carriageway. Furthermore,
a review of the updated evidence base documents suggests that no specific feasibility work has
been undertaken, in order to confirm that the envisaged dualing is attainable and viable.
Related to this, a further concern is that the proposed modification envisages that the delivery of the
dual carriageway would partly rely on developer contributions. Any request for planning obligations
to deliver this dual carriageway (as may be sought through a planning application) would need to comply with the tests set out at Regulation 122 of the ‘Community Infrastructure Levy Regulations
2010’. It is not clear how the specified tests could be met, because the Council’s own modelling
suggests that the dual-carriageway is not necessary to mitigate the transport impacts of the
allocations proposed in the VALP.
As such, FMM089 (as relevant to Buckingham) cannot be regarded as justified, effective or
consistent with national policy.
FMM091 – Proposed Modifications to Policy T7 ‘Electric Vehicle Infrastructure’
This proposed further modification envisages an increase in the technical standards required for
electric vehicle charging points. In this respect, FMM091 seeks to further modify the standards set out in
MM218 (introduced in the previous Main Modifications consultation), such that charging points at private
dwellings must be 7.4kW/32A (as a minimum) instead of 3.7kW/16A.
In principle, Wates supports planning policies which require the inclusion of electric vehicle charging
points. However, based on experiences elsewhere, there can be issues regarding the capability of
the utility provider to supply sufficient electrical load to sites. Wates have taken advice on the matter
and do not anticipate this will negatively impact the allocation proposed via D-BUC046, as high voltage
transmission lines are proximate to the site. This makes it less likely that extensive upgrades
to the network would be required.
However, utility providers are generally unable to provide detailed electrical load assessments and
specify related infrastructure requirements, until after outline planning permission is granted and
often not before reserved matters submissions are made. This process creates a degree of
uncertainty, which is proving increasingly problematic, as the provision of electric vehicle charging
infrastructure becomes more widespread in new developments.
Taking this into account, we recommend that the supporting text to Policy T7 should be modified to
allow for flexibility, in those circumstances when the utility provider identifies significant concerns
regarding the supply of electrical load to a site, which cannot be practically overcome in a realistic
timeframe.
Such flexibility could be achieved by permitting (in specific circumstances) lower levels of immediate
charging point provision, whilst ensuring that all necessary groundwork and passive wiring is put in
place to facilitate the introduction of further charging infrastructure in future. This would allow for
development to take place, without prejudice to the future provision of charging points, when
electrical load issues have been overcome.
As such, although we agree that FMM091 is a reasonable modification in principle, there may be
instances where the supply of electrical load proves to be problematic in practice. The wording of
Policy T7 and/or its supporting text should therefore signal a degree of flexibility, in instances where
it can be demonstrated that there are genuine obstacles to the delivery of electric vehicle charging
infrastructure. This will assist in ensuring the effectiveness of the Plan.
Should you have any questions, then please do not hesitate to contact me, via the details overleaf.

Then attachment follows - Technical Note (prepared by iTransport) covering Buckingham and transport infrastructure.

Object

VALP Further Main Modifications

Representation ID: 4005

Received: 23/02/2021

Respondent: Carter Jonas - Associate SWMK Consortium

Agent: Carter Jonas - Associate SWMK Consortium

Legally compliant? Yes

Sound? No

Representation Summary:

Planning Officer Summary

The new link road for Shenley Park should be a requirement and should be a grid road.

Not sound - not justified or consistent with national policy

Change suggested by respondent:

It is requested that the following additional modification is made to FMM089 at Table 16 to Policy T3:
Edge of Milton Keynes (North East Aylesbury Vale) - New roundabout access on A421 to serve Shenley Park and subject to more detailed traffic modelling possible dualling between new access and Bottledump roundabout and link road grid road through the site connecting the A421 with H6 and/or H7.
(see attached document for change's formatting)

Full text:

See attached documentation

Object

VALP Further Main Modifications

Representation ID: 4027

Received: 09/02/2021

Respondent: Pegasus Group (for Revera Limited)

Agent: Pegasus Group (for Revera Limited)

Legally compliant? Yes

Sound? No

Representation Summary:

It is suggested that Policy T3 should be further amended to make reference to the future aspiration of achieving a ‘North Eastern Link Road’ from the A413(N) to the A418(N). The Aylesbury Garden Town Masterplan recognises that the orbital link road could be provided in the medium to longer term. This would help to work towards completing the orbital link road. As such, this is considered to be an important future aspiration, and therefore, the VALP should make reference to this in Policy T3.

Not sound as not justified or effective

Change suggested by respondent:

It is suggested that Policy T3 should be further amended to make reference to the future aspiration of achieving a ‘North Eastern Link Road’ from the A413(N) to the A418(N). The Aylesbury Garden Town Masterplan recognises that the orbital link road could be provided in the medium to longer term. This would help to work towards completing the orbital link road. As such, this is considered to be an important future aspiration, and therefore, the VALP should make reference to this in Policy T3.

Full text:

See attached documentation

Attachments: