Aylesbury Vale Area

FMM091

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Object

VALP Further Main Modifications

Representation ID: 3851

Received: 10/02/2021

Respondent: Boyer Planning

Legally compliant? Yes

Sound? Yes

Representation Summary:

We consider that FMM091 can be improved in order to improve the Plan’s effectiveness.
Officer summary added:
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.

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.