Aylesbury Vale Area

FMM103

Showing comments and forms 1 to 5 of 5

Support

VALP Further Main Modifications

Representation ID: 3716

Received: 28/01/2021

Respondent: Anglian Water Services Limited

Representation Summary:

We note that a modification is proposed to Policy I4: Flooding of the Local Plan to refer to a requirement to undertake ground investigations when developing proposals for Sustainable Drainage Systems.

We support this modification as it will provide evidence to demonstrate whether infiltration is an appropriate method of surface water management based upon groundwater conditions.

Full text:

We note that a modification is proposed to Policy I4: Flooding of the Local Plan to refer to a requirement to undertake ground investigations when developing proposals for Sustainable Drainage Systems.

We support this modification as it will provide evidence to demonstrate whether infiltration is an appropriate method of surface water management based upon groundwater conditions.

Support

VALP Further Main Modifications

Representation ID: 3725

Received: 04/02/2021

Respondent: The Canal & River Trust

Representation Summary:

Further amendment would be preferable. New criterion l could be amended to include canals & reservoirs as well as ordinary watercourses. Although as manmade structures, water levels are to an extent controlled and monitored, sudden failure, over topping and breaches can occur resulting in inundation of land. By making this addition developers may contact the Canal & River Trust to discuss these issues and design a site accordingly.

Full text:

Further amendment would be preferable. New criterion l could be amended to include canals & reservoirs as well as ordinary watercourses. Although as manmade structures, water levels are to an extent controlled and monitored, sudden failure, over topping and breaches can occur resulting in inundation of land. By making this addition developers may contact the Canal & River Trust to discuss these issues and design a site accordingly.

Object

VALP Further Main Modifications

Representation ID: 3748

Received: 08/02/2021

Respondent: Mr Chris Webbley

Legally compliant? Yes

Sound? No

Representation Summary:

The routing of the Eastern Link Road (South) in D-AGT3 is not the most appropriate with regards to flood risk on that site or elsewhere. This therefore goes counter to Policy I4 para e.

An alternative route exists that would more dependably meet the requirements of the paragraph and was illustrated in an earlier version of the VALP.

Unless the routing is amended, the Plan will contain an unjustified major inconsistency between policies I4 (e) and D-AGT3 and will thus be rendered unsound.

Change suggested by respondent:

Address the inconsistency that is baked into the Plan.

Full text:

FMM103 (e) Policy I4 Flooding

This element of the Plan aims (paragraph e) to “ensure no increase in flood risk on site or elsewhere, such as downstream or upstream receptors, existing development and/or adjacent land...” One major site in the Plan (D-AGT3) is highly likely to breach this intention, rendering the Plan unsound against the criterion ‘Justified’.

A core component of D-AGT3 is the proposed Eastern Link Road (South). This is currently routed across a Flood Zone 3 as shown in the planning application for the ‘Woodlands’ development (16/01040/AOP) that comprises by far the majority of the D-AGT3 area.

However, an alternative routing of the ELR(S) was illustrated in an earlier version of the VALP documents originally published by the council's own consultants, Aecom, in 2017 as part of the Local Plan process. (See attached: the route proposed by Aecom is represented by the blue edged alignment.) This routing would take a considerable portion of the road out of the area of highest flood risk. It would therefore be highly preferable as a way to fulfil para (e) in Policy I4.

This alternative routing has been consistently ignored despite repeated, evidence-based attempts by the public to have it considered and adopted.

If the current proposals for D-AGT3 are not amended, they will automatically cause Policy I4 to be breached by one of the six core elements of the VALP Garden Town. If this were to happen, the VALP would not be presenting “the most appropriate strategy when considered against reasonable alternatives.” These are grounds on which we invite the Inspector to find the Plan as Further Modified in FMM103 (e) unsound.

This representation is posted for the Hampden Fields Action Group that I chair. We represent 2,000 local supporters.

Attachments:

Support

VALP Further Main Modifications

Representation ID: 3819

Received: 09/02/2021

Respondent: The Environment Agency

Representation Summary:

FMM103 Policy I4
Part e
End 2
We are pleased to see and support that the proposed further changes have included fluvial flood risk in part e of the policy wording.
Part W
We are pleased to see and support the proposed further changes have include wording about compensation storage for the built footprint as well as ground level raising.

Full text:

Dear Sir/Madam
Vale of Aylesbury Local Plan Main Modifications consultation. December 2020.
Thank you for your consultation on the above Aylesbury Vale Local Plan main modifications. I refer to our consultation response to the pre-submission draft of the local plan dated 14 December 2017, our comments dated 06 June 2019 for the consultation for the proposed 3 additional site allocations and our comments dated 16 December 2019 for the main modifications submitted in November 2019. We have the following comments to make.
Water cycle study soundness points
Regarding our comments on the pre-submission draft of the local plan we made soundness comments on the water cycle study. However this soundness point is still outstanding as we can’t see that this has been addressed in the main modifications consultation. I have attached our soundness comments dated 14 December 2017 for the pre-submission draft.
Further to this, in June 2019 we responded to a consultation for the water cycle study for three additional site allocations. We also have an outstanding point of soundness for the water cycle study information that was submitted for these sites. I have also attached a copy of our response on this consultation.
Please can you clarify this and send us any information regarding the water cycle study that was made in response to our pre-submission draft soundness response and our soundness comments for the three additional sites consultation.

Main Modifications
FMM103 Policy I4
Part e
We are pleased to see and support that the proposed further changes have included fluvial flood risk in part e of the policy wording.

Part W
We are pleased to see and support the proposed further changes have include wording about compensation storage for the built footprint as well as ground level raising.
Strategic Flood Risk Assessment (SFRA)
We have been contacted regarding your SFRA. A request for data has been submitted to us. Are you intending to update your SFRA for your local plan? If so will we be formally consulted on the SFRA as part of the local plan process?

Sustainability Appraisal Addendum
We are pleased to see and support the bullet point about climate change and flood risk paragraph 2.2.1. Part of this bullet point states:
“no built development to take place in the functional floodplain other than for essential strategic infrastructure;”
However Tables 1-3 concerning flood risk in the Planning Practice Guidance states that water compatible development is also appropriate in the Flood Zone 3b (functional floodplain). Please can you clarify this?

Final Comments
Once again, thank you for contacting us. Please quote our reference number in any future correspondence.
If you have any queries please contact me.

Object

VALP Further Main Modifications

Representation ID: 4103

Received: 07/02/2021

Respondent: The Buckingham Society

Legally compliant? Yes

Sound? No

Representation Summary:

Although we support the inclusion of this requirement, to be “effective”, these principles must lead to a more up to date evaluation of the sites referenced above, evidence for which is totally lacking and which, considering local flooding history, must be brought to bear before these sites are considered as firm allocations.

Full text:

FMM059

BUC043 (Moreton Road, Phase III)
The Society has consistently opposed the inclusion of this site in VALP. It did not form part of the development plan in the adopted Buckingham Neighbourhood Development Plan and a previous application was rejected at appeal by the Planning Inspectorate. It cannot deliver sustainable housing growth, as can be understood from the many objections to the planning application validated on 11th February 2020 and without major infrastructure mitigation, no development is possible within the plan period.
Pollution: It is acknowledged that the relative high growth strategy at Buckingham and Maids Moreton carries a severe risk of pollution since current waste water treatments are at capacity and necessitate major works to prevent pollution. The inclusion of “reference to consultation with the water and sewerage undertaker” does not adequately mitigate against anticipated pollution.
Transport:ED257 Buckingham and Maids Moreton VALP Allocations
This document appears to be produced by Buckinghamshire Council in response to the conclusions reached by Jacobs’ (ED255), Additional Buckingham Modelling Report (produced in October 2020).
ED257 focus’ on the withdrawal of BUC051, using the calculations carried out by the recent additional modelling by Jacobs. The modelling methodology used focus’ on the impacts at the two town centre junctions (Moreton Road/Stratford Road/Market Square and West Street/Bridge Street/Market Square). The report concludes that the impact of traffic emanating from BUC043 and MMO006 combined (300 dwellings) is less than that might be generated by BUC051 (125 dwellings). The Buckingham Society believes this is disingenuous for the following reasons:
1. Alternative routes for BUC046 cannot be compared to the so-called “alternative routes” for BUC043 and MMO006 combined.
2.Figs 2-5 – 2-8 indicate traffic flows from BUC043 and MMO006 using the principal village roads of Avenue Road, Mill Lane* and Main Street. This “alternative” route has been deemed unacceptable and there are mitigation measures proposed to discourage any use of these routes.
3.If the modelling is predicting a 25% increase in flows eastwards from the Moreton Road/High Street junction, the A422 will be subject to long queues at the approaches from both Stratford Road and Mill Lane*.
4.Why is it assumed that all traffic emanating from site BUC051 will flow through the town centre? The Brackley Road (A422 westwards) is a likely route, leading as it does to the Silverstone Enterprise Zone.
5. Both BUC043 and MMO006 are approached from the town centre via a steep hill, making cycle access difficult and, with limited footpath access at historic pinch points, interaction between cars and pedestrians will be problematic. By contrast, site BUC051 could initiate an attractive, flat, pedestrian/cycle access via the riverside walks.
6. There is equally (if not worse) significant on street parking along the Moreton Road further exacerbating the queuing traffic from an easterly direction.
* Mill Lane is also referred to as ‘College Farm Road’.

FMM003

Buckingham is expected to accommodate additional growth (2,177 houses) without any indication of the associated infrastructure that will be required to service this growth.
Sustainable growth is not justified without sustainable transport links. This requires public transport that is easily accessible without the use of the car. In the light of the recent confirmed financial support for the East-West Rail link, which will offer a real alternative to the car, the Society calls for a re-directed balance of housing towards Winslow. The reduction of dwellings stated in FMM006 (27) should be re-instated in Winslow, and the increase in Buckingham (10) diverted to a more sustainable location.

In the Inspector’s Interim Findings, it is noted that ”growth in the north of the district would lead to increased lengths of commuting flows” and that this is contrary to the NPPF, paragraph 34, which seeks to “ensure that developments which generate significant movement are located where the need to travel will be minimized”.

ED245 Policies Map

Please note this is neither a ‘support’ or ‘object’ matter. It is simply an observation, which leads to the conclusions set out under other responses from The Buckingham Society to this consultation.
Policies Map
It is noticeable when examining the Policies Map for Buckingham and the neighbouring settlement of Maids Moreton (page 5) that allocations BUC043 and MMO006 are located at the furthest edges of Buckingham and Maids Moreton respectively and distanced by some margin from the main employment areas.

The reserved site for Buckingham’s additional cemetery site is not shown. This is a commitment within the Buckingham Neighbourhood Development Plan and marked ‘F’ on Fig.4.2.

FMM072

D-MMO006 Land east of Walnut Drive and west of Foscote Road
Maids Moreton has been wrongly categorized as a “medium” village. For a settlement of a lower order with acknowledged, major transport restraints, the proposed growth of 170 dwellings on this site, now compounded by an additional 12 dwellings on MMO005 (FMM107) is not sustainable. The insertion of the words “at least” further undermines the sustainability of this site. Contrary to FMM067, the village is not “moderately well served with services and facilities”, having only 4 of the 6 criteria cited as a minimum number to qualify as a “medium” village. And, even if it WAS a “medium” village, “at least 170 houses” is in total conflict with FMM015, Policy S2 (h): “growth in medium villages will be at a scale in keeping with the local character and setting. It is also in direct conflict with NPPF, Paragraph 34, since the “significant” movement that will be generated by 170 dwellings outside the settlement boundary of a small village cannot be minimised.
One can observe the ludicrously unbalanced nature of this allocation in FMM068, noting that no other ‘medium’ village is expected to accommodate more than 37 dwellings.
Pollution
As noted under FMM059, the high growth strategy at Buckingham and Maids Moreton carries an unacceptable risk of pollution owing to the inadequacy of waste water treatment in the area.
Transport
The SA Addendum report (ED246 9.12.4) considers the “at least 170 houses” to add a further degree of constraint since it is acknowledged that a “larger site at a lower order settlement” will generate significant vehicular movement contrary to NPPF, paragraph 34.
Maids Moreton is approached from the town centre via a steep hill, making cycle access difficult and, with limited footpath access at historic pinch points, interaction between cars and pedestrians will be problematic.
ED257 Buckingham and Maids Moreton VALP Allocations
This document appears to be produced by Buckinghamshire Council in response to the conclusions reached by Jacobs’ (ED255), Additional Buckingham Modelling Report (produced in October 2020).
ED257 focus’ on the withdrawal of BUC051, using the calculations carried out by the recent additional modelling by Jacobs. The modelling methodology used focus’ on the impacts at the two town centre junctions (Moreton Road/Stratford Road/Market Square and West Street/Bridge Street/Market Square). The report concludes that the impact of traffic emanating from BUC043 and MMO006 combined (300 dwellings) is less than that might be generated by BUC051 (125 dwellings). The Buckingham Society believes this is disingenuous for the following reasons:
1. Alternative routes for BUC046 cannot be compared to the so-called “alternative routes” for BUC043 and MMO006 combined.
2.Figs 2-5 – 2-8 indicate traffic flows from BUC043 and MMO006 using the principal village roads of Avenue Road, Mill Lane* and Main Street. This “alternative” route has been deemed unacceptable and there are mitigation measures proposed to discourage any use of these routes.
*Mill Lane is also referred to as ‘College Farm Road’.

FMM096 and FMM103

Policy I4 Flooding
(e) and (i)Noting the changes in FMM103 to “ensure no increase in flood risk on site or elsewhere such as downstream, or upstream receptors, existing development and/or adjacent land” , The Buckingham Society considers that development on the scale envisaged in BUC043, BUC046 and MMO006 would see a significant increase in surface water discharge and lead to even greater flood risks within the Great Ouse catchment area. Calculations for floodplain compensation and volume-for-volume compensation up to the 1% annual probability (1 in 100) are no longer adequate.

FMM096 requires “a new requirement to include detailed modelling of any ordinary watercourses within or adjacent to the site, where appropriate, to define in detail the area at risk of flooding and model the effect of climate change.” This is an important proposal as it can be the case that small streams and ditches shown by the nationally available flood risk dataset to be associated with surface water flood risk can be found to be associated with fluvial flood risk upon further investigation.
There are vast numbers of active springs around the town and it is noticeable that these and related underground watercourses have changed the pattern of surface discharge; so much so that in each of the recent major flood events (1998, 2007 and most recently December 2020), the associated flooding within and without the town has significantly worsened, flooding properties and land that has not seen such volumes of water in previous decades. Should planning applications proceed for sites BUC043, BUC046 and MMO006, further evidence is needed on such matters.