Aylesbury Vale Area

VALP Proposed Submission

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Object

VALP Proposed Submission

1.9

Representation ID: 567

Received: 13/12/2017

Respondent: Marrons Planning

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

The Plan fails the duty to cooperate in that the provision of the Bletchley Southern Bypass has not been addressed by the Council in liaison with the neighbouring authority of Milton Keynes.

Full text:

Paragraphs 1.9 - 1.12 : Duty to Co-operate

Aylesbury Vale District Council's (the District) administrative area abuts that of Milton Keynes. Of greater significance is that the built up area of Milton Keynes and Bletchley (the City) abuts the north eastern boundary of the District and yet there is no specific reference to the importance of the City to the economy of the area, not least as a source of jobs for residents of the District. Travel between the two authorities whether by road or rail is consequently an issue of mutual interest. It is therefore a matter of concern that in the context of the 'Duty to Co-operate', the focus is on the District's co-operation with "other councils in Buckinghamshire", (paragraph 2.8 of the 'Duty to Cooperate Statement of Compliance, November 2017, in respect of Transport refers - the countywide traffic modelling solely assessed the impact of the emerging local Plan proposals within Buckinghamshire) and there is no specific reference to the need for co-operation with Milton Keynes.

Paragraph 178 of the Framework stipulates that public bodies have a duty to cooperate on planning issues that cross administrative boundaries, particularly those which relate to the strategic priorities set out in paragraph 156; one of which relates to the "provision of infrastructure for transport". In this context, one issue which it is considered should be the subject of co-operation between the District and the City is the provision of the Bletchley Southern Bypass / Relief Road. This road would relieve some of the pressure on the east-west A421 route and could only be provided by traversing land within Aylesbury Vale; as reflected in the safeguarded route which has been provided through the Salden Chase development as shown on the Concept Plan reproduced in Policy D-NLV001.

The Proposed Submission version of Plan:MK is currently the subject of consultation. It is therefore relevant to note that the 'Transport Vision and Strategy for Milton Keynes Local Transport Plan 3 - 2011 to 2031' includes, as Annex B, the Bletchley Transport Strategy 2011. (HTo22 on page 67 states that: "The council supports, in principle, the .... Bletchley Southern bypasses subject to design, feasibility (including affordability), public consultation and funding"). The new road would pass through the District and must therefore be the subject of co-operation if there is to be any chance of securing its delivery as it is only by so doing that the infrastructure necessary to support current and projected future levels of development will be secured.

Object

VALP Proposed Submission

1.13

Representation ID: 569

Received: 13/12/2017

Respondent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Specific reference has not been made to those major settlements, notably Milton Keynes and Bletchley, which adjoin the District. It should be recognised that land in this location (over and above that which is allocated) provides the opportunity for a sustainable approach to meeting housing need in the District in the form of one or more larger Sustainable Urban Extensions.
The suitability of these locations to accommodate development is acknowledged elsewhere in the Plan and it is therefore appropriate to include a similar statement in Paragraph 1.13

Full text:

Rey Construction supports the Council's decision to allocate sites on the basis of their suitability and location rather than applying a blanket housing percentage based on settlement size. It also acknowledges that Aylesbury is a suitable location "for more than half of the new homes". However, it is a matter of concern that specific reference has not been made in paragraph 1.13 to those major settlements, notably Milton Keynes and Bletchley, which adjoin the District. It should be recognised that land in this location (over and above that which is allocated) provides the opportunity for a sustainable approach to meeting housing need in the District in the form of one or more larger Sustainable Urban Extensions.

The suitability of these locations to accommodate development is acknowledged in subsequent policies and proposals within the Plan (paragraph 3.14, Policy D-NLV001 and its accompanying text) and it is therefore considered appropriate to include a similar statement in paragraph 1.13.

Object

VALP Proposed Submission

2.4

Representation ID: 570

Received: 13/12/2017

Respondent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

It is notable that although the Local Plan provides for "2,212" dwellings on sites adjacent to Milton Keynes (Policies S2 f and Table 1), the Spatial Vision contains no reference to the sustainable growth to Milton Keynes and Bletchley which will have occurred within AVDC's administrative area by the end of the plan period. Further, in view of the scope to provide for significantly more development in this sustainable location, it is incumbent that the Vision fully reflects the opportunity to provide for sustainable development within this area.

Full text:

Paragraph 2.4 sets out the Vision for those areas within the District where change is likely to have occurred by the end of the plan period and specifically refers to Aylesbury (sub paragraph g), Buckingham (sub paragraph h) and the rural areas (sub paragraph i) where development is to be focussed at Winslow, Haddenham, Wendover and other larger sustainable villages.

It is notable that even though the Local Plan provides for "2,212" dwellings on sites adjacent to Milton Keynes (Policies S2 f and Table 1), the Spatial Vision contains no reference to the sustainable growth to Milton Keynes and Bletchley which will have occurred within AVDC's administrative area by the end of the plan period. Further, in view of the scope to provide for significantly more development in this sustainable location, (as reflected in the 'Plan:MK Strategic Development Directions' Consultation Paper), it is incumbent that the Vision fully reflects the opportunity to provide for sustainable development within this area.

Object

VALP Proposed Submission

2.6

Representation ID: 572

Received: 13/12/2017

Respondent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

2: As the Council has committed to meeting the unmet need of 8,000 dwellings arising in the Councils to the south of the District, this issue should not be the subject of on-going consideration once the Plan has been adopted.

4: There is no reference to the provision within the Local Plan for the sustainable growth of Milton Keynes and Bletchley which will have occurred within AVDC's administrative area by the end of the plan period.

Full text:

Objective 2
Rey Construction objects to the qualification of providing for "unmet needs from elsewhere" by the statement "if reasonable and sustainable". The Council has committed to meeting the unmet need of 8,000 dwellings arising in the Councils to the south of the District and states in paragraph 1.12 that sufficient suitable and deliverable sites have been found to meet this need. Consequently, this issue should not be the subject of on-going consideration once the Plan has been adopted.

Objective 4
In commenting on the Spatial Vision, it has been noted that there is no reference to the provision within the Local Plan for the sustainable growth of Milton Keynes and Bletchley which will have occurred within AVDC's administrative area by the end of the plan period. The same omission has been made in Objective 4 which solely refers to the focus of development being Aylesbury Garden Town, Buckingham, Haddenham, Winslow and Wendover, together with an appropriate level of development at the most sustainable settlements in the rural areas.

Object

VALP Proposed Submission

3.13

Representation ID: 573

Received: 13/12/2017

Respondent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The evidence in the HEDNA was formulated prior to the Government's commitment to build 300,000 dpa.
The proposed provision of 19,400 dwellings between 2013 - 2033 and the 8,000 dwellings to meet the unmet need of neighbouring authorities is less than the previous assessments.
At a time when there is considerable public and political pressure for an uplift in the provision of new homes, it is counter intuitive to be providing for a lower number of dwellings.
The Government's proposed methodology should be applied; an increase of the number of dwellings per year of over 50%.

Full text:

The Government has committed to the building of 300,000 dwellings per year (dpa); a significant increase on previous policy objectives (250,000 dpa) and current output of approximately 170,000 dpa. It is only by securing this scale of uplift that it will be possible for the severe housing crisis in this country to be addressed and it is therefore essential for all those involved in the residential development process to facilitate this provision.

It is in this context that the provision now being proposed by the Council needs to be assessed. It may be that the latest evidence contained in the Housing and Economic Development Needs Assessment (HEDNA, December 2016 and its Update Addendum dated September 2017), and prepared on the basis of current formulae, correctly identifies an objectively assessed need (OAN) for Aylesbury Vale of 19,400 dwellings between 2013 - 2033 as well as the unmet need from neighbouring authorities (8,000 dwellings). However this was formulated prior to the Government's aforementioned commitment to build 300,000 dpa. It is also pertinent to note that it is 1,900 fewer homes than in the previous assessment and before any account is taken of the reduction in the neighbouring authorities' OAN. Consequently at a time when there is considerable public and political pressure for an uplift in the provision of new homes, it is counter intuitive to be providing for a lower number of dwellings.

Further, evidence of the pressure for the number of dwellings in this area to be increased is contained in the Government's consultation paper on 'Planning for the right homes in the right places' which sets out a standard approach to assessing local housing need. Accompanying tables set out an indicative assessment of housing need based on the proposed formula. For Aylesbury Vale, the application of this methodology results in an increase of the number of dwellings per year of over 50% from 970 dpa to 1,499 dpa. Rey Construction is aware that the Government's announcement on the methodology to be adopted when undertaking the standard approach for housing need assessments is still awaited; even so there is a clear direction of travel which should be reflected in those Local Plans which are currently being prepared, not least because it is only in so doing that it will be possible to "boost significantly the supply of housing" as required by paragraph 47 of the Framework

It is also relevant to the consideration of this issue to note that the National Infrastructure Commission published its report 'Partnering for Prosperity: a new deal for the Cambridge-Milton Keynes-Oxford Arc' in November 2017. This considers how to maximise the potential of the Cambridge - Milton Keynes - Oxford corridor as a single, knowledge-intensive cluster. In so doing, it argues that, if East West Rail and the Expressway were developed, analysis of land constraints suggests that key opportunities for growth over the next 30 years could include the re-establishment of Milton Keynes as a development location of national significance expanding the town to at least 500,000 (from a current population of approximately 267,000). This will clearly have implications for Aylesbury Vale as well as Milton Keynes and in view of the importance of the Arc to the national economy, it is essential that development in this area is not unnecessarily constrained.

In the circumstances it is imperative that the Plan provides for more dwellings than currently proposed if the needs of the country are to be met in the most sustainable locations.

Object

VALP Proposed Submission

S2 Spatial Strategy for Growth

Representation ID: 574

Received: 13/12/2017

Respondent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

It is inappropriate to specify "2,212" homes and to attempt to inject this degree of precision into a strategic planning policy. In any event, there is greater scope for further development to the south west of Milton Keynes which would enable the provision of a greater number of dwellings.

Flexibility will be essential to ensure that changing circumstances and requirements can be accommodated during the application process.

The final sentence is too dogmatic in its approach to development proposals which will contravene the presumption in favour of sustainable development as set out in Policy S1.


Full text:

Rey Construction has no objections in principle to Policy S2 and the spatial strategy for growth contained therein. In particular, it welcomes the reference to sites adjacent to Milton Keynes, and within Aylesbury Vale, making provision for new homes. However when a plan needs to be "positively prepared" to be sound, it is considered unacceptable to specify a figure of "2,212" homes as it is totally inappropriate to attempt to inject this degree of precision into a strategic planning policy. In any event, it is considered that there is greater scope for further development in the area to the south west of Milton Keynes which would enable the Council to provide for a greater number of dwellings; an issue which is expanded upon in the representations to Table 1.

In this context, it is notable that paragraph 4.117, which provides some of the explanatory text to Policy D-NLV001 'Salden Chase', explains that the application which now has a favourable resolution is for up to 1,885 dwellings; a maximum figure which could presumably be significantly less which could undermine the Council's delivery strategy.

The exact capacity of any development site will only be known when detailed technical studies have been undertaken and these will then inform any application(s) for planning permission. Even then it is very rare for an outline planning application to be able to specify an exact number of dwellings. A degree of flexibility will be essential to ensure that changing circumstances and requirements can be accommodated through the consultation and negotiation stages.

Further it is considered that the final sentence of Policy S2 ("development which does not fit with the scale, distribution or requirements of this policy will not be permitted") is too dogmatic in its approach to development proposals which will contravene the presumption in favour of sustainable development as set out in Policy S1 which states that proposals should fit with the intentions and policies of the Local Plan (and Neighbourhood Plans were relevant). It is therefore imperative that the policy is amended as it is only in so doing that it will be consistent with national policy.

Object

VALP Proposed Submission

Table 1 Spatial strategy for growth in Aylesbury Vale

Representation ID: 575

Received: 13/12/2017

Respondent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Provision needs to be made for additional dwellings in Table 1. A significant proportion of these dwellings could and should be provided in the most sustainable location for development within the District, namely adjacent and within the vicinity of Milton Keynes; an area which Milton Keynes Council in its Plan:MK Strategic Development Directions consultation described as "an arc of urban extensions" which includes the land to the 'south and west around Newton Longville'.

This area has the scope and capacity for more development than AVDC is currently envisaging.

Full text:

In the representations to Policy S2, the case has been made for an uplift in the housing requirement as it is only in so doing that the Plan will be consistent with existing and emerging national policy. It therefore follows that provision needs to be made for additional dwellings in Table 1.

A significant proportion of these dwellings could and should be provided in the most sustainable location for development within the District, namely adjacent and within the vicinity of Milton Keynes; an area which Milton Keynes Council in its Plan:MK Strategic Development Directions consultation described, within 'Direction of Growth 1', as "an arc of urban extensions" which includes the land to the 'south and west around Newton Longville'. In so doing, it has clearly been acknowledged that the area has the scope and capacity for more development than AVDC is currently envisaging.

Object

VALP Proposed Submission

Table 2 Proposed settlement hierarchy and housing development

Representation ID: 577

Received: 13/12/2017

Respondent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

These comments relate to the 'Land adjacent to Milton Keynes' category and the provision of 2,212 dwellings.

Rey Construction does not agree with the conclusions of the HELAA (Version 4, January 2017). It is considered more sites could and should have been assessed as suitable, including 'land between Manor Farm and railway line, Whaddon Road' (Site Ref: NLV019).

Sites to the south of the railway line and north of Newton Longville should be assessed together to determine their suitability to provide a much larger SUE than currently identified.

Full text:

These comments relate specifically to the 'Land adjacent to Milton Keynes' category and the total provision for this area of 2,212 dwellings.

Rey Construction does not agree with the conclusions of the HELAA (Version 4, January 2017) not least because it is considered that more sites could and should have been assessed as suitable, including 'land between Manor Farm and railway line, Whaddon Road' (Site Ref: NLV019).

It is considered that there is a fundamental flaw in the approach which the Council has adopted when assessing the suitability of sites to the south west of Milton Keynes, largely but not entirely within the parish boundaries of Newton Longville. For those sites to the north of the railway line (NLV001, NLV023 and NLV020) sites are assessed in relation to Bletchley's urban area, the strategic road network and East West Rail, in respect of which the potential for a future station is referred to. However those sites to the south of the railway line, albeit adjacent to it, are assessed in relation to the village of Newton Longville; for example, it is noted that the Manor Farm site does not adjoin the village and that it is approximately 1.1 km to the village core.

The sites to the south of the railway line and north of Newton Longville would not be developed on an individual, ad-hoc basis, but as part of a wider urban extension or as an extension to the allocation immediately to the north of the railway line (which now has a resolution to approve an outline planning application for the site). The Manor Farm site should be considered in conjunction with other development opportunities in the area which, when combined, could deliver not just a significant contribution to the housing needs of the area but also could facilitate the provision of requisite infrastructure such as the Bletchley Southern Bypass, a railway station on the East West Rail line and Green Infrastructure. It is therefore essential that the District Council, working with Milton Keynes Council, adopts a positive approach to development in the vicinity of the Newton Longville and does not limit its vision to the provision of an urban extension to the north of the railway line.

In this context, Rey Construction is aware that when Milton Keynes Council consulted on its 'Plan:MK - Strategic Development Options'; one of the areas considered related to 'Development to the west, south/west and/or south east of the City' which included land within Aylesbury Vale's administrative area to the north of Newton Longville. In the document, it explained that growth would be in the form of "an arc of urban extensions" extending beyond the existing expansion areas "including land beyond the administrative boundary .... to the south and west around Newton Longville......" Unlike the HELAA, it recognised the benefits of development in the area and in so doing specifically referred to the opportunities afforded by the East-West rail route and that the "The growth arc could potentially help to deliver a Bletchley southern bypass relieving some of the pressure on the east-west A421 route through the city"; a proposal which would also overcome those concerns about the railway line forming a barrier to a well connected urban extension to Milton Keynes. (In this context it is important to note that there is a track which passes under the railway line immediately to the east of the Manor Farm site).

It was further recognised in the consultation document that consideration would need to be given to the impact of development on existing villages; the suggestion being that they are "sensitively treated, for example through the creation of landscape or green buffers."

Having regard to the increasing and acknowledged need for more housing, it is imperative that a positive approach is taken to the development of a much larger sustainable urban extension in the vicinity of Newton Longville than currently envisaged and identified as suitable in the existing HELAA..

Object

VALP Proposed Submission

4.112

Representation ID: 579

Received: 13/12/2017

Respondent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

No objections in principle to Policy D-NLV001 and its accompanying text insofar as it allocates land for a strategic allocation to the south west of Milton Keynes. The objections are those set out in response to previous policies and text; namely:

1. There is scope for significantly more development to the south west of Milton Keynes.

2. The Plan should be providing about 7,500 dwellings in the broad location for growth known as south west Milton Keynes.

3. Land between Manor Farm and the railway line (NLV019) should be included within the additional area to be allocated as a SUE.


Full text:

There are no objections in principle to Policy D-NLV001 and its accompanying text insofar as it allocates land for a strategic allocation to the south west of Milton Keynes. The objections are those set out in response to previous policies and text; namely:

1. There is scope for significantly more development to the south west of Milton Keynes which would enable the Council to provide for a much larger amount of housing in a sustainable location.

2. The Plan should be providing about 7,500 dwellings in the broad location for growth known as south west Milton Keynes and north west of Newton Longville.

3. The land between Manor Farm and the railway line (NLV019) should be included within the additional area to be allocated as a sustainable urban extension

Object

VALP Proposed Submission

D-NLV001 Salden Chase

Representation ID: 580

Received: 13/12/2017

Respondent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

No objections in principle to Policy D-NLV001 and its accompanying text insofar as it allocates land for a strategic allocation to the south west of Milton Keynes. The objections are those set out in response to previous policies and text; namely:

1. There is scope for significantly more development to the south west of Milton Keynes.

2. The Plan should be providing about 7,500 dwellings in the broad location for growth known as south west Milton Keynes.

3. Land between Manor Farm and the railway line (NLV019) should be included within the additional area to be allocated as a SUE.



Full text:

There are no objections in principle to Policy D-NLV001 and its accompanying text insofar as it allocates land for a strategic allocation to the south west of Milton Keynes. The objections are those set out in response to previous policies and text; namely:

1. There is scope for significantly more development to the south west of Milton Keynes which would enable the Council to provide for a much larger amount of housing in a sustainable location.

2. The Plan should be providing about 7,500 dwellings in the broad location for growth known as south west Milton Keynes and north west of Newton Longville.

3. The land between Manor Farm and the railway line (NLV019) should be included within the additional area to be allocated as a sustainable urban extension

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