Aylesbury Vale Area

VALP Proposed Submission

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Support

VALP Proposed Submission

1.1

Representation ID: 741

Received: 13/12/2017

Respondent: Buckingham Town Council

Representation Summary:

BTC welcomes that with the advent of an up-to-date Local Plan as part of the overall Development Plan, opportunistic development which the Town Council has opposed will become less of a feature in the North of the District. BTC has invested considerable public money in the preparation and making of the BNDP [October 2015] which together with VALP [when adopted] will form the LDP for Buckingham Neighbourhood Development Area in the immediate future. VALP also provides the up-to-date Local Plan from which any review of the BNDP can assess its compliance with the Strategic Plans as set out in VALP.

Full text:

BTC welcomes that with the advent of an up-to-date Local Plan as part of the overall Development Plan, opportunistic development which the Town Council has opposed will become less of a feature in the North of the District. BTC has invested considerable public money in the preparation and making of the BNDP [October 2015] which together with VALP [when adopted] will form the LDP for Buckingham Neighbourhood Development Area in the immediate future. VALP also provides the up-to-date Local Plan from which any review of the BNDP can assess its compliance with the Strategic Plans as set out in VALP.

Support

VALP Proposed Submission

S8 Neighbourhood plans

Representation ID: 747

Received: 13/12/2017

Respondent: Buckingham Town Council

Representation Summary:

Buckingham Town Council acknowledges S8 but notes that it pertains only to future NDPs being made after the adoption of the VALP. Given that it is acknowledged that there is a significant number of NDPs within the district, it was hoped that there would be more clarity as to the status of the components of the Development Plan overall after adoption of VALP.

Officer Note: reassigned from 1.20 to S8 for relevance

Full text:

Buckingham Town Council acknowledges S8 but notes that it pertains only to future NDPs being made after the adoption of the VALP. Given that it is acknowledged that there is a significant number of NDPs within the district, it was hoped that there would be more clarity as to the status of the components of the Development Plan overall after adoption of VALP.

Support

VALP Proposed Submission

1.14

Representation ID: 748

Received: 13/12/2017

Respondent: Buckingham Town Council

Representation Summary:

It is acknowledged that S1 does include site allocations within neighbourhood plans, in addition E2 is now worded to include "appropriate" allocations within neighbourhood development plans and thus may in fact be seen to be within the Local Plan now.

Full text:

It is acknowledged that S1 does include site allocations within neighbourhood plans, in addition E2 is now worded to include "appropriate" allocations within neighbourhood development plans and thus may in fact be seen to be within the Local Plan now.

Object

VALP Proposed Submission

D-BUC043 Land west of AVDLP allocation BU1 Moreton Road, Buckingham

Representation ID: 886

Received: 14/12/2017

Respondent: Buckingham Town Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Site has been rejected by BNDP and the Secretary of State for that reason. It breaches S3 of VALP regarding coalescence and in doing so, makes the coalescence between Buckingham and Maids Moreton de facto. No consideration has been given to the additional impact on services in Buckingham and infrastructure, especially roads increasing traffic congestion in Buckingham town centre, when additional site allocation for Maids Moreton is included. There will be incursions to the build line from potential future developments as evidenced in HELAA, where is was deemed "part suitable".

Full text:

This site has been contentious. It was subject to a planning inquiry and was called in by the Secretary of State. The planning inspector's decision was overturned by the Secretary of State.
It is understood that VALP will become the most up-to-date part of the Development Plan when adopted, and thus will take precedence over the BNDP, and that AVDC is required to provide for housing need, and has allocated sites to fulfill this.
This however, does not explain the decision to include such a contentious site, which was called in by the Secretary of State partly on the basis that it was in breach of the BNDP. AVDC refused permission for the site, and joined with BTC at the planning inquiry in support of refusing planning permission. Why then is it included, when it is clearly known that the people of Buckingham have firmly rejected this site. It does not seem to consider the relevant consideration of co-operation between councils in the development of NDPs.
The selection of this site is unsound in that it contradicts AVDC's policy as stated in S3 of VALP:
"The scale and distribution of development should accord with the settlement hierarchy set out in Table 2 and the site allocation policies that arise from it. Other than for specific proposals and land allocations in the Plan, new development in the countryside should be avoided, especially where it would:
a. Compromise the character of the countryside between settlements, and
b. result in negative impact on the identities of neighbouring settlements or communities leading to their coalescence.
In considering applications for building in the countryside the Council will have regard to maintaining the individual identity of villages and avoiding extensions to built-up areas that might lead to coalescence between settlements."[emphasis added]
It may be that AVDC has tried to reserve its position by stating that any allocated site in the Plan [see emphasized text above] is exempt from this strategic policy, but BTC queries whether it is sound to breach a stated strategic policy which will govern development, without providing strong cogent reasoning for so doing, whilst at the same time ignoring the BNDP.
Buckingham is a "strategic settlement" and Maids Moreton is a "medium village" [Table 2 of VALP].
Medium Villages have "some provision key services and facilities, making them moderately sustainable locations for development. The plan allocates some sites at medium villages." Maids Moreton has a small village hall and a pub. Site allocations for Medium Villages range from 6 to 171 within Table 2. Maids Moreton has 171 allocated. In addition, another 180 dwellings are allocated in site BUC 043, which lies on the boundary of Maids Moreton and Buckingham. In this allocation it would appear that AVDC is making coalescence de facto and going against its stated aim in S3 to avoid the loss of identity of settlements.
Acknowledgement of this would mean that the village of Maids Moreton should have questions of infrastructure addressed, as it will have questions of road access not just from their own development but also from the site BUC 043 as traffic seeks to avoid congestion in Buckingham town centre.
It should also be considered in terms of impact on Buckingham. The BNDP was not prepared with such complete coalescence as is evidenced by the Town Council's objection to planning permission being granted to the site on BUC 043. Much convenience shopping [Tesco; Aldi & the planned Lidl], as well as potentially the new combined health centre lie south of the by-pass. Many residents will be tempted into cars for journeys through Buckingham to reach these sites. At present the A413 will be the main route as the only alternative in Mill Lane to access A422 and the by-pass. This can only add to the congestion in the town centre, especially at the Old Gaol junction. The town centre congestion is noted in the BTS.
It will mean that opportunistic developers will be able to argue that as coalescence has been de facto achieved by AVDC's own Local Plan, then future development is exempt from S3.
To be sound it is submitted that AVDC should honestly address the fact that by these allocations coalescence will be achieved and should show strategic planning to that effect; or allocate alternative sites.
It should be noted that it is "Part suitable" under HELAA as northwest corner to be reserved for sports pitches and open recreation ground. The build line may be held level but the introduction of the site opens up further development - as is noted in the HELAA as regards BUC007 [land behind Gilbert Scott Drive] which is not deemed suitable until BUC043 is built out [on basis of previous AVDLP allocation].
If the current proposal to relocate all GP surgeries to Lace Hill to the south, then this site will not be within 800m, if it is now, which is debatable - it will not be possible to walk for many people; in addition three major convenience shops - Lidl, Aldi and Tesco will all be located south of the by-pass, encouraging residents to use car to access out of town shopping, and not supporting Town Centre First policy stated in E5

Object

VALP Proposed Submission

D-NLV001 Salden Chase

Representation ID: 889

Received: 14/12/2017

Respondent: Buckingham Town Council

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

No provision is made to support the local grammar school for which successful 11+ candidates will be eligible. This will place an additional burden on the underfunded Royal Latin School. There is evidence of alternative provision in supporting evidence but no clarity as to that policy within VALP and no evidence of consultation with Milton Keynes Council as to viability.

Full text:

A secondary school is mentioned in the box pertaining to key development and land use requirements but the site specific requirements as to Education only make mention of provision of land for new schools and pre-school facilities. As part of Buckingham County Council area, residents will be eligible for Grammar School places under the 11+ scheme. Given the attraction and reputation of the local Grammar schools, and the land falls within the catchment area of the Royal Latin School in Buckingham, some provision should be made for a contribution to this school in addition to the new secondary school as it might be assumed that as 11+ exam results in the selection of around 25-30% of primary school children [even allowing for those individuals who elect for the new secondary school; faith schools in Milton Keynes; private education or home schooling] a significant number of secondary school pupils may well attend the Royal Latin School. The school itself believes that it is one of the most underfunded schools in England & Wales at the current time.
There is in fact a potential answer given in the Infrastructure Delivery Plan [part of the Supporting Evidence to VALP, at p.23] which suggests that it would be better to redraw the boundary of Milton Keynes to include this expansion from a point of view of schools, thus making it a catchment are for Milton Keynes schools as opposed to Buckinghamshire County Council's selective grammar school system.
However, this policy is not set out in VALP, and if in fact Milton Keynes Council is not prepared to accept this proposal [there is no indication in the Infrastructure Delivery Plan of any consultation on this or the likelihood of it being delivered/agreed] then VALP remains ill-equipped to deliver on education for the District.

Object

VALP Proposed Submission

I5 Water resources

Representation ID: 891

Received: 14/12/2017

Respondent: Buckingham Town Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

There is failure to consider essential evidence brought forward in the Water Cycle Study. If Buckingham is to remain a strategic settlement, a clearer policy as to how to upgrade WwTw needs to be provided if deliverability and viability issues are to be met, and to justify the additional allocation within the deliverability timescale set out. Otherwise Buckingham will lose out on other essential infrastructure from developer contributions/viability concerns.

Full text:

It is understood that the site allocations in the BNDP are assumed but that in addition to the reserve site from that Plan, BUC051, further housing numbers are required, and the designation of Buckingham as a strategic settlement has driven these additional site allocations.
There is internal consistency within the VALP. The allocation of two of these sites is inconsistent with other strategic policies within VALP. It is submitted that the inconsistency makes it unsound, as the lack of apparent consideration as to whether there are other suitable sites consistent with the Plan.
In addition it is noted that the Water Cycle Survey notes that upgrading to sewerage will be required by the Anglian Water before any further major development is possible at Buckingham [Water Cycle Study Volume 2 at 5.4.6.2].
The overall RAG score for Buckingham sites was Amber - broken down into 1-5 years and 6-15 years the sewerage System Capacity- WwTw Capacity - Red; Sewerage Network capacity - Amber; Surface water Network Capacity Red
It is noted in the document that pertaining to Buckingham "Infrastructure and/or treatment upgrades will be required to serve proposed growth. Major constraints have been identified"[p.89] There is only one other red area across the area and that is Stanbridgeford.
This might question why Buckingham is allocated such a high proportion of new housing, while such serious contraints remain an issue.
What is immediately concerning is that VALP does not seem to address this evidence in terms of deliverability. Anglian Water comments in response to Water Cycle Study:
"In relation to Buckingham WRC it is important to note that we are currently progressing a scheme to accommodate growth as part of the current Asset Management Plan period (2015-2020). Please note that this scheme has a design horizon of 2021. Anglian Water have confirmed that Buckingham WwTw remains as "red" assessment for both periods of 1-5 years and 6-15 years."
and also the Recommendation at 5.4.7.

"AVDC to take into account the available WwTw capacity in phasing development going into same WwTw".
Yet on site allocations for Buckingham:
BUC043 - 130 homes between 2018 and 2023
BUC051 - 100 homes to be delivered 2018-23 [200 2024-2033]
BUC046 - 100 homes between 2018-23 [320 homes 2024-2033]
This is in addition to the provision within BNDP for 617 homes and 400 student units as well as windfall development - all potentially possible within the first five years.
This does not seem to accord with the recommendation above, and it is not explained how at paragraph 4.128 of VALP:
"The Water Cycle Study (2017) assessed the impact of growth on water cycle infrastructure in the village. The following policy is to ensure that growth takes place with any upgrades to the treatment works that may be needed."
The first, obvious, point is that Buckingham is not a village. The second point that is perhaps not just a careless mistake is that how this policy achieves this in terms of site allocations and phasing is not made out in answer to the points raised within the Water Cycle Study document itself.
If developer contributions to the sewerage upgrade are required to bring this development on sooner, then this will affect viability calculations and may reduce affordable housing and infrastructure. It should be noted that s.106 of Town and Country Planning Act prevents such infrastructure forming part of CIL or S. 106 agreements.
This may not lead to quick delivery, if construction cannot be undertaken in its absence.
The allocation of additional sites on top of the sites already allocated in BNDP is not fully justified against the supporting evidence contained within the Water Cycle Study [Aylesbury Vale Water Cycle Study (Final) 2016, JBA Consulting, part of Supporting Evidence]. In this document there are two issues for Buckingham:
(i) The inability to deal with phosphorus, and the observation that this may be a constraint on development in Buckingham;
(ii) The requirement of sewerage infrastructure - whilst this may be provided by Anglian Water under the Asset Management Programme and also potentially from developer contributions - this would seem to have an effect on deliverability of the sites within the proposed timescales; and also to the viability of the development. The concern is that in potential contributions to sewerage infrastructure, developers will be able to assert viability concerns against requirements for affordable housing levels and other infrastructure, thereby not delivering sustainable development for Buckingham.
If Buckingham is to remain a strategic settlement, a clearer policy as to how to upgrade WwTw needs to be provided if deliverability and viability issues are to be met, and to justify the additional allocation within the deliverability timescale set out.

Object

VALP Proposed Submission

E2 Other employment sites

Representation ID: 1073

Received: 14/12/2017

Respondent: Buckingham Town Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

The existing Buckingham Industrial Estate is specifically saved under E1 of VALP and offered specific protection. However, E2 Other Employment sites will mean that the employment site allocations in BNDP are now governed by E2 and not the BNDP.
E2 jeopardises the potential for future expansion to accommodate an increased population over the term of the Plan.
Reliance on Silverstone Park is misplaced and unsound due to the serious transport constraints noted below.

Full text:

Please see attachment.

Object

VALP Proposed Submission

S8 Neighbourhood plans

Representation ID: 1182

Received: 14/12/2017

Respondent: Buckingham Town Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

BTC acknowledges S8 but notes that it pertains only to future NDPs being made after the adoption of the VALP. Given that it is acknowledged that there is a significant number of NDPs within the district, it was hoped that there would be more clarity as to the status of the components of the Development Plan overall after adoption of VALP.

Full text:

See attachment

Object

VALP Proposed Submission

E6 Shop and business frontages

Representation ID: 2619

Received: 14/12/2017

Respondent: Buckingham Town Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Further confusion as to the position of NDPs is found when the retail section is considered in E6, whilst BNDP sets the location and definition of primary and secondary shop frontages, the policy applying to them is in fact E6. There is a lack of clarity as to which policy and associated aims are being pursued; going to the effectiveness and again internal inconsistency thus soundness of the Plan.

Full text:

Please see attachment.

Object

VALP Proposed Submission

BE2 Design of new development

Representation ID: 2620

Received: 14/12/2017

Respondent: Buckingham Town Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

The intention is that there will be an SPD document produced under this policy. There is no mention either in the policy or the policy explanation that explains how such documents in existing NDPs are to be treated. it is attempting to be a District-wide policy that differs according to the area of the district to which it pertains specifically in BE2 (b). This requires clarity as to how existing and future NDPs co-exist here.

Full text:

Please see attachment.

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