Aylesbury Vale Area

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Object

VALP Main Modifications

MM016

Representation ID: 3456

Received: 09/01/2020

Respondent: Carter Jonas - Associate SWMK Consortium

Legally compliant? Yes

Sound? No

Representation Summary:

It is requested that the date when RAF Halton will close is confirmed so that the dates are consistent throughout PSVALP. As set out in the SWMK Consortium's representations to Main Modification MM088, it is suggested that much less housing will be delivered from the RAF Halton site during the plan period than currently predicted because of the range of tasks that need to be completed before development can commence.

It is anticipated that the redevelopment of the RAF Halton site for housing would much be more complex and delivery would take much longer than currently predicted; the redevelopment of other former RAF sites demonstrate the likelihood of delays to housing deliver at the RAF Halton site.

Change suggested by respondent:

It is requested that the date when RAF Halton will close is consistent throughout PSVALP, and that the housing trajectory for the site is amended to reflect the full range of tasks that need to be completed before housing can be delivered.

Full text:

Main Modification MM016 states that RAF Halton is due to close in 2026. However, there is some inconsistency between the closure date of RAF Halton referred to in Main Modification MM016 and elsewhere in Proposed Submission Vale of Aylesbury Local Plan (PSVALP); Main Modification MM088 anticipates that housing will be delivered from 2023, and Appendix A (containing the housing trajectory and referenced in Main Modification MM023) anticipates that first housing completions will occur during 2024/25. It is noted that previously in PSVALP and in the DIO Hearing Statement for Matter 15r: RAF Halton it was stated that closure would occur in 2022.

It is requested that the date when RAF Halton will close is confirmed so that the dates are consistent throughout PSVALP. The closure date has an impact on the housing trajectory for PSVALP. It is noted that the housing trajectory contained in Appendix A (see Main Modification MM023) and in the VALP Housing Land Supply Document July 2018 [Doc Ref. ED 213] that housing is due to be delivered at the RAF Halton site from 2024/25 i.e. before the site is closed and operations have ceased, which is unrealistic. As set out in the SWMK Consortium's representations to Main Modification MM088, it is suggested that much less housing will be delivered from the RAF Halton site during the plan period than currently predicted because of the range of tasks that need to be completed before development can commence.

It is anticipated that the redevelopment of the RAF Halton site for housing would much be more complex and delivery would take much longer than currently predicted; the redevelopment of other former RAF sites demonstrate the likelihood of delays to housing deliver at the RAF Halton site.

Support

VALP Main Modifications

MM007

Representation ID: 3457

Received: 09/01/2020

Respondent: Carter Jonas - Associate SWMK Consortium

Representation Summary:

The spatial strategy contained in Policy S2 of PSVALP does refer to strategic scale development on the edge of Milton Keynes and it would be consistent for the strategic objectives in Paragraph 2.6 to refer to this too.

The proposed change in Main Modification MM007 referring to the north east of Aylesbury Vale adjacent to Milton Keynes as a sustainable location for development is supported.

Full text:

The SWMK Consortium's representations to the strategic objectives contained in Paragraph 2.6 of the Proposed Submission Vale of Aylesbury Plan (PSVALP) noted the failure to mention the edge of Milton Keynes and the opportunities associated with delivering housing in this location, including connecting new development with significant transport infrastructure projects in this area - see Rep Id. 2281. The spatial strategy contained in Policy S2 of PSVALP does refer to strategic scale development on the edge of Milton Keynes and it would be consistent for the strategic objectives in Paragraph 2.6 to refer to this too.

The proposed change in Main Modification MM007 referring to the north east of Aylesbury Vale adjacent to Milton Keynes as a sustainable location for development is supported.

Support

VALP Main Modifications

MM004

Representation ID: 3459

Received: 17/12/2019

Respondent: Carter Jonas - Associate SWMK Consortium

Representation Summary:

It is considered that there is sufficient unconstrained land available on the edge of the strategic settlements, including at Milton Keynes, to accommodate future housing needs. It is acknowledged that a new settlement may be identified and assessed as an option to meet future development needs, but there should be no commitment to take the new settlement option forward in any future review of VALP.

The proposed change in Main Modification MM004 deleting the reference to a commitment to consider a new settlement option through an early review is supported.

Change suggested by respondent:

SWMK Consortium submitted representations and hearing statements and participated at previous hearing sessions relevant to these main modifications.

Full text:

The SWMK Consortium's representations to Paragraph 1.13 of the Proposed Submission Vale of Aylesbury Local Plan (PSVALP) commented on a new settlement option to meet future development needs - see Rep Id. 2278. It is considered that there is sufficient unconstrained land available on the edge of the strategic settlements, including at Milton Keynes, to accommodate future housing needs. It is acknowledged that a new settlement may be identified and assessed as an option to meet future development needs, but there should be no commitment to take the new settlement option forward in any future review of VALP.

The proposed change in Main Modification MM004 deleting the reference to a commitment to consider a new settlement option through an early review is supported.

Object

VALP Main Modifications

MM088

Representation ID: 3460

Received: 17/12/2019

Respondent: Carter Jonas - Associate SWMK Consortium

Legally compliant? Not specified

Sound? No

Representation Summary:

The proposed closure date of RAF Halton will need to be clarified, in order to inform the subsequent delivery timetable for development at the site. There are a number of tasks that need to be completed following closure before development can commence at the RAF Halton site. It is considered that a more realistic delivery timetable and annual delivery rate for development at RAF Halton would mean that only 425 dwellings would be delivered from the site during the plan period i.e. 575 dwellings fewer than currently predicted

Change suggested by respondent:

requested that the closure date for RAF Halton is confirmed, and that the identified date is consistent throughout PSVALP. It is requested that a more realistic delivery timetable and annual delivery rate is applied to development at RAF Halton, taking into account the number of tasks that need to be completed following closure and before development can commence; the redevelopment of the site is complex and will require specialist input and consultation with a range of stakeholders and statutory consultees.

It is considered that additional land needs to be identified to address the under delivery of housing from the RAF Halton site. It is requested that an additional allocation in North East Aylesbury Vale is made i.e. at Site Ref. NLV020.

Full text:

The SWMK Consortium's representations to Main Modifications MM016 seeks clarity and consistency on the proposed closure date of RAF Halton, and for that date to be consistent with the predicted housing delivery at the site in the housing trajectory.

It is predicted in Main Modification MM088 that 1,000 dwellings would be delivered at the RAF Halton site between 2023 and 2033. Appendix A (referred to in Main Modification MM023 and the VALP Housing Land Supply Document July 2018 [Doc Ref. ED 213] also include the RAF Halton site in the housing trajectory. It is predicted that housing would be delivered at the site from 2024/25, and that once established 125 dwellings per annum would be delivered from the proposed development.

Firstly, it is not realistic for housing to be delivered at the RAF Halton site before it has closed and operations have ceased. As set out above, the proposed closure date of RAF Halton will need to be clarified, in order to inform the subsequent delivery timetable for development at the site. Secondly, it is noted in the DIO's Matter 15r Hearing Statement (prepared by JLL June 2018) that housing would be delivered two years after the closure of the site i.e. two years from 2022 in 2024/25, and that approximately 100 dwellings per year would be delivered at the site from 2024/25. It should be noted that the previously stated annual delivery rates for development at the site are different to those now predicted. It is likely that the conversion of the buildings at RAF Halton will require some specialist input because they are heritage assets and as such construction will take longer to complete contracts, particularly for a complex and sensitive site such as RAF Halton.

As set out in the SWMK Consortium's Matter 15r Hearing Statement there are a number of tasks that need to be completed following closure before development can commence at the RAF Halton site. It will take time to complete technical surveys and the design and layout of the proposed development, discuss and agree the proposed development with statutory consultees, consult with residents, prepare and obtain approval for a masterplan, prepare and submit a planning application, submit reserved matters and discharge conditions, market the site to developers and housebuilders, and complete infrastructure
It is considered that, based on the above comments, a more realistic delivery timetable and annual delivery rate for the proposed development at RAF Halton is as follows: site closure and operations cease in 2025/26; pre-development planning tasks complete by 2027/28 i.e. two years after closure; site preparation, including decontamination and infrastructure works, complete by 2028/29; housing delivery to commence in 2028/29, and assume 25 dwellings completed; and, annual housing delivery rate of 100 dwellings per annum from 2029/30 i.e. housing delivery rate identical to that assumed by DIO in 2018. The outcome of these amendments are that only 425 dwellings would be delivered from the RAF Halton site during the plan period i.e. 575 dwellings fewer than currently predicted.

In these circumstances, it is considered that additional land needs to be identified to address the under delivery of housing from the RAF Halton site.

As set out in the SWMK Consortium's representations, it is requested that an additional allocation in North East Aylesbury Vale is made i.e. at Site Ref. NLV020.

Object

VALP Main Modifications

MM076

Representation ID: 3461

Received: 17/12/2019

Respondent: Carter Jonas - Associate SWMK Consortium

Legally compliant? Yes

Sound? No

Representation Summary:

It is considered that there are anomalies between the technical work completed to inform the transport assessment of the site options for additional development on the edge of Milton Keynes and the decision to select Shenley Park as the most suitable site allocation. In summary, the transport modelling has not included a new grid road proposed as part of Shenley Park and has not included mitigation measures that relate to the dualling of the A421.

It is considered that there are limited differences in landscape terms between the preferred site allocation at Shenley Park and the SWMK Consortium's site Ref. NLV020 at South West Milton Keynes. In summary, there are no differences in terms of landscape value and both sites would have a similar relationship with the existing and emerging edge of Milton Keynes.

Overall it is concluded that the transport and landscape evidence to support an allocation at Shenley Park is not robust.

Change suggested by respondent:

It is requested that the transport modelling should be updated to provide an accurate distribution of traffic and impacts of the proposed grid road within the site allocation at Shenley Park. It is requested that the transport modelling is updated to include all potential mitigation schemes to determine and compare impacts of the potential site allocation options.

It is requested that the landscape value of the Shenley Park and NLV020 sites are reassessed. It is requested that the landscape assessment process reassesses the existing and emerging relationship of the sites with the edge of Milton Keynes.

It is requested that an additional allocation is needed at North East Aylesbury Vale. The SWMK Consortium's representations requested an additional allocation at South West Milton Keynes at Site Ref. NLV020.

Full text:

Main Modification MM076 allocates an additional site at Shenley Park, located on the edge of Milton Keynes, for 1,150 dwellings. The SWMK Consortium has instructed consultants to assess the transport and landscape evidence used to support the decision to allocate Shenley Park. In summary it is concluded that the evidence is not robust.

In terms of transport, it is considered that there are anomalies between the technical work completed to inform the assessment of the site options for additional development on the edge of Milton Keynes and the decision to select Shenley Park as the most suitable site allocation. In summary, the transport modelling has not included a new grid road proposed as part of Shenley Park and has not included mitigation measures that relate to the dualling of the A421. The proposed development at Shenley Park includes a proposed grid road from the A421 to Kingsmead, but this road has been omitted from the transport modelling which it is considered would potentially underestimate the impact on the A421 and other local roads in Milton Keynes. It is requested that the transport modelling should be updated to provide an accurate distribution of traffic and impacts of the proposed grid road. The modelling has also not assessed a mitigation scheme involving the dualling of the A421 between Buckingham and Milton Keynes, or the impact of dualling of the A421 in combination with a Bletchley Bypass. It is requested that the transport modelling is updated to include all potential mitigation schemes to determine and compare impacts of the potential site allocation options.

In terms of landscape, it is considered that there are limited differences between the preferred site allocation at Shenley Park and the SWMK Consortium's site Ref. NLV020 at South West Milton Keynes (referred to in the assessment as Salden Chase extension). There are two factors that are used to justify the decision to allocate Shenley Park, but it is considered that the assessment of these factors is not robust. Firstly, the Shenley Park site is wholly located within a Landscape Character Areas which is assessed as being in 'very good' condition with a 'high' sensitivity. However the landscape assessment process has downgraded these factors and concluded that the value of the landscape at the Shenley Park site is 'low', which is an anomaly in the assessment process. The agricultural character of the NLV020 site is also typical of the wider area and ordinary, and as such the landscape value of the site should have been identical to that of Shenley Park. It is requested that the landscape value of the Shenley Park and NLV020 sites are reassessed. Secondly, the Shenley Park site is preferred because it is concluded that it is better located to the existing and emerging edge of Milton Keynes. In comparison, the assessment process occasionally refers to the NLV020 site as detached from the existing settlement, when in fact it would be immediately adjacent to Site Allocation NLV001 located on the edge of Milton Keynes and adjacent to existing residential areas. Site Allocation NLV001 includes strategic landscaping and green infrastructure to connect the urban area with the surrounding area. There are no differences between the sites in terms of their relationship with the edge of Milton Keynes. It is requested that the assessment process reassesses the existing and emerging relationship of the sites with the edge of Milton Keynes.

Overall it is concluded that the transport and landscape evidence to support an allocation at Shenley Park is not robust.

In addition, as set out in the SWMK Consortium's representations to Main Modification MM088, it is considered that development at RAF Halton will not be completed during the plan period.

For both these reasons, it is requested that an additional allocation is made at North East Aylesbury Vale. The SWMK Consortium's representations requested an additional allocation at South West Milton Keynes at Site Ref. NLV020 [see Rep Id. 2336].

In summary, Site Ref. NLV020 was assessed in the Housing and Economic Land Availability Assessment (January 2017) and a number of technical studies have been prepared to support development at the site including a concept masterplan; those supporting documents were submitted with the SWMK Consortium's representations.

It is considered that development could be accommodated at Site Ref. NLV020 without resulting in significant landscape and visual effects. Site Ref. NLV020 is well placed to provide a variety of options for sustainable travel, including extensions to the bus service, and connections to the existing pedestrian and cycle network in the surrounding area. It is also considered that subject to reaching agreement on an appropriate transport mitigation package, Site Ref. NLV020 is deliverable in transport and highway terms and offers an opportunity to enhance strategic and local transport infrastructure and thereby create a highly sustainable integrated new community.

As set out in the SWMK Consortium's representations, it is requested that Site Ref. NLV020 is allocated for a mixed use residential-led development, comprising the following uses:
* Residential 31.26 Ha - 1,095 dwellings (including affordable)
* Care Village 1.66 Ha
* Employment 0.51 Ha
* Education 9 Ha
* Neighbourhood Centre 0.7 Ha (plus an additional 30 dwellings)
* Community Centre 0.5 Ha
* Allotments 1.0 Ha
* Cemetery 1.2 Ha
* Green Infrastructure 50.01 Ha

If it is decided that, despite the above, the site should not be allocated as a strategic allocation, then as an alternative it is considered that Site Ref. NLV020 should be identified as a reserve site to provide flexibility and allow for any change in circumstances, e.g. an anticipated shortfall in housing land supply, to meet jobs growth or the planned provision of new strategic infrastructure. A reserve site approach at Site Ref. NLV020 would be in accordance with the existing development strategy of directing development to the larger and more sustainable settlements, including to the edge of Milton Keynes.

Support

VALP Main Modifications

MM074

Representation ID: 3465

Received: 17/12/2019

Respondent: Carter Jonas - Associate SWMK Consortium

Representation Summary:

Main Modification MM074 identifies a number of main modifications to Allocation Ref: NLV001. This allocation is promoted by the SWMK Consortium.
The proposed changes in Main Modification MM074 are supported.

Full text:

Main Modification MM074 identifies a number of main modifications to Allocation Ref: NLV001. This allocation is promoted by the SWMK Consortium.

In summary the proposed modifications relate to the following matters: delivery timescales, green links and linear park, defensible boundaries, views and skyline, priority habitats, noise, flood mitigation, and cycle links. The proposed delivery timescale assumes that 250 dwellings per annum would be delivered from the South West Milton Keynes site, which is consistent with historic delivery rates at other urban extensions to Milton Keynes and reflects the fact that the site is controlled by a mix of experienced housebuilders and developers. The relationship between development at South West Milton Keynes and neighbouring areas has already been taken into account within the planning application at the site (15/00314/AOP) including providing appropriate boundaries for the development, protecting views and the skyline from development with landscape enhancement measures, protecting and enhancing protected habitats, and providing flood mitigation measures and a sustainable drainage strategy. The proposed development includes green infrastructure comprising green links and linear parks, and provides walking and cycling connections to the surrounding area.

The proposed changes in Main Modification MM074 are supported.
As set out in the representations to Main Modifications MM070 and MM071 it is requested that all references to the site as 'Salden Chase' are changed to South West Milton Keynes, including the Concept Plan referred to in Policy NLV001.

Object

VALP Main Modifications

MM070

Representation ID: 3470

Received: 17/12/2019

Respondent: Carter Jonas - Associate SWMK Consortium

Legally compliant? Yes

Sound? No

Representation Summary:

The name 'Salden Chase' related to a much larger urban extension, and as such it is confusing and inaccurate to continue to use it. The Council's response to the Inspector's Question 62 [Doc Ref. ED100] confirmed that all future references to Allocation Ref. NLV001 would be changed to South West Milton Keynes, however that previous response is not reflected in the proposed main modifications.

It is requested that all references to 'Salden Chase' in PSVALP are changed to South West Milton Keynes.

Change suggested by respondent:

It is requested that all references to 'Salden Chase' in PSVALP are changed to South West Milton Keynes.

Full text:

Main Modifications MM070 and MM071 refer to Allocation Ref: NLV001 as 'Salden Chase'. The SWMK Consortium's representations to the Proposed Submission Vale of Aylesbury Plan (PSVALP) requested that the site should be called South West Milton Keynes - see Rep Id. 2289. The site name of South West Milton Keynes is consistent with the planning application for the proposed development. South West Milton Keynes also accurately reflects the location of the site, and is consistent with the name given to the proposed urban extension on the eastern edge of Milton Keynes in Plan:MK i.e. South East Milton Keynes.

The name 'Salden Chase' related to a much larger urban extension, and as such it is confusing and inaccurate to continue to use it. The Council's response to the Inspector's Question 62 [Doc Ref. ED100] confirmed that all future references to Allocation Ref. NLV001 would be changed to South West Milton Keynes, however that previous response is not reflected in the proposed main modifications.

It is requested that all references to 'Salden Chase' in PSVALP are changed to South West Milton Keynes.

Object

VALP Main Modifications

MM071

Representation ID: 3474

Received: 17/12/2019

Respondent: Carter Jonas - Associate SWMK Consortium

Legally compliant? Yes

Sound? No

Representation Summary:

The site name of South West Milton Keynes is consistent with the planning application for the proposed development. South West Milton Keynes also accurately reflects the location of the site, and is consistent with the name given to the proposed urban extension on the eastern edge of Milton Keynes in Plan:MK i.e. South East Milton Keynes.

The name 'Salden Chase' related to a much larger urban extension, and as such it is confusing and inaccurate to continue to use it. The Council's response to the Inspector's Question 62 [Doc Ref. ED100] confirmed that all future references to Allocation Ref. NLV001 would be changed to South West Milton Keynes, however that previous response is not reflected in the proposed main modifications.

It is requested that all references to 'Salden Chase' in PSVALP are changed to South West Milton Keynes.

Change suggested by respondent:

It is requested that all references to 'Salden Chase' in PSVALP are changed to South West Milton Keynes.

Full text:

Main Modifications MM070 and MM071 refer to Allocation Ref: NLV001 as 'Salden Chase'. The SWMK Consortium's representations to the Proposed Submission Vale of Aylesbury Plan (PSVALP) requested that the site should be called South West Milton Keynes - see Rep Id. 2289. The site name of South West Milton Keynes is consistent with the planning application for the proposed development. South West Milton Keynes also accurately reflects the location of the site, and is consistent with the name given to the proposed urban extension on the eastern edge of Milton Keynes in Plan:MK i.e. South East Milton Keynes.

The name 'Salden Chase' related to a much larger urban extension, and as such it is confusing and inaccurate to continue to use it. The Council's response to the Inspector's Question 62 [Doc Ref. ED100] confirmed that all future references to Allocation Ref. NLV001 would be changed to South West Milton Keynes, however that previous response is not reflected in the proposed main modifications.

It is requested that all references to 'Salden Chase' in PSVALP are changed to South West Milton Keynes.

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