Aylesbury Vale Area

VALP Main Modifications

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Object

VALP Main Modifications

MM008

Representation ID: 3529

Received: 15/12/2019

Respondent: Hampden Fields Action Group

Legally compliant? Yes

Sound? No

Representation Summary:

The modified Plan has downgraded the need to take full and early
account of the largest transport infrastructure project to affect the
District since the building of the M40, namely the Oxford - Cambridge
Expressway. No longer does the Council anticipate the need for an early
review, but rather defers consideration to some "future Local Plan
update", which appears to may not even be necessary. This major
strategic weakness in the modified Plan indicates the inadequacy of the
Council's thinking.

Change suggested by respondent:

Full remedial action to correct the errors and gaps in the transport evidence base and modelling,
followed by a revised set of proposals including funding plans and timetable, with public consultation
on these modifications.

Full text:

see attachments

Object

VALP Main Modifications

MM022

Representation ID: 3530

Received: 15/12/2019

Respondent: Hampden Fields Action Group

Legally compliant? Yes

Sound? No

Representation Summary:

(See also MM008) The Plan no longer uses evidence to indicate that a
review will be needed soon after adoption. The modified statement
jettisons any evidence reference and simply envisages an update at some
undefined future point. As that would inevitable during the remaining
13-year life of the Plan, the modification can only mean that the Council
has changed its commitment to a positive, evidence-based approach in
favour of a bland, "drift and see" policy.

Change suggested by respondent:

Full remedial action to correct the errors and gaps in the transport evidence base and modelling,
followed by a revised set of proposals including funding plans and timetable, with public consultation
on these modifications.

Full text:

see attachments

Object

VALP Main Modifications

MM031

Representation ID: 3531

Received: 15/12/2019

Respondent: Hampden Fields Action Group

Legally compliant? Yes

Sound? No

Representation Summary:

The Plan lacks forward-looking strategy and vision on
transport. A prime example is the lost opportunity to
integrate the Oxford-Cambridge Expressway and East-West
Rail into the District's transport plans (see also MM008 and
MM031). Nor are the collection of proposed link roads
'strategic', being a mixture of single and dual carriageway
roads with maximum speeds as low as 30mph in some places.
2. Nor is the Plan sustainable as it will lead to increased
traffic congestion on major Primary Public Transport
Corridors and other key points around Aylesbury,
particularly the Walton Street gyratory.
3. As a result, the Plan will not support economic prosperity or
wellbeing as claimed.

Change suggested by respondent:

Full remedial action to correct the errors and gaps in the transport evidence base and modelling,
followed by a revised set of proposals including funding plans and timetable, with public consultation
on these modifications.

Full text:

see attachments

Object

VALP Main Modifications

MM035

Representation ID: 3532

Received: 15/12/2019

Respondent: Hampden Fields Action Group

Legally compliant? Yes

Sound? No

Representation Summary:

1. several increases in proposed local
housing numbers not accompanied by traffic mitigation
measures.
2. The modified wording replaces "provision of" by "prioritising
the delivery of" the distributor road (the SEALR). This is a
downgrading of the council's commitment
3. It is most unlikely that this 'priority' road can be completed by
the committed date of 2021
4. Some funding of the SEALR depends on developer contributions but the timings of these is highly questionable - after the completion date of the SEALR
5. We do not accept the basis on which the Countywide Model
has been created. The model shows congestion on the SEALR. (officer summary)

Change suggested by respondent:

Full remedial action to correct the errors and gaps in the transport evidence base and modelling,
followed by a revised set of proposals including funding plans and timetable, with public consultation
on these modifications.

Full text:

see attachments

Object

VALP Main Modifications

MM041

Representation ID: 3533

Received: 15/12/2019

Respondent: Hampden Fields Action Group

Legally compliant? Yes

Sound? No

Representation Summary:

1. The assertion that, "...the delivery of the South West Link Road
[will relieve] traffic pressures in the town centre and enabling
easier vehicular movement around Aylesbury" is heavily contested
given the flaws in the model and therefore it has not been proven.
2. Even the Jacobs report (see above) accepts that significant
mitigation will be required in the Coldharbour area, yet no
mitigation is included or modelled. The requirement for updated
traffic modelling is once again reinforced.

Change suggested by respondent:

Full remedial action to correct the errors and gaps in the transport evidence base and modelling,
followed by a revised set of proposals including funding plans and timetable, with public consultation
on these modifications.

Full text:

see attachments

Object

VALP Main Modifications

MM044

Representation ID: 3535

Received: 15/12/2019

Respondent: Hampden Fields Action Group

Legally compliant? Yes

Sound? No

Representation Summary:

1. The modified text states that Woodland homes are projected to be delivered some time from 2021. AVDC's Strategic Development
Management Committee were advised that no residential land
would be brought forward in the first 5 years (Officer report
16/01040/AOP, para 9.33, October 2017)
2. Uncertainty expressed by a previous inspector and supported by
the Ouseley Manor Oak judgement is relevant across the whole
Transport Strategy (see comment below on MM202 and MM203)
but we draw the Inspector's attention to it in this section as well.
The uncertain delivery of Woodlands (see MM048 below) means
that delivery of the ELR(S) and the SEALR are uncertain despite
BCC's assertions.

Change suggested by respondent:

Full remedial action to correct the errors and gaps in the transport evidence base and modelling,
followed by a revised set of proposals including funding plans and timetable, with public consultation
on these modifications.

Full text:

see attachments

Object

VALP Main Modifications

MM048

Representation ID: 3537

Received: 15/12/2019

Respondent: Hampden Fields Action Group

Legally compliant? Yes

Sound? No

Representation Summary:

1. (See comment 1 against MM044).
2. This raises serious questions about the timing of developer
contributions to the £23.6m costs of building the ELR(S) (MM210).
3. The financial viability of this scheme was questioned during the
planning application process, with an official report stating that it
was 'challenged' (i.e., unviable). The riskladen
lower figure of £28m is being adopted, which is a highly
questionable approach and unsound because it does not meet
objectively assessed requirements and cannot be delivered. (officer summary)

Change suggested by respondent:

Full remedial action to correct the errors and gaps in the transport evidence base and modelling,
followed by a revised set of proposals including funding plans and timetable, with public consultation
on these modifications.

Full text:

see attachments

Object

VALP Main Modifications

MM055

Representation ID: 3539

Received: 15/12/2019

Respondent: Hampden Fields Action Group

Legally compliant? Yes

Sound? No

Representation Summary:

1. The modification to the Plan increases the proposed housing
numbers by 7% (from 'around 3111' to 'at least 3358'). Yet there is
no evidence of any updated transport assessment that gives
confidence in the network's capacity to absorb this increase. (It is
worth noting that the existing Transport Assessment for the
planning application for Hampden Fields was based on a still lower
housing figure ("up to 3,000"). As the Inspector will be aware, a
10% uplift of traffic in an already congested space is of serious
concern.
2. The proposed Southern Link Road through this site, rated as
'critical' and costing >£17m (MM210) is not mentioned anywhere
at all in this section. Such a lack of 'joined up thinking' is a
significant error in the modified Plan.

Change suggested by respondent:

Full remedial action to correct the errors and gaps in the transport evidence base and modelling,
followed by a revised set of proposals including funding plans and timetable, with public consultation
on these modifications.

Full text:

see attachments

Object

VALP Main Modifications

MM088

Representation ID: 3540

Received: 15/12/2019

Respondent: Hampden Fields Action Group

Legally compliant? Yes

Sound? No

Representation Summary:

1. Although the narrative of the Jacobs Report (Countywide Local
Plan Modelling Support Phase 3 Final 160817) claims that 1,000
houses at Halton are included, Figure 3-A in the report shows
virtually no housing for Halton. As a result, the Inspector can have
no confidence that this part of the modified Plan with major
impact has been properly considered.
2. Paragraph 5.2.1.6 in that same report shows significant travel time
increases in and around Wendover. The acknowledged limitations
in the Countywide model mean that these have most likely been
underestimated. Once again, no mitigation is offered or been
modelled in Countywide model runs.
3. This is also relevant as the A413 from this site into Aylesbury is a
Priority Congestion Management Corridor, which threatens the
modified Plan aim of safeguarding "a network of cycling and
walking links to and from Aylesbury Town..." (MM088 para e)

Change suggested by respondent:

Full remedial action to correct the errors and gaps in the transport evidence base and modelling,
followed by a revised set of proposals including funding plans and timetable, with public consultation
on these modifications.

Full text:

see attachments

Object

VALP Main Modifications

MM202

Representation ID: 3541

Received: 15/12/2019

Respondent: Hampden Fields Action Group

Legally compliant? Yes

Sound? No

Representation Summary:

In brief, the ATS:
a. Is based on below-standard modelling at County and District
level, with the Aylesbury element only validated for one small
part .
b. Lacks a sound evidence base, with inadequate and incomplete
data gathering
c. Will not obtain DfT funding for schemes listed in MM210
because of failure to comply with DfT standards
d. Proposes a set of timescales that are highly questionable on
logistical and financial grounds
e. Gives no confidence that the Highway Authority (BCC) has
reacted in any sort of positive manner to the Inspector's
comments and questions in July 2018, despite being on record
as having given a clear impression that work would be done to
satisfy him
(officer summary)

Change suggested by respondent:

Full remedial action to correct the errors and gaps in the transport evidence base and modelling,
followed by a revised set of proposals including funding plans and timetable, with public consultation
on these modifications.

Full text:

see attachments

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