Aylesbury Vale Area

VALP Main Modifications

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Object

VALP Main Modifications

MM001

Representation ID: 3327

Received: 17/12/2019

Respondent: Willis Dawson Holdings Ltd

Agent: Pegasus Plannning Group

Legally compliant? Yes

Sound? No

Representation Summary:

The proposed housing requirement of 28,600 homes does not respond to the concerns identified by the Inspector. It is necessary, as a minimum, to increase this to 30,345 homes, although this could well be greater depending upon the market signals uplift and the inclusion of the buffer within the housing requirement.

Change suggested by respondent:

All of the references to the housing requirement or objectively assessed need should be amended accordingly.

Full text:

Please see attachment.

Attachments:

Object

VALP Main Modifications

MM007

Representation ID: 3374

Received: 17/12/2019

Respondent: Willis Dawson Holdings Ltd

Agent: Pegasus Plannning Group

Legally compliant? Yes

Sound? No

Representation Summary:

Pegasus consider that not all reasonable alternative sites have been considered to determine which site should meet the housing needs adjacent to Milton Keynes; particularly in the light of new evidence that was submitted to the Council in March 2019. The new evidence considered that the merits of land to the west of Newton Leys has an excellent prospect of being able to deliver an additional allocation pursuant to the Vale of Aylesbury Local Plan in meeting the Council's and the Inspector's need to identify additional housing for c 500 dwellings in close proximity to Milton Keynes.
The process of site selection is not transparent and the SA cannot be justified.

Change suggested by respondent:

Changes to the proposed modifications should be:
1. include land at Newton Leys for approximately 400 dwellings
2. Policy D2 to be amended to include the above site.

Full text:

Please see attachment.

Object

VALP Main Modifications

Sustainability Appraisal Report Addendum to the Vale of Aylesbury Local Plan (October 2019)

Representation ID: 3391

Received: 17/12/2019

Respondent: Willis Dawson Holdings Ltd

Agent: Pegasus Plannning Group

Legally compliant? Yes

Sound? No

Representation Summary:

An objection is made to the SA Addendum which is not transparent. It fails to demonstrate why the 3 options were chosen, or indeed ultimately why one option was preferred over and above the others. There is no RAG assessment of the 3 options, instead the report relies upon Appendix 1 Alterative Appraisal Findings which are based on a sustainability topic and ranking in order of preference. Given that the HELAA assessment of sites (ED208) May 2019 has been updated in respect of the sites chosen, it is considered that the RAG assessment of 2017 should have been updated.

Change suggested by respondent:

Changes to the proposed modifications should be:
1. include land at Newton Leys for approximately 400 dwellings
2. Policy D2 to be amended to include the above site.

Full text:

Please see attachment.

Object

VALP Main Modifications

MM009

Representation ID: 3405

Received: 17/12/2019

Respondent: Willis Dawson Holdings Ltd

Agent: Pegasus Plannning Group

Legally compliant? Yes

Sound? No

Representation Summary:

The VALP provides an insufficient plan period supply.

Change suggested by respondent:

The VALP is unable to demonstrate a sufficient supply over the plan period and accordingly it will be necessary to identify additional sources of supply.

Full text:

As set out in response to MM001, in order to address the Inspector's concerns, it is necessary to meet the housing need for at least 30,345 homes. It should be underlined that this is an absolute minimum which should be exceeded to better account for the migration effects of the financial crisis and to provide an appropriate market signals uplift.

The Inspector has identified that it is appropriate to plan for an additional buffer of 5.2% to ensure that these needs are met, whether as part of the housing requirement or additional to it. This would equate to a supply of 31,923 homes.

The VALP however only proposes to provide a supply of 30,233 homes in MM009. This is not only insufficient to meet the absolute minimum housing need but it also provides absolutely no contingency to ensure that this minimum need is met as required by the Inspector.

Object

VALP Main Modifications

MM023

Representation ID: 3406

Received: 17/12/2019

Respondent: Willis Dawson Holdings Ltd

Agent: Pegasus Plannning Group

Legally compliant? Yes

Sound? No

Representation Summary:

The five-year land supply position identified by the Council is contrary to national policy and guidance.

Change suggested by respondent:

The VALP is unable to support a five-year land supply either for plan-making or decision-making purposes and accordingly additional sources of supply will need to be identified and/or additional flexibility provided within policies to enable a sufficient supply to be restored.

Full text:

Please see attachment.

Object

VALP Main Modifications

MM070

Representation ID: 3407

Received: 17/12/2019

Respondent: Willis Dawson Holdings Ltd

Agent: Pegasus Plannning Group

Legally compliant? Yes

Sound? No

Representation Summary:

Object to the proposed allocation of Shenley Park to meet needs in the north east of the district.

Object to the site selection process - see reps on MM007

Land West of Newton Leys should be allocated for 400 dwellings (the HELAA fails to take account of new evidence for land west of Newton Leys yet assessments for other sites have been updated).

Transport evidence identifies that there will be significant impact on traffic congestion along the A421 corridor yet AVDC have allocated Salden Chase and Shenley Park, which both access off the A421. The southern transport corridor (Stoke Road and A4146) has a greater capacity to accept additional development.

Change suggested by respondent:

Pegasus seek a change to the proposed modification so that an additional site is included - land west of Newton Leys, Milton Keynes for approximately 400 dwellings.

Policy D2 Delivery site allocations in the rest of the district - should be amended to include land west of Newton Leys (this can be in addition to the other additional sites such as part of Shenley Park or part of Eaton Leys in recognition of the need to provide a range and choice of sites to ensure delivery in the plan period and acknowledging that there are already delays to the Salden Chase strategic allocation following the refusal to grant permission for highway access by Milton Keynes Council).

As a consequence other sites do not have to deliver as many dwellings in the plan period, such an approach reduces the risk of the strategic site not coming forward as soon as anticipated, spreads the risk and supports housing delivery.

Full text:

This representation addresses MM070 and the consequential text to Policy D2 set out in MM071. It should also be read alongside our representations to MM007.

Pegasus object to the proposed allocation of Shenley Park.

Whilst supporting the strategy of concentrating the additional development required in the AVLP around the southern and south western edges of Milton Keynes, an objection is made to the reliance on one site of approximately 1,150 dwellings.

Pegasus have also objected to the Addendum to the Sustainability Appraisal (ED204) and the selection of only three reasonable alternatives to meet the housing shortfall in this location on the edge of Milton Keynes. It is not clear on what basis these three sites were selected, it appears that their choice was because they are of a strategic scale and can contribute to meeting infrastructure requirements.

However, smaller sites may make contributions to infrastructure in accordance with the NPPF para 56.

The objection is justified on the grounds that there are other alternatives which should have been assessed and secondly providing a range and choice of sites in accordance with paragraph 68 of the NPPF will support the 5 year housing land supply. (It should be noted that there are already issues with the delivery of the proposed allocation at Salden Chase - whilst it has a resolution to grant planning permission by AVDC, the issue is that the highway access is required from Milton Keynes roads and MC Council have recently refused access).

Having reviewed the transport evidence in particular ED214C and ED215A it is considered that the transport evidence does not necessarily support the Proposed Modifications to the Plan.

- The "Do Minimum" Scenario, which it is assumed does not include any development allocated around MK e.g. Salden Chase, identifies that there will be significant impact on traffic congestion in both the AM and PM Peaks along the A421 corridor within Aylesbury Vale district. Alternatively the roads further south such as Stoke Road and the A4146 show that there would be either a slight or moderate impact on traffic congestion in the DM scenario.

- Despite this AVDC have not only proposed to allocate 1,855 dwellings at Salden Chase, which is accessed directly off the A421, but now also propose about 1,150 dwellings at Shenley Park, which is also accessed directly off the A421.

- As a result it is perhaps not a great surprise that with the various "Do Something" Scenarios involving further new development along the A421 the traffic congestion gets worse along the A421 and on adjoining roads such as Coddimore Lane, which is the road to Whaddon. Furthermore the increases in traffic congestion extends into the Milton Keynes boundary.

- Alternatively roads to the south such as Stoke Road and the A4146 do not appear to be impacted significantly by traffic congestions under the various Do-Something modelling scenarios and in particular the scenario which includes an additional 1,200 dwellings at Eaton Leys rather than further development adjacent to the A421 such as Salden Chase Extension or Shenley Park. This would seem to suggest that this southern transport corridor has a greater capacity to accept additional development. Furthermore, the attached transport note produced by Buckinghamshire County Council (ED215A) confirms that the scenario "DS4" involving no development at Shenley Park and 1,200 units at Eaton Leys has the least impact on the Buckinghamshire roads of all the scenarios. In addition, the note also confirms that Highways England have informally said that the proposed improvements to the A5 and A5 roundabout (which are of course to the south of MK) should be able to accommodate the additional potential development options around Milton Keynes.

- Lastly the above is all confirmed within section 6.2 of the Summary and Conclusions of ED214C, where is clearly states that of the development options assessed Eaton Leys has the least impact on traffic in the NE of the Aylesbury Vale district.

It is considered that Policy D2 should be amended to include land west of Newton Leys (this can be in addition to the other sites such as part of Shenley Park or part of Eaton Leys in recognition of the need to provide a range and choice of sites to ensure delivery in the plan period and acknowledging that there are already delays to the Salden Chase strategic allocation following the refusal to grant permission for highway access by Milton Keynes Council).

As a consequence other sites do not have to deliver as many dwellings in the plan period. By including land west of Newton Leys the housing requirement can be met and housing delivery can be maintained.

Object

VALP Main Modifications

MM075

Representation ID: 3426

Received: 17/12/2019

Respondent: Willis Dawson Holdings Ltd

Agent: Pegasus Plannning Group

Legally compliant? Yes

Sound? No

Representation Summary:

Object to the proposed allocation of Shenley Park to meet needs in the north east of the district.
Object to the site selection process - see reps on MM007
Land West of Newton Leys should be allocated for c.400 dwellings (the HELAA fails to take account of new evidence for West Newton Leys yet assessments for other sites have been updated).

Change suggested by respondent:

Pegasus seek a change to the proposed modification so that an additional site is included - land west of Newton Leys, Milton Keynes for approximately 400 dwellings.

Policy D2 Delivery site allocations in the rest of the district - should be amended to include land west of Newton Leys (this can be in addition to the other sites such as part of Shenley Park or part of Eaton Leys in recognition of the need to provide a range and choice of sites to ensure delivery in the plan period and acknowledging that there are already delays to the Salden Chase strategic allocation following the refusal to grant permission for highway access by Milton Keynes Council).

As a consequence other sites do not have to deliver as many dwellings in the plan period.

Full text:

This representation addresses MM075- new site policy for Shenley Park.
Pegasus object to the proposed allocation of Shenley Park.
Whilst supporting the strategy of concentrating the additional development required in the AVLP around the southern and south western edges of Milton Keynes, an objection is made to the reliance on one site of approximately 1,150 dwellings.
See representations to MM007, MM070

Object

VALP Main Modifications

MM076

Representation ID: 3429

Received: 17/12/2019

Respondent: Willis Dawson Holdings Ltd

Agent: Pegasus Plannning Group

Legally compliant? Yes

Sound? No

Representation Summary:

Object to the proposed allocation of Shenley Park to meet needs in the north east of the district.

Object to the site selection process - see reps on MM007

Land West of Newton Leys should be allocated for 400 dwellings (the HELAA fails to take account of new evidence for land west of Newton Leys yet assessments for other sites have been updated).

Change suggested by respondent:

Pegasus seek a change to the proposed modification so that an additional site is included - land west of Newton Leys, Milton Keynes for approximately 400 dwellings.

Policy D2 Delivery site allocations in the rest of the district - should be amended to include land west of Newton Leys (this can be in addition to the other additional sites such as part of Shenley Park or part of Eaton Leys in recognition of the need to provide a range and choice of sites to ensure delivery in the plan period and acknowledging that there are already delays to the Salden Chase strategic allocation following the refusal to grant permission for highway access by Milton Keynes Council).

As a consequence other sites do not have to deliver as many dwellings in the plan period, such an approach reduces the risk of the strategic site not coming forward as soon as anticipated, spreads the risk and supports housing delivery.

Full text:

This representation addresses MM076, but should be read in conjunction with our representations to MM070 and the consequential text to Policy D2 set out in MM071; and also our representations to MM007.

Pegasus object to the proposed allocation of Shenley Park.

Having reviewed the transport evidence in particular ED214C and ED215A it is considered that the transport evidence does not necessarily support the Proposed Modifications to the Plan.

In addition to the representations to MM070, one of the key requirements in the policy wording relating to Shenley Park within the revised Local Plan, is the provision of "a new link road between the A421 Buckingham Road and H6 and or H7 Childs Way/Chaffron Way". However, it is not clear whether any traffic impact assessment been undertaken to assess the impact of this road connection on the existing MK residential areas of Oxley Park, Kingsmead and Tattenhoe.

The modelling work demonstrates that there will be a significant amount of traffic congestion on the A421 in the future and whilst this proposed link road could help alleviate the situation this traffic will be re-routed through existing residential areas.

ED215A states the DS3 Scenario with both Shenley Park and Salden Chase appears to perform worse in terms of impact on the highway network. ED215A states "The only advantage of the Shenley Park development is that it has the potential to provide a new grid road which would address the rat running through Whaddon."

Given the environmental constraints to the site,{ED210A} (Development within the western part of the northern parcel would be seen as extending the development edge to within close proximity of Whaddon Conservation Area, to include Whaddon Hall. Development within the southern parcel would represent an unacceptable extension of development into the countryside and visible from the wider landscape.) It is not clear why this site has been included in the proposed modifications, given the highways and other evidence.

Whereas development to the south of Milton Keynes such as around Newton Leys and also Eaton Leys would seem to have less impact on both Buckinghamshire CC roads and also MK roads and existing MK residential areas.

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