Vale of Aylesbury Local Plan
Consultation July – September 2016
Representation from Great Horwood Parish Council Introduction
0.1 The Development Plan
0.1.1 Aylesbury Vale District Council is the Local Planning Authority (LPA) for the Vale of Aylesbury. The Development Plan represents its settled view on how development in the Vale should proceed. The Town and Country Planning Act 1990 (TCPA) states that planning permission is required for development (Section 57) and that, when dealing with an application, the LPA shall have regard to the provisions of the development plan, so far as material to the application (Section 70 (2) (b)). In addition the Planning and Compulsory Purchase Act 2004 (PCPA) states If regard is to be had to the development plan for the purpose of any determination to be made under the planning Acts the determination must be made in accordance with the plan unless material considerations indicate otherwise. (Section 38 (6)).
0.1.2 The Development Plan for the Vale of Aylesbury comprises the development plan documents (taken as a whole) which have been adopted or approved in relation to that area, (PCPA Section 38 (3) (b)) together with neighbourhood development plans which have been made for the area.
0.1.3 The Aylesbury Vale District Local Plan (January 2004) (AVDLP) is a development plan document. Paragraph 1.1 of AVDLP states The Aylesbury Vale District Local Plan (AVDLP) applies to the whole of the District and covers the period to 2011.
0.1.4 The expiry date of policies in AVDLP was, however, modified by PCPA. Paragraph 1 (2) of Schedule 8 in that Act states The transitional period is the period starting with the commencement of section 38 and ending on whichever is the earlier of— (a) the end of the period of three years; (b) the day when in relation to an old policy, a new policy which expressly replaces it is published, adopted or approved. and paragraph 1 (3) states But the Secretary of State may direct that for the purposes of such policies as are specified in the direction sub-paragraph (2)(a) does not apply.
0.1.5 On 24 September 2007 the Secretary of State directed that certain of the policies in AVDLP should be “saved” under paragraph 1 (3), so that these policies remain part of the Development Plan for the Vale of Aylesbury. The Vale of Aylesbury Local Plan (VALP) is intended to be a development plan document which will replace the saved policies of AVDLP.
Page 2 0.2 The structure of this representation
0.2.1 This representation from Great Horwood Parish Council (GHPC) contains comments on both the content and the presentation of the draft VALP. Each section of the representation refers to a similarly-numbered chapter in the draft VALP with, from section 3 onwards, subsections referring to the similarly-numbered policies in that chapter; a few sections contain a final subsection with general comments about that chapter.
0.2.2 The National Planning Policy Framework (NPPF) constitutes guidance for local planning authorities and decision-takers both in drawing up plans and as a material consideration in determining applications. Paragraph 154 of the NPPF states Local Plans should be aspirational but realistic. They should address the spatial implications of economic, social and environmental change. Local Plans should set out the opportunities for development and clear policies on what will or will not be permitted and where. Only policies that provide a clear indication of how a decision maker should react to a development proposal should be included in the plan. GHPC therefore regards its comments about the presentation of the draft VALP to be equally as important as its comments on the content.
0.2.3 GHPC has previously submitted two representations concerning the specific question of a proposed new settlement. For convenience these are appended as appendices to the present document.
0.3 GHPC general comments
0.3.1 In general, the layout of the chapters 3–11 in the draft VALP is that, after the chapter title page, each policy is preceded by explanatory text. GHPC suggest that, at the beginning of each chapter, a list of the policies (including their titles) be given.
0.3.2 The view of GHPC is that, whereas many of the policies are written at an appropriate level of detail, some policies contain detail that would be better provided as guidance in a supplementary planning document, with a suitable reference. This would, for example, give a decision taker more freedom to exercise planning judgement in favour of an innovative solution which satisfied the intention rather than the letter of the guidance.
0.3.3 It is also the view of GHPC that, on occasion, policies have been drafted in a repetitive manner so that the intention is obscured rather than clarified. Where this is the case, simplified wording is suggested.
0.3.4 On the other hand, it appears to GHPC that there are a few occasions where the clear intention of a policy is circumvented by a failure to use suitably robust wording, or by the inclusion of an inadequately restricted mechanism for avoidance. Again, where this appears to be the case, a modification is suggested.
Page 3 0.3.5 It was felt inappropriate, at this draft stage, to highlight any typographical errors found, as the text of the draft plan will be modified for submission and such errors corrected at that stage. There are, however, several itemised lists in the draft VALP where the grammatical structure varies from item to item. GHPC is particularly concerned that these be checked so that the grammar is consistent from item to item, as inconsistencies in such cases can lead to ambiguity and disputes about the meaning of the plan.
0.3.6 Occasionally, proposals for modifications to the draft VALP make reference to the South Worcestershire Development Plan (SWDP), adopted in February 2016. It is not suggested that SWDP is better in any way that other recently adopted local plans; SWDP has simply been chosen as an instance of a plan which has been prepared in the context of the NPPF, and which has been determined to be sound by the examining Inspector. Subject of course to context, reference to SWDP policies may be helpful when considering the wording of VALP policies.
0.3.7 GHPC’s penultimate general comment concerns the relationship of VALP to AVDLP. As the saved policies in AVDLP continue in force until a new policy “expressly replaces it”, there should be an appendix to VALP listing the saved AVDLP policies and, in each case, either specifying the replacement policy or else indicating why no new policy is required.
0.3.8 The Glossary should be in alphabetical order! (Please check the entries for Brownfield register and Cultural facilities.)
Chapter 1: Background
1.1 Duty to cooperate
1.1.1 Paragraph 1.13 states The councils to the south of Aylesbury Vale district have identified an estimated collective unmet need of 12,000 homes. As paragraph 180 of the NPPF, in the section Planning strategically across local boundaries, states Local planning authorities should take account of different geographic areas the need identified by each council should be given separately. This will remain the case if those needs are modified during subsequent negotiation. It will then be clearer how the different areas have been taken into account. (A similar comment applies to paragraph 3.11 in the Strategic chapter of the draft VALP.)
1.4 Neighbourhood plans
1.4.1 Paragraph 1.26 states that … the overall housing need for the district and the proposed settlement hierarchy leads to different housing figures than those set out in neighbourhood plans. and paragraph 1.27 states
Page 4 Rather than impose sites on settlements with neighbourhood plans to meet these figures, the council will work with town and parish councils to identify sites which can be allocated through revisions to their neighbourhood plans. While this is the case for several made neighbourhood plans, there are some (such as the Great Horwood Neighbourhood Plan) where the neighbourhood plan allocations, together with known existing completions and commitments, do meet the current draft VALP housing requirement for the neighbourhood area. GHPC considers that paragraphs 1.26 and 1.27 should be modified to acknowledge this possibility.
1.5 Transport
1.5.1 Paragraph 1.57 states The northern half of the district is less well served by good road links, although places such as Silverstone and Buckingham have reasonable north bound access to the M1 and M40 motorways via the A43. This is correct regarding Silverstone, but incorrect regarding Buckingham. The A43, part of the Highways England strategic road network, passes nowhere near Buckingham, as may be seen from the District key diagram on page 19 of the draft VALP. The A413, which connects Buckingham to the A43, comprises 13km of winding single-carriageway road.
1.5.2 Paragraph 1.60 should say that, when fully open, the western section of East West Rail will connect Aylesbury and Winslow to Milton Keynes and Oxford/Bicester. It is not clear that the link to Aylesbury (which is not planned to be electrified) will open at the same time as the main route between Oxford and Milton Keynes.
Chapter 2: Vision and Strategic Objectives
2.1 Both the Spatial Vision and the Strategic Objectives for VALP are based on those included in the withdrawn Vale of Aylesbury Plan Strategy, May 2013, with some modifications and additions. GHPC notes that the draft VALP, unlike the VAP, does not list which policies are identified as implementing each objective, and considers that it might be helpful to include such a list.
Chapter 3: Strategic
3.1 S1 Sustainable development for Aylesbury Vale
3.1.1 GHPC considers that the phrase “and neighbourhood planning documents” in the first paragraph of this policy should be deleted, because it is circular: the second paragraph would appear to suggest that neighbourhood planning documents should then fit with the policies within
Page 5 neighbourhood plans where relevant. Policy S1 is, in reality, intended as guidance where decisions are taken on development proposals, and it is not appropriate for it to refer also to the making of neighbourhood plans.
3.1.2 The second paragraph in the policy, including list item (a), is essentially the content of the part of paragraph 14 of the NPPF referring to decision taking.
3.1.3 List item (f) “Building integrated communities with existing populations” is not expressed well. GHPC considers that this list item would be better expressed along the lines of (f) Building extended communities which integrate well with existing populations.
3.2 S2 Spatial strategy for growth
3.2.1 As the bullet-point list in this policy refers to the development of housing, employment land and retail provision, it should be made clear that the percentages given in the subsequent itemised list refer specifically to housing growth.
3.2.2 GHPC considers that the second bullet point in the policy should be modified to say Provision of 22 hectares of employment land, and consideration of whether the remaining 51 hectares currently currently identified as committed to employment should be reallocated. Such a modification would be consistent with paragraph 22 of the NPPF.
3.2.3 Paragraph 3.18 in the text following Table 1 in this section proposes a delivery rate of 1,623 dwellings per annum in the first five years of the plan, to be followed by a delivery rate of 1,859 dwellings per annum in the remaining 13 years of the plan, giving a total delivery of 32,282 dwellings over 18 years. However, as the plan period is 2013–2033, a 20 year period, the meaning of this is unclear – the delivery of around 33,000 dwellings is supposed to take place over the whole 20 year period rather than over 18 years. (Although no starting year is given on the title page of the draft VALP, the period 2013–2033 was specified for the Issues and Options consultation document, and a starting year of 2013 is implicit at numerous places in the text of the draft VALP, namely in Table 1, in paragraphs 4.11, 4.58, 4.65, 4.75, 4.85 and 4.93, and in the tables in paragraphs 4.61, 4.69, 4.79 and 4.87.)
3.2.4 GHPC considers that it would be better to specify expected delivery rates (per annum) for each of the first two five-year periods 2013–2018 and 2018–2023, and also for the following ten- year period 2013–2033. The expected delivery rate for the first five-year period should be informed by historic data, and the delivery rate for the second five-year period should be lower than the rate for the ten-year period.
3.2.5 The justification for providing an increasing (rather than steady) delivery rate over the plan period is that around 35% of the housing need being satisfied arises from other authorities which are reaching capacity constraints. It is in the nature of such capacity constraints that they impact more severely as time passes, so that the delivery rates in the other authorities would reduce over time, and therefore their unsatisfied need (expressed per annum) would increase over time. An
Page 6 increasing delivery rate in Aylesbury Vale would be appropriate to satisfy this unmet need from other authorities.
3.3 S3 Settlement Hierarchy and cohesive developments
3.3.1 GHPC is grateful for the revised version of the Settlement Hierarchy, and notes that it proposes an allocation scheme for villages in the three categories which is proportionate to their existing size rather than being fixed for each category.
3.3.2 GHPC is, however, concerned that that the July 2016 version of the Draft Settlement Hierarchy Assessment, which introduces a category of “medium village”, contains in its Appendix A a table having a final column “Settlement hierarchy outcome” containing only the earlier large/small classification. The final column of this table should be corrected to show the new classification where settlements have been reclassified as medium villages.
3.3.3 The asterisk footnote on page 36 of the draft VALP says “See footnote 9” whereas the reference should instead be to footnote 11. There should be a similar asterisk footnote on the following page where Bierton (including Broughton) and Weston Turville are listed.
3.3.4 The second part of Policy S3 is a modified version of saved AVDLP Policy RA2. List item (b) in this policy has a label supposedly indicating footnote 6, whereas this should indicate footnote 12.
3.4 S4 Green Belt
3.4.1 This policy is generally consistent with paragraphs 87–90 of the NPPF. List items (a) and (c) in the policy are very similar to saved AVDLP policy RA6, and list item (b) is very similar to lapsed AVDLP Policy RA16.
3.4.2 List item (d) in the policy is similar to part of saved AVDLP Policy RA17, and list item (e) is similar to part of saved AVDLP Policy RA18. However both the saved policies contain requirements that the replacement, extension or alteration should not materially reduce the openness of the Green Belt; such a requirement is consistent with paragraphs 87–90 of the NPPF, and GHPC considers that it should be included in list items (d) and (e) of this policy.
3.5 S5 Infrastructure
3.5.1 Paragraph 3.44 of the supporting text states We will urge government, and support Buckinghamshire County Council, the local economic partnerships (LEPs) and other partners. Urge them to do what?
3.5.2 Paragraph 3.54 refers to an Infrastructure Delivery Plan. As previous paragraphs in this section have stressed the importance of infrastructure delivery in order to achieve the strategic
Page 7 objectives of VALP, GHPC considers it essential that an indicative timescale for the adoption of such a plan be included in this text.
3.5.3 Policy S3 is generally consistent with paragraph 162 of the NPPF. However GHPC notes with concern that there is no reference in the accompanying text to joint work with water authorities to ensure that there is an adequate water supply for the planned population increase in the district, even though such joint work is a requirement of paragraph 162.
3.6 S6 Protected transport schemes
3.6.1 Paragraph 3.57 in the accompanying text to this policy suggests that there might be an upgrade of the A421 through the district as part of the government's proposal for an Oxford to Cambridge Expressway. The Strategic Study for this Expressway is expected to propose several route options, one of which might be an upgrade of the existing A421 around Buckingham, but others of which would avoid Buckingham and would involve reclassifying the road around Buckingham if the Expressway retained the A421 designation. The wording of this text is therefore misleading, and similarly the wording of the second sentence of paragraph 3.63 The A421 which runs across the northern part of Aylesbury Vale, bypassing Tingewick and Buckingham is included for upgrade within the expressway study. is misleading.
3.6.2 Paragraph 3.62 of the accompanying text, indicating that “The implementation of East West Rail Phase 1 Bicester to Oxford is well underway”, should note that the opening of this line is now unlikely to be before 2022 in view of Network Rail funding issues, and might even be delayed until beyond 2024 (the end of funding period CP6). The second part of this paragraph, stating Phase 2, Bicester - Aylesbury - Milton Keynes, is planned for an earliest opening of services by 2020. gives a misleading route description (there will be no services from Bicester to Aylesbury).
3.6.3 GHPC considers that the second and third bullet points in Policy S6 are inappropriate. This policy is about protected transport schemes, whereas the two bullet points are not specifically about protected transport schemes but are rather about the relationship of new housing developments to transport requirements in general. These two bullet points would be more appropriate as part of a separate policy in Chapter 7, and would be consistent with paragraph 30 of the NPPF.
3.7 S7 Gypsy, Traveller and travelling showpeople provision
3.7.1 GHPC has concerns about the approach taken in the site assessment process described in paragraph 3.75, where sites with temporary permission were the first to be considered for allocation.
Page 8 3.7.2 Paragraph 4(f) of the DCLG Planning policy for traveller sites (August 2015) (PPTS) states that plan-making and decision-taking should aim to reduce the number of unauthorised developments and encampments and make enforcement more effective and paragraph 4(i) states to reduce tensions between settled and traveller communities in plan-making and planning decisions
3.7.3 Temporary permissions may well (as in Great Horwood, regarding land opposite Causter Farm, Nash) be the result of retrospective applications following unauthorised encampments, and a wholesale policy of converting temporary permission to permanent permission is unlikely to conform to paragraph 4 (f) of PPTS.
3.7.4 GHPC considers that further consideration be given to the possibilities, mentioned briefly in the accompanying text to the policy, of providing pitches on surplus employment land (which could potentially be consistent with paragraph 18 of PPTS) and also in the proposed new settlement, in order to provide an adequate supply of sites.
3.7.5 GHPC also considers that it would be appropriate to include wording, either in Policy S7 or else in Policy D14, along the lines of If temporary planning permission is granted retrospectively for an unauthorised encampment then the condition will be discharged to allow permanent occupation only in very special circumstances.
3.8 S8 Previously developed land
3.8.1 This policy is in conformity with paragraph 111 of the NPPF, and with paragraph 9.15 of Fixing the foundations: Creating a more prosperous nation (Cm 9098), presented to Parliament in July 2015.
3.9 S9 Securing development through neighbourhood plans
3.9.1 GHPC considers that Policy S9 is too abbreviated, and would be clearer if it were to differentiate between neighbourhood plans which have already been made, neighbourhood plans which are in preparation at the time the VALP is adopted and which have a realistic prospect of submission within eighteen months, and neighbourhood plans which might be submitted later during the VALP period.
3.9.2 All neighbourhood plans must be in general conformity with the strategic policies contained in the development plan for the area of the authority (or any part of that area) (PCPA Schedule 4B, sub-paragraph 8 (2) (e)).
Page 9 3.9.3 A neighbourhood plan which has been made before the adoption of VALP might not promote sufficient new housing to meet the VALP requirement. In such a case (but only in such a case) either the neighbourhood plan should be revised, or else additional housing sites should be allocated in VALP. This is essentially the current proposal in the draft VALP. However GHPC considers that, in such circumstances, additional VALP allocations should (where possible) conform to the spatial policies in the existing neighbourhood plan, as these have satisfied an examination and passed a referendum, and that in any event the total number of dwellings expected in the sites allocated should not substantially exceed the total VALP requirement.
3.9.4 A neighbourhood plan which is now in preparation will necessarily, if it contains a spatial strategy at all, be in general conformity with the VALP strategic policies, for if it is not then it will be unable to satisfy the Basic Conditions at examination. The current proposal in the draft VALP covers this eventuality. GHPC considers that the proposal in Policy S9 for reserve sites to be specified in VALP, and for these to be allocated if the neighbourhood plan is not submitted within a year of VALP adoption, should be modified to allow an eighteen month period, and that any allocation of reserve sites in this manner should have regard to the views of the qualifying body preparing the neighbourhood plan.
3.9.5 Policy S9 does not contemplate the effect of the submission and making of neighbourhood plans later in the VALP period, although such a sequence was the original intention of Government policy and is anticipated in paragraphs 16 and 184 of the NPPF. GHPC considers that the word “general” in the expression “general conformity” is significant; as neighbourhood plans are intended to shape and direct development in the neighbourhood area (paragraph 185 of the NPPF) it is necessary to contemplate the possibility that a neighbourhood plan might effectively de- allocate a VALP allocated site, and allocate a different site to meet the strategic housing requirement for the area. Such an eventuality would be permitted by legislation: If to any extent a policy contained in a development plan for an area conflicts with another policy in the development plan the conflict must be resolved in favour of the policy which is contained in the last document to be adopted, approved or published (as the case may be). (PCPA, Section 38 (5)) and, for small sites, would clearly be in general conformity with VALP.
3.9.6 GHPC therefore considers that Policy S9 should be modified to take account of these issues. GHPC also considers that the final part of the policy “Neighbourhood plans should:”, and the itemised list immediately following, should be deleted. The question of whether a draft neighbourhood plan may be permitted to proceed to referendum is a matter for the plan’s independent examiner, who is guided by legislation and the NPPF and will necessarily take into account the matters included in the itemised list.
Page 10 Chapter 4: Strategic Delivery
4.0 General matters concerning this chapter
4.0.1 Chapter 4 is, at 56 pages, by far the longest chapter in the draft VALP (the second longest, Chapter 3, runs to 30 pages). GHPC believe that there is scope for the length of this chapter to be reduced.
4.0.2 Policies D1 Delivering Aylesbury Garden Town, D11 Site for town centre redevelopment, D12 Aylesbury town centre and D13 Housing in Aylesbury town centre, together with their accompanying text, take up 15 pages and go into a level of specific detail far greater than that of the other policies in this chapter. The intention of these four policies is clearly to implement the third planning action point on page 38 of the Aylesbury Town Plan Ensure the Vale of Aylesbury Local Plan (VALP) supports the aims and delivery of this Plan, influences and shapes it, and vice versa. GHPC suggests that these policies be placed in a separate chapter, perhaps entitled “Delivery of Aylesbury Garden Town”, to acknowledge the central importance of Aylesbury town to the planning strategy for the Vale of Aylesbury as a whole. As an alternative, with the advantage of a greater ease of updating, these policies could instead be included in a separate Development Plan Document which would bear the same relationship to VALP as the proposed Princes Risborough Town Plan bears to the proposed New Wycombe District Local Plan.
4.0.3 Policies D4 Housing development at strategic settlements (excluding Aylesbury), D5 Housing development at larger villages and D6 Housing development at medium villages are, apart from housing numbers and the tables of neighbourhood plan allocations, virtually identical; Policy D7 Housing development at smaller villages is almost identical, with some minor differences and simplifications in the paragraph starting “New housing development ...” and its associated list of criteria. GHPC note paragraph 19 of the Examining Inspector’s report on SWDP: Many of the MMs involve eliminating duplication and repetition between policies, in order to make them more focussed and effective. This led to concerns being expressed in the consultation responses about the removal of clauses from certain policies. However, the Plan is to be read as a whole. Where policy requirements apply generally, they do not need to be stated in more than one policy. GHPC therefore suggest that policies D4 – D7 be amalgamated, with differences between the different levels of the settlement hierarchy being highlighted where appropriate. The supporting text for the policies should similarly be amalgamated.
4.1 D1 Delivering Aylesbury Garden Town
4.1.1 The wording of this policy is, in part, more suitable to a vision statement than a policy (which is supposed to provide guidance to developers and decision takers). In particular, GHPC considers that list items (b) and (f) do little to provide such guidance.
Page 11 4.2 D2 Delivering a new settlement
4.2.1 GHPC have already submitted comments on the New Settlement Scoping Study (June 2016): Comments from Great Horwood Parish Council on the relative suitability of sites at Winslow and Haddenham for a new settlement and Comments from Great Horwood Parish Council on the traffic effect in Great Horwood of a possible new settlement north of Winslow For convenience, these are appended to the present representation as Appendices B and C.
4.2.2 GHPC note that the proposal for a new settlement would be consistent with paragraph 52 of the NPPF. That paragraph also advises that local planning authorities should consider whether it is appropriate to establish Green Belt around or adjoining any such new development. Paragraph 82 of the NPPF makes clear that the development of a new settlement would constitute the exceptional circumstances where a new Green Belt might be established; the need to avoid coalescence with other nearby settlements would help to demonstrate consistency with the other bullet points in that paragraph. Furthermore, bullet points 3 and 4 of paragraph 85 of the NPPF would allow the allocation of land for development of 4,500 new dwellings within the plan period, while safeguarding the remaining land for the subsequent extension of the settlement to its projected final size of 6,000 dwellings.
4.3 D3 Delivering sites adjacent to Milton Keynes
4.3.1 The figure of 4,274 for the potential housing capacity of sites adjacent to Milton Keynes, quoted in paragraphs 4.48 and 4.49 of the accompanying text to this policy, does not arise from other data. The three suitable sites (NLV001, NLV023 and WHA001) provide 1,885 + 39 + 2,000 = 3,924 dwellings, as stated correctly in paragraph 4.53 and in the policy itself; but adding a further 268 dwellings from site SHM012 gives 4,192, not 4,274, a discrepancy of 82. Although the figure for site WHA001 is clearly an estimate, the arithmetic using that estimate should still be carried out correctly.
4.3.2 The fourth bullet point in paragraph 4.49 suggests that the sites will provide a reserve site for a station and a financial contribution to East West Rail. Whereas Network Rail intend to make technical provision for an additional station at Queen Catherine Road near Steeple Claydon, no such provision is currently planned for a further station near Newton Longville. The text accompanying this paragraph should indicate whether negotiations with Network Rail have indicated any real possibility of a station near Newton Longville or whether this is simply an aspiration.
4.3.3 One of the sites, NLV001, is the subject of an outline planning application (15/00314/AOP), validated on 30 January 2015, for 1,885 dwellings. It is unclear how that proposal, if it is approved,
Page 12 will be required to adhere to an as yet unwritten supplementary planning document describing design codes, standards and required infrastructure for sites adjacent to Milton Keynes.
4.3.4 The accompanying text should indicate the impact of the proposed development at site WHA001 on the BCC Whaddon Chase Green Infrastructure Plan 2010.
4.3.5 GHPC considers that the observations made in 4.2.2 above regarding designation of a Green Belt around a new settlement would apply equally to these developments, as the new sites would naturally be regarded as an urban extension of Milton Keynes which happened to cross the local authority boundary into Aylesbury Vale. As well as discouraging coalescence with Newton Longville and Whaddon, such a Green Belt would encourage post-2033 development of Milton Keynes to be to the east, so that Central Milton Keynes, the city’s main shopping hub, remained in the centre of the city’s developed area.
4.4 D4 Housing development at strategic settlements (excluding Aylesbury)
4.4.1 In view of the remarks in 4.0.3 above, the comments regarding all four policies D4–D7 are included in this section.
4.4.2 GHPC has some concerns about the consistency and reliability of some of the data in the tables in paragraphs 4.61, 4.69, 4.79 and 4.87, and the tables of neighbourhood plan allocations in the four policies, and these are outlined below.
4.4.3 It is understood that the figures for commitments and completions in the four tables refer to a cut-off date of 1 April 2016. No doubt this will change for the submission plan, but for clarity the cut-off date should be stated explicitly. GHPC considers that that these figures should be supported by an audit trail, in a separate document presented as part of the evidence to support the plan, giving application references and dates for the various commitments and completions.
4.4.4 The commentary in the table in paragraph 4.61 regarding Winslow states The commitments include 205 homes identified in the made Winslow Neighbourhood plan. whereas the table in Policy D4 gives the neighbourhood plan allocation for Winslow as 455; the latter figure is taken from paragraph 4.17 of the Winslow Neighbourhood Plan. This discrepancy should be corrected.
4.4.5 The wording of the commentary for Winslow and some other settlements having neighbourhood plans, along the lines of The commitments include XXX homes identified in the made (Settlement) Neighbourhood plan. This leaves a shortfall of YYY ... suggests that the numbers XXX and YYY should give the total housing requirement, whereas it is the total of commitments and completions (including neighbourhood plan allocations) which should be added to the shortfall YYY to give the total housing requirement. Although this is simply a matter of the presentation of data, GHPC considers that the current wording has the potential to introduce confusion and should be modified.
Page 13 4.4.6 In the table in paragraph 4.79, the commitments figure for Cheddington does not include neighbourhood plan allocations, whereas the commitments figure for Great Horwood does include neighbourhood plan allocations. The approach to the commitments column in all four tables should be consistent.
4.4.7 The table in Policy D4 gives a neighbourhood plan allocation for Haddenham of “(476)”. The correct figure for the allocation is, at present, zero as Chapter 6 of the Haddenham Neighbourhood Plan has been quashed by order of the High Court on 7 March 2016. There should be no reference at all to the earlier allocation.
4.4.8 GHPC considers that, for clarity, the column labelled “Housing requirement” in the tables in paragraphs 4.61, 4.69, 4.79 and 4.87 should be supported by an audit trail in a separate document, giving the existing housing stock upon which the appropriate percentage increase has been calculated. This has particular relevance where a village contains only part of the housing stock in a parish, such as in Great Horwood parish, where the parish contains over 400 dwellings but fewer than 350 are in Great Horwood village (the remainder being in the hamlet of Singleborough, the small cluster of houses near the A421 known as The Common, and outlying farms). If the hierarchy assessment is based on the “capacity of settlements to accommodate sustainable development” but the housing requirement is based upon a percentage increase to the existing housing in the parish containing the settlement, then a justification of this approach should be given.
4.4.9 GHPC considers that the second sentence of asterisked paragraph in each of the policies D4– D7 is ambiguous. It is not clear whether the word “This” at the beginning of the sentence This includes former agricultural barns ... refers to “the existing developed footprint” or to the excluded “individual buildings and groups of dispersed buildings”. The paragraph should be reworded to clarify this along the lines of the footnote to Policy H2, which does not suffer from this ambiguity.
4.5 D5 Housing developments at larger villages 4.6 D6 Housing development at medium villages 4.7 D7 Housing developments at smaller villages
[Comments on these policies are included in Section 4.4 above]
4.8 D8 Housing at other settlements
4.8.1 The use of the term “other settlements” in this policy is inconsistent with its use in Table 3, in the accompanying text to Policy S3 Settlement hierarchy and cohesive development. That table, referring to settlements too small to be classed as small villages, distinguished between “Other settlements (with a population of over 100)” and “All other settlements”. This distinction is not maintained in Policy D8. GHPC considers that this matter should be clarified in order to remove the tension between the two policies.
Page 14 4.9 D9 Provision of employment land
4.9.1 GHPC suggest that this policy should make specific reference to petrol stations, farm shops (which need not be associated with a specific farm and would therefore not fall under the itemised list entry (c)) and garden centres.
4.9.2 The term “live-work development”, mentioned in the policy, should be included in the VALP Glossary. The use of an alternative spelling “live/work” should be considered.
4.10 D10 Town, village and local centres to support new and existing communities
4.10.1 GHPC considers that in this policy the paragraph New local centres will be provided within major development areas. should be more specific about the meaning of the term “major development areas” and should specify that it refers to the development areas described in Policies D1, D2 and D3.
4.10.2 GHPC also considers that the final paragraph of the policy should be strengthened by rewording along the lines of Local and village centres will also be encouraged to grow, and proposals for change of use which entail the loss of essential facilities or businesses such as local shops, pubs and post offices will be resisted unless there is compelling evidence of the lack of viability of the existing use.
4.11 D11 Site for town centre redevelopment 4.12 D12 Aylesbury town centre 4.13 D13 Housing in Aylesbury town centre
4.13.1 Policy D12 starts “Elsewhere in the town centre ...” and is clearly written as a continuation of Policy D11 which immediately precedes it (the final two lines of Policy D11 at the top of page 108 should be shown on a coloured background). These two policies should be merged, and the combined policy should be give the title “Aylesbury town centre”.
4.13.2 As indicated in 4.0.2 above, it would be appropriate for these policies together with policy D1 to be in a separate chapter of VALP.
4.14 D14 Gypsy/Traveller and Travelling Showpeople Sites
4.14.1 A suggested addition to either this policy or policy S7 is given in 3.7.5 above.
Page 15 Chapter 5: Housing
5.1 H1 Affordable Housing
5.1.1 GHPC notes that the Written Ministerial Statement of 28 November 2014 (which introduced the 10-dwelling threshold for affordable housing contributions mentioned in paragraph 5.5) combined this with a size threshold of a maximum combined gross floor space of 1,000 square metres GHPC considers that the size threshold should also be included in Policy H1.
5.1.2 GHPC also considers that the phrase “a minimum of 31% affordable homes on site” in the policy should be replaced by a minimum of 31% affordable homes on site, unless a policy in a made neighbourhood plan covering all or part of the site specifies a greater percentage.
5.2 H2 Rural Exception sites
5.2.1 GHPC considers that this policy should incorporate the wording Proposals for these rural exception sites must accord with the Plan’s design policies and reinforce the distinctive character of the villages in which they are located from saved AVDLP Policy GP4.
5.2.2 GHPC also considers that the maximum proportion of market housing to be included in a rural exception scheme should be 30% rather than 50% in order to preserve the essential nature of the scheme. This modification to policy H2 would make it consistent with paragraph 54 of the NPPF, which refers to “some market housing” in contrast to “significant additional affordable housing”; the present policy with a maximum of 50% would not be consistent with paragraph 54.
5.3 H3 Rural Workers dwellings
5.3.1 In the itemised lists within the policy it is not clear why items (b) and (c) for permanent dwellings are worded differently from the corresponding items (i) and (j) for temporary dwellings. If these two pairs of items are indeed supposed to be equivalent then GHPC suggests a single itemised list for both types of dwelling, with a “fork” in the list to provide items (e) and (f) for permanent dwellings, and item (l) for temporary dwellings.
5.4 H4 Replacement dwelling in the countryside
5.4.1 GHPC suggest that the phrase “is considered acceptable in principle” in the policy be replaced by “will be permitted”, and that a suitably modified version of the sentence about increases in size from paragraph 5.54 be incorporated in the policy itself.
Page 16 5.5 H5 Self/custom build housing
5.5.1 GHPC supports the inclusion of a quantified policy for the provision of plots for self/custom build housing on large development sites.
5.6 H6 Housing mix
5.6.1 GHPC considers that the second and third paragraphs of this policy should be quantified, giving targets for the proportions of specialist housing to be provided in developments of different sizes, with a requirement to present open-book viability evidence for any proposals where it is claimed that such targets cannot be attained.
5.6.2 It would be helpful to provide a full reference to Approved Document M, indicating that it is a guidance document relating to the Building Regulations 2010.
5.7 H7 Dwelling sizes
5.7.1 GHPC notes that a policy requiring compliance with the Technical Housing Standards document would, with the provision of viability evidence, be in conformity with paragraphs 173 and 174 of the NPPF, but suggests that in any event a policy requirement that applicants provide a schedule of floor areas for each type of unit proposed would be of help to decision takers.
Chapter 6: Economy
6.1 E1 Protection of key employment sites
6.1.1 This policy is consistent with paragraph 21 of the NPPF. However paragraph 22 of the NPPF includes a requirement that land allocations (in the context of employment land) should be regularly reviewed, and indeed the number of key employment sites was reduced from 16 to 12 between 2012 and 2016. GHPC considers that this policy should include a reference to a review mechanism to allow for modifications in the list of key employment sites during the plan period.
6.2 E2 Other employments sites
6.2.1 This policy is consistent with paragraphs 21 and 22 of the NPPF.
Page 17 6.3 E3 Provision of complementary facilities for employees
6.3.1 GHPC considers that the first instance of the word “appropriate” in this policy should be replaced by the word “permitted”.
6.4 E4 Working at home
6.4.1 This policy is a rewritten version of lapsed AVDLP Policy GP7.
6.5 E5 Development outside town centres
6.4.2 The first part of this policy is a slightly modified version of 24 of the NPPF.
6.4.3 GHPC considers that, to clarify that this policy is consistent with paragraphs 26 and 27 of the NPPF, the second paragraph should be modified so that after the second comma it reads …, will be refused unless it can be demonstrated that ...
6.6 E6 Shop and business frontages
6.6.1 This policy is consistent with the third bullet point of paragraph 23 of the NPPF, and is a rewritten version of various saved policies from AVDLP applying to the shopping frontages in individual strategic settlements.
6.7 E7 Tourism development
6.7.1 GHPC considers that the first sentence of this policy, ending in the word “… and support proposals”, is is of too general a nature, contradicts the remainder of the policy, and should be deleted. The second sentence should be amended to read Proposals for new or expanded tourism, visitor or leisure facilities will be supported within or adjacent to settlements, subject to compliance with other policies in the Development Plan.
6.8 E8 Tourist accommodation
6.8.1 The second paragraph of this policy, “Proposals … as a going concern.”, concerning proposals to reduce tourist accommodation, is inappropriately positioned. GHPC considers that it would be better placed at the end of the policy.
6.8.2 The remainder of the policy is broadly consistent with the third bullet point of paragraph 28 of the NPPF.
Page 18 6.8.3 The term “medium tier of the settlement hierarchy”, used in the first bullet point of this policy, is not defined anywhere in the draft VALP; nor is it defined in the draft Settlement Hierarchy (July 2016). There are no logical connectives joining the three bullet points in the policy, and so the meaning of this part of the policy is ambiguous. Furthermore, the second bullet point and list item (c) appear to cover the same contingencies, as do the third bullet point and list item (d).
6.8.4 GHPC considers that the middle part of this policy should be completely rewritten in order to clarify its intended meaning. GHPC would also suggest that the rewritten version should be stated to apply to those non-strategic settlements in the Settlement Hierarchy described as “villages” rather than “other settlements”, so that the existing list item (b) should become Tourist accommodation in other settlements will not generally be supported.
6.8.5 The final part of the policy, concerning camping and touring caravan sites, is essentially a rewrite of saved AVDLP Policy GP73.
6.9 E9 Agricultural developments
6.9.1 This policy is generally consistent with the second bullet point of paragraph 28 of the NPPF.
6.9.2 GHPC considers that there should be a further sentence at the end of the policy, along the lines of Proposals should provide evidence that the design of such buildings is consistent with the AVDC Design Guide for New Buildings in the Countryside.
6.9.3 GHPC also considers that, for clarity, the policy should state explicitly whether it applies to retail outlets related to agriculture, such as farm shops and garden centres.
Chapter 7: Transport
7.1 T1 Vehicle parking
7.1.1 The first part of this policy is largely a restatement of paragraph 39 of the NPPF.
7.1.2 GHPC considers that the remainder of this policy, specifying parking standards, from the bottom of page 144 to page 149, is at an inappropriate level of detail for inclusion in the Local Plan, and suggests that it would be more appropriate for these standards to be included in a separate Supplementary Planning Guidance document. A reference should be made in the policy to this document, in a similar manner to the reference made in saved AVDLP Policy GP24 to the then current guidance document.
Page 19 7.2 T2 Footpaths and cycle routes
7.2.1 This policy has the general support of bullet point 2 in paragraph 35 of the NPPF.
7.2.2 Item (b) in the list of criteria in this policy (for cycle routes) is copied verbatim from the lapsed AVDLP Policy GP27, and item (c) in the list (for pedestrian routes) is almost, but not quite, identical to the lapsed AVDLP Policy GP28.
7.3 T3 Electric vehicle infrastructure
7.3.1 This policy has the general support of bullet point 4 in paragraph 35 of the NPPF.
7.3.2 GHPC considers that item (c) in this policy should include a sentence along the following lines: Development proposals required to provide such charging points should outline a financial mechanism for purchasing the electricity required for operation but not available from renewable sources.
Chapter 8: Built Environment
8.1 BE1 Heritage assets
8.1.1 GHPC suggest an additional sentence at the beginning of this policy along the lines of Development proposals affecting heritage assets will be considered in accordance with the NPPF, relevant legislation and published national and local guidelines. with an appropriate adjustment to the wording of the existing first sentence. The suggested insertion is essentially the same as paragraph A in Policy 24 Management of the Historic Environment of SWDP.
8.1.2 GHPC also suggest that Policy BE1 should include a reference to the positive contribution which heritage assets can offer in the way of, for example, the development of employment or tourism, in addition to describing the way in which such assets should be protected. Such a sentence would be in conformity with paragraph 126 of the NPPF: Local planning authorities should set out in their Local Plan a positive strategy for the conservation and enjoyment of the historic environment, [...]
8.1.3 The sentence The level of detail required will depend upon the nature of the works proposed. at the end of the first paragraph of Policy BE1 should be in parentheses, as the phrase “the following information” in the preceding sentence is intended to refer to the list on the next page.
Page 20 8.1.4 Paragraph (g) in the list does not describe information that should be included in a heritage assessment. The text of this paragraph should not be part of the policy, and would be more appropriate in the supporting text.
8.1.5 The remaining text in the first part of this policy is essentially taken verbatim from saved AVDLP Policy GP53. The section of the policy headed Archaeology and ancient monuments is taken verbatim from saved AVDLP Policy GP59. The section of the policy headed Historic parks and gardens is taken verbatim from saved AVDLP Policy GP60. GHPC do not suggest any modifications to these parts of the policy.
8.2 BE2 Design of new developments
8.2.1 The first part of this Policy, at the bottom of page 157, is copied from saved AVDLP Policy GP35 with some minor modifications, and with the interchange of clauses (b) and (c).
8.2.2 GHPC suggest that consideration be given to including in addition some more specific guidance, such as that included in paragraphs B (ii) Relationship to Surroundings and Other Development, B (viii) Scale, Height and Massing, and B (x) Detailed Design and Materials in Policy 21 Design of SWDP.
8.2.3 The second part of Policy BE2 could be improved in several ways. The first sentence of the first paragraph The distance between dwellings and the treatment of spaces around them have an important effect on the appearance of an area, the quality of life for residents and the distinctiveness of development. Is descriptive rather than normative, and so should form part of the accompanying text rather than part of the Policy.
8.2.4 The first sentence of the second paragraph Outlook from a dwelling is allied to privacy and both are necessary for quality of life in dwellings. is again descriptive and should be moved. The second sentence Whilst an adequate standard of privacy may be achieved by the use of walls, fences and planting, consideration will need to be given to the outlook that would then be achieved, as an enclosed or cramped outlook from habitable rooms is likely to be oppressive. Is too negative, and should be rephrased along the lines of Walls, fences and planting should be used to achieve an adequate standard of privacy without imposing an enclosed or cramped outlook from habitable rooms.
8.2.5 The detailed information about space between dwellings on page 159 is presumably not part of Policy BE2 as it is not on a coloured background, but its status is unclear. GHPC suggest that this page be removed from the VALP and included in “the council’s adopted design guides” and that a suitable reference be included in the first paragraph of the second part External space standards of Policy BE2.
Page 21 8.2.6 GHPC’s comments below on draft VALP Policy C3 Renewable energy suggest that those aspects of the policy concerning carbon emission reduction methods for residential development should be included in this Chapter, either as part of Policy BE2 or as a separate policy.
8.3 BE3 Protection of the amenity of residents
8.3.1 This Policy is copied verbatim from saved AVDLP Policy GP8.
8.3.2 GHPC suggest the insertion of the following sentence between the two existing sentences in the Policy, in order to provide more specific guidance to decision takers: In particular, development should provide an adequate level of privacy, outlook, sunlight and daylight, and should not be unduly overbearing. The suggested insertion is essentially the same as paragraph B (iv) Neighbouring Amenity in Policy 21 Design of SWDP.
Chapter 9: Natural Environment
9.1 NE1 Protected sites
9.1.1 This policy is consistent with paragraph 118 of the NPPF. However GHPC suggest that it should make specific reference to legislative requirements, such as Section 28E of the Wildlife and Countryside Act 1981.
9.2 NE2 Biodiversity
9.2.1 This policy is an implementation of paragraph 113 and 114 of the NPPF. The policies in AVDLP covering these areas (such as GP61, GP62, GP64) were not saved, and so have lapsed.
9.3 NE3 Landscape character and locally important landscape
9.3.1 This policy is a significant extension of the saved AVDLP Policy RA8 (most of the wording of which is incorporated in the final paragraph of the new draft policy), and is consistent with paragraph 113 of the NPPF.
9.4 NE4 The Chilterns AONB and setting
9.4.1 This policy is an implementation of paragraphs 115 and 116 of the NPPF.
Page 22 9.5 NE5 Pollution, air quality and contaminated landscape
9.5.1 This policy is an implementation of paragraphs 109 and 110 of the NPPF. In particular the section of the policy labelled Light pollution is an implementation of paragraph 125 of the NPPF, and the section labelled Air quality is an implementation of paragraph 124 of the NPPF. The policies in AVDLP covering these areas (such as GP41, GP97, GP102) were not saved, and so have lapsed.
9.6 NE6 Local green space
9.6.1 This policy is an implementation of paragraph 76 of the NPPF.
9.6.2 GHPC wish to propose the Great Horwood Recreation Ground (“Horwode Pece”) as Local Green Space. Details of this proposal are given in Appendix A to this document.
9.7 NE7 Best and most versatile agricultural land
9.7.1 This policy is consistent with paragraph 112 of the NPPF.
9.8 NE8 Trees, hedgerows and woodlands
9.8.1 This policy is a replacement for saved AVDLP Policies GP39 and GP40. The species Black Poplar, several of which grow in Great Horwood, is mentioned in GP40 as particularly worthy of preservation as it is regarded by the Forestry Commission as the most endangered native timber tree in Britain1.
9.8.2 Policy NE8 states in its first paragraph Development should seek to enhance and expand the district’s tree and woodland resource,including native Black Poplars. There is, however, no specific reference to Black Poplars in the paragraph following, regarding loss of or damage to trees. GHPC suggests that the following sentence be added to the end of the second paragraph: Development that would result in the unacceptable loss of, or damage to, or threaten the continued well-being of Black Poplars will be permitted only in exceptional circumstances.
1 Forestry Commission Research Information Note 239, issued by the Research Division of the Forestry Authority, December 1993
Page 23 9.9 General matters concerning the Natural environment chapter
9.9.1 There does not appear to be a general policy in the draft VALP referring to riverside or canalside development proposals. GHPC suggest that saved AVDLP Policy GP66 be included as a policy in this Chapter, for the purpose of maintaining public amenity.
Chapter 10: Countryside
10.1 C1 Conversion of rural buildings
10.1.1 This policy is an expansion and modification of saved AVDLP Policy RA11.
10.1.2 GHPC considers that much of the section of this policy headed Proposed uses is repetitious and could usefully be simplified. While the first paragraph in this section could remain unchanged, the remainder of the section would be clearer if it were rewritten along the lines of The re-use of existing buildings for occupational or non-occupational residential purposes will be permitted only if • the redundant or disused status of the building(s) has been confirmed, • no new dwellings are created in the open countryside in the absence of special circumstances, and • it can be demonstrated that the re-use of the building would enhance the immediate setting. If the building proposed for such re-use is a heritage asset, whether designated or not, then the proposal will also be considered under Policy BE1.
10.2 C2 Equestrian developments
10.2.1 This policy is a significant expansion of saved AVDLP Policies GP77 and GP78.
10.2.2 Whereas the section of the policy headed Failure of a commercial enterprise requires an assessment that an existing equestrian enterprise is not viable before a subsequent change of use is permitted, and whereas paragraph 10.47 of the accompanying text refers to the need for a business plan to show that a commercial equestrian development would be viable, there is no explicit requirement in Policy C2 for a positive viability assessment of a proposed equestrian development. GHPC believe that this is an unintended loophole which should be closed by an explicit statement within the policy.
Page 24 10.3 C3 Renewable Energy
10.3.1 GHPC considers this policy to involve the conflation of two separate issues which should be separated. The first issue concerns the reduction of carbon emissions relating to proposals for residential or non-residential development (which might include, amongst other methods, the provision of renewable energy schemes) in accordance with paragraph 95 of the NPPF; the second concerns the impact of stand-alone proposals for the generation of renewable energy in accordance with paragraph 97 of the NPPF.
10.3.2 The first paragraph of the policy, starting “Planning applications ...” and including the itemised list (a) – (g), together with the final paragraph “Planning permission will be granted ...” and including the itemised list (m) – (o), would appear to concern stand-alone proposals; it is appropriate for them to appear in Chapter 10 Countryside.
10.3.3 The remaining part of the policy “In seeking to … as part of the development.” would appear to concern the reduction of carbon emissions for residential or non-residential development. In the view of GHPC this part of Policy C3 would sit better in Chapter 8 Built environment, either as a part of Policy BE2 or as a separate policy.
10.3.4 Wherever it is located, the itemised list describing the “energy hierarchy” should not include item (l), specifying a requirement for an Energy Statement. This requirement is not part of any hierarchy, and should appear as a stand-alone paragraph immediately after the itemised list.
10.4 C4 Protection of public rights of way
10.4.1 This policy is an implementation of paragraph 75 of the NPPF.
10.4.2 GHPC suggest an additional item in the list of requirements in the policy, along the lines of the following: g. if rights of way are modified or enhanced, special attention should be given to the amenity and convenience of people with disabilities
10.4.3 GHPC also suggest an additional paragraph along the lines of the following: If, exceptionally, it is proposed to stop up or divert a public right of way to enable development to take place, permission will only be granted where there is an existing suitable alternative route, or provision is so made. This wording is taken from saved AVDLP Policy GP84.
Page 25 Chapter 11: Detailed Infrastructure
11.1 I1 Green infrastructure
11.1.1 This policy is consistent with bullet point 1 of paragraph 114 of the NPPF.
11.1.2 GHPC considers that the detailed list of green infrastructure accessibility and quantitative standards provided at the end of this policy gives an inappropriate level of detail, and suggests that instead the paragraph introducing the itemised list should instead read As part of this development proposals must demonstrate that the green infrastructure network would be maintained and, where appropriate, enhanced within the site to the standards set out in the Assessment of Leisure and Cultural Facilities (2012) or its replacement, as follows:
11.2 I2 Sports and recreation
11.2.1 This policy is consistent with paragraph 73 and 74 of the NPPF, except insofar as the 2012 Assessment of Leisure and Cultural Facilities does not qualify as an “up-to-date assessment … of quantitative or qualitative deficits or surpluses ...”
11.2.2 GHPC considers that the first sentence in item (c) in the list in this policy should contain a reference to the SPG ready-reckoner, so that the phrase “commensurate to the need” can be quantified.
11.3 I3 Community facilities
11.3.1 This policy is essentially a combination of saved AVDLP policies 93 and 94; it is consistent with bullet point 4 of paragraph 28 of the NPPF.
11.3.2 GHPC considers that the final sentence of the policy should be extended so that it reads Conditions will be imposed on permissions, or planning obligations sought in order to secure appropriate community facilities, or financial contributions towards community facilities, reasonably related to the scale and kind of housing proposed and with appropriate facilities for access and use by disabled people.
11.4 I4 Flooding
11.4.1 This policy is consistent with paragraph 100 of the NPPF. The current version of the Strategic Flood Risk Assessment, although dated 2012 and prepared for the withdrawn Vale of Aylesbury Plan, is still appropriate as evidence to support this policy.
11.4.2 Paragraphs 11.31 and 11.32 of the supporting text appear in a section headed Water resources, after (rather than before) Policy I4. While there is some reference in the policy to
Page 26 development restrictions in order to maintain water quality, GHPC considers that the final three sentences of paragraph 11.32 should be incorporated with this policy.
11.5 I5 Telecommunications
11.5.1 This policy is a modification and extension of saved AVDLP Policy GP100, and is consistent with paragraph 43 of the NPPF.
11.5.2 There is a conflict between the wording of this policy, which is written as a list of conditions to be satisfied before permission is granted, and the aspirations expressed in paragraph 11.41 of the supporting text. The former appears to concern masts for wireless communication, whereas the latter includes ducting for wired communication.
11.5.3 GHPC considers that this policy should contain an additional paragraph, incorporating the aspirations from paragraph 11.41, along the lines of the following: All new housing and commercial development should incorporate high quality on-site communications infrastructure, including ducting to industry standards, for efficient connection to existing networks and including potential for future upgrades. If such infrastructure cannot be delivered, the developer will need to submit evidence to justify the reasons why this is the case, whether it be for viability or technical reasons.
11.6 General matters concerning the Detailed infrastructure chapter
11.1 GHPC suggest that the labels for policies in this chapter might be typographically clearer if the label prefix was DI rather than I, rather as the prefix for policies in the Built environment chapter is BE.
Page 27 Appendix A: “Horwode Pece” recreation ground – Local Green Space proposal
A.1 Great Horwood Parish Council wish to propose that the “Horwode Pece” recreation ground be designated a Local Green Space, in accordance with paragraph 76 of the NPPF and section 37 of the Planning Practice Guidance. This Appendix contains details of the proposal.
A.2 The Great Horwood Parish Plan 2006 contained the following: A piece of land off Spring Lane has been gifted to the Parish with a view to its becoming a new recreation area, although planning issues are not yet resolved. A significant proportion of the parish would be prepared to support facilities in this new area by paying a higher local precept. • We will continue to work to provide appropriate recreation facilities for the parish, focusing this effort through the former Parish Plan Work Group which will operate as a sub-committee of the Parish Council • We will endeavour to secure planning permission from AVDC for the new Spring Lane recreation area • We will plan and procure necessary installations for any new recreation area
A.3 Planning permission for change of use as a new recreation ground (application reference 07/03248/APP) was granted by AVDC on 1 May 2008. The location plan for this application, showing the land in question, is included at the end of this Appendix.
A.4 The land is owned by the Great Horwood and Singleborough Recreation Trust (registered charity 1119620). The objects of the Trust are To promote for the benefit of the inhabitants of the parish of Great Horwood and Singleborough and the surrounding area the provisions of facilities for recreation or other leisure time occupation of individuals who have need of such facilities by reason of their youth, age, infirmity or disablement, financial hardship or social and economic circumstances or for the public at large in the interests of social welfare and with the object of improving the condition of life of the said inhabitants. The recreation ground is managed by the Horwode Pece Management Committee on behalf of the Recreation Committee of Great Horwood Parish Council.
A.5 Significant sums have been received by way of grants for play equipment to be installed on the recreation ground.
A.6 Designation of the recreation ground as Local Green Space would be consistent with the conditions specified in paragraph 77 of the NPPF: • where the green space is in reasonably close proximity to the community it serves; (the recreation ground is about 700m from the centre of Great Horwood) • where the green area is demonstrably special to a local community and holds a particular local significance, for example because of its beauty, historic significance, recreational value (including as a playing field), tranquillity or richness of its wildlife;
Page 28 (Horwode Pece, with its distinctive name, has particular local significance as the only equipped public recreation space for children within walking distance of Great Horwood) • where the green area concerned is local in character and is not an extensive tract of land (the recreation ground has an area of about 1ha).
Page 29
Vale of Aylesbury Local Plan New Settlement Study Consultation July – September 2016
Comments from Great Horwood Parish Council on the relative suitability of sites at Winslow and Haddenham for a new settlement Introduction
These comments are a further response to the Draft Vale of Aylesbury Local Plan Consultation (July to September 2016), where comments are requested on the new evidence documents published in support of the draft plan.
The comments in this document address a specific point: if there is a new settlement in the Vale of Aylesbury, and it is located at one of the two shortlisted sites, then which of those two sites should be preferred?
These comments are separate from those presented in an earlier document1, and they should be read together.
Contents
1. Summary of representation
2. Housing need and the Duty to Cooperate
2.1 Housing need in the Vale of Aylesbury
2.2 Advice from the NPPF regarding location
2.3 Housing market areas and travel-to-work areas
3. Other considerations
3.1 The draft VALP Sustainability Appraisal
3.2 Other relevant matters
3.3 Conclusions
1 Comments from Great Horwood Parish Council on the traffic effect in Great Horwood of a possible new settlement north of Winslow (July 2016)
Page 2 1. Summary of representation
1.1 The draft Vale of Aylesbury Plan was withdrawn by AVDC in 2014 after adverse comments from the Inspector conducting its Examination in Public. These comments concerned a failure to plan for an adequate supply of housing, and a failure in the duty to cooperate with neighbouring authorities.
1.2 The draft Vale of Aylesbury Local Plan, at present the subject of consultation, intends to remedy these two deficiencies. It proposes, not merely a significantly increased supply of housing to meet the objectively assessed need in the Vale of Aylesbury, but also an uplift of over 50% to take account of unmet need from neighbouring authorities.
1.3 A new settlement is proposed in the draft VALP as part of a strategy to meet the total need. There would, however, be no need for a new settlement without the requirement to provide for unmet need from other authorities.
1.4 The National Planning Policy Framework (NPPF) provides advice on the preparation of local plans in these circumstances, indicating that matters of geography should be taken into consideration. The unmet need is principally from other authorities in Buckinghamshire to the south of Aylesbury Vale. Of the two shortlisted sites for a new settlement, Winslow is in the north of the district and Haddenham is in the south. The NPPF therefore provides a strong presumption in favour of siting the new settlement at Haddenham.
1.5 This presumption is not irrebuttable, but any successful challenge would require compelling evidence of the disadvantages of Haddenham, or the advantages of Winslow. The Reasonable Alternatives SA Report2 indicates no such compelling evidence, and additional study provides further confirmation.
1.6 It follows that Haddenham should be the preferred site for the new settlement in order to satisfy the NPPF requirement of sustainable development.
2 Sustainability Appraisal of the Vale of Aylesbury Local Plan – Reasonable Alternatives: Sites (July 2016)
Page 3 2. Housing need and the Duty to Cooperate
2.1 Housing need in the Vale of Aylesbury
2.1.1 A consultation draft of the Buckinghamshire Housing and Economic Needs Assessment 2015 (HEDNA) was published in January 20163. This presented, in Figure 3 on page 11, the Full Objectively-Assessed Need for Housing (FOAN) across Buckinghamshire for the period 2013–2033. Figures were given for the FOAN for the four constituent districts, as follows:
Aylesbury Vale 21,289 Chiltern 6,602 South Buckinghamshire 7,051 Wycombe 15,011
The total FOAN for the four districts was therefore 49,954, with Wycombe having a FOAN greater than the combined total for Chiltern and South Buckinghamshire.
2.1.2 Paragraphs 178–181 of the National Planning Policy Framework (NPPF) are in a section entitled Planning strategically across local boundaries. Paragraph 179 states, in part, … Joint working should enable local planning authorities to work together to meet development requirements which cannot wholly be met within their own areas – for instance, because of a lack of physical capacity or because to do so would cause significant harm to the principles and policies of this Framework. […]
2.1.3 The draft Vale of Aylesbury Local Plan (VALP), published for consultation in July 2016, makes provision for meeting such requirements. Chapter 1 of the VALP is entitled Background, and paragraphs 1.10–1.13 form a section entitled Duty to cooperate. Paragraph 1.12, referring to the other councils in Buckinghamshire, states Comparing the land available for development in each districts plan area against the forecast need for that development shows that the capacity for development in the areas to the south of the district does not match the need for development. This is primarily because of the constraint of the Green Belt and an Area of Outstanding Natural Beauty (AONB). (Emphasis added.) Paragraph 1.13 then states The councils to the south of Aylesbury Vale district have identified an estimated collective unmet need of 12,000 homes. If sufficient suitable and deliverable sites can be found to meet this need, the housing requirement for the district will total about 33,300 homes. The council will be robustly challenging the level of unmet need, but this draft local plan has to based on this requirement as a worst case scenario. (Emphasis added.) Furthermore, Chapter 3 of the VALP is entitled Strategic, and paragraph 3.11 states, in part,
3 This superseded the Central Buckinghamshire HEDNA, published in October 2015, by regarding the whole of Buckinghamshire as a single best-fit housing market area.
Page 4 […] At present we are estimating a figure of 12,000 to meet unmet needs from Wycombe, Chiltern and South Bucks. [...]
2.1.4 VALP Policy S2 Spatial strategy for growth states, in part, The Vale of Aylesbury Local Plan will make provision for the delivery of the following in the period to 2033: • A total of 33,300 (this is subject to a decision on unmet needs) homes to be provided in accordance with the spatial distribution set out below and in Table 1. • […] Table 1 sets out a strategy for the delivery of 34,910 new dwellings over the plan period, slightly exceeding the target. This total includes 4,500 new dwellings in the proposed new settlement.
2.1.5 It is clear that, if the housing need for the VALP had been restricted to the FOAN for Aylesbury Vale, there would have been no need for a new settlement at all, and in addition the growth planned for existing settlements could have been reduced by a substantial margin. The need for a new settlement arises from the duty to cooperate with other councils to the south of Aylesbury Vale.
2.2 Advice from the NPPF regarding location
2.2.1 Chapter 4 of the draft VALP is entitled Strategic delivery, and paragraphs 4.27–4.43 form a section entitled Delivering a new settlement. Reference is made to a scoping study4 (provided as supporting evidence to the VALP) which considered twelve possible sites and produced a final shortlist of two options, at Haddenham and at Winslow.
2.2.2 VALP paragraph 4.35 states Both of the shortlisted options provide suitable locations for a new settlement based on current information. None of the other sites appraised are considered to perform as strongly as the two shortlisted options in terms of overall suitability. At present it seems that the site at Haddenham is marginally preferable to the site at Winslow because it already has a railway station with a good service, including to London, whereas the station and railway service at Winslow are not in place yet. In addition to this consideration Haddenham is close to the higher-order services provided by Thame, is closer to a range of employment location and to the motorway network than Winslow. Another consideration is that Haddenham is closer to the source of unmet housing need which the Vale has to try to accommodate (unmet needs are coming from Districts to the south of Aylesbury Vale). (Emphasis added.)
2.2.3 Great Horwood Parish Council contend that the highlighted sentence from VALP paragraph 4.35, presented as merely “another consideration”, must be given very substantial weight in order to conform with Government policy. Paragraph 180 of the NPPF, part of the section entitled Planning strategically across local boundaries, states in part
4 Aylesbury Vale - New Settlement Study Scoping Study (June 2016)
Page 5 Local planning authorities should take account of different geographic areas, including travel-to-work areas. It will be demonstrated that this requirement in NPPF paragraph 180 strongly indicates a preference for Haddenham over Winslow.
2.3 Housing market areas and travel-to-work areas
2.3.1 Figure 6 on page 19 of the Buckinghamshire HEDNA is entitled Functional housing and economic market areas for Buckinghamshire and the surrounding area. The left-hand map in Figure 6, reproduced here, shows the functional housing market areas (HMAs) covering Buckinghamshire. These are different from best-fit HMAs, where boundaries are adjusted to match those of local authorities, and take direct account of matters such as travel-to-work areas and market signals.
It may be seen from this map that all of Wycombe and Chiltern districts, together with the northern part of South Buckinghamshire district, are in the same purple-coloured functional HMA as the central and south-eastern part of Aylesbury Vale. Haddenham, to the north-east of Thame, is just within this HMA and is close to Wycombe district. However Winslow is outside this HMA (it
Page 6 is within the green-coloured functional HMA containing Milton Keynes) and is a significant distance from Wycombe, Chiltern and South Buckinghamshire districts.
2.3.2 The analysis of functional HMAs in Buckinghamshire was carried out in a report published in March 2015 (HMA Report)5; Figure 6 of the Buckinghamshire HEDNA is a repeat of Figure 1 of the HMA report, and was informed by a study of travel-to-work areas (TTWAs).
2.3.3 Chapter 3 of the HMA Report is entitled Analysing Commuting Patterns, and this Chapter contains several maps (Figures 18–19 and 22–23) showing TTWAs assessed on the basis of a range of containment thresholds and with various assumptions concerning the growth of London. All of these maps show Winslow in the same TTWA as Milton Keynes. Winslow is not in the same TTWA as any of the districts south of Aylesbury Vale (nor, indeed, is it in the same TTWA as Aylesbury Town).
2.3.4 On the other hand, Haddenham is in the same TTWA as the majority of Wycombe district in Figure 18 map 4 (67% containment), Figure 19 map 4 (70% containment with restricted growth of Central London), Figure 22 (75% containment with restricted growth of Central London) and Figure 23 maps 2, 3 and 4 (72%, 74% and 78% containment with restricted growth of the London region excluding Greater London). It should be noted that a containment threshold of 67% is the minimum threshold for ONS travel to work areas (HMA report, paragraph 3.7) and that only one of the thirteen TTWA maps in these four figures with a containment threshold of 67% or more (Figure 23 map 1) places Haddenham in a different TTWA from that containing Wycombe district. For policy-making purposes one must therefore assume that Haddenham is in the same TTWA as Wycombe district.
2.3.5 On a more anecdotal level, one might note the following claim from the New Wycombe District Local Plan (Consultation version, June 2016) in Policy CP4 item 2: the unmet element of the District’s housing need (around 5,000 homes) to be met in Aylesbury Vale District; The quoted figure of 5,000 has not been agreed by AVDC, and may well be reduced. Nevertheless a new settlement near Haddenham delivering 4,500 dwellings over the plan period would be well- placed to support the unmet need of Wycombe District, at whatever level that might be. The Chiltern Railways timetable6 indicates that travelling by train from Haddenham and Thame Parkway to High Wycombe takes between 14 and 19 minutes, depending on the number of intermediate stops, with a daily service of two trains per hour and some extra trains at rush hours.
2.3.6 In contrast, Winslow does not at present have a railway station. There are plans to reopen the disused railway line through Winslow (“East-West Rail”) with Winslow station reopening in 2019; but funding issues at Network Rail suggest that a more realistic date would be 2022. The initial service through Winslow is likely to be from Milton Keynes or Bedford to Oxford (at two trains per hour). The spur from Winslow to Aylesbury is also planned to reopen some time after 2022, with one train per hour from Milton Keynes to London Marylebone via Aylesbury and High Wycombe, but the main route to Oxford will have a higher priority as it will be part of a strategic
5 Housing Market Areas and Functional Economic Market Areas in Buckinghamshire and the Surrounding Areas, March 2015 6 Chiltern Railways, Summer and Autumn Train Times, 15 May to 10 December 2016
Page 7 freight spine, taking traffic from the West Coast Main Line through to Oxford, Reading and then Southampton. The existing journey from Aylesbury to High Wycombe typically takes 38 minutes, so even with track realignment the journey from Winslow to High Wycombe is unlikely to take much less than three-quarters of an hour.
2.3.7 It is clear from this that, in terms of an impartial “view from space”, the choice between Haddenham and Winslow for a new settlement whose need arises from unmet demand from the south of Aylesbury Vale is quite obvious. It therefore follows that, unless other considerations are overwhelming, the advice in NPPF paragraph 180 is that the new settlement should be sited near Haddenham.
Page 8 3. Other considerations
3.1 The draft VALP Sustainability Appraisal
3.1.1 The July 2016 Sustainability Appraisal (cited earlier) contains in Chapter 4 an assessment of the two shortlisted sites for a new settlement. The assessment is carried out according to the SA Framework tabulated in Appendix A of the Appraisal. That Framework does not consider the source of the housing need justifying the new settlement.
3.1.2 A summary of the assessment matrices for the three options on each of the two sites may be found in Table 5.2 (incorrectly labelled Table 5.1) on page 128 of the assessment. Standard symbols and colour coding are used: −− moderate adverse − minor adverse +/− uncertain 0 negligible/no effect/not applicable + minor positive ++ moderate positive
3.1.3 As stated in paragraph 2.2.8 of the Appraisal […] The matrix is not a conclusive tool. Its main function is to show visually whether or not the proposed options are likely to bring positive, adverse or uncertain effects in relation to the SA Objectives and the magnitude of these effects. The matrices may nevertheless be used to see whether there are any material considerations sufficiently compelling to overcome the strong presumption in favour of siting the new settlement at Haddenham in accordance with NPPF paragraph 180, as described above.
3.1.4 The relevant options for comparison are Haddenham Option 2 (new garden village) versus Winslow Option 3 (new garden village), and Haddenham Option 3 (western expansion) versus Winslow Option 2 (northern expansion). For each site Option 1 is only a small expansion and would not qualify as a new settlement.
3.1.5 The following table shows the two comparisons, giving the numbers of each symbol for each option.
−− − +/− 0 + ++ Haddenham Option 2 5 3 1 2 0 1 Winslow Option 3 5 3 2 1 0 1 Haddenham Option 3 2 2 2 4 1 1 Winslow Option 2 5 3 2 1 0 1
It may be seen that there is essentially no difference between the two sites for the garden village option, and that an expansion of Haddenham is marginally preferable to any of the other options.
Page 9 3.2 Other relevant matters
3.2.1 The site north of Winslow shortlisted in the draft VALP as a possible site for a new settlement has a planning history, and documents relating to this history may also be used to inform the present assessment.
3.2.2 An application for outline planning permission for a development of 3,300 dwellings on a site of around 270 ha north of Winslow was submitted to AVDC in December 2008, with reference 08/02944/AOP, and was known as “Winslow Green”. This would have been a development on a site essentially the same as the one shortlisted for a new settlement at Winslow in the draft VALP, although with significantly fewer residential dwellings. Permission for this development was refused by committee decision on 1 April 2009.
3.2.3 The development site is commonly known as the “Airfield Site” because Little Horwood Airfield was operational on part of the site during the Second World War. However, according to paragraph 8.45 of the Winslow Green Environmental Statement (WGES) The majority of the site comprises farmland in active agricultural use, either as arable or semi improved grassland [...] Indeed the airfield, which had been opened in 1942, ceased operations in January 1946 and most of it reverted to farmland. Only a small part of the site could reasonably be described as previously developed land.
3.2.5 The Winslow Green proposal included 138 ha of open space and recreational facilities consisting of sports pitches, country park and parkland, native reserve and play areas7. Thus just over 50% of the site would have been open, compared with 40% proposed for the new settlement. However Winslow Green proposed development of 3,300 dwellings at an average density of 35dph, taking up around 95 ha, whereas the New Settlement Scoping Report envisages an eventual capacity of 6,000 dwellings8 at the same density, taking up around 170 ha. As 60% of 270 ha is 162 ha, it seems that the authors of the Scoping Report have used up all the developable area for housing and have forgotten to allow for items such as employment9, retail space, schools, health centre, community facilities, or indeed a cemetery – all needed, as the draft VALP states in paragraph 4.42 “the development will provide a balanced mix of facilities”.
3.2.6 It is evident that the concept of a standard-density 6,000 dwelling new settlement on the Airfield site is illusory. The only ways such a total could be achieved would be by a significant increase in the density of the residential development, or by including other land to the east or to the west – there is no land available to the north, because Great Horwood village is in the way10.
3.2.7 There are other problems with creating a substantial development on the Airfield site. The stream known as the Washbrook runs across the south of the site, and delineates the parish boundary between Winslow on the one hand, and Great Horwood or Little Horwood on the other.
7 Committee Report on application 08/02944/AOP (CR), page 4 8 Appendix C of the Scoping Report; 4,500 dwellings would be provided during the plan period 9 The north-west corner of the site is an existing employment site (Greenway Business Park) 10 The field immediately to the north of Horwood Mill is the Great Horwood Reacreation Ground Horwode Pece
Page 10 As may be seen from the Great Horwood Environmental Constraints map (attached as Appendix A) the stream is associated with a flood plain with a typical width of 100m. This is noted in WGES paragraph 16.34: An area in the south of the site (adjacent to the unnamed [sic] stream) is recorded as being an area that is prone to flooding from rivers without defences. The Winslow Green proposal was not, however, successful in persuading AVDC that the flood risk from its proposal could be managed adequately, as indicated in Reason for Refusal 11: The submitted Flood Risk Assessment fails to demonstrate that flood risk from increases in surface water run-off and wastewater can be effectively managed without detriment within the site or surrounding area. The proposals therefore do not provide a suitable basis for flood risk and are contrary to the advice in PPS25. Although PPS25 was superseded by PPG7 in March 2014, it is unclear how the flood risk from a substantially larger development would satisfy the updated guidance.
3.2.8 Evidence concerning the need for a new link road from any substantial development on the Airfield site to the A421 was presented in the previous representation from Great Horwood Parish Council (cited earlier). It should also be noted that page 11 of the Committee Report on Winslow Green stated […] Predicted traffic generations are considered to be an underestimate, and the Highway Authority has concerns about the potential for a wide adverse impact on the surrounding highway network and surrounding sensitive villages. There are also concerns that traffic operations within and surrounding the development will be significantly more congested than is suggested. This will have an impact on junction operation overall. […] As submitted, the Highway Authority recommend refusal of the application. Note that this was for a development of 3,300 dwellings rather than 6,000, and that the proposal included a link road.
3.2.9 Looking more to the future, the Strategic Study into the Oxford to Cambridge Expressway will suggest, this autumn, a number of route options for a new road between the two university cities, and one option (arguably the most direct) is likely to run close to the East West Rail route. Such a road would improve the east-west connectivity of any new settlement on the Airfield site, but would not affect the north-south connectivity and so would not affect the arguments in Section 2 about, for example, travel-to-work areas. On the other hand, such a road would necessarily pass through the Airfield site and so further reduce the amount of land available for development. In any event, the present status of the Expressway is that it is a proposal with no firm timescale or funding commitment for construction; the precautionary principle suggests that possible benefits be discounted at this stage, and that cognizance be taken of a possible need for land provision from the Airfield site.
3.2.10 The final comment from Great Horwood Parish Council relates to the Landscape and Visual Assessment produced for the Winslow Green proposal. As might be expected in an LVIA produced for a developer, this contains various photomontage images giving wide-angle views intended to place the proposal in the best possible light. The Parish Council wish to draw attention to the map in Appendix 8.6 entitled Site Landscape and Visual Analysis” which indicates a main view to the Airfield site from Little Horwood Road (running out of Great Horwood to the east) “limited by
Page 11 height of roadside hedgerow”. It is significant that Great Horwood is a north Buckinghamshire ridge-top village, and that Little Horwood Road runs along this ridge. The photomontage labelled “View 1” in Appendix 8.8 shows this view from the ridge, looking down onto the Airfield site from the north. One of the features indicated in this image is “Pylon to be removed”; this pylon is part of the 132kV electricity transmission line that passes along the south of the airfield site, the far side of the site from the viewpoint. It is clear that the development of a new settlement on the Airfield site would have an effect on this public view that can only be described as Major Adverse, and that the magnitude of the effect is a specific consequence of the topography of the site and the adjacent land.
3.3 Conclusions
3.3.1 Given the choice of two locations, Haddenham and Winslow, for a new settlement of 4,500 dwellings in the VALP plan period with an expected expansion to 6,000 dwellings, Great Horwood Parish Council believe firmly that the evidence in favour of Haddenham is overwhelming. The site at Winslow is too far from the source of the additional housing need, and is in a different functional housing market area and a different travel-to-work area from the source of that need, so that national policy argues against the choice of Winslow. The Sustainability Appraisal prepared for the draft VALP, using a methodology considering effects rather than need, found little difference between the two sites with a marginal benefit for one of the Haddenham options. The proposed site at Winslow is in fact too small for the development requirement, and there are further specific disadvantages concerning flood risk, highways, and visual impact. While some further development to the north of Winslow will be expected over time, both as part of the town's natural expansion and as part of the Government's policy for development of the “Brain Belt” between Didcot and Cambridge, this specific proposal cannot be regarded as feasible.
Page 12 Great Horwood Environmental Constraints
Great Horwood CP
Key
Parishes TPO 0 100200 400 600 800 1,000 1,200 Flood Plain Areas Suseptible to Surface Water Flooding Metres Ancient Woodland This map is based upon Ordnance Survey material with the permission of Ordnance Survey on behalf of the Controller of Her Majesty's Stationery Office. ´ % Notable Species © Crown copyright. Local Wildlife Sites Unauthorised reproduction infringes Crown copyright and may lead to prosecution or civil proceedings. Aylesbury Vale District Council 100019797 2010 1:18,000 Biological Notification Sites Vale of Aylesbury Local Plan New Settlement Study Consultation July – September 2016
Comments from Great Horwood Parish Council on the traffic effect in Great Horwood of a possible new settlement north of Winslow Introduction
These comments are in response to the Draft Vale of Aylesbury Local Plan Consultation (July to September 2016), where comments are requested on the new evidence documents published in support of the draft plan.
The comments in this document address a specific point: if there is a new settlement north of Winslow, what effect will there be on Great Horwood in terms of traffic, and how might this be mitigated?
These comments are presented without prejudice to the general view of the Parish Council on the New Settlement Study and, in particular, to the appropriateness of a new settlement north of Winslow. This more general view will form part of the Parish Council's response to the overall Draft VALP consultation.
Contents
1. The 2008 proposal for “Winslow Green”
2. Access to a new settlement at Winslow
2.1 With a new road to the A421
2.2 Without a new road: traffic flows north
2.3 Without a new road: Little Horwood Road through Great Horwood
2.4 Without a new road: B4033 Nash Road / Little Horwood Road junction
2.5 Without a new road: Little Horwood Road / Church Street junction and onwards
3. Conclusions
Page 2 1. The 2008 proposal for “Winslow Green”
1.1 At the end of 2008 an application for outline planning permission was submitted to AVDC with reference 08/02944/AOP, and was validated on 29 December 2008. This was an application for the Construction of mixed use development to provide a sustainable extension to Winslow comprising 3300 new dwellings (including affordable); open space and recreation facilities (including sports pitches, country park, nature reserve and play area); employment land (up to 68,000 sq metres of office space) retail floor space (up to 3500 sq metres) and supermarket (3000 sq metres); hotel; education facilities (1 secondary, 3 primary and 3 nursery schools); community facilities (including community centre, creche, GP centre, PACE facility, library and allotments) cemetery; railway station and bus interchange (including parking); relief road with landscaping; Sustainable Urban Drainage Scheme; drainage attenuation lakes; and Sewage Treatment Works | Former Little Horwood Airfield And Adjacent Land To The North Of Winslow Winslow Road Great Horwood Buckinghamshire MK17 0NY on a site of 270.2 ha (area taken from the application form1) at Former Little Horwood Airfield and adjacent land to the North of Winslow, Winslow Road, Great Horwood MK17 0NY.
1.2 Although the application was refused by committee decision dated 1 April 2009, the details of the proposal and its supporting evidence may be used to illuminate the VALP new settlement options of a development to the north of Winslow, with either Option 2 “Northern expansion” or Option 3 “New garden village” proposing 6000 new dwellings on the Airfield site. Either new proposal would provide 80% more housing than that proposed in 2008.
1.3 As a passing comment, one should note that the capacity calculations for Options 2 and 3 are claimed to be based on keeping 40% of the site area for open space, drainage, etc. and a density of 35dph, which would give 5670 dwellings. However the indicative splodge on the map for Option 3 in the Winslow Options Assessment document is rather smaller than the 270 ha of the earlier proposal as it is entirely to the north of the Washbrook stream.
1.3 Of particular interest is the Transport Assessment2 submitted in 2008. This states, in paragraph 10.3 in the Summary and Conclusions, The existing road network immediately adjacent to the site includes the B4033 Great Horwood Road to the west, the Little Horwood – Winslow Road to the east and Little Horwood Road to the north. These roads are typical country roads which do not conform to current highway standards. The mothballed Oxford – Bedford railway line provides a southern boundary to the site. and in paragraph 10.4 The proposals include a new development road which will provide the sole allpurpose vehicular route to the development. This road will run from the east of Winslow, along part of the existing Little Horwood – Winslow Road, through the development to the improved 1 Document reference 843001 in the AVDC public access database 2 Document reference 843151
Page 3 A421 / B4033 roundabout, north of Great Horwood, providing relief to Winslow from through traffic travelling between Aylesbury and Buckingham. Traffic from Winslow Green will be discouraged from travelling through Winslow and the Horwoods via the provision of this more direct route to Aylesbury, Buckingham and Milton Keynes.
1.4 A plan of the proposed development road may be found in the Appendices to the Transport Assessment3, in drawing CS-18246-RD-400. This shows that the access road was planned to leave the north of the development, crossing Little Horwood Road at a new roundabout, and finishing at an improved A421/B4033 roundabout.
1.5 The rationale for the development road was given in the Transport Assessment at paragraph 10.11 This TA demonstrates that the Winslow Green development proposals have been considered in such a way so as to offer significant safety and capacity enhancements to the transportation network (walking, cycling, public transport and road) for residents of Winslow, and the Horwoods, whilst ensuring that additional vehicular traffic through these locations is minimised. and paragraph 10.12 It is anticipated that 55% of commuter trips out of Winslow Green will be to Milton Keynes; within AVDC, Winslow Green’s proximity to Milton Keynes is particularly compatible with RPG9’s requirement for developments to be “concomitant with Milton Keynes growth needs”.
1.6 The present options are being considered in a context different from that of the earlier proposal (although there are also some similarities – the delivery of East-West Rail was anticipated for 2012 in the 2008 proposal, whereas the current delivery date is not expected to be earlier than 2020). Nevertheless the earlier proposal was supported by detailed traffic modelling, and so a comparison with the access method proposed for the present options will be instructive.
3 Document reference 843165
Page 4 2. Access to a new settlement at Winslow
2.1 With a new road to the A421
2.1.1 Section 5 of the VALP New Settlement Scoping Study considers the potential for strategic growth at Winslow. Paragraphs 5.27 to 5.38 consider the highways implications of a new settlement on the Airfield site.
2.1.2 The Scoping Study makes several references to the possibility of a road linking any proposed new settlement to the A421. From paragraph 5.32: […] We have sought to identify potential mitigation at this junction4 which at least enables it to operate at a level similar to the situation without the development. This has required widening on each arm of the junction, longer flares and modifications to the central island. Given the scale of development planned, consideration would need to be given to providing a new link road connected northwards to the A421, and taking traffic away from Winslow Town Centre and Great Horwood. From paragraph 5.33: […] Signalisation could be considered here5 alongside provision of a new link road connecting Winslow northwards to the A421. Further work will be needed to investigate wider transport impacts beyond these immediate junctions. From paragraph 5.35: Further technical work is clearly needed to consider the potential for provision of a link road which takes traffic away from Winslow Town Centre and connects northwards to the A421. From paragraph 5.36: The strategic need for a western link road which diverts traffic away from Winslow Town Cntre; and for a link nothwards to the A421 to mitigate the impacts of growth on roads through Little Horwood and Great Horwood require further consideration. (Typos in the original.)
2.1.3 The Scoping Study does not, however, take adequate care when considering the implications of failing to build a link road. The rest of this representation provides further information about those implications, and explains why the planning harm of failure to build such a road would be fatal to the proposal.
2.2 Without a new road: traffic flows north
2.2.1 The Winslow Initial Junction Modelling appendix lists initial proposals for seven new or remodelled junctions. This representation is concerned with traffic to the north of any proposed new settlement, and therefore with the following junctions:
4 “This junction” is the A421/B4033 roundabout north of Great Horwood 5 “Here” refers to the B4033 Nash Road / Little Horwood Road junction in Great Horwood
Page 5 1. A421 / B4033 Nash Road 2. B4033 Nash Road / Little Horwood Road 3. Little Horwood Road / New Settlement 4. Little Horwood Road / Church Street / Shucklow Hill 5. B4033 Great Horwood Road / New Settlement
2.2.2 Traffic flow from the new settlement to the A421 would therefore have three possible routes: a) north to junction 3, then left to junction 2, then right (B4033) to junction 1; b) north to junction 3, then right to junction 4, then left to the A421 at one of the two unimproved junctions; c) west to junction 5, then right (B4033) to junction 2, then left (B4033) to junction 1. The existing traffic from Winslow and the A413 would continue to take the B4033 to junction 5, and would then follow route (c) as at present.
2.3 Without a new road: Little Horwood Road through Great Horwood
2.3.1 The Transport Assessment for the 2008 proposal stated, at paragraph 2.30, Little Horwood Road is approximately 1.5 miles long and links the villages of Great Horwood and Little Horwood It has a 30 mph speed limit within Great Horwood and a 60mph limit between Great Horwood and its junction with Shucklow Hill/Church Street.
2.3.2 The present proposal envisages a road leaving the new settlement to the north, and joining Little Horwood Road at a new roundabout (junction 3). This is at almost the same place as the roundabout shown for the 2008 proposal, but without the fourth arm to the north.
2.3.3 The route of Little Horwood Road west of the proposed roundabout is at present in open countryside for the distance of two fields and then enters the village of Great Horwood. The Great Horwood Neighbourhood Plan envisages development on both sides of Little Horwood Road; with this development the road would be in open countryside for the distance of a single field.
2.3.4 Within Great Horwood village there are several side roads off Little Horwood Road, together with parking access for several dwellings. Many of the older dwellings do not have any on-site parking facilities, and so some cars are normally parked in the road. The road is not wide enough to allow two-way traffic where cars are parked, although the current traffic flow is not high enough to result in delays. There are occasions where many more cars are parked in the road, particularly near the junction with B4033 Nash Road, and this can cause delays.
2.3.5 A BCC Highways report for a recent planning application6 advised refusal of permission for a development off one of the side roads. The report noted, with regard to parking in Little Horwood Road, Whilst I recognise that the applicants have suggested that parking restrictions could be introduced in the vicinity of the junction to provide greater confidence that the routing of vehicles will not be affected and that the junction will be unobstructed, I am not satisfied
6 14/02414/AOP Land off Willow Road, report dated 6 June 2016
Page 6 from the information available to me that any parking that would be displaced by the parking restrictions could be accommodated without creating or adding to a problem elsewhere.
2.4 Without a new road: B4033 Nash Road / Little Horwood Road junction
2.4.1 Table 8 in the Scoping Study, considering “Junction modelling results with Mitigation”, observes with respect to this junction A 3arm roundabout although signalization may be preferred Paragraph 5.33 also observes Where mitigation is required to address local impacts, our proposal is for roundabouts which would be more in keeping with the rural nature of the area. This would be particularly difficult at the B4033 Nash Road / Little Horwood Rd junction in the centre of Great Horwood as it would impact upon the village car park.
2.4.2 There are several comments to be made about this. The first is that the “village car park” is a misnomer. The whole of the open area in the centre of Great Horwood is a registered village green under the provisions of the Commons Act 2006, and is available for local people to take part in lawful sports and pastimes. Part of the village green has a hard surface, and cars may be parked there for the benefit of residents and visitors provided that this part of the green is not required for other purposes.
2.4.3 A Summer Fair is held on the village green every year on the Feast of St James, under a charter granted in 1447; for two days in August the Fair vehicles are parked on the hard surface of the green. During this period residents cars are parked in High Street and at the top of Little Horwood Road, causing a significant reduction in the capacity of the latter road. There are also other events held on the green which require the removal of parked cars.
2.4.4 On school days Great Horwood High Street (part of the B4033) is congested in mid-afternoon as parents park their cars along the street, waiting for their children to leave school. If cars are parked partly on the footway then the rest of the carriageway is wide enough for two-way traffic. Part of the time, however, the school bus waits at the bus stop outside the Church, and traffic can pass in only one direction at a time. Similarly, when there are parked cars then traffic containing wide vehicles such as HGVs will be able to pass in only one direction at a time.
2.4.5 There are no alternative parking places in Great Horwood. The increase in traffic taking routes (a) or (c) from any proposed new settlement to the A421 would therefore be likely to result in major congestion in Great Horwood, even with a signal-controlled junction at B4033 Nash Road / Little Horwood Road (and such a junction would be inappropriate in a village setting). A roundabout, even if it were permitted under the provisions of the relevant legislation, would make the congestion significantly worse by increasing on-street parking and thereby reducing the capacity of both Little Horwood Road and High Street.
2.4.6 There have been rare occasions where a significant increase in traffic has been diverted through Great Horwood. Any obstruction to the free movement of traffic on such occasions has
Page 7 resulted in severe congestion, as the following photograph shows.
This photograph was taken in the morning of Saturday 18 June 2016, and shows the view looking south from B4033 Nash Road towards the junction with Little Horwood Road. The increased traffic
Page 8 flow was caused by the closure of the A421 for resurfacing, and the congestion was caused by the A413 / B4033 junction at Winslow, over two miles away (there were no parked cars in the High Street on that day). Although the traffic flow to and from a new settlement would be lower, it would still experience peaks during weekday rush hours which could be comparable with the A421 Saturday morning flow; parked cars or other obstructions would then cause a rapid build-up of congestion.
2.4.7 The use of routes (a) and (c) for traffic between any proposed new settlement would therefore result in unacceptable congestion, even with the mitigation measures suggested.
2.5 Without a new road: Little Horwood Road / Church Street junction and onwards
2.5.1 Traffic leaving any proposed new settlement to the north, and arriving at the roundabout at junction 3 on Little Horwood Road, could turn right towards Little Horwood on route (b) instead of turning left to Great Horwood on route (a). It would then arrive at junction 4.
2.5.2 The suggested improvement to junction 4 comprises a right-turn filter lane for traffic arriving from Little Horwood Road. This would be of benefit for traffic turning along Church Street towards Little Horwood and then, in the village, turning left towards Mursley. It would not benefit traffic continuing through Little Horwood towards Winslow, as such traffic could more easily reach its destination by leaving the new settlement to the east and joining Winslow Road at junction 6.
2.5.3 Most of the traffic arriving at junction 4 from Little Horwood Road would be avoiding the congestion in Great Horwood and would turn left up Shucklow Hill. It would then arrive at the A421 at one of the two unimproved junctions.
2.5.4 In the other direction, traffic from the A421 coming down Shucklow Hill and wishing to turn right at junction 4 into Little Horwood Road would still have an awkward turn with poor visibility. It is not clear that the model being used by the authors of the Study has captured the nature of the problem at this junction.
3. Conclusions
3.1 The promoters of the 2008 application were clear that, if their application were to succeed, then a new link road would be needed to take traffic from Winslow Green to the A421.
3.2 The current options for a new settlement north of Winslow are significantly larger than the 2008 proposal. The authors of the Study note that a new link road would be beneficial, but shy away from recommending it. For the reasons given above, Great Horwood Parish Council believes that the Study has seriously underestimated the problems that would arise without such a link road. Without prejudice to the Parish Council's general view on the appropriateness of a new settlement north of Winslow, it believes that any such development without a link road would be unacceptable.
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