Vale of Aylesbury Local Plan Examination

Further Written Statement submitted on behalf of Gallagher Estates Limited (32326)

June 2018

Vale of Aylesbury Local Plan Examination

Further Written Statement submitted on behalf of Gallagher Estates Limited (32326)

Project Ref: 20704/P12/A5 20704/P12a/A5

Status: Draft Final

Issue/Rev: - a Date: 16th June 2018 19th June 2018

Prepared by: Michael Knott / Emily Ford Michael Knott / Emily Ford

Checked by: Michael Knott Michael Knott Authorised by: Michael Knott Michael Knott

The Blade Abbey Square Reading Berkshire. RG1 3BE

Tel: 0118 943 0000 Ref: 20704/P12a/A5/MK/dw Fax: 0118 943 0001 Email: [email protected] Date: 19th June 2018

COPYRIGHT

The contents of this document must not be copied or reproduced in whole or in part without the written consent of Barton Willmore LLP.

All Barton Willmore stationery is produced using recycled or FSC paper and vegetable oil based inks.

CONTENTS

1.0 Introduction 1

2.0 Response to Main Matter 16 (Policy NE5) 2

APPENDICES

1 - Suggested Main Modifications to Policy NE5

2 - Landscape and Visual Statement (Barton Willmore; June 2018)

3 - Sustainability Appraisal Review (Barton Willmore, June 2018)

Vale of Aylesbury Local Plan Examination Introduction Gallagher Estates (32326)

1.0 INTRODUCTION

1.1 This written statement is submitted on behalf of Gallagher Estates Limited in response to Matter 16.w relating to Policy NE5 of the Vale of Aylesbury Local Plan (VALP).

1.2 This statement supplements the representations we submitted at the regulation 19 consultation stage on behalf of Gallagher Estates, relating to Land at Eaton Leys, , an omission site located on the northern edge of Aylesbury Vale District. Immediately to the north of the site is land within Milton Keynes, also controlled by Gallagher Estates which benefits from outline planning permission for up to 600 dwellings, a local centre, primary school and public open space (MKC ref: 15/01533/OUTEIS).

1.3 The site is identified in the VALP as forming part of the Brickhills Area of Attractive Landscape (AAL). Our previously made representations, and the information presented in this statement which supplements them, explains why the site’s inclusion within the AAL is unsound, taking account of the Council’s evidence base and our assessment; and why Policy NE5 as drafted is considered to be unsound, having regard to the national policy and the relevant supporting text set out in the VALP.

1.4 We look forward to participating in the examination hearings and assisting the Inspector with his assessment of the plan’s soundness and legal compliance.

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2.0 MAIN MATTER 16.w Policy NE5

2.1 This statement seeks to provide the Inspector with a succinct summary of our main points against the draft agenda which was circulated by the programme officer on 9th June 2018. It is understood that the agenda implicitly allows for consideration of main modifications to the wording of Policy NE5 to be discussed at the hearing and suggested modifications to the policy are set out in Appendix 1 of this statement.

Have I correctly understood the thrust of the representations?

2.2 The Inspector’s ‘summary of issues’ (dated 5th June 2018) provides a reasonable summary of the main issues and matters for discussion. We have written separately to the programme officer to advise of additional issues which we consider to be of particular relevance. These are:

• The weight to be attached to the Strategic Landscape and Visual Capacity Study (August 2017) prepared by Bradley Murphy Design Ltd. for the Council (which we address under item 5. below); and • Suggested modifications to Policy NE5, if retained (which we address under item 2. below).

2) Compliance with NPPF paragraph 113

2.3 As stated in our representations submitted at Regulation 19 stage, we consider the wording of Policy NE5 to be inconsistent with paragraph 113 of the NPPF. We do not repeat these objections. Notwithstanding this in principle objection, in seeking to assist the Inspector’s assessment in respect of Policy NE5, we have set out our suggested modifications to the wording of the policy and supporting text at Appendix 1, should the Inspector conclude that the designation of AALs and Local Landscape Areas (LLAs) is sound.

2.4 The representations which were submitted on behalf of Gallagher Estates at the Regulation 19 consultation stage and the information presented in this further written statement provides the supporting justification for the suggested modifications to Policy NE5.

20704/P12a/A5/MK/dw Page 2 June 2018 Vale of Aylesbury Local Plan Examination Main Matter 16.w: Policy NE5 Gallagher Estates (32326)

2.5 Notwithstanding our in principle objection to the designations of AALs (and LLAs) through Policy NE5, the NPPF requires plans to provide a ‘practical framework within which decisions on planning applications can be made with a high degree of predictability and efficiency’ (Paragraph 17; first bullet).

3) Recognition of degrees of harm

2.6 Policy NE5 fails to recognise that development will inevitably result in some change to character; that change can also retain important views to a sufficient degree; that important views are not defined; and that the hierarchy of local landscape designations is not justified in the policy.

2.7 As stated above, we have put forward suggested modifications to the wording of Policy NE5 (Appendix 1) which seek to address this soundness issue, but not the other soundness issues associated with the extent of the Brickhills AAL, as set out in our Regulation 19 stage representations and in this statement including the Landscape and Visual Statement at Appendix 2.

4) Land Use Consultants’ advice and 5) Adequacy of technical evidence

2.8 The Landscape and Visual Statement provided at Appendix 2 of this statement sets out our analysis of LUC’s advice and the adequacy of technical evidence relevant to Policy NE5.

2.9 We do not repeat the detailed assessment presented in the Landscape and Visual Statement. However, based upon its conclusions, we find that the VALP fails to meet the tests set out in paragraphs 158 and 165 of the NPPF, that planning policies and decisions should be based on “adequate”, “up-to-date” and “relevant” evidence.

2.10 For all of the reasons we set out, Policy NE5 and the principle of the proposed AAL designations, and particularly the inclusion of Eaton Leys within the proposed Brickhills AAL, is unsound.

2.11 To resolve the soundness issues raised, Policy NE5 and the AAL designations should be deleted. Alternatively, the boundaries of the Brickhills AAL should be redrawn to exclude Land at Eaton Leys.

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6) Need for criterion of visual coalescence

2.12 We have no comments on this issue.

20704/P12a/A5/MK/dw Page 4 June 2018

Appendix 1

Suggested Main Modifications to Policy NE5

Landscape character and locally important landscape

9.26 All the landscape in the district is considered to have character and particular distinctive features to be conserved, positive characteristics to be enhanced and detracting features to be mitigated or removed. The 2008 landscape character assessment (LCA) is the primary evidence base which divides the entire landscape (beyond towns and Areas of Outstanding Natural Beauty) into landscape character areas and landscape character types. The assessment sets out landscape conservation guidelines for each landscape character area. Therefore all the landscape in the district is considered to can have innate ‘value’ as referred to in the National Policy Planning Framework (NPPF)40. That said, of the locally significant designated landscape, the areas of attractive landscape (AALs) are of the greatest significance followed by the local landscape areas (LLAs).

9.27 In early 2015, AVDC engaged the consultants Land Use Consultants (LUC) to review the 2008 LCA, update it in light of major developments since 2008, and consider its conformity with the NPPF. The evidence base was considered by the Council to be a valid basis to develop a policy approach and a specific policy approach was recommended to note landscape character across the district and special qualities and differences between character areas and character types.

9.28 Areas of attractive landscape (AALs) were first designated in the County Structure Plan 1979 and in successive plans through to the Aylesbury Vale District Local Plan (AVDLP) (2004). Local landscape areas (LLAs) were designated by AVDC in the 1990s and carried forward into AVDLP in 2004. Neither of these designations are seeking to resist development in principle., unless When preparing and determining planning applications for development, regard has not been should be given to distinctive features and key characteristics of the AALs and LLAs.

9.29 LUC carried out a criteria-based assessment of all AALs and LLAs, applying a nationally- accepted methodology to what influences landscape value. This evidence base ‘defining the special qualities of local landscape designations in Aylesbury Vale District’ has been published as a final report following stakeholder engagement in August 2015 and public engagement in October-December 2015. A final report was completed in March 2016. The report states at paragraph 2.12:

9.29a ‘There may be areas within a designated landscape that are of less value, as well as areas outside of the defined AALs and LLAs that are of greater value.’

9.29b The study report concludes at paragraph 4.2:

9.30 ‘Most of the areas of attractive landscape (AALs) have stronger special qualities and are relatively higher in landscape value in comparison to the local landscape areas (LLAs), which are generally smaller scale locally valued features. The LLAs generally do not contain so many nationally significant natural or cultural designations, and they are typically less memorable or distinctive than the AALs. It may therefore be useful to retain the hierarchy of AALs and LLAs in order to distinguish the most valued landscapes from those that are not so greatly valued although still considered worthy of designation.’

9.31 AVDC has accepted the recommendations of LUC on which AALs and LLAs have the greater value (following criteria based assessment of each sub area) and together with the support for locally designated landscapes received in response to the VALP Issues and Options consultation, designate new AALs and LLAs. AVDC has also accepted the recommendations of the LUC Addendum on ‘Defining the special qualities of local landscape designations in Aylesbury Vale District’ (February 2018) that notwithstanding the nationally designated landscape (AONB) and locally designated landscapes in the VALP, non-designated landscapes can also be considered valued for the purposes of Paragraph 109 of the NPPF.

9.31a When determining planning applications for development within the AALs and LLAs, the protection afforded to them will be commensurate with their status in accordance with Paragraph 113 of the NPPF.

9.32 AVDC intends to review the 2008 LCA to take place relatively early in the VALP plan period. The LUC study of 20165 did not include primary on-site fieldwork and did not review the AAL and LLA boundaries.

40 paragraph 109.

NE5 Landscape character and locally important landscape

To ensure that the district’s landscape character is maintained, development must have regard to the 2008 LCA (as amended 2015 and any future review). Development must recognise the individual character and distinctiveness of particular landscape character areas set out in the 2008 LCA (as amended) and any future assessment, their sensitivity to change and contribution to a sense of place. Development should consider the role of the landscape character area and meet consider all of the following criteria:

a. be grouped where possible with existing buildings to minimise impact on visual amenity b. be located to avoid the loss of retain important on-site views and off-site views towards important landscape features, where they exist c. reflect respect local character and distinctiveness in terms of settlement form and field pattern, topography and ecological value d. Carefully consider spacing, height, scale, plot shape and size, elevations, roofline and pitch, overall colour palette, texture and boundary treatment (walls, hedges, fences and gates) e. minimise the impact of lighting to avoid blurring the distinction between urban and rural areas, and in areas which are intrinsically dark and to avoid light pollution to the night sky f. ensure that the buildings and any outdoor storage and parking areas are the development is not visually prominent in the landscape g. not generate an unacceptable level and/or frequency of noise in areas relatively undisturbed by noise and valued for their recreational or amenity value

The first stage in mitigating impact is to avoid the any identified harmful significant adverse impact where possible. Where it is accepted there will be harm to the landscape character, specific on-site mitigation will be required to minimise that harm and, as a last resort, compensation willmay be appropriaterequired as part of a planning application. This reflects the mitigation hierarchy set out in paragraph 152 of the NPPF. Applicants must consider the enhancement opportunities identified in the LCA and how they apply to a specific site.

The Policies Map defines areas of attractive landscape (AALs) and local landscape areas (LLAs) which have particular landscape features and qualities considered appropriate for particular conservation and enhancement opportunities. Of the two categories, the AALsareas of attractive landscape have the greater significance. Development in AALs and LLAs should have particular regard to the character identified in the report ‘Defining the special qualities of local landscape designations in Aylesbury Vale District’ (Final Report, 2016) and the LCA (2008). Development that significantly adversely affects this character will not be permitted unless appropriate mitigation can be secured. Where permission is granted, the Council will require conditions to best ensuresecure the provision of mitigation of any significant harm caused to the landscape.

Appendix 2

Landscape and Visual Statement (Barton Willmore; June 2018)

Eaton Leys, Milton Keynes: Landscape and Visual Statement, in response to Matter 16.w Policy NE5

Prepared on behalf of Gallagher Estates Ltd

June 2018

Eaton Leys, Milton Keynes: Landscape and Visual Statement, in response to Matter 16.w Policy NE5

Prepared on behalf of Gallagher Estates Ltd

Project Ref: 20704

Status: Final

Issue/ Rev: 3

Date: June 2018

Prepared by: PC

Checked by: MC

Authorised by: MC

Barton Willmore LLP 7 Soho Square London W1D 3QB

Tel: 020 7446 6888 Fax: 020 7446 6889 Email: [email protected]

COPYRIGHT

The contents of this document must not be copied or reproduced in whole or in part without the written consent of Barton Willmore LLP.

All Barton Willmore stationery is produced using recycled or FSC paper and vegetation oil-based inks.

CONTENTS

1.0 Introduction ...... 1

2.0 Draft Policy NE5 - Landscape and Visual Commentary ...... 2

3.0 Consideration of AAL designation in the vicinity of the Site ...... 3

4.0 Summary and Conclusion ...... 11

Appendix L1 ...... 13

Appendix L2 ...... 15

ILLUSTRATIVE MATERIAL

Figure 1: Visual Corridor Concept

Figures H1-H9: Historic Mapping (bound separately)

Landscape and Visual Statement Introduction

1.0 INTRODUCTION

1.1 This Landscape and Visual Statement (LVS) has been prepared on behalf of Gallagher Estates to provide consideration of landscape and visual matters relevant to land at Eaton Leys ('the Site'), which lies to the west of the A4146 Fenny Stratford/Water Eaton by-pass, on the south- eastern edge of Milton Keynes.

1.2 The LVS has been prepared as an appendix to the Further Written Statement on behalf of Gallagher Estates in response to Matter 16.w Policy NE5, pertaining to the Examination in Public (EIP) of the Vale of Aylesbury Local Plan (VALP).

1.3 The LVS provides additional detail to the points set out in the Response to the Proposed Submission Vale of Aylesbury Local Plan 2013-2033 (December 2017) submitted by Barton Willmore on behalf of Gallagher Estates.

1.4 This LVS considers first the Draft Policy NE5, as included in the draft VALP. The LVS then considers the application of the Area of Attractive Landscape (AAL) designation to the Site. Finally, the LVS includes a summary of these considerations and conclusions arising.

20704 1 June 2018 Landscape and Visual Statement Draft Policy NE5 - Landscape and Visual Commentary

2.0 DRAFT POLICY NE5 - LANDSCAPE AND VISUAL COMMENTARY

2.1 Over and above the commentary provided in the Further Written Statement of Barton Willmore in response to Matter 16.w Policy NE5, including Appendix 1 of that Statement, a number of comments on draft Policy NE5 are provided below.

2.2 The use of the word ‘maintained’ in the opening sentence of draft Policy NE5 is inappropriate as development will inevitably result in some degree of change to character. The policy should seek to manage change through directing development that responds to key characteristics rather than necessarily maintaining existing character. Furthermore, in many instances, there will be opportunities for landscape character to be enhanced, rather than simply ‘maintained’.

2.3 The draft policy also refers to the need to ‘avoid the loss of [important views]’. This too is an inappropriate blanket approach that denies the possibility for sensitively-managed change where these views may be lost from some locations but retained from others. Furthermore, the identification of which ‘important views’ are covered by this policy; and the evidence for their identification, is not made clear.

2.4 The policy notes that Areas of Attractive Landscape (AAL) are of ‘greater significance’ than Local Landscape Areas (LLA), but provides no justification for this conclusion.

20704 2 June 2018 Landscape and Visual Statement Consideration of AAL designation in the vicinity of the Site

3.0 CONSIDERATION OF AAL DESIGNATION IN THE VICINITY OF THE SITE

3.1 The key concern with the extent of the Brickhills AAL boundary, from a Landscape and Visual perspective, is that it has been in place since at least 1979 (on the basis of available mapping records, although it is understood that the designation has been in place since the 1950s), and that in the intervening period, there has been no evident consideration by AVDC of review of these boundaries, notwithstanding clear and significant changes in circumstances on the ground, as described below.

Historic Mapping

3.2 Figures H1.1-H1.9 set out change in urban and highway development in the vicinity of the Site, in the post-war period.

3.3 Figures H1.1-H1.3 (1945, 1958 and 1968) show the arrangement of the settlements of Fenny Stratford and Water Eaton, from which Stoke Road extends south towards Stoke Hammond. On the eastern side of the area, Galley Lane extends south from Watling Street to Galleylane Farm, before extending south-east towards Great Brickhill.

3.4 As shown in Figure H1.4, by 1977, the extension of the Milton Keynes urban area to incorporate Fenny Stratford and Water Eaton has taken place. Stoke Road (now identified in the centre of Water Eaton as the A4146) still forms the link from Watling Street within the extended urban area, to Stoke Hammond to the south. Galley Lane maintains its original course south and south-east from Watling Street (now identified as the A5 (T)).

3.5 By 1984, as shown in Figure H1.5, a notable change in the strategic road network is evident, in the form of the roundabout junction of Watling Street with a new alignment of the A5 (T), which forms a dual carriageway north-eastern by-pass of Fenny Stratford, before extending into and through the Milton Keynes urban area to the north-west. Galley Lane still maintains its original course.

3.6 This pattern of by-pass road development is then extended south, as shown in Figure H1.6 (2003), which shows the creation of the substantial 2-lane roadway corridor of the A4146 extending north-east from a new roundabout on Stoke Road at the southern end of the Water Eaton urban area as far as another roundabout on the alignment of Galley Lane, which to the north is upgraded to a similar scale of roadway as that to the south-west. These features create a major new structural element in the landscape. At this time, the construction of another by-pass along the southern edge of the Water Eaton urban area can be seen in progress.

20704 3 June 2018 Landscape and Visual Statement Consideration of AAL designation in the vicinity of the Site

3.7 By 2005 (Figure H1.7), the dual carriageway along the southern edge of Water Eaton can be seen to be completed, in addition to a new roundabout to the south-west, just to the west of the mainline railway. This roundabout has arms extending north and south, intended to serve future residential development to the north and the extension of the A4146 to the south. Both of these changes can be seen in Figures H1.8 and H1.9 (2007 and 2017, respectively) which show the southbound route of the A4146 in dual carriageway form, flanking the mainline railway as it extends south. This road ultimately extends as far as the south-western edge of Leighton Buzzard, at which point the A4146 extends south-west towards Aylesbury.

3.8 Figure H1.8 shows an increase in development extending south-east along Watling Street towards the A4146/A5 junction and Figure H1.9 shows the extent of consented development to the north of the Site (600 residential properties), contained and bound into the urban area by the A4146 Fenny Stratford/Water Eaton by-pass.

3.9 The evolution of development shown in Figures H1.1-H1.9 therefore includes the substantial extension of the Milton Keynes urban area, in addition to the establishment of a strategic road network by-passing this development, to link the A5 trunk road to the north with the Aylesbury Vale to the south.

3.10 These features represent a significant change in the landscape between the designation of the extent of the Brickhills AAL by Buckinghamshire County Council (on the basis of the earliest conclusive mapping available, from 1979); and the current situation. The introduction of the A4146 roadway corridor has created a marked distinction between the landscape to the east and west of the roadway. The landscape to the east is now more closely associated with the Greensand Ridge, which forms the basis for designation of the AAL. The landscape to the west is now more closely associated with the urban area, of which the A4146 serves as a by-pass; and has become physically separated from the Greensand Ridge.

3.11 As illustrated in the historic mapping, the Stoke Road (former A4146) roadway to the south of Water Eaton is used as a boundary to the AAL to the west of the Ouzel corridor. This demonstrates that roadways are deemed suitable as boundaries to the AAL.

Consideration of AAL boundary

3.12 There is no evidence before the Inspector that suggests that the AAL boundaries have been considered in the light of these evolving circumstances. The only evidence that relates to this issue is the Strategic Landscape and Visual Capacity Study prepared by Bradley Murphy Design Ltd (‘BMD’), for AVDC (August 2017). The BMD report identifies that 70% of the Site (BMD ref: GRB002) would be developable (a substantial area of green infrastructure being required along the Ouzel corridor to the west; along a number of narrower corridors crossing the Site east-

20704 4 June 2018 Landscape and Visual Statement Consideration of AAL designation in the vicinity of the Site

west; and along the eastern edge), owing to the reduction in susceptibility resulting from the consented development to the north of the Site.

3.13 Notwithstanding the lack of reference to the role of the A4146 in creating a clear dividing feature across the character of the landscape, this assessment is considered to be an appropriate response to changing circumstances in the form of the consented development to the north, which further diminishes the association of the landscape to the west of the A4146, including the Site, with that of the AAL to the east of the A4146.

3.14 The BMD study appears to be based on sound principles of methodology, drawn from the Guidelines for Landscape and Visual Impact Assessment (LI and IEMA, 2003), in establishing the sensitivity of the landscape. It was commissioned and then published by AVDC and it is therefore assumed that AVDC also consider the study to be robust. Furthermore, AECOM, who prepared the Sustainability Appraisal (SA) of the Vale of Aylesbury Local Plan, Technical Annex (September 2017) for AVDC, which references the BMD study, express no concerns with the robustness of the BMD study.

3.15 Given the findings of the BMD study, it is surprising that no further consideration of the boundaries of the AAL has been undertaken by AVDC.

3.16 Related to this, it is notable that the report ‘Defining the special qualities of local landscape designations in Aylesbury Vale District’ by Land Use Consultants (LUC) (March 2016) did not assess the boundaries of the AAL. Appendix 2 of the LUC 2016 report comprises notes from a stakeholder workshop. It includes numerous references to concern expressed at the lack of a boundary exercise undertaken as part of the work, including, in Table 5.1, by AVDC’s Landscape Officer. The LUC response to the Landscape Officer query is that if a boundary review had been undertaken: ‘the study would be even more robust, but this would be a much larger piece of work. However, the study LUC has carried out is robust.’

3.17 The study cannot be considered to be robust given that it has not examined the extents of the Brickhills AAL in respect of the clear and significant extent of change that has taken place since the boundary was first drawn. The concern expressed at the stakeholder workshop in this respect is well-founded. Review of the AAL designation boundaries in the vicinity of the Site is long overdue owing to the range of significant changes that have taken place; and should have been undertaken as part of the LUC 2016 report.

3.18 It is notable that the LUC 2016 report makes no reference at all to the A4146 roadway. This is surprising, given its substantial form and dominant presence in the landscape. The AVDC Landscape Character Assessment of 2008 notes the intrusive influence of the A4146 in relation to both LCA 5.2 Ouzel Valley and LCA 5.3 Ouzel Valley Lower Slopes (see Appendix 2). At the

20704 5 June 2018 Landscape and Visual Statement Consideration of AAL designation in the vicinity of the Site

very least, the omission of any consideration of the A4146 in the LUC 2016 report, is inconsistent with the AVDC LCA 2008.

3.19 These considerations make AVDC’s response to the AECOM Sustainability Appraisal Technical Annex of September 2017 (included on p.27 of the Sustainability Appraisal) untenable. Not only does the AVDC comment rely on the adjacent land within MK Borough not being built-out for a number of years, which appears to be merely a denial of the inevitable fundamental change occurring in the vicinity of the Site; but it also fails to recognise the findings of its own landscape character assessment in relation to the influence of the A4146 in this area. Whatever the weight attributed to the AAL designation by AVDC in their response to the Sustainability Appraisal (it is contended that this weight should be limited, for reasons given in Barton Willmore’s Response to the Proposed Submission Vale of Aylesbury Local Plan 2013-2033 (December 2017)), AVDC have no evidential basis to support its conclusion that the designation should apply to the Site, in a context that has changed so much since the AAL boundary was drawn up (earliest available mapping dating from 1979) and which will continue to change with the ongoing development of land to the north of the Site.

3.20 In taking this approach, AVDC has also ignored the up-to-date, site-specific evidence that AVDC itself commissioned, in the form of the BMD 2017 study, which recommends that 70% of the Site is developable.

3.21 Both AVDC’s ignoring of this up-to-date, site-specific advice and the lack of consideration of boundary review of the Brickhills AAL designation are contrary to the requirement in paragraph 165 of the NPPF that:

‘Planning policies and decisions should be based on up- to- date information about the natural environment and other characteristics of the area’

3.22 This approach to taking forward the Brickhills AAL designation reflects the concern set out in GLVIA 3, paragraph 5.25, which notes that:

‘Unfortunately, many of these locally designated landscapes do not have good records of how they were selected, what criteria were used and how the boundaries were drawn. This can make it difficult to get a clear picture of the relationship between the study area and the wider context of the designation.’

3.23 This problem is evident in the case of the Brickhills AAL in the vicinity of the Site. There is no detailed justification available for the ongoing retention of the 1979 boundary. The location of the Site to the west of the A4146 and to the south of consented development of 600 residential properties, makes the retention of the Site within the AAL unjustifiable in the wider context of the designation.

20704 6 June 2018 Landscape and Visual Statement Consideration of AAL designation in the vicinity of the Site

3.24 In summary, the A4146 is a defining feature in the perception of the landscape in the vicinity of the Site. As noted above, the A4146 has created a marked distinction between the landscape to the east and west of the roadway, that to the east being more closely associated with the Greensand Ridge, which forms the basis for designation of the AAL; and that to the west being more closely associated with the urban area, of which the A4146 serves as a by-pass.

3.25 MKC appear to recognise the role and character of the A4146, as evidenced in two ways. First, in MKC land the AAL boundary lies to the east of the A4146. Second, MKC have consented large-scale residential development (600 residential properties) to the west of A4146 and to the north of the Site, on land which is of no material character difference from that within the Site. This development is also proposed to be allocated in Milton Keynes Council’s Local Plan, ‘Plan:MK’, which is also currently subject to Examination.

3.26 Hankinson Duckett Associates provided an objection to the Aylesbury Vale District Local Plan Deposit Draft (1998) that noted the influence of the A4146 Fenny Stratford/Water Eaton By- Pass in the landscape and how this detached the area to the west from the Brickhills AAL.

3.27 BMD in their 2017 report consider that development to the south of the consented development (which itself lies to the west of the A4146), of up to 70% of the Site would be acceptable.

3.28 Barton Willmore also consider that the Development would provide a sensitive response in landscape and visual terms to the Site and its setting, including the retention of a number of key characteristics in response to published character assessments, as well as input from AVDC officers. Most notably, the Development proposes broad visual corridors, of between 46 and 130m in width, between the valley floor and open space within the Site and the ridgeline to the east, retaining the visual interconnectivity noted in published character assessments. Figure 1 below shows these visual corridors.

20704 7 June 2018 Landscape and Visual Statement Consideration of AAL designation in the vicinity of the Site

Figure 1: Visual Corridor Concept

3.29 In contrast to the views of these three landscape consultancies and of MKC, AVDC do not appreciate the changing context of the Site since the last consideration of the AAL boundaries in 1979. This has resulted in the Site, on land to the west of the A4146 and to the south of consented development, not being worthy of inclusion within the AAL.

Characterisation of AAL

3.30 Over and above the commentary on the LUC 2016 Report Criteria for the Brickhills AAL provided in Barton Willmore’s Response to the Proposed Submission Vale of Aylesbury Local Plan 2013- 2033 (December 2017) (see Appendix 1), which largely correspond to the factors for identification of valued landscapes in Box 5.1 of GLVIA 3, the following points are noted in relation to how the Brickhills AAL has been characterised in the LUC 2016 report.

3.31 The LUC 2016 report starts its Statement of Significance commentary on the Brickhills AAL with an inherent contradiction. It states on p.19 that:

‘The Brickhills are the western extent of the greensand ridge which stretches into and across ;’

3.32 The commentary then goes on to include reference to how the slopes of this area:

20704 8 June 2018 Landscape and Visual Statement Consideration of AAL designation in the vicinity of the Site

‘…fall down to the enclosed valley of the and Grand Union Canal’

3.33 The lower-lying area that this comment refers to is self-evidently not part of the ridge of hills, formed of greensand (the material used for brick production). In fact, the report goes on in the Statement of Significance and Special Qualities on p.19, to note the contrast between the two landscapes.

3.34 It is therefore clear that the Brickhills AAL designation includes landscape that does not logically belong there. The basis for designation of the AAL is the ridgeline itself. The Ouzel valley floor, whilst it has a visual inter-relationship with the ridgeline and forms a contrast with it, cannot reasonably be considered to be part of it.

3.35 The characteristics of the ridgeline, which form the majority of the Special Qualities of and Criteria for the Brickhills AAL, are entirely distinct from the character of the lower-lying area to the west. Published character assessments recognise this clear distinction, including at a local level in Jacobs for AVDC, 2008, Landscape Character Areas 6.1 Brickhills Scarp; 5.3 Ouzel Valley Lower Slopes; and 5.2 Ouzel Valley (see Appendix 2). The distinction between the ridgeline and valley floor is made stronger in the vicinity of the Site by the separation provided by the corridor of the A4146 Fenny Stratford/Water Eaton by-pass, which lies on the interface between the slopes of the Greensand Ridge to the east; and the valley floor to the west. It is therefore clear that the AAL includes land which is not necessary to include within it to preserve the character of the Brickhills Greensand Ridge.

3.36 This is contrary to the 2016 LUC report methodology criteria for ‘Distinctiveness’ in Table 2.1 (p.9), which includes:

‘Coherent landscape character conferring a recognisable sense of place;

Distinct landform or topography forming a discrete and recognisable area’

3.37 The current extent of the AAL does not have a coherent landscape character as it clearly combines separate and different landscape character areas, as set out in published assessment (Jacobs for AVDC, 2008 – see Appendix 2). As a result, the comment in Table 4.1 of the LUC 2016 report that the Brickhills is worthy of local landscape designation as it is ‘a… coherent landscape’ is inaccurate. The distinct landform of the Brickhills Greensand Ridge forms a discrete and recognisable area. The inclusion of the Ouzel valley floor to the west within the AAL confuses this specific identity of the AAL and is contrary to the LUC methodology. This character distinction is reinforced by the corridor of the A4146 Fenny Stratford/Water Eaton by-pass to the east of the Site, which would form a more logical western boundary for the AAL.

20704 9 June 2018 Landscape and Visual Statement Consideration of AAL designation in the vicinity of the Site

3.38 It is noted that paragraph 4.7 of the report states:

‘It should also be noted that within all of the areas, whether considered within this study as being of relatively higher or lower value themselves, there will be smaller areas of higher and lower value. When using this report to judge landscape value for an individual site, the qualities and characteristics of the site itself should be assessed against the special qualities and summary criteria in this report to inform the judgement.’

3.39 Such an exercise was undertaken for the Site in the Barton Willmore’s Response to the Proposed Submission Vale of Aylesbury Local Plan 2013-2033 (December 2017), which found that the Site does not contribute more than a very limited amount to the Special Qualities and Criteria descriptions of the AAL (see Appendix 1 for Criteria commentary).

20704 10 June 2018 Landscape and Visual Statement Summary and Conclusion

4.0 SUMMARY AND CONCLUSION

4.1 This Landscape and Visual Statement provides supplementary information to that provided in Barton Willmore’s Response to the Proposed Submission Vale of Aylesbury Local Plan 2013- 2033 (December 2017).

4.2 In addition to commentary provided in the Further Written Statement of Barton Willmore in response to Matter 16.w Policy NE5, it is considered that draft Policy NE5 fails to recognise that development will inevitably result in some change to character; that change can also retain important views to a sufficient degree; that important views are not defined; and that the hierarchy of local landscape designations is not justified in the policy.

4.3 In relation to the Brickhills AAL, historic mapping shows that there has been a significant change in the landscape between the designation of the extent of the Brickhills AAL by Buckinghamshire County Council (on the basis of the earliest conclusive mapping available, from 1979); and the current situation. Notably, this includes the substantial extension of the Milton Keynes urban area (including consented development of 600 residential properties to the north of the Site), in addition to the establishment of a strategic road network by-passing the urban area, to link the A5 trunk road to the north with the Aylesbury Vale to the south. This includes the major infrastructural feature of the A4146 Fenny Stratford/Water Eaton By- Pass, to the east of the Site, which has physically separated land to the west of the A4146 from the Greensand Ridge.

4.4 There has been no consideration of boundary changes to the AAL in the LUC 2016 report ‘Defining the special qualities of local landscape designations in Aylesbury Vale District’. This is a failing of the scope of the report given the clear and substantial changes in the landscape since the last available mapping of the boundary (1979).

4.5 The LUC 2016 report makes no reference at all to the A4146 roadway. This is surprising, given its substantial form and dominant presence in the landscape. The AVDC Landscape Character Assessment of 2008 notes the intrusive influence of the A4146.

4.6 In its Sustainability Appraisal Response, AVDC have made no attempt to consider whether or not the designation should apply to the land within the Site, in a context that has changed so markedly since the AAL boundary was last drawn and which will continue to change with the ongoing development of land to the north of the Site. The separate Sustainability Appraisal Review prepared by Barton Willmore, which is provided at Appendix 3 of the Further Written Statement, provides further detail.

20704 11 June 2018 Landscape and Visual Statement Summary and Conclusion

4.7 In summary, the A4146 is a defining feature in the perception of the landscape in the vicinity of the Site. It has created a marked distinction between the landscape to the east and west of the roadway, that to the east being more closely associated with the Greensand Ridge, which forms the basis for designation of the AAL; and that to the west being more closely associated with the urban area, of which the A4146 serves as a by-pass.

4.8 MKC appear to recognise the role and character of the A4146, as evidenced in two ways. First, the AAL boundary lies to the east of the A4146 in MKC land. Second, MKC have consented large-scale residential development (600 residential properties) to the west of A4146 and to the north of the Site, on land which is of no material character difference from that within the Site. This development is also proposed to be allocated in Milton Keynes Council’s Local Plan, ‘Plan:MK’, which is also currently subject to Examination.

4.9 Hankinson Duckett Associates provided an objection to the Aylesbury Vale District Local Plan Deposit Draft (1998) that noted the influence of the A4146 Fenny Stratford/Water Eaton By- Pass in the landscape and how this detached the area to the west from the Brickhills AAL.

4.10 BMD in their 2017 report consider that development to the south of the consented development (which itself lies to the west of the A4146), of up to 70% of the Site would be acceptable.

4.11 Barton Willmore also consider that the Development would provide a sensitive response in landscape and visual terms to the Site and its setting, including the retention of a number of key characteristics in response to published character assessments, as well as input from AVDC officers.

4.12 In contrast to the views of these three landscape consultancies and of MKC, AVDC do not appreciate the changing context of the Site since the last consideration of the AAL boundaries in 1979. This has resulted in the Site, on land to the west of the A4146 and to the south of consented development, not being worthy of inclusion within the AAL.

4.13 The AAL designation includes landscape within the designation that does not logically belong there. The basis for designation of the AAL is the ridgeline itself. The Ouzel valley floor, whilst it has a visual inter-relationship with the ridgeline and forms a contrast with it, cannot reasonably be considered to be part of it. Contrary to LUC 2016 methodology, the current extent of the AAL does not have a coherent landscape character as it clearly combines separate and different landscape character areas, as set out in published assessment.

4.14 The Site lies within the character that is associated with the valley floor, not the Brickhills Greensand Ridge. This character distinction is reinforced by the corridor of the A4146 Fenny Stratford/Water Eaton by-pass to the east of the Site, which would form a more logical western boundary for the AAL.

20704 12 June 2018 Landscape and Visual Statement Appendix L1

APPENDIX L1

Commentary on the LUC 2016 Report Criteria for the Brickhills AAL (as provided in Barton Willmore’s Response to the Proposed Submission Vale of Aylesbury Local Plan 2013-2033 (December 2017))

Criteria Summary description Commentary Distinctivene Prominent scarp rising from the valley of the Owing to the intrusion of the major ss river Ouzel; contrasts with the flatter clay routeway corridor of the A4146, the landscape surrounding it. Coherent landscape, vicinity of the Site is not part of a with a strong and unified landscape pattern of unified landscape pattern or extensive woodland cover on the scarp and connected with the ridgeline by a surrounding rolling landform, and the valley of strong field pattern. the River Ouzel and Grand Union Canal connected by strong field pattern creates a strong sense of place. Continuity to the south into Central Bedfordshire Greensand Ridge/ Ouzel Valley. Perceptual Tranquil, rolling countryside of smooth arable The vicinity of the Site is neither character and pastoral hills and woodland. A transition tranquil nor lacking intrusion from between the ridge and valley, with a rich mosaic development or major roads, owing and patchwork of different landscape types and to the existing influences of roadway contrasts with the enclosed wooded areas and infrastructure at the urban edge. steep winding lanes and the quiet and enclosed These influences will increase canal and river corridors. A lack of intrusion markedly with the introduction of the from development, especially tall structures or consented residential development major roads. immediately to the north of the Site. Landscape Long distance spectacular views from open Development of the Site would result and scenic vantage points on the scarp (e.g. from Ivy Lane in limited effect on the ‘spectacular quality and Great Brickhill village to the west) over the panoramic views from the high surrounding countryside across the Ouzel ground’, owing to the existing and valley, and the Vale of Aylesbury towards the future baseline influences of built Aylesbury hills and to Milton Keynes to the development in the valley floor in north; refer to the Conservation Area Appraisal these views, which extend over a far for Great Brickhill. The wooded scarp slopes wider area. have strong visual character, particularly when The proposed layout would to viewed from the west and north west from maintain substantial view corridors Milton Keynes. Small scale and picturesque up to the wooded scarp slopes from setting for the recreation routes that pass the west, across and from within the through (cycle path and national trail). The hills Site. provide a backdrop to villages. Natural Areas of semi-natural, mixed and coniferous None of these habitat features are character woodland, and lowland mixed deciduous present within the Site. woodland priority habitat, including ancient woodland (e.g. Duncombe Wood, Oak Wood) and ancient coppice woodland in Rushmere Country Park. Part of Kings and Bakers Wood & Heath SSSI (partly within Bedfordshire) – rich in floral and faunal diversity. Large areas of neutral and acidic grassland priority habitat. Pockets of heathland – especially around Rammamere. Large number of Local Wildlife Sites/ Biological Notification Sites including woodlands, wetlands and grasslands. Aquatic habitats and a small area of fen. Part of the Greensand Ridge Nature Improvement Area

20704 13 June 2018 Landscape and Visual Statement Appendix L1

Cultural Historic settlement with distinctive sandstone None of these cultural features lie character buildings. within the Site. Great Brickhill Conservation Area and listed buildings – associations of the village with the manufacture of pottery and tiles in the medieval period. Small deserted medieval settlement at Bragenham Farm. Historic flood meadows and sites of prehistoric and Roman occupation along the valley; listed bridge and locks on the Grand Union Canal. Listed buildings associated with Stockgrove Park. Function Recreational value of the canal. Half of The Site includes only limited Rushmere Country park (the other part is within recreational value from the PROW Bedfordshire) – a tranquil parkland and traversing it. The Site does not woodland with facilities, country walks and include any recreational open space. sense of isolation. A number of national trails – None of the waymarked trails shown Milton Keynes Boundary Walk, Grand Union are National Trails. None extend Canal Walk, Greensand Ridge Walk and cycle through the Site or alongside it (the routes. Grand Union Canal Walk is separated Provides a high quality rural landscape and ‘gap’ from Waterhall Park and the Site by function between Milton Keynes and Leighton hedgerows and canopy vegetation). Buzzard/ Heath and Reach, alongside the part The Site makes no contribution to the of the landscape within Bedfordshire. Provides a perceived openness between Milton landscape setting to Milton Keynes. Keynes and Leighton Buzzard. Provides a strong setting to Great Brickhill The Site makes a limited contribution Conservation Area. to the setting of Milton Keynes, as the A4146 already extends from one part of the urban area to another, binding the landscape of the Site to the urban area. This impression will increase with the introduction of residential development immediately to the north of the Site.

20704 14 June 2018