WHADDON PARISH COUNCIL
14th December 2019
� .. ----- · - Reply to; Suzanne Lindsey , ...... ------Clerk to Whaddon Parish Council 1 Vicarage Rd 6l0Z 330 g I Whaddon C3JJ\U3103/� MK17 0LU Tel: 01908 507970 Email: [email protected]. uk
Planning Policy, Aylesbury Vale District Council, The Gateway, Gatehouse Road, Aylesbury, HP19 8FF
DearSirs,
Please findenclosed this Council's objection response, and completed response form,to the V ALP Proposed Main Modifications Consultation in respect of MM076, Shenley Park, Whaddon. Please forward to Mr Clark with the letter attached.
As agreed with your Council we enclose all original copies of the residents slips, fromelderly residents, and those people who either have no internet facilities, lack internet skills, or who have foundthe whole process either too tortuous or difficultto fully understand due to the volume and complexity of attendant documents.
) There will, we believe, be many others who have made individual responses and we have triedhard to ensure that there are no duplicates. Will you please ensure that these 'manual process' residents are duly recorded as having joined in with, and support, the Parish Council response. Contact details are recorded as requested on the slips, should you wish to verify authenticity, but this information is not replicated on the actual consultation response to the Inspector.
Should you have any queries, then please do not hesitate to contact me.
Yours sincerely,
Suzanne Lindsey Clerk to Whaddon Parish Council AYLESLllJRY VALE DISTIi.KTCUL:NCIL
For internal Use only Rep No:
) Responses are encouraged via the Council's online consultation system available on the website, see https://aylesburyvaledc.jdi-consult.net/localplan. However, this form can be returned via email to [email protected] or in hard copy if necessary to: Planning Policy, Aylesbury Vale District Council, The Gateway, Gatehouse Road, Aylesbury, Bucks, HP19 8FF The consultation runs from 12pm Tuesday 5 November until 5.15pm Tuesday 17 December
This form has two parts: Part A - Personal Details and Part B - Your comments
PARTA 1. Personal Details 2. Agent's Details (if applicable)
) Title PARISH CLERK Title
First Name First Name
Last Name l-1 i--lOSe Y Last Name
Organisation Pnrc..is'-' Wll',.Ja� Organisation (Where relevant) �------'-i.JHflOootJ Address Line 1 Address Line 1 / 1 UtcAr2R6E Address Line 2 Address Line 2 I tJHAVDON Address Line 3 Address Line 3 i3VCk S .. Post Code Post Code /HKl7 OLU E-mail Address E-mail Address jpc:[email protected],udzsp4, or9. �R Telephone Telephone / 01'10� 507970 / Number Number PARTB TATION FO Please Note: You do not need to return this form if you have made the same comments via the council's online system for this consultation. Duplicates will not be considered. Please specify which Proposed Main Modification, part of the Sustainability Appraisal addendum or Habitat Regulation Assessment your comments relate to. Any representations on the content of the new evidence published alongside the Proposed Main Modifications must also relate to a specified Main Modification to the VALP or they will not be accepted. If you wish to comment on more than one Modification please use a separate form for each.
e.g. MM001 MM 076
Do you support or object? D Support I./I Object Do you consider the Local Plan to be legally compliant? D Yes [lJNo Do you consider the Local Plan to be sound? D Yes [ZJNo
If you do NOT consider the Local Plan to be sound, please specify on what grounds: I v"I Positively prepared I../I Justified I /I Effective [ZJConsistent with National Policy Enter your full representation here: Continue onto another page if needed
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If the inspector decides further hearing sessions are needed would you wish to speak at these? G2J' Yes D No If Yes - you wish to speak at any further hearings, please outline why you consider this to be necessary:
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Do you wish to be notified ... 0 When the Inspector's report is published? G2J' When the Vale of Aylesbury Local Plan is adopted?
Vale of Aylesbury Local Plan: Responses should be returned to Aylesbury Vale District Council by 5.15pm Tuesday 17 December 2019 (responses will not be accepted after this time) 25 October 2019 Privacy Notice for Vale of Aylesbury Local Plan (VALP) Main Modifications consultation
Aylesbury Vale District Council (AVDC) is committed to protecting your privacy when you use our services. The law requires us to give you a Privacy Notice which gives you details about how we use and protect your information.
Our contact details are:
The Gateway, Gatehouse Road, Aylesbury, Buckinghamshire, HP19 8FF. Telephone: 01296 585858
Our Data Protection Officeris Mr Andy Barton. He can be contacted via [email protected] or telephone 01296 585495.
What information will we collect about you:
• Name and address • Contact details • Job title/organisation (where relevant) • Your comments/representations
Why are we using your information?
We are asking for your information so that we can support the local planning process and creation of the Local Plan, including within the independent examination process. As a Local Planning Authority, the law requires us to carry out consultations for this purpose.
We can use your information because you have given us your permission to use it and we need to comply with the law. You may have rights to stop us using your information depending upon the stage of the local plan and the applicable legislation. If you want to check or stop us using your information you should email [email protected] and quote 'Vale of Aylesbury Local Plan consultations'.
If you do not give us your information or you stop us using your information {where possible) your comments or representation may not be taken into account within the local planning process and we may not be able to contact you with any follow up information on the plan's development, including the outcome of the independent examination.
Your information will normally be retained for the length of the plan period or until the plan is no longer in effect.
Your information is only used for the reasons above but if we need to use it for any other reason we will normally tell you.
We may share your information with:
JDi Solutions who operate our online local plan consultation system for us. Your information is held in their system as result of representations you make, but only your name is published in relation to your representation. Importantly JDi Solutions are not permitted to do anything with your information other than provide it to us for our lawful use in relation to the preparation of the Local Plan
Once the consultation closes we are required by Regulations to share all valid and existing comments/representations with the independent Planning Inspector appointed by government to AVDC to undertake the examination. If the Inspector wishes to invite you to answer any follow up questions in response to your representation or invite you to attend any further public hearing for the purposes of the examination, we will share your contact information with the Inspector, via our appointed external Programme Officer, so he can contact you about the local plan.
Please note that your name, organisation, system ID and representation will be made publically available. However your contact information will not be published in the report of representations and will be redacted if it appears in the body of your representation.
Automated Decision Making
We will not carry out any automated decision making. All decisions are made by a living person. WHADDON PARISH COUNCIL
RESPONSE TO THE VALEOF AYLESBURYVALE LOCAL PLAN 2013 - 2033 PROPOSED SUBMISSION PLAN (NOVEMBER 2017) AS PROPOSED TOBE MODIFIED (OCTOBER 2019) AND THE SUSTAINABILITY APPRAISAL OF VALP (OCTOBER 2019)
DATE COMPLETED: 14/12/2019, HAND DELIVEREDTO AVPC OFFICES: 16/12/2019
MULTIPLESUBMISSION.
This consultation representation is made by WhaddonParish Council (WPC) and has been read and approved by all seven elected Parish Councillors. WPC were first made aware of the reintroduction of Shenley Park, Whaddon, as an Omission Site, at a special Aylesbury Vale District Council (AVDC) 'Briefing Meeting for Parish Councils' on the Vale of Aylesbury Local Plan, (VALP), held on Tuesday evening 23 July, with a presentation () given by AVDC officersPeter Williams, Planning Policy Specialist, and Andy Kirkham, Growth Project Consultant. Since that date, WPC have held two Parish Meetings attended by over 110 residents, all of whom considered that 'Fairness' by AVDC has not been observed, which is likely to lead to strong objections from many, if not all of them. Furthermore, this WPC submission is wholly supported by the following residents, some elderly, who either have no internet facilities, lack internet skills, or who have found the whole process too tortuous and difficultto understand due to the volume and complexity of the copious attendant documents, made especially difficult without any supporting plans to guide them. These residents have been briefed by Whaddon Councillors about the issues and the likely impact that the Shenley Park development is likely to have on their lives, and they wish their personal details to be duly registered as part of the 'multiple' WhaddonP. C. submission. This arrangement has been agreed by Aylesbury Vale District Council (AVDC), who suggested this was the best way of dealing with this situation. Accordingly, the completed personal information forms from these residents, with contact details as required by the Council (for verification purposes if necessary), have been forwarded to AVDC in order that they can be recorded as 'duly made' objections. ( ) The following residents of Whaddon support the WPC detailed submission:-
) Clare Hadida, F. Hayward, Joyce Adams, Valerie Bond, Mr. M. C. Maciver, Mr. John Mortimer, Mrs Margaret Barrie, Nesta Dutton, Mr, Kieren Beasley, Sally Jaworska,
THIS UST CONTINUESON FOLLOWING UN-NUMBERED PAGES,
1 WHADDON PARISH COUNCIL
MULTIPLE SUBMISSION CONTINUED - MM076 - SHENLEY PARK, WHADDON.
Donna Cowley, Peter Willis, Andrew Walsh, Barbara Northend, Hannah Conisbee, Maria Cole, Millie Cole, Andy Cole, Melisa Burnett, Mark Burnett, Hayley Walsh, ( ) Vicki Burnett, Christion Davis, Ruth Davis, Joanne Brodrill, Bipin, Dana and Hiren Patel, Karen Holfeld, Mrs Lillian Ross, Fiona Thompson, Daphne willis, John Cowley, Mr. Peter Williams, Mrs. Veronica Dormer, Clive Herbert, Linda Herbert, Jean Barnes, Eleanor Chambers, ( ) Mr. T. Bennett, Eliza Bennett, ) Douglas Stewart, Jennifer Groom, Sally Te lford, Mrs E. Moss, Charlotte Male, Richard Male. David Ferriman, Mrs Sophie Freshwater, Alice Hain, Valerie Peters, Russell and Amanda Hardman, Joan Bowkett, la WHADDON PARISH COUNCIL
MULTIPLE SUBMISSION CONTINUED - MM076 - SHENLEY PARK, VVHADDON.
Mrs H. Dudley, Ralph and Debbie Spinks, Mr. Monk, David & Trudy Buckner, Mrs Evelyn Jaworska, Helen & James Meredith, Amy Jones, Mr. H Cheema, Barbara Brown, Emily Short, Peter Dobson, r Anika James, Suzanne Lindsey, David Cooke, Ben James, Mrs V.J.Stewart, Tim Catlow, Sarah Cox, Helen Wallace-Fisher, Clare Wallace-Fisher, Alexis Mitchell, Jill Aitken, Nigel Aitken, Abigail Wood, Jane Porter, Gillian Hosier, Edward Mitchell, l ) David Porteous, Edith Cileniene, Alexander & Phillippa Marwick, David Willerton, Lawrence John, Rachel Fensome, Vincent B, Dudley, Mary & John Mortimer, Sue McAuley, Paul Bailey, Paul Bessel!, Sharon Bessel!, Mrs Neeru Mathius, lb WHADDON PARISH COUNCIL
MULTIPLE SUBMISSION CONTINUED - MM076 - SHENLEY PARK, WHADDON.
Mr Sushil Mathius, Dr, Christine Robinson, John Robinson, Simon French, Mignon French, J Dietsch, Mr. Howard Jones, Peter Mitchell, Ella Petch-Stewart, Nadine Mitchell, Mallkah Mitchell, ) Mathew Stewart, Livia Lenart-Stewart, Dave Osborn, Phil Hasker, Lucy Stewart, Riaz Bowmer, Mary Bowmer, C, Sturridge, Grant Gibson, Thomas E Short, Mikael Czerski, Susan Burghart, Mrs J. Jones, Marlen Lawrenz, Mrs. Sally Green, Annabel Green, Sue Simmonds, Gerald Simmonds, Mr John Vicent, Mrs.S Vincent, Miss F.A. Vincent, Mr J. S. J. Vincent, Rachael Macintyre, David Macintyre,
EMQ.. Approx 125 Whaddon Residents wish to join In with and support the Whaddon Parish Council Objection response to MM076, Shenley Park Whaddon (WHA0Ol) in the VALP. WPC are advised that other residents have made their own personal responses either by hand or on the AVDC planning portal. Whilst helping those who have found the process too complicated WPC has tried very hard to ensure that there are no duplications. 16 December 2019. le VALE OF AYLESBURY LOCAL PLAN 2013 - 2033.
Proposed Submission Plan (November 2017) as Proposed to be Modified (October 2019)
CONSULTATIONRESPONSE FROM : WHADDON PARISH COUNCIL
INTRODUCTION.
WhaddonParish Council (WPC) have significant concerns about and strongly OBJECT TO the late reintroduction into the Main Modifications (MM) of the Vale of Aylesbury Local Plan (VALP) and the entire section MM076 (pages 133-135) relating to WHA00l - Shenley Park, Whaddon (SP), both in terms of fairness, legal compliance and soundness. These concerns and OBJECTIONS also relate to the verylate production and content of the AECOM Sustainability Appraisal (SA), which WPC believes to be unsound. This consultation response is divided into nine Sections specifically dealing with these crucially important issues. These sections are:-
SECTION 1: LEGAL COMPLIANCE - FAIRNESS AND HEARING SESSIONS. SECTION 2: LEGAL COMPLIANCE - DUTY TO COOPERATE. SECTION 3 : SOUNDNESS. SECTION 4: COMMENTS ON THE AECOM SUSTAINABILITY APPRAISAL. SECTION 5: MM076 - SHENLEY PARK (WHA00l) - Why this site should be deleted from VALP, SECTION 6 ; EATON LEYS - Why an extension to this site is the preferred alternative. SECTION 7 : SALDEN CHASE - Why this site should be considered as a reserve site. SECTION 8: SPATIAL DEVELOPMENT - Comment on financial contributions from development. SECTION 9: CONCLUSION.
SECTION ONE 1 LEGAL COMPLIANCE - 'FAIRNESS' AND 'RE-OPENING THE 'HEARING SESSIONS •
1. WHA00l - Shenley Park, Whaddon (SP) was not included in the November 2017 'Proposed Submission' version of the Vale of Aylesbury Local Plan (VALP) 2013 - 2033. WhaddonParish Council (WPC), and some 225 households within the Parish (with approximately 450 residents) have therefore been completely denied the opportunity to properly debate and cross examine AVDC's decision to choose SP over the other two competing sites at and during the public hearing sessions held by the Inspector in July 2018. The alternative sites are Eaton Leys (EL) and Salden Chase (SC), both of which will be referred to later in this submission. It is worth revisiting what was said within this key 2017 'Proposed Submission' document, where neither Whaddon village nor Shenley Park were identified on the 'District Key Diagram' :- "STRATEGIC OBJECTIVES 2. 6 no. 4, The main focus of growth will be at Aylesbury Garden Town, with remaining housing being located in the next suitable locations, the other strategic settlements which are Buckingham, Haddenham, Winslow and Wendover together with an appropriate level of development at the most sustainable settlements in the rural areas" - and at - 2. 6 no. 6, "The council willmanage development in a way that ensures the protection and enhancement of the districts built, natural and historic environment, landscape and biodiversity. Planning positively for biodiversityand green
2 infrastructure, the overall approach will minimise development on high quality agricultural land, conserve and enhance areas of sensitive landscape including designated Local Landscape Areas" "POLICY S2 - SPATIAL STRATEGY FOR GROWTH -point f- Land within Aylesbury Vale adjacent to Milton Keynes will make provision for 2212 homes on a number of sites", and under table 2 it states "allocation of land adjoining MK specificallywithin the parishes of Newton Longville and Stoke Hammond". 2. AVDC have stated that the WHA00l site (now referred to as Shenley Park) was mentioned in earlier drafts of the plan, namely ; 2015 'VALP Issues and Options Consultation', and the July 2016 'VALP Draft Submission' but this does not alter the fact that the site was excluded from the '2017 VALP Proposed Submission', Regulation 19 stage as an 'Omission' site. At each of these earlier stages WPC made lengthy detailed written submissions, full copies of which can be produced to the Inspector if required. It is worth reiterating however that over three years ago, at the July 2016 Draft Submission stage the WPC response included the following very important comment at para 1 - 1 :- "There is universal agreement that site WHA001 should not be ) 'Background' recommendedfor inclusion wit/Jin the VAL8 due to a completelack of sUJ)IJorting evidence(technical and otherwise), as to Its suitablfitv as a sustainable site". It is also felt that in the event of major development being included in future versions of the plan (in the general Whaddon area), there must be far greater and closer involvement with the local community so that very many worries and concerns - not adequately dealt within the current Draft VALP document - can be discussed and resolved to the satisfaction of all stakeholders. This is of course most important to al/ local residents, who due to the serious deficiencies of the plan will suffer the consequences of major development and have their chosen way of life severely disrupted". And then the response continuedat para 4.52;- "Development of the magnitude proposed should be fully researched and proper studies undertaken, before they are prqposedin a strategic plan. The truth of the matter is, WPC suspects that little or no work has been done on WHA00l, and AVDC are playing 'catch up'. To expect a community to comment on a site where no work has been done on any of the important infrastructure issues,or where no proper comparative studies have been undertaken against alternative sites, is frankly poor at best, and shows a lack of concern by the council on it's affected residents. WPC and the community expect to be fully involved in these discussions, and this must commence with an opportunityto properly comment on both the so called emerging Infrastructure Plan and any other studies - not least a proper traffic and transport assessment - well before any plan ts presented to a Government Inspector forconsideration, in order that WPC and resident views and concernsare both properly considered and fully taken into account. If AVDC are to have a 'sound' and 'legally compliant' plan it must be properly researched and preferably have the support of those people it's policies affect most". wee coutd not havemade their position any clearer,vet despite these comments this Council received no further communication whatsoever from AVDC. But.even after WHA001 was removed fromthe 2017 VALP Proposed submission (Reg 19 stage) wee feltit both importantand necessary to respond during thatconsu!tat;on period, sa,yingat para 1.13:- "WPC fully support the deletion (from the previous draftversion of VALP) of the proposed major a/location at WHA00l (Shenley Park, Whaddon), because to have
3 proceeded with that allocation would have only supported an already thriving and growing future city, to the detriment of Aylesbury Vale, especially as stated before that there appears no unmet needs from Milton Keynes Council (MKC), and in the longer term that Council are pursuing growth proposals that will extend Milton Keynes across and beyond the Ml motorway to the east towards Bedford, whichis directlyopposite to where WHA001 would have been located. This applaudable forward thinking within the emerging Plan:MK, is a much more sustainable and economically viable solution for growth, that will take advantage of existing and proposed infrastructure as well as excellent leisure and employment opportunities, whilst retaining both historic and highly valued landscapes and countryside to the west of Milton Keynes, which remains available to both districts for future generations to enjoy. Keeping this small but nevertheless very important green gap between Milton Keynes and Aylesbury Vale's most northerly villages will ultimately prove to be of huge strategic landscape importance to both districts especiallyif public access can be improved, along with strengthening the historic woodland structure. This landscape has long been recognised as the strength of the rural north of AylesburyVale, ever since it was the Whaddon Chase hunting grounds of past Kings and Queens. This strategy is completely in line with para 1. 7 of this plan which states 'At the same time, the NPPF also states that the planning system should contribute to and enhance the natural and local environment and that there should be a positive strategy for the conservation and enjoyment of the historic environment'. And at para l.16/1.17 WPC went on to comment on Infrastructure provision:- "Present growth levels are already giving rise to significant local problems, especially from Milton Keynes. WPC believe there exists only limited opportunity for housing growth in the rural north of AVDC without exacerbating the current problems, or further damaging existing conservation, landscape and heritage principles, the ever worsening problems of increased traffic, issues surrounding on street parking, heavy goods vehicles on unsuitable roads, etc. WPC note the comment that ·provision of infrastructure to support new housing is essential' and 'growth will be accompanied by the deliveryof infrastructure,services, and facilitiesin the d 4 serious concerns with WPC, it said 'Following debate of the site at the Examination hearings ...... '. This statement raised the question Why did the Inspector allow the Shenley Park to be discussed, when WPC and those most closely involved with the site, neither knew it would be discussed nor had been invited to the hearing to discuss it? WPC, in the belief that the Inspector should not have allowed the site to be introduced at the hearing, sought answers from AVDC as to why and how the SP site had been allowed to be introduced and were told 'The debate was regarding the merits or otherwise of RAF Halton, but Savi/ls, acting for Crest Strategic Ltd. (the proposers of the deleted Shenley Park site) when challenging this new a/location at the 2017 VALP Proposed Submission stage were able to introduce Shenley Park into the debate'. WPC believe this was totally wrong, particularly unfair, and should not have been allowed. Whilst WPC have no knowledge of the discussion that occurred at the hearing, WPC can guess at the likely 'exchanges', having seen a copy of the eight page letter sent from Savills to AVDC dated 5 October 2017 headed 'Omission of Shenley Park', which sets out the Savills/Crest Nicholson 'dismay' at AVDC actions to remove Shenley Park (WHA00l) and introduce RAF Halton instead. Worryingly at summary point 1 the letter states "In light of Counsel advice, we believe there are evidentiary and procedural flaws associated with the draft VALP which would lay open the Council to a successful judicial review claim". Similarly, the closing 'Future steps' paragraphs seeks to advise AVDC of the way forward, including ".. .. this would entail the substitution of Shenley Park for RAF Halton and a focussed update to the SA and consideration of the plan in terms of SEA Regulations". WPC earnestly hope that such correspondence and 'urgently requested meetings' have not influenced AVDC's choice of sites at the subsequent SA appraisal stage relating to the three competing sites at SP, SC and EL. 4. Whilst not wishing to dwell on the four page FAQs sheet, there are other misleading answers that seek to justify AVDC preferred choice of the SP site. Q3 states 'Outside of the VALP Milton Keynes Council, as part of the preparation of Plan:MK, consulted on Strategic Development Directions (SOD) in January 2016 which included 'Direction of Growth 1 - Development to the west, south west and/or east of the city'. That document said :- "The growth envisaged in this direction takes the form of extensions to the existing urban area. This form of development has advantages in that it could be relatively straightforward to strengthen connections to the existing transport corridors and services within MK, whilst still being large enough to provide the additional facilities and infrastructure to meet the needs of residents." Also, the MK Futures 2050 Commission Report states ".. we see some of the preferred locations for growth as beyond the boundaries of the MKC area in adjacent local authorities. WPC would simply say these comments by AVDC are very misleading. The MKC Strategic Directions of Growth consultation in 2016, included 6 options for growth, and option 1 was not selected, indeed it received a very large number of objections. The MK Futures 2050 Report, whilst welcomed by WPC as being sensible 'forward thinking' on the part of MKC is not an adopted policy document and purely a 'vision' approach. The document did not state into which local authority area future growth might penetrate, but it's approach that the city should cross the Ml motorway and look to further growth in an easterly direction, has now been adopted and taken up in the recently adopted Plan:MK. 5 5. These issues raise the important question of reopening the 'Hearing Sessions'. which WPC raised with the Inspector via the Programme Officer, in a detailed email dated 17 September 2019, (attached as Addendum 2 ) in which WPC acknowledged ''Although Shenley Park did appear in the 'VALP DraftPlan for Summer 2016 Consultation' it was withdrawn in the 'Proposed Submission VALP 2013-2033 November 2016' and was therefore not tested during the recent hearing sessions". Importantly, this email went on to explain that WPC's consultation response to the Summer 2016 consultation included the sentences, worth repeating which state:- "There is unfversal agreementthat site WHA001 should not be recommended for inclusion within the VALP due to a complete lack of sueporting evidence (technicaland otherwise). as to its suftability as a sustainable s1m.., It is also felt that in the event of major development being included in future versions of the plan (in the general Whaddon location), there must be far greater and closer involvement with the local community so that very many worries and concerns - not adequately dealt with within the current Draft VALP document - can be discussed and resolved to the satisfaction of allstakeholders, and local residents". For AVDC to reintroduce the site so late in the VALP process, without any prior notice cannot be right, and WPC strongly contend that to do so, without prior consultation - especially following specific requests to do so at earlier stages of the VALP process - is totally UNFAIR, hence the strong argument for a further hearing session to properly debate the validity of AVDC's preferred choice of site. WPC gave simplified reasons in the 17 September email to the Inspector, as to why the Hearing Sessions should be reopened, and WPC asks that the Inspector takes these reasons into account whilst reviewing this response. Needless to say, despite all the comments properly made in earlier consultation responses, no discussions have been held with WPC during the period prior to the late introduction of this site, and importantly no 'Concept' or 'Illustrative' plan is available within the M.M. upon which residents can sensibly comment. 6. To simply accept AVDC's 'preferred choice' of Shenley Park without proper scrutiny at a hearing renders the Main Modifications (MM) of the VALP Proposed Submission Plan Legally Non-Compliant and possibly unlawful, leaving it open to further legal challenge. Such action, causing yet further lengthy delays would be regrettable and should be avoided if possible. WPC seek a Sound and Lawful Plan, to be adopted at an early date, because without one would leave AVDC (or it's successor - a single Bucks Unitary Authority - after April 2020) open to hostile and unwelcome planning applications throughout the district, which could prove disastrous for good and well located sustainable development. Whaddon residents must therefore be given the opportunity to inform the Inspector of the impact that such a major strategic development would have on the environment, their lives and general well-being. This six week consultation is TOO LITTLE TOO LATE, and WPC would suggest near impossible for residents to grasp without a 'Concept Plan'. AVDC's reason for not providing a plan (i.e. it is strategic in nature and there is no requirement) in the FAQ's sheet may be true, but WPC know that AVDC are in possession of various 'illustrative' plans from Crest Homes, from which a 'Draft Concept Plan' could easily have been devised to support and illustrate how the requirements of the MM's might work in practice - at least as a discussion document. Detail would not be required, but there are important issues raised in the SA, and at the very least an indicative plan showing proposed new highway connections, re-routed roads, landscape constraints, proposed strategic gaps to avoid coalescence and location 6 of proposed long term defensible boundaries, would have aided discussion on what is, after all, a major strategic site. This point is further discussed at paragraph 11 below. 7. Local Plan hearing sessions are the accepted way of providing key stakeholders and interested parties the opportunity to cross-examine the way in which a Council has undertaken it's site selection process, and to ensure that comparison process has been undertaken with due diligence. Questions can often be asked of the statutory undertakers, and those bodies and specialist lead consultants that provide crucial evidence and technical information to the development industry on essential services, such as highway capacity, flood risk, landscape assessment etc. AVDC have indicated that because the Shenley Park Site was mentioned in the 'VALP DraftPlan for summer 2016 consultation' document, such action may not be necessary, but they add that such a decision is for the Inspector alone to decide. Please remember WPC had specifically requested answers to such questions in 2016, and at every consultation opportunity since, but no satisfactory answers have been received from AVDC. 8. WPC believe there is a precedent to reopen hearing sessions. Paragraph 30 of the Inspector's letter (Mr. Simon Berkeley), dated 9 July 2019 to the North Herts District Council, regarding the 'Examination of the North Hertfordshire Local Plan 2011 - 2031 states " The main tnodificationsproposing to allocate new land tor development. A number of the draftmain modifications put forward by the Council which have now been consulted upon propose the a/location of new land for development that was not included in the submitted Local Plan. Numerous representations have been made about these draft modifications. People's lives can be affected by the allocation of land for development, for example where they live next to or nearby a proposed site. It is, therefore, only right that those who have submitted written representations in this regard should be able to have their say at a hearing, as would have been the case if the land had been included at submission" 9. The Planning Inspectorate's 'Procedural Guide for Local Plan Examinations' makes clear at Stage 2 - Key actions - bullet 5 that "Further hearing sessions are only held where essential in the interests of fairness or in order to clarifyor resolve substantial new issues arising from the representations". This important principle is repeated at paragraph 6.9. Then reading para 6.10, it is suggested that "If the MM's involve the allocation of additional sites that did not appear in the submitted plan (as with Shenley Park, Whaddon), the Inspector may ask the LPA to undertake SA and consultation on the additional sites as a separate process, before the schedule of MM's is agreed. This will enable the Inspector to consider the representations on the additional sites, and if necessary hold further hearings to discuss them, before consultation on the other MM's takes place." For the avoidance of any doubt, this process has not been followed and this is why WPC wrote to the Inspector early, as soon as the Shenley Park Omission site was known about. Importantly, WPC do not know when instructions were given to AECOM, to produce the Sustainability Appraisal but as the report is dated October 2019 - just a few weeks before the public consultation commenced, it appears that this may have been after AVDC presented the MM's to all Parish Councils at the special meeting for Parish Councils on 23 July. Whatever the dates, clearly no meaningful consultation occurred with any interested party or stakeholder, including WPC and MKC, on this crucially important SA document. WPC conclude that such an important document was hurriedly prepared to meet an unnecessary tight deadline - that being an early conclusion to the 7 VALP process, in the expectation that the Plan could achieve adoption before AVDC became part of a single Buckinghamshire Unitary Authorityin early 2020. This desire and time line was expressed by AVDC at the Parish meeting. Furthermore, the SA rather than being an objective document to inform the process is, in WPC's opinion, written in a fashion that is 'skewed' to support a 'preferred' AVDC site, which will be fully explored in Section 4 of this consultation response. 10. CONCLUSION Because of the very late introduction of WHA00l, Shenley Park, Whaddon and for all the above reasons WPC must strongly encourage the Inspector to reopen a further hearing session at the end of the public consultation period, so that the crucial earlier omission of the Shenley Park site can be rectified. It is completely UNFAIR and UNJUST not to do so, and without holding a further hearing session to consider the concerns of WPC and Whaddon residents will render MM076 and the SA to the VALP legally Non Compliant. . ) WPC wish to make one further point and stress that although there are copious background documents and what appears to be a rapidly produced SA, the lack of a concept/Illustrative plan for such an important proposed strategic site is worrying. Although AVDC inform WPC that such a plan is not required at the Local Plan stage, WPC would ask the Inspector, especially as it is so important on a number of issues, to consider the following paragraph, which has been drafted following conversations with numerous residents, who have openly shared their concerns :- CONCEPT/ ILLUSTRATIVE PLAN. 11. There is no 'Concept Plan' or 'Illustrative Layout', unlike some other developer-led major sites in the VALP. WPC therefore asks "How can residents understand what is proposed, or be expected to respond sensibly to a major amendment and lengthy list of Main Modifications - without for instance, knowledge of how the existing and proposed highway networkwill be affected, what green gap between the site and Whaddon has been discussed, and what landscape mitigation is to be provided?" - especially as this information was repeatedly requested at much earlier stages of the plan preparation, before the proposed SP allocation was deleted. WPC's concern is that because of the sites very late introduction, AVDC simply did not have time to prepare such a plan. The copious documents placed 'online' are far too complex for most residents to understand - that is, if they can even find those parts that are relevant to WHAOOl - Shenley Park, in the first place! Understanding and locating the 'supporting evidence', especially that relating to 'highway/traffic' and 'landscape' issues which are crucial for Whaddon residents, is even worse! AVDC answer this concern by saying in their FAQ's sheet that 'There is no requirement for detailed concept plans of Local Plan a/locations as they are strategic in nature. A similar sized allocation at RAF Halton does not have a concept plan'. WPC are not seeking a 'detailed' plan, but just one that allows sensible debate, and in respect of RAF Halton, the ownership and late knowledge of its proposed vacancy is a totally different story to that at SP, where AVDC have held discussions with Crest Homes over several years. AVDC advise that such plans will form part of a future Supplementary Planning Document, and at Detailed Planning - during which there will be time for further 8 consultation, but importantly for Whaddon residents, this would be after the VALP has been adopted. Because SP is a major strategic site, with such huge implications on a small Parish WPC believes this to be unreasonable and completely unfair on residents, especially considering the expressed requests at earlier Plan stages. All major strategic sites like SP offer 'constraints' and 'opportunities', and it is important that residents understand that both disadvantages and benefits can derive from such a large and complex site, and accordingly, they may wish to comment on both. WPC know that plans exist, because a Shenley Park 'Vision Statement' was submitted to AVDC at the December 2017 Draft VALP stage, and we must assume that meetings between AVDC and Savills (acting for Crest Homes) have occurred following the 5th October 2019 letter that ended "Please can we urgently request a meeting with you to discuss the contents of this letter and the suggested way forward". Such a plan could provide both justification and more accuracy for housing numbers. The draft MM (end July 2019) stated that 'the site will make provision for around 1150 dwellings'. This suggests that the figure could be lower than that stated, and based on the SA comment under 9.9.1, and The '2017 Strategic Landscape and Visual Capacity Study' which advises 'only around 35% of the site is likely to be developable on the basis of sensitivity within the landscape' this might be the case. This might indicate that without mitigation the site is only capable of providing 400 - 500 dwellings - (to the north of Shenley Road) the amount the Inspector originally agreed with AVDC was needed close to MK. Despite this, and without explanation, the proposed MM schedule has been changed to 'at least 1150 dwellings'. RPS - transport advisors to Crest Homes, in their December 2017 response to the Draft VALP advise that subject to, and dependent upon transport connectivity from the A421 to one or more points within MK then between 1600 and 2000 dwellings are feasible. Consultants acting for Crest Homes have produced a plan showing 'Future directions of growth' arrows (beyond the area proposed in this Plan) which if implemented could greatly increase this number again! What are WPC or residents of Whaddon to believe, when such differing figures are proposed in an emerging Strategic Plan? In the event that Crest Homes or Savills submit a concept plan as part of this current MM / SA consultation, WPC would expect it to be made available in good time prior to the hearing sessions to properly inform any ensuing debate, and to aid proper cross examination of both AVDC and especially M KC, who should be encouraged to attend. The lack of any form of 'concept plan', to guide residents is the final reason for requesting a further Hearing Session, and if the Inspector is persuaded to hold one, then WPC hopes that he will share our belief that such a plan must be prepared for complete transparency. SECTION TWO - LEGAL COMPLIANCE- DUTY IOCO-OPERATE, 12. WPC have been concerned for some time about the apparent lack of 'meaningful cross boundary discussion' between AVDC and MKC. Yes, WPC understands that 'lip-service' has been paid to this advice by AVDC indicating to MKC what they were doing, but it appears that the two authorities have not properly addressed this key strategic housing allocation - or indeed the two competing alternative sites - through 'effective discussion' 9 or 'proper joint working', which WPC believes represents a significant failing of duty to co-operate at an early stage - especially as M KC is the major town and lead authority, which importantly adjoins the three sites that lie within the AVDC district, and upon whom future residents will be almost fully dependent. The FAQ sheet provided by AVDC, at WPC's specific request, seeks to answer this question and provides dates when 'talks, discussions and meetings occurred', but significantly these took place 'following the publication of the Inspector's Interim Findings and during the site analysis process, with meetings held in December 2018, May 2019 and September 2019, with dialogue continuing with officers. Milton Keynes Council is being formally consulted about the proposal as part of the Main Modifications consultation process'. WPC have asked for the note or minutes recording the meetings but have been informed that none were taken. WPC find this response completely unacceptable. Both authorities must fully understand the importance of 'the Duty to Cooperate' instruction from Government, so surely in order to show compliance they are duty bound to record what discussions took place and what resolutions and agreements occurred. Without such information how can the Council's word be interpreted? WPC believe that in any event these 'dates' do not constitute 'at an early stage' as required by Government direction. Nor does this information sit comfortably with the content of an email from an AVDC officer dated 26 July 2019 that states "On MK, as I said we have not formallyconsulted MK (as Peter Williamsmade clear, we have had to take a stance of keeping things close to our chest until we submitted to the Inspector) but will be part of the Modifications process. Our relationship with MK has been with various officersto ensure they were aware of what we were doing - not looking for support as such but more for information. Mainly phone calls and I'm not aware that the meetings were minuted or notes taken. Our only real consultation with them was with the public transport section at MK as BCC felt that their view was more appropriate as service provider in this area - as I said at the meeting MK public transport favoured Eaton Leys as it reflected their current service review work". WPC believe that had 'effective discussion' or 'proper joint working' been held much earlier in the 'strategic site location' process, perhaps as far back as the 2015 'Issues and Option' stages, then many of the problems being experienced now - especially in respect of site selection, and calculation and distribution of Section 106 monies (discussed separately in Section 8 of this response) - would have ended differently, as we try and demonstrate below. 13. Government requires that adjoining Authorities have a 'Duty to Co-operate' - when considering significant, strategic cross-boundary housing allocations. Such a 'duty' cannot be rectified during a public consultation period. Failure to engage in constructive dialogue with a neighbouring authority at a much earlier stage can lead the Inspector to recommending a non-adoption report to be issued. WPC are not advocating this, but it strengthens our request for a reopening of the hearing sessions to determine exactly when 'cross boundary' discussions took place with this 'strategic' cross boundary allocation and what actually occurred. If the Inspector invites both MKC and AVDC to attend a further hearing session it should be possible to determine whether or not MKC actually agree that Shenley Park site is the most appropriate and sustainable site of those appraised, and the one that best fits Policy SD15 of the recently adopted Plan:MK, which is a specific requirement for any site that abuts MK, wherever it's location in AVDC.. 14. AVDC clearly recognise this Duty of Care. In the 'Proposed VALP Submission November 2017', it states at paragraph 1.9 "Aylesbury Vale does not exist in isolation. It has major 10 conurbations nearby which have effectsacross district boundaries. Councils are under a formal duty to cooperate over strategic issues which cross their boundaries. This means the council has to engage positively with neighbouring councils and other organisations, about issues such as housing numbers and employment requirements." WPC suggests that in respect of S.P. this has not properly occurred, if indeed it has occurred at all. 15. A Memorandum of Understanding between AVDC and MKC was signed in Jan/Feb 2018, and agreed "That the two councils will continue to engage proactively at both Officer and member level in relation to longer term cross border strategic planning issues". The Salden Chase and Eaton Leys sites were specifically referred to in this document, but the agreed "continuing need for active and positive cooperation" was not applied to Shenley Park. AVDC may have paid 'lip-service' to this advice by indicating to MKC (the major town and Lead Authority adjoining the three neighbouring and competing sites) what they were doing, but WPC contend that they have not diligently addressed the key strategic 1150 housing allocation at S.P. through effective discussion or proper joint working. This represents a significant failure of 'Duty to Co-operate' at an early stage, because AVDC have chosen to defer the late inclusion of SP to this MM and SA consultation period, during which they advise WPC that they now expect MKC to respond. WPC believe that MKC officers will probably not wish to 'rock the boat' with regard to future relationships between the two councils, but clearly there is a tension between officers and elected members, made clear recently when members went against officer advice and refused planning consent for the access into the main Salden Chase site (discussed later in this response). WPC worry that good planning is once again being frustrated by political interference - or that councils are not properly undertaking and fulfilling their statutory duty to involve and properly consult with all affected communities, or are making the process particularly difficultto follow and so non transparent and unclear, that those affected by the Plan simply cannot have their concerns properly heard. 16. AVDC signed a further Memorandum of Agreement on 'Strategic transport matters' with four adjoining authorities on 26 February 2018, but notably M KC was not included. This agreement referred to NPPF guidance paragraphs 178-181, and reiterated the duty to cooperate particularly on 'provision of infrastructure for transport', which involves a continuous process of engagement from initial thinking through to implementation. This clearly has not occurred at the SP site to date, and would appear not to have happened at SC either. Bold statements are being made on very serious highway matters, (including from Bucks CC), that seek to justify the SP site allocation, but without any supporting evidence to demonstrate that proper mitigation can or will work. Until highway issues, including capacity can be properly investigated and resolved and it can be demonstrated and proved that mitigation will work through effective co-operation between AVDC, MKC and BCC as the main highway providers, the MM's relating to both SP and SC must be legally non-compliant. 17. MKC discussed the issue of 'cross boundary' cooperation with AVDC at their Full Council meeting on 23 October 2019. The late introduction of SP was a special agenda item. Many residents of Tattenhoe and Oxley Park and Westcroft, attended the meeting as their estates directly adjoin the proposed SP site, separated only by an historic 'drovers route', being the North Bucks bridleway. Elected members across all parties agreed that a failure of co-operation had occurred with regard to the understanding and promotion of 11 the S.P. site. Four specific concerns (amongst several) within the approved minutes of the meeting relating to VALP were recorded, namely :- a) Allocations have been brought up only towards the end of the plan-making process, meaning that community engagement on these sites has been minimal. b) This Council believes that the development could place unacceptable strain on the infrastructure and services in Milton Keynes including on highways and transport infrastructure, quality public open space, GP services and school provision. c) The development proposals lack any conformity or integration with the surrounding and adjoining infrastructure of Milton Keynes. d) Shenley Park would likely be regarded informally and geographically as part of Milton Keynes, but falls outside the administrative boundaries of Milton Keynes Council, so any planning decisions and future income would not fall to MKC. If any evidence is required to show a 'lack of meaningful and ongoing discussions at an early stage' has occurred then these MKC minutes must rank highly in demonstrating a council's failure of duty to cooperate, thereby making SP and MM076 unlawful. ) 18. Non compliance with such an important 'Duty to Cooperate' issue, where MKC should have been engaged and consulted by AVDC, thereby ensuring that the best and most sustainable site was selected, renders this part of the plan both legally non compliant and unsound. It is worth repeating that WPC were informed by an email from AVDC on 26 July 2019 part of which stated "On MK, we have not formally consulted MK (as Peter made clear we have had to take a stance of keeping things close to our chest until we submitted to the Inspector) but we will be as part of the Modifications process". Why was this comment made and what does it mean? This surely is further reason to re-open the hearing sessions to ascertain exactly why AVDC chose not to engage earlier and more fully with MKC and all local residents within both authority areas prior to selecting the Shenley Park site. SECTION 3: SOUNDNESS 19. AVDC's Guidance Notes that accompanied the VALP Proposed Main Modifications Response Form, explain and detail the tests of Soundness, under the headings of 'Positively prepared', 'Justified', 'Effective', and 'Consistent with national policy'. The actual response form then had various tick boxes, two of which are 'Do you consider the Local Plan to be Legally compliant?' and 'Do you consider the Local Plan to be sound?' Unfortunately,these twoimportant guestjonscto not appear within the onlineportal documentation, and so for the avoidance of doubt, WPC wish to make clear that MM076 WHA00l, Shenley Park, Whaddon, is NOT legally compliant (as explained earlier), NOR is it Sound. WPC do not believe that the four tests are properly met, when applied to the SA. The omission of these important tick boxes is one reason why WPC has chosen the form method of response (as opposed to online) - the other reason being - due to its length and detail - the necessity for ease of reading and cross referencing. SECTION 4 : AECOM - SUSTAINABILITY ASSESSMENT (SA) 20. This document forms a crucial part of this public consultation, and is an addendum to the 2018 SA. WPC has serious concerns regarding it's contents and findings and considers 12 that it should not be relied upon and is accordingly 'Not Sound'. The document is dated October 2019, and although WPC does not know (but would like to know) when the report was commissioned and what the terms and conditions of that appointment were, it seems obvious from many comments within that it was compiled post the Main Modifications being drawn up, and is presented in a way that attempts to justify the selection of Shenley Park above the two other competing sites, being extensions to Eaton Leys and Salden Chase. WPC believes this is inappropriate for such an important document. WPC understands that the purpose of a SA is to identify sustainability issues and problems whilst the Local Authority is evidence gathering. Having considered the 'pros and cons' of competing sites (i.e. the reasonable alternatives) and considering ways of mitigating adverse effects and maximising beneficial effects, the SA should then develop the Local Plan options before selecting the most sustainable site. WPC do not believe that this proper procedure has been followed because this SA appears to have been developed - perhaps by retrofitting evidence to make a particular case. That case, WPC believes, is to justify a site that is the Local Authority's preferred choice, for questionable ) reasons, one being 'the easy and quick option', given that time was not on their side. 21. The SA should have been commissioned at a much earlier date, that date being immediately after the Inspectors 4 March 2019 response highlighting the need for 500 new dwellings close to MK, or alternatively immediately after AVDC realised their expected allocations at Buckingham, Winslow and Haddenham were flawed and they would require 600 plus more dwellings (i.e. a total of 1150 dwellings) to fill the void. An example of this is at para 1.1.4 point E) - Introduction, where the SA states 'Given that the required increase in housing numbers only equates to 500 homes and this can be met through allocations in close proximityto Milton Keynes, it seems clear that there is no need to allocate additional land for housing in the villages ..... Clearly this casts doubt on the SA purpose to test reasonable alternatives - and WPC wonders - whether or not in reality - there was sufficient time, possibility or opportunity to reconsider the sustainability of larger towns and villages by allocating more sites in those locations. Whaddon, even as a 'small' village, had been expecting to have to provide between 10 and 15 new dwellings to support sustainable objectives, (as were all other settlements in the district, in varying quantities), but it seems that AVDC took the 'easy option' to replace everything with one large allocation close to MK. This action might address the perceived north-south district imbalance, but does not address the sustainability issues of towns and larger villages in Aylesbury Vale in general. Instead of 10 - 15 new dwellings, which would have been welcomed if the tenures related to village need (i.e. smaller homes and possible retirement bungalows to 'free-up' larger homes), the Whaddon Parish now has to consider a minimum five-fold increase of dwellings from circa 210 homes now, to at least 1150, and possibly a nine-fold increase if 1800 homes are to be built within the Parish boundaries. 22. At AVDC's presentation to Parish Councils on July 23, the following points were stressed by officers. a) All three sites have the capacity to accommodate 1150 homes. b) We have been looking at constraints and updating our evidence base (transport and flood assessments, landscape impacts, ecology, heritage, education,relationship to Milton Keynes etc.) to enable us to come to a conclusion on which site performs best and should be included as an a/location in VALP. c) The new evidence does not provide any show 13 stoppers for any of the sites, or enable a decisive reason to allocate one site over the other two. d) However, there are key pieces of evidence which do guide us towards a decision - in particular the Strategic Flood Risk Assessment (SFRA) and Landscape Comparison Assessment. Both come out in support of Shenley Park as the best site to accommodate the new housing requirement. WPC asks whether the full and detailed SA findings were available at the date of this meeting, and whether or not they really do support such comments from specialist AVDC officers? Clearly these AVDC statements try to justify what is in effect a very unconvincing conclusions by AECOM in the SA at pages 3 and 65, which in parts state :- 'In conclusion, all alternativeshave pros and cons; however the appraisal has not been able to conclude the likelihood of any of the alternatives leading to 'significant' effects, either positive or negative. The appraisal serves to highlight Shenley Park as performing relatively wellin respect of several objectives; however, it does not necessarily follow that this site is the most suitable overall, as the various objectives are not assigned any weighting'. (WPC's highlighting). The conclusion then provides examples where the author suggests "That the Council - as decision makers - might assign particular weight to certain matters." WPC believes these statements cast significant doubt on the report's findings, because WPC, and we believe many other people, do not agree AVDC's undisclosed, unknown and untested method of weighting - if indeed they applied any. 23. WPC are by no means experts in the field of SA's, but it is clear, once again that these statements are 'skewed' in favour of Shenley Park, because the Salden Chase Extension also scores 4, 'number 1 stars', but local knowledge suggests that several of the scoring numbers are not only questionable but also very subjective in their nature - and for some reason Eaton Leys has only been given 2 'number 1 stars' which WPC are struggling to comprehend. WPC therefore question whether the SA can truly be relied upon when recommending such an important strategic site location, and indeed whether or not its evidence is sufficiently robust and properly researched, because it is full of caveats. 24. AECOM in the SA Background, page 1, para 2, refer to the Inspectors 29th August 2018 findings, and at point D) "additional housing land - should be on the Milton Keynes edge; _) there is no need to allocate additional land for housing at Buckingham or at the villages" Similarly, AVDC have stated both at the July 23rd 2019 VALP Parish event "The Inspector is clear that new housing should be on an allocation in 'close proximityto Milton Keynes", and in their recent 'Community News' publications concerning VALP updates that 'The most substantive piece of work was the allocation of a new site in close proximity to Milton Keynes to fulfil the Inspector's requirements for new a/locations in that area". WPC believes that these statements disguise the actual facts, and are an attempt to justifythe only option open to AVDC, given the limited time available, that they should allocate a single large site. The Inspector's response to Council's reply to Discussion Document D5 and dated March 2019, is quite clear to WPC, in that on page 2 it states "so I (the Inspector) agree that new a/locations amounting to around 500 dwellings is what the Council should aim for" It was only later, during the 'key evidence' gathering exercise that AVDC realised that three of their already allocated sites could not, due to infrastructure deficiencies (highway, drainage, flood problems etc.), be depended on to produce the number of homes anticipated. These losses included a 300 house 14 site in West Buckingham (BUC051), 275 houses from Winslow (WIN00l) and some 46 at the North Rosemary Lane site at Haddenham (HAD007). As a result the 500 dwelling figurewas increased, by AVDC and not the Inspector to 1117, and rounded up to 1150 for the VALP. Rather than take time to solve and reconsider the sustainable growth and community benefits that were obviously planned and presumably required in these towns (and which might have been welcomed by those communities - as WPC notes the Buckingham site was in the 'made' Buckingham Neighbourhood Plan), it was the quick and easy choice for AVDC to allocate SP close to MK, which in turn also overcame their dilemma of possibly having to allocate growth more widely in the district to sustainable towns and larger villages. WPC believe the evidence points to this conclusion simply because there was insufficient time to consider suitable sustainable local alternatives. WPC asks that If AVDC appear unable to plan and allocate proper sustainable growth opportunities adjoining larger towns and settlements within their own district (in towns they know intimately), how can they decide and comprehend major growth along essentially uncharted district boundaries, especially without full advice and constructive dialogue with MKC - the authority who will essentially 'feed' that allocation due to their assimilation and close interaction with the site, and secondly, how will AVDC now deal with sustainability issues and lost sites, that exist in the larger AVDC towns and villages? The conclusion is simple, and WPC suggests will set a precedent, once this VALP is adopted and a single Unitary Bucks CC authority assumes control of the district after April 2020. Rather than address the needs of the Vale, it's towns and villages and the sustainability issues within these areas - the simple answer is to allocate homes in the relatively unrestricted north of the district, close to MK. For instance, how will AVDC deal with any 'slippage' of numbers beyond 2033, if Salden Chase is delayed (which now seems inevitable - see later paragraph 75), or if any phased closure of RAF Halton occurs? 25. As previously stated, the AECOM Sustainability Appraisal, that accompanies the Proposed Main Modifications of the VALP, fails the tests of Soundness, and WPC contend that AVDC have selected the least sustainable site of the three that were objectively assessed. For this reason, WPC based solely on local knowledge, common sense and informed logic - without the aid or input of specialist consultants - whose conclusions may ) show bias - attempt to correct in the following paragraphs what are believed to be questionable comments and conclusions within the AECOM SA. WPC believes it is important to carefully analyse, examine and comment on the twelve individual Topics' raised within the AECOM SA, whilst remembering that while the authors have 'starred' the columns, the various objectives are not assigned any weighting. The reasons given in the following paragraphs 26 - 39, lead WPC to believe that Shenley Park should be deleted from the VALP at this time. Thereafter, in this submission WPC will attempt to explain why an extension to Eaton Leys should be the preferred alternative choice of site for the VALP to 2033, and why an extension to Salden Chase should be a possible 'reserve' choice for any subsequent Local Plan review. Looking to the longer term, it is highly likely that promotion of all the sites will continue, and indeed at some future date they may all be developed in part or fully, but WPC strongly believe that .the. choice now. for this Local Plan is to select the least damagjng site first. as opposed to the one that may offer substantial future benefits when sustainability, landscape, highway and 15 public/resident benefits are all considered, post expected Government decisions on major planned infrastructure projects (Oxford - Cambridge Expressway and East - West rail). 26. BIODIVERSITY. Of the circa 250 examination documents placed online WPC could find nothing specific about biodiversity, which this council believes relates to the variety of plant and animal life in a specificarea of habitat, that is considered to be important, desirable, and worth protecting. The 'Discussion of effects' on page 27 of the SA suggests that SP would appear to be more appropriate than SC or El, but only because it is adjacent to existing development and supports larger field parcel features which could accommodate larger blocks of development with minimum hedgerow severance. The scoring reflects this making SP number 1. The discussion goes on to explain the benefits of SP being within a Biodiversity Opportunity Area, (BOA) which could extend ancient historic woodland, create large areas of habitation and facilitate new targeted habitation, all leading to landscape-scale 'biodiversitygain', yet perversely and In WPC's view most importantly in Appendix 1 : Alternatives Appraisal Findings it states :- 'However this is uncertain. Perhapsmore flkelv Is thatsignificant development would becontra,y to BOA/Bucks GI Plan obiectives. In particular,there is a risk of worsening fragmentation of woodland patches (i.e. Reducing ecological/functional connectivity). Both Shenley Park and Sa/den Chase extension potentially give rise to a concernIn this respect'. WPC cannot accept, given the excellent potential that is available at SP for future enhanced countryside access, landscape improvement, habitat creation and given M KC's commitment to becoming the greenest city in the world that this opportunity is being cast aside by the unwelcome introduction of 'significant development', especially at this time whilst a far less damaging site exists at El which is not within a BOA The report concludes that these opportunities can be managed by mitigation 'through standard approaches', .... But surely it must be far more sensible, and good planning principle to develop less sensitive areas not in a BOA location in the first instance, thereby protecting and further enhancing identified BOA areas for future habitat creation, public enjoyment and additional woodland planting, thereby improving that which is already known to exist. Sites such as SP should be the last resort for 'significant' development and not the first, because a little extra woodland planting accompanied by significant development is a very poor substitute for losing, for ever, a large area with such excellent potential. VALP Policies NEl (all para's c-i, especially d) and NE9 must apply. 27. CLIMATE CHANGE ADAPTATION. The scoring appears to reflect just the degree of intersect with a fluvial flood zone. Whilst WPC have scant knowledge in this area, there seems little difference between SP and SC, but in respect of El, the SA 'assumes' that in providing 1150 dwellings it is possible to avoid flood risk, leading to a score of three. Why the SA then introduces the matter of a secondary school in this topic section is strange. MKC advise WPC by email dated 14 November 2019, (attached as addendum 3) that within an earlier planning application on the El site ref :- 15/01533/OUTEIS (withdrawn by the applicants through lack of AVDC support) the Environment Agency and Lead Local Flood Authority did not raise any objections to the development of the site on grounds of flood risk, provided certain planning conditions were attached to any planning permission that was granted. It is also 16 notable that the adjoining site (within MK), that is currently being developed with some 450 new dwellings enjoys similar frontage to the River Ouzel, and clearly any concerns that may have existed there have been satisfactorily mitigated, which will allow new river frontage to be brought into the public domain to be enjoyed by all and importantly with future protection and management of that area being guaranteed by Parks Trust. The scoring does not seem to reflectthese points. Indeed did AECOM investigate this issue, or were they actually made aware of the consultee comments on the earlier planning application by AVDC who presumably as the determining authority were in possession of that information? 28. COMMUNITY. This section includes education and schools, which WPC also address in paragraph 37 below. The SA then addresses 'wider community infrastructure' and correctly states that all three sites are a long way from CMK (6km plus), but this comment fails to identify that access to CMK is considerably better and easier from EL, which is just one major roundabout junction distant from the A5 trunk road (diversion) which then provides fast, easy and uncomplicated access to CMK, the main line railway station, and the many social/entertainment/shopping facilities not available within local centres (Le.restaurants, cinemas, theatre, major chain stores etc.) The same journey from either SP or SC involves 8-10 roundabouts whilst crossing three main east-west grid roads (Tattenhoe Street V2, Fulmer Street V3 and Watling Street V4) all of which offer the considerable frustration of heavily congested traffic, especially but not exclusively at peak times. It is not uncommon on certain roundabouts to have up to half a mile traffic queues (approaching one grid square) which can take at least 10 - 15 minutes, or longer to negotiate. This inevitably leads to unwanted and unnecessary levels of pollution, and frequent accidents. On this point alone EL should have scored much more favourably. Similarly, WPC do not agree the SA 'wider community' comments, which omits the fact that SC is about the same distance from the Westcroft centre, and whilst EL may be slightly constrained by the canal and river Ouzel, the commentary omits to inform that new connections to Bletchley will be forthcoming from the approved planning benefits associated with the EL Barratt site in MK. These include a new redway along the A5 corridor, and a new cycle/pedestrian footbridge over the River Ouzel. The EL site within AVDC, would include similar benefits once planning consent is approved. The importance of cycling and walking connections do not appear to be properly recognised within the SA. WPC agrees that all sites would have good access to the countryside - that is obvious, but again the SA fails to appreciate - and score appropriately - the enormously added benefit of opening up and making public access available for the first time, to the remaining eastern bank of the River ouzel, which would be a tremendous asset to the existing Waterhall Park. This, for the firsttime would facilitate complete access (with the Barratt site included) to over one and a half miles of further riverside walk. This side of the river is in need of improvement and management, and WPC have no doubt that with The Parks Trust being the likely beneficiary, this would be an exciting and welcome benefit to a much wider community than that on offerat the alternative sites. This seems especially important to WPC, because the future care and maintenance of public open space within the AVDC areas of MK growth are unknown and therefore questionable. This is a point wee would liketo Investigate at areopened Hearing session, because both AVDC and 17 Crest Homes remain silent on this important issue. Excluding the school element· which the SA agrees is an unknown quantity, WPC finds the scoring on Community wrong, as it should recognise the travel and POS benefits and constraints more appropriately and score EL No.l, being the site which offers, by far, the most benefits to communities. 29. ECONOMY. The SA chooses not to score this section which appears to be solely based on the fact that none of the three sites offer employment opportunities, yet the discussion singles out SP and states that 'SP in this location may be supportive of employment growth in the local area, noting that the site is located along the east-west corridor, at the southern edge of Milton Keynes, which is an emerging growth corridor'. The Inspector must know that all three appraised sites fall within this corridor, (and WPC discuss prematurity later at paragraph 38) but given the route remains under discussion, and may yet be reviewed following the recent strong Conservative majority election result, it is highly likely that of the three sites SP is actually the worst located - being the furthest away from both the east-west rail line and likely expressway route, which if as reported, may generally follow to the south of the rail route. However, for this Local Plan, this topic deserves to be scored based on 'travel to work time' (one of the Inspectors reasons for wishing to see sites close to MK due to NPPF requirements), and distance to/from existing employment facilities - especially when walking and cycling is factored - which are very important considerations. SP and SC are both, without doubt furthest away from existing major employment facilities, with only very limited opportunity existing at Snelshall East and West being within about 1km distant. By comparison, EL has much better and faster transport links to eight plus major employment districts at Bletchley, Caldecotte and Tilbrook etc., all within 3-4km. It only needs a cursory look at a plan of MK to realise that to the south and west of the V4 Watling Street, and main rail line, the land use is predominantly residential, with the vast majority of larger employment locations being 'pepper potted' around all areas north and east of these two transport corridors towards the M 1 motorway. SP and SC, are located as far south-west as you can currently go within MK, and as detailed in paragraph 28 above have serious connectability issues in respect of vehicular access via the MK grid road system. On this basis Economy should show EL as the best performing and preferred site. 30. HERITAGE. Frankly, WPC do not understand the logic here, and it seems the SA is doing everything possible to make a case for developing SP rather than considering the actual 'on site' facts. Specifically on EL, it states 'The development of the site has the potential to affect the setting of the scheduled monument of the Roman Town of Magiovinium and Roman Fort that is located to the north-east of the site as well as the setting of the grade 11 listed Mill House and canal bridge to the west. Any proposals for the development of the site a/so have the potential to affect the setting of the listed buildings within Water Eaton and Fenny Stratford while there is a/so potential for key views from the Brickhi/1 Conservation area towards the site and the scheduled monument of Magiovinium to be affected.' Once again the discussion appears very 'tilted' in favour of ensuring that SP remains the favoured candidate. Are AECOM oblivious to the fact that the 450 or so houses currently under construction by Barratt Homes on the MK Eaton Leys site lie directly between that 18 site under development and the scheduled monument, and if any site is likely to affect the setting of the ancient monument it is the Barratt one. Sadly any damage - if there is any - is already done and it is difficult to see how the EL site within the AVDC district can make matters worse, if at all, as it is further away, beyond the Barratt development! In respect of the other points, where settings of listed buildings and views are observed as being potential problems, the damage (whilst limited in WPC's view due to existing landscape screening) has already occurred following the granting of planning consent on that portion of the overall site lying within MK. Similarly, AECOM report on the AAL status of the EL site, and whilst WPC understand (but do not agree) this point, the original boundaries of this area were based on county and road boundaries, which have now been severed by the A4146, and the potential 'trade off' benefits of gaining important riverside POS, as previously mentioned are not discussed. However the impact on all these points is unlikely to be totally apparent until the 450 plus homes already under construction along the full north-east boundary are completed by Barratt Homes in the next 3-4 years. The SA makes reference on EL that 'there is also potential for key views from the Brickhi/1 Conservation Area towards the site and the scheduled ancient monument at Magiovinium to be affected'. No doubt the Inspector will make his own mind up on this matter, when he visits the locations in question, but from WPC's perspective, (having viewed the locations) the 'under construction' Barratt Homes site will block out views (if any) of the ancient monument, and even if some views might be affected from the conservation area, these are limited (as there are few public access points) and from over 1 mile away will appear minimal. If a few homes on the north-eastern edge of the village are affected, these again are very long distance, and 'enjoyment of a view' is understood by WPC not to represent a legitimate planning ground for refusal. Other homes in the Great Brickhill C.A. tend to face south-west and the EL site is not visible. The much admired view from opposite the now closed 'Duncombe Arms Pub' at 32 Lower End, Great Brickhill demonstrates this, with long distant views over Stoke Hammond and Drayton Parslow to Mursley and it's landmark water tower on the horizon. From this vantage point Eaton Leys is not visible to the north, but a slither of the recently built Newton Leys to the west clearly is. One public footpath runs just to the south of the village church, from Church Lane and from this vantage point the EL site is just seen as a thin slither behind the heavy hedged and . ) planted A4146 road, with the existing built form of Bletchley, Fenny Stratford and MK as the prominent backdrop rising up to the horizon. The EL site if built would be barely visible, and what is interesting is that the recently completed major development at Newton Leys, to the west (and the A4146 running in that direction) are much more visible in the overall landscape, even at this long distance. There is one view that would be affected, that being from the footpath running south from Fox Farm road, as you leave Little Brickhill travelling down to the main A5, and whilst medium middle distant views would be affected, these are already being interrupted and damaged by the 'under construction' Barratt Homes site, beyond which the city landscape rises and dominates. Finally on heritage, despite the SA trying to make a case for SP as the preferred site, by highlighting mitigation measures, WPC believe that on balance EL will cause the least damage, simply because of the planning consent recently granted by MKC which has unequivocally changed the status and potential of the site. As pressure for housing grows WPC believe that it is inconceivable that the EL site will remain undeveloped due to its contained nature and newly built boundaries, so to develop it now - before valued and 19 unconstrained open countryside' is taken prematurely and lost for good, seems to be eminently logical and to do otherwise represents very poor planning practice. 31. HOUSING. WPC understand how and why AECOM have come to the conclusion that 'it is not considered appropriate to differentiate between the three alternative sites', but whilst accepting that all three sites could contribute towards housing needs, the crucial issue here is - 'are the sites able to deliver the required housing numbers within the VALP period to 2033?' AECOM do not address this issue. Firstly, EL has a fairly lengthy planning history and is 'way ahead of the game', especially having already made a planning application - albeit subsequently withdrawn because, WPC believe, progress could not be made with AVDC. Importantly however EL does not appear to have the serious highway issues that blight the other two sites - indeed Bucks C.C. view EL as the site that performs best in highway terms. By comparison both SP and SC are inextricably linked to highway tensions that clearly exist between AVDC, BCC and MKC together with residents from both MK, Whaddon and Newton Longville on 'live and ongoing' highway issues and concerns. These mainly relate, but are not restricted to, capacity and safety on the A421, rat running, road safety concerns in affected rural communities, whether or not satisfactory and workable connections can be made to the existing MK grid/estate roads and what are 'workable' solutions for existing rural roads that are affected by much increased trafficmovements. AECOM can perhaps be forgiven for not knowing the full extent of these problems, especially not living In the affected areas and presumably unaware of the very recent decision of M KC to refuse access into SC. If as looks likely, an appeal is pursued by the developer consortium promoting this site, the result is uncertain and could take many months to resolve. This gives AVDC a problem, because the possible allocation of SP must be dependant on not only the result of the appeal on SC but also the outcome of highway connection discussions and capacity constraints on the A421. It surely cannot be wise to allocate a new SP site that is dependant on the outcome of such complex and unknown traffic and highway scenarios, especially as these are intrinsically linked to the same highway issues - and possibly worse considering the unknown connection costs that will be necessary to connect to the MK grid system. The ) allocation of EL instead of SP removes these concerns at a stroke, at least in the short to medium term until these problems are resolved - and those of 'guaranteed housing delivery' within the plan period to 2033. 32. LANDSCAPE. Again, it seems to WPC that AECOM are trying to justify the allocation of SP, rather than objectively trying to demonstrate which of the three sites is most suited for such a large amount of development. The SA advises that a Strategic Landscape and Visual Capacity study (2017) finds :- 'only 35% of the SP site is likely to be developable on the basis of sensitivitywithin the landscape, but yet again this can be mitigated by retaining and enhancing existing areas of perimeter woodland'. Disappointingly the SA raises yet again the opportunity of providing a long term defensible boundary to the western edge of the MK, but fails to mention the one that already exists in the form of the North Bucks Way bridleway, also referred to as the Milton Keynes Boundacy Walk, on Google Maps. WPC have little confidence in AVDC's ability to ensure such a boundary can be provided - let 20 alone be guaranteed, given the comments made by their officer (see para 40 below), and the 'future direction of growth' arrows drawn on the 2014 Crest Homes 'Development Opportunities Plan'. Developments of this size and nature are normally bounded by landscaped Public Open Space, to ensure proper transition between the built form and the open countryside beyond. WPC could be persuaded that a long term defensible boundary is feasible, but only if the ownership and future management of this land was vested in Whaddon Parish Council, or indeed a reputable management company such as the MK Parks Trust, - but such action is highly unlikely to occur, especially at SP. WPC predicts that a private management company would be set up, and rather than an endowment made by the developers to a responsible body for future long term management and maintenance, this cost would probably be passed to future house owners as a management fee, thereby ensuring the future control of the land - and importantly the land beyond - remained with the developers. WPC would like to understand how edge land and boundaries would work in practice, and what distances relate to and are acceptable to avoid coalescence, if the SP site is to be confirmed in the VALP as the preferred site? These are fundamental planning questions that residents deserve to have answered prior to allocation, at a hearing session, and should not be left to uncontrollable developer interests at an unknown future date, post allocation. The discussion in this SA section refers to the site specific policy, which reads 'The site will be designed using a landscape led approach. The development design and layout will be Informed by a full detailed landscape and visual Impact assessment (LVIA). It will provide a long term defensible boundary to the western edge of Milton Keynes. This recognises that whilst being totallylocated in Aylesbury Vale the development will use some facilities in Milton Keynes, given it's proximity Milton Keynes will also provide an access point into the site. WPC have commented previously about the long term defensible boundary, but have serious reservations on these and other comments that need to be explored at the new hearing. AVDC are completely underplaying the extent of the role that this site will be dependant on MK. To say "the development will use some facilities in MK given its proximity" is an even greater 'untruth' than some of those proclaimed during recent ) electioneering campaigns! The development and more importantly it's future residents will almost certainly use 'all' (not some) facilities in MK, and AVDC are acting irresponsibly to suggest otherwise. The only exception will be the social and community facilities that are actually delivered on the site by the development itself - and those may not be delivered early enough or in a timely fashion to please early occupiers. And, it is noted that only a 'contribution' towards a healthcare facility (site or temporary building) is required in the MM076 - Is this really sufficient for some 2500 residents? Almost every other 'facility' used by future residents will be MK based. Not only are they making a totally misleading comment they are starving MK of infrastructure money, as MK elected members have recently been quick to point out, at recent public committee meetings - and which WPC explore later at Section 8. Additionally AVDC say 'an access' (singular) whereas Crest Homes highway advisers are saying two connections to MK grid roads, and possibly a third to a minor road. WPC believe there are too many uncertainties and potential 'stumbling blocks' that have not been properly discussed between authorities or with 21 interested parties, and these reflect in the current tensions apparent within the two local authorities. A further issue is that of 'edge/transition' land use (green infrastructure). Many developers view such land as the ideal location for playing fields and other public uses, as it does not take up land that might otherwise be used for housing. Such community uses often attract intrusive lighting, large parking areas, pavilions etc. which WPC do not consider appropriate uses in land designed to avoid coalescence. These facilities should be located more centrally within the development close to the homes they are meant to serve. WPC accept that these slightly less, but nevertheless important issues, could be addressed during early Supplementary Planning Documents (which are essential in advance of any detailed planning applications) and future public consultation, but even so they should be viewed as being part of a strategic site allocation. WPC would go as far as suggesting that any SPD's should be drawn up jointly with MKC, to ensure it complies with Plan:MK Policy SD15. Properly planned, appropriately funded and well managed parkland, woodland planting and perhaps allotments are viewed by WPC as being acceptable land uses in these sensitive transitional edge of development areas, thereby guaranteeing that the separate identity and longevity can be permanently maintained. The SA in the discussion section tries hard to justify the allocation of SP above both EL and SC. These claims need to be examined, especially those such as 'The Eaton Leys site is considered to have a lower capacity to accommodate development than the other two sites'. WPC asks, where has this information come from, and have the promoters of the EL site been asked as to whether or not this assumption is correct? Also at the presentation to Parish Councils in July, AVDC officersstated, and put in writing 'All three sites have the capacity to accommodate 1,150 homes', so who and what are WPC expected to believe? The SA then discusses the impact of a green infrastructure corridor, that softens the MK edge at EL, and an existing watercourse that results in a degree of separation from the existing 'settlement pattern' at SC, but without any mention of comparison or consideration of the old 'drovers road' along the North Bucks Way corridor, which WPC and others believe to be at least equal if not a better MK edge to the west of MK. WPC also ask, 'what existing settlement pattern is the SA referring to at SP and SC, because neither Ta ttenhoe Park nor Salden Chase sites have yet commenced?' Sadly, WPC find the SA unconvincing with many questionable statements - not just within the Landscape section of the report, but throughout. The landscape appraisal should not be relied upon, as it highlights the impact that the major access road will have on the most sensitive part of the SP site - which importantly was not factored into the Landscape Appraisal. The SA states that 'It is not considered appropriate to highlight Shenley Park as the most preferable site ahead of the Sa/den Chase extension, contraryto the findings of the Landscape Appraisal' and 'Eaton Leys is the worst performing site but the Landscape appraisal does not conclude significant impacts'. At their VALP Parish meeting in July AVDC officershighlighted Landscape Comparison Assessment as one of two points that guided them to a decision - albeit a very close choice - for SP the other being flood risk assessment. WPC would suggest that if AVDC are relying on this SA for either landscape or flood risk evidence then their preferred choice of SP being the most suitable and sustainable site is seriously flawed and these issues should be re-examined at hearing. In making these comments WPC have had reference to Policy NES Landscape Character. 22 33. NATURALRESOURCES. The SA scores EL at 2, with both SP and SC at equal 1, but then states 'The permitted site adjacent to Eaton Leys (circa 450 homes) comprises mostly grade 2 agricultural land, which serves to highlight that loss of BMV agricultural land is not necessarily a barrier to development. Whilstthe concluding paragraph omits to mention which is the worst performing site, it concludes that it is inappropriate to apply significant negative effects, as it is a relatively small area of land to be lost. Although all three sites have grade 3b land, WPC wonders whether with expected and worsening climate change, population growth etc. is it not more important to consider the actual amount of productive agricultural land to be lost rather than the similar land quality? EL is by far the smallest site, being 9ha (22 acres) smaller than SC but some 32ha (79 acres) smaller that SP. Surely the loss of so much potentially productive land is a far greater reason to consider, rather than the minimal difference in grade of agricultural land quality. WPC believes that this is yet another, and far more important reason for selecting EL in advance of SP, and are equally surprised that Policy NE7 (Best and most versatile agricultural land) does not reflect this, because WPC believe that development at SP does not outweigh the harm that would be caused by the irreplaceable loss of so much agricultural land with so much BOA potential. 34. POLLUTION, WPC have no reason to question the non scoring within this section, but please refer to paragraph 25 above which highlights the impact of travel to work, 'ease and time', which inevitably has an impact on air quality, pollution safety and residents quality of life - even in a city designed for motor car usage. This will only change with major improvement in electric vehicles, where MK is taking a leading role ..... but this necessary change could be 20 years away. Whilst WPC understand Government's desire to change people's travel habits, and mode of travel from private car to public transport, they could be fighting a losing battle in MK. WPC suggests that distance from the approved site to places of employment becomes a very, and probably the most important consideration in this section, as does the ability to walk and cycle to nearby destinations. If the Inspector agrees with WPC, then this section should, without doubt highlight EL as the preferred location for a minimum 1150 homes with possibly some 2000 vehicles, scoring it well above the two competing and appraised sites at SP and SC. 35. TRANSPORT. A great deal of this submission (in other sections and paragraphs) relates to traffic and transport and WPC do not wish to repeat those arguments here. WPC have no reason to question the SA findings that support Bucks cc, inasmuch as EL being the best performing site. The SA once again attempts to justify the selection of SP by saying 'Shenley Park also performs relativelywell' (note the word relatively!), but there are simply too many uncertainties, concerns and ongoing problems to change the conclusion that EL performs best, and can deliver the required dwellings within the planperjod. WPC would not wish the Inspector to underestimate the importance of traffic impact during these proceedings, especially on the residents of Whaddon, Newton Longville and nearby MK residents in Tattenhoe Park and Kingsmead. The impact on MK grid roads, the A421 and the adjoining rural road network must be realised and concerns reduced 23 because as a consequence of these two major developments at SP and SC traffic and highway congestion can only get considerably worse. WPC Councillors are not traffic experts, nor are the residents we serve, but jointly it is them that have to suffer the consequences of the traffic increases that major developments of these scales generate. Ideally, before this VALP is adopted (thereby casting these developments virtually in stone), proper traffic modelling must be undertaken JOINTLY between BCC, AVDC and MKC, all of whom have vested and crucial interests, not least financial ones. WPC ventures to suggest this should have been undertaken at a much earlier stage as part of early and meaningful cooperation - but it is too late for that now! Crucial traffic and highway assessments should not be driven simply by the development industry, but carefully planned by a joint authority approach, ensuring that compatible technology is employed and fit for purpose. The results should be transparent, legible and easy for those affected - i.e. local residents - to understand, so that appropriate and timely highway improvements can be implemented, with the necessary finance coming from either Government or developer/landowner resources, paid for from the huge financial increase from agricultural value to residential use value. It is unfair that those responsible for the major developments that create highway problems, should not pay the improvement costs, thereby effectively passing it to settled residents through their local council taxation. WPC highlighted earlier, the problems that already exist at certain MK roundabouts and the problems crossing three main 'V' highway routes, but has the SA or anyone realistically modelled or financially costed what the impact of this new transport corridor through SP and running from the A421 to Childs Way and/or Chaffron Way will do in reality? Clearly BCC, AVDC and the developers believe that by providing a new access route into MK will ease the rat running through Whaddon, and ease congestion at Bottledump roundabout, but in reality will it, and what about the problems it will cause elsewhere if it does not? Childs way has to be accessed via Saltwood Avenue and a landscaped MKC/ Highways reservation strip, and if MKC agree to this some 500m of new road, footpaths and redways needs to reach Whitney roundabout before it reaches Childs Way proper - which essentially is single carriageway and would probably need dualling (bearing in mind the amount of traffic that might be tempted/encouraged to use this route from the A421). WPC notes that sufficient land is available/reserved for dualling this part of Childs Way, so should development within AVDC that is dependant on MKC infrastructure not contribute towards such necessary improvement, or do MKC residents pay for it from their future taxation? Not until you reach the Shenley Roundabout (via the Oxley Park roundabout) some 2km distant do you reach the wider dualled section of Childs Way, which would safely accept the likely increased traffic volumes. This potential problem might be mitigated by opening a second 'through' route along ChaffronWay, but the problems here, running through the highway reservation strip alongside Canterbury Meadows and via Hayton Way, a predominantly residential area with off street parking with no real dualling capability built in, are probably worse, especially in road safety and pedestrian terms. It should be remembered also, that this particular link has never been opened due to the concerns about the amount of extra traffic that would be generated in the Whaddon Village direction, adding to the rat running problems. Are MK likely pay these enormous extra infrastructure costs ...... WPC don't think so. Think again - drivers are sensible, they choose (after learning the hard way) the quickest and shorter routes to 24 their destinations, and they would soon realise that rat running through Whaddon, or continuing up the A421 is by far quicker and easier than tackling the MK grid system (especially at peak travel times), thereby adding greatly to the existing problems in these areas. Clever computing modelling by developer employed consultants may show different conclusions depending on the input data and predictions required, so this is why WPC suggest that a joint MKC/BCC/AVDC/ initiative, perhaps with Government help is urgently needed, to solve these perceived problems, and is in WPC's opinion the only acceptable answer, unless the existing problems are left to be exacerbated. WPC is both surprised and concerned as to why these issues have not been highlighted or investigated by the SA and why given such problems, solutions and answers have not been provided before now by AVDC. The scoring method simply ignores these concerns. 36. WASTE. WPC have no reason to question the SA findings, other than to suggest that there could well be implications for waste management in respect of local household disposal sites, which is not addressed by the SA It should not be forgotten that these will be frequented and used often by the 3000 - 3500 approx residents of the new homes. It is clear to WPC that the residents of at least 1150 new houses will need access to Household refuse sites, and whichever of the three appraised sites is eventually chosen, they will undoubtedly use Bleak Hall which is just 5km distant as opposed to the nearest site in AVDC at Buckingham which is 16km distant. Many Whaddon and north AVDC residents already use the Bleak Hall facility. WPC ask, what arrangements have been made or what cross boundary discussions have taken place to resolve this possible tension, and indeed, are MKC aware of how many AVDC residents already use their waste facility? Will the new Bucks Unitary Authority make a substantial contribution to MKC to facilitate the continued use of MK waste facilities or will the doors to Bleak Hall be eventually closed to AVDC residents meaning much longer car journeys to Buckingham adding to pollution concerns and even more A421 congestion? Again the SA does not address this situation. 37. EDUCATION. The SA does not specifically include education within its 'Topics' list but in 'Discussion of effects' it raises 'a degree of uncertainty in respect of a secondary school delivery', 'the need to minimise travel to school', and suggests that 'as Bucks cc favour larger secondary schools on 7-9 ha of land, financial contributions towards expansion may be considered, rather than the provision of a new secondary school as part of a new development'. However, in appendix 1, under alternatives the SA ventures to suggest that SP with its density constraints may not have the ability to direct funds to a secondary school, but it may be a suitable site for a secondary school on the landscaped constrained southern part of the site. This appears to WPC to be looking for justifiable reasons for keeping SP in the plan, rather than trying to solve the education problems in the first place. The SA confirms that landscape and density constraints exist within a BOA area, especially to the south of Shenley Road, so perhaps the site selection is indeed flawed, and an alternative site should be considered. A school, or indeed any development in this location, would be very unfortunate in the extreme, because from all along the A421, and especially from the footpath that crosses the site, the views into and across this expanse of gently rolling countryside are particularly fine and deserve to be given protection. 25 38. PREMATURITY. Whilst this is not considered within the SA, the Inspector commented on it within the discussion papers, so it is important for AVDC to consider and plan for the Oxford to Cambridge Expressway. The Inspector is saying that without certainty of its route, this future major highway infrastructure should not influence the Council's choice of site at this time. Once the route is known and the new East West rail link reopens there will be a review of this VALP, as these strategic links will dictate where future areas of major growth (and where a possible new village/garden town) should realistically be placed. So, although prematurity is not an argument that the Inspector is likely to listen to now, surely it is common sense and good planning practice to use the least damaging and disruptive sites first. Why destroy valued open countryside until it's need is proven, especially when better and less environmentally damaging alternative sites are available? Also, if the expressway should proceed, it is highly likely that the preferred route - will as suggested, lie to the south and parallel with the reopened railway line. If this is confirmed then both EL and SC will be closer than SP, making SP the most unattractive in location terms. It Is totally Indefensible to make a decision that will adversely impact on this area and those living here, based on "convenience" and "time" reasons, without looking at the bigger strategic picture for the future, and making reasonable judgements. 39. CONCLUSION ON SA WPC can only reiterate what the SA concludes :-'The appraisal serves to highlight Shenley Park as performing relatively well in respect of several objectives; however, it doesnot necessarilv. follow that this siteis the most suitableor sustainableoverall. as the various ob{ectives are not assigned any weighting'. (WPC highlighting). WPC believes that the SA (addendum to the 2018 version) is seriously flawed and should have been written to advise on the most appropriate site, and not simply as it would appear, to justify a site already favoured by the Local Authority. It is clear from certain paragraphs that this document was written after the Main Modifications were devised and produced, which is . ) way too late. A public consultation should have been undertaken much earlier. WPC do not believe that the SA is a meaningful document that can be relied upon, in relation to the evidence it provides, and accordingly the document is profoundly UNSOUND. The SP site cannot and does not offerthe opportunities available at the two alternative sites. The inherent opportunities and constraints, not least the unknown traffic implications, and inexplicable landscape and flooding concerns raised by AVDC, suggests that in fact SP Is the least favourable of the three sites when closely examined...... So, WPC now ask, why delete SP now, and where should these 1150 new homes go? WPC now attempt to answer these questions :- SECTION 5: MM056- SHENLEY PARK. WHADDON - (WHA00l) and the SA. Reasons why this site should be deleted from the MM and YALP. atthis time. 40. The SA under table A page 2 states c.1,150 additional homes. The original AVDC modifications stated 'around 1150 new houses', but the revised version states 'at least 26 1150 new homes'. Minor differences, but with potentially devastating consequences bearing in mind that the SP site may have the capacity to provide up to 2000 houses, as stated in the Crest 2017 Vision Statement and Master plan. Crest Homes, in their May 2014 'Development Opportunities Plan' have demonstrated an even more dangerous concept by showing future development directional arrows heading further west, towards Coddimoor Lane, well beyond the boundary they are currently proposing, possibly meaning they have longer term ambitions to exceed this 2000 dwelling figure. AVDC are well aware of these possibilities, so WPC ask "What would the conclusions of the SA findings be if say a figure or 1800 new homes were applied, or an even greater housing figure if the 'future direction of growth' arrows were followed, and why was this eventuality not factored into the SA during its production? Additionally, how would this quantum of housing impact on the as yet untested traffic and highway systems both in AVDC, MKC and indeed through Whaddon? These are major concerns, and Whaddon residents have reason to be anxious, especially when the Planning Policy director at AVDC when asked the specific questions "what forms a defensible edge" and "How long is long term" answers "a major road, significant landform features, a river etc., ..... but ttmewiseonly to the next reviewot thePlan!" 41. Depending upon how and where access to SP is gained, it would be necessary for new 'grid roads' or 'city streets' to cross the strong and natural boundary that currently forms, and has been recognised by previous Local Plan Inspectors, as being a long established, strong defensible western edge to the existing bullt up area of MK, separating It from the rolling open countryside beyond. The only exception might be the possibility of extending H7 Chaffron Way to join Shenley Road (which itself joins two lengths of the bridleway abutting Kingsmead), but this may not be without it's problems and has always been dismissed as a feasible option due to the increased trafficthat would be directed towards Whaddon. Cutting through the ancient Bridleway (BW006 & BW009) referred to locally as the North Bucks Way corridor, or to cut through the Bottlehouse Plantation, in any other location (H6 - Childs Way, or the as yet unbuilt Tattenhoe Park - where unknown land ownership issues might exist?) will unnecessarily exploit/damage attractive and as yet unspoilt countryside - virgin land which does not enjoy any further logical outer boundary that could be described as being as good or similar, long-term defensible boundary. The bridleway is a valuable ecological and wildlife corridor, a county and planning boundary and not least an important landscape feature, running on from the Shenley Ridge to the north, that has been identified in previous Inspector decisions as being an important break between Milton Keynes and the valued open countryside beyond, to which the route provides access. WPC are frankly astounded that the SA report fails to mention this important feature in either it's Landscape or Biodiversity sections, a point especially notable when you consider that at their Full Council meeting on 23 October 2019, elected members across all political parties of M.K. Council agreed to ensure that 'biodiversity' and 'natural processes' were placed at the top of MK's agenda, with ambitions to become the 'Greenest City in the World', with a vision of becoming a 'World-leading sustainable City' whilst celebrating the rich variety of wildlife by protecting landscapes and habitats etc. Crossing the hugely important North Bucks Way bridleway, wildlife corridor into much valued open BOA countryside would destroy such MKC ideals, especially when less harmful sites exist such as at EL. This again would appear to highlight the lack of effective 27 cross boundary discussion between the two Councils, but hopefully this consultation process and possible hearing will allow M KC to arbitrate on which site best fite its World leading ambitions, sustainability requirements and newly adopted Plan:MK SD15 and other related landscape policies. 42. Whilst on the question of possible access points WSP (highway and transport advisors to Crest Homes at the Draft VALP stage - and more latterly RPS in their December 2017 Deposit VALP representations) have suggested 'a primary access from the A421, with secondary accesses onto Shenley Road and Saltwood Avenue with perhaps additional minor accesses from Tattenhoe and Kingsmead'. WPC suggest that the description of 'a secondary access onto Saltwood Ave' is majorly underplaying this route's importance. Connection to Saltwood Avenue would essentially be a major extension to grid road H6 Childs Way, and whilst this land may be retained by MKC as a possible future grid road extension it is bound to prove very unpopular with residents of large adjoining residential areas who did not 'buy into' this concept, nor probably were advised or informed by solicitors/agents at the time of purchasing their homes, about this land's future prospects and use. Why? - because of course SP was not in any approved Local Plan at that time! Objections can also be expected from Hayton Way and Shenley Road (through . Kingsmead) residents, because this would similarly have to involve an extension of H7 Chaffron Way, which leads into Hayton Way and runs up to a further 'grid road reservation strip' alongside the recent conversions and new build at the Tattenhoe Bare Farm complex. WPC are unaware as to whether or not any of these potential accesses are protected by third party 'ransom strips' or whether Crest Homes enjoy unfettered access onto all the MK highway system - but this is a point that needs answering because an undevelopable site due to inability to easily connect into an appropriate highway system, or indeed the huge costs of upgrading existing roads, can lead to costly delays, which in turn may affectand impact upon dwelling deliverability within the Plan period.. WPC would like assurances from AVDC, and indeed MKC Highways, that these issues and costs have been fully and thoroughly investigated, because if not, it again suggests a lack of cross boundary discussion between AVDC and MKC and highlights the importance of early discussion with residents, who will have almost certainly been unaware of these ) proposals emanating from an adjoining Local Authority's emerging Local Plan. 43. Again, on the crucial Highway and Transport issues, the SA states at 9.12.2, 'The proposed new strategic location at Shenley Park performs well in the sense that it is located at the edge of Milton Keynes, which is a major employment location. The site also has good potential to gain access from the major road network, and there is moderately good potential to support modal shiftaway from the reliance on the private car and towards walking, cycling and use of public transport. On this basis the proposed modifications are predicted to result in positive effects". The SA does not once consider the impact on the rural road network served off'the major road network', nor the ongoing and worsening rat-running through Whaddon village, a year on year problem which is well known to both AVDC and MKC Councils. Recent discussions with both MKC and AVDC conclude that the two authorities use different traffic modelling methods, neither of which are capable of determining the traffic impacts on the rural road network. AVDC tell us the solution will be subject to further testing at a later date, whilst MKC tell WPC that they will 28 review all the evidence provided by the Bucks County Wide model to inform the MK consultation response. Furthermore, MKC advise WPC by email dated 14 November 2019 (Addendum 3) that "If as a result the Council consider the modelling to indicate a clear preference for one of the alternativesites, or that the modelling is insufficientto cover MKC interests and concerns, eitherfor site selection or the specific Shenley Park tests, the council would raise these concernsin it's response, recommending how these concerns should be addressed". WPC will be very interested in MKC's response, but despite advising WPC that they will consider Whaddon's rat running problems, this surely will be difficult - if not impossible - without origination and destination data which has implications on travel times/routes within the rural areas where minor inappropriate roads join with MK grid roads or major County 'A' roads. WPC suggest that traffic and directional highway matters are two of Whaddon residents main concerns, and the SA conclusion is absurd and wildly off the mark, as the following paragraphs will demonstrate. 44. Bucks CC have stated in an undated response to an AVDC request (document reference ED215A) "The advantage of the SP development is that it has the potential to provide a new grid road which would address rat-running through Whaddon". When asked to explain "how will this happen?" AVDC had no plans or answers, only to say that this will be resolved following further traffic investigations at the detailed planning stage. Answers must surely be provided D.QW,before such a major site is confirmed in a Local Plan, as the impact could have a devastating impact on Whaddon, it's residents quality of life and road safety, all due to the ever worsening rat-running through Its two conservation Areas, and past a primary school and playgroup, held in a Village Hall which is oftenvery busy with many other varied events. Through traffic numbers and higher levels of HGV's have worsened year on year since development at MK began ..... despite a traffic calming scheme costing approx £110,000, being installed some six years ago and paid for mainly by the now defunct Government controlled MiltonKeynes Partnership. who recognised the impact that traffic generated by an ever growing MK was having on the Whaddon Community and rightly and sensibly diverted MK Tariff monies to help rectify the problem. Developers of the ongoing major Western Expansion Area and BCC also contributed smaller amounts, with Whaddon Village not being expected to contribute anything. ) However, whilst reminding drivers that they are travelling through a village community, and perhaps improving the driving standards and courtesy of some drivers, sadly the scheme has done nothing to reduce the volume of traffic or speed of some impatient drivers - who now race to beat oncoming motorists, rather than 'give way' to any oncoming trafficat the three strategically located road narrowings. The Traffic data collected from the Whaddon MVAS signage showed an average weekday count of 2024 vehicle movements per day in November 2014. This figure has increased to 3098 in November 2019 - an increase of 50% in just 5 years. The Inspector will also be interested to learn, that if and when the 1855 home SC development proceeds, Whaddon Village is to benefit from a ·very hard fought for', £22000 section 106 contribution towards 20mph 'Variable Speed Sign' School warnings and new kerbing for damaged highway verge areas. These are welcome improvements, but also act as a clear and urgent reminder of the damage caused, and dangers arising from the unwelcome impact of major development on rural roads - in particular the ever increasing traffic and safety concerns through a small community, which it would seem, are impossible to reduce or control. 29 45. Within the same document Bucks CC state "The DS4 scenario - with Shen/ey Park removed and 1200 at Eaton Leys has the least impact on the Buckinghamshire highway network". Furthermore it states "the DS3 scenario with both Shenley Park and Sa/den Chase appears to perform worse in terms of impact on the highway network". The SA is blind to these and other important statements, leading WPC to the conclusion that either AECOM were not given full access to AVDC information, or the SA was poorly prepared without sufficient investigation into the crucial highway issues. 46. The SA is silent on the question of traffic impact, especially in the rural areas to the south and west of MK, and makes no comparison between the competing sites. AVDC say that an Extension of the H6 Childs Way and H7 Chaffron Way MK grid roads to a new roundabout on the A421 will help resolve or reduce the long term 'rat-running' problems through Whaddon and ease congestion on the A421, but they have no way of justifying this claim. Hopefully they can be more specific when cross examined at a new hearing. 47. Allocating at least 1150 new homes will produce at least 1500 - 2000 vehicles and will generate many more actual journeys. 'Origination and Destination' evidence has not been gathered so it is difficult to understand how AVDC can make these claims or how the existing network can be changed to cope with such a huge increase in traffic numbers. The 150 page Jacobs evidence is based on unreliable assumptions, modelling predictions and methodology, all of which is unfathomable to most readers and certainly to WPC, and in any event appears to be questioned by Bucks CC's own comments (ED215A) which suggest that "The DS4 scenario - withShenley Park removed and 1200 dwellings at Eaton Leys has the least impact on the Buckinghamshire highway network", and that "The advantage of the SP development is that is has the potential to provide a new grid road which would address rat running through Whaddon". WPC have asked AVDC for a simple and understandable explanation of the evidence demonstrating how this can possibly work in practice, but AVDC inform WPC in an email dated 23 August "This would be a further piece of work that would need to be prepared as no such document exists" and " ...there is no specific testing of effects on individual settlements that I can supply as ) this was not the basis of the testing". On the engagement with M KC on highway issues the same email says "There is however no detailed agreement on how the site's traffic can be dealt with, but this will need to be addressed before a planning consent can be granted. As part of the consultation AVDC will expect MK to state their position on the proposed a/location and the Inspector will consider that response to determine Ifthe VALP can be found sound. " WPC suggest that these are serious and indefensible deficiencies. 48. The AECOM document says that the 'Scope of the SA' provides a list of sustainable objectives which provides a framework for appraisal, and at no 11 page 9 it lists 'improve the efficiencyof transport networks', with bulleted issues being 'Traffic congestion hotspots and infrastructure upgrades', yet these issues are not appraised within the document whatsoever. The N.E. Aylesbury policy map (ED202P) shows indicative dualling for a short length heading east from the new A421 roundabout into the SP site. The initial draft Main Modifications said "Provide for the dual/ing of the section of the A421 from the new access into SP to Bottledump roundabout" but this has been changed in the 30 current MM076 schedule to "more detailed traffic modelling will be required to inform on the extent of offsite highway works to determine whether this section of A421 needs to be dual/ed". Everyone knows that Bottledump roundabout is a 'Traffic congestion hotspot', and that the A421 is already at or beyond capacity at peak travel times, so why has the SA not addressed this issue now, when answers are most needed? The Inspector should be reminded that MKC have recently refused access into the SC 1855 house site, and the same issues apply to both this site and the SP site, both being linked inextricably to the A421 and Bottledump roundabout. Improvements to this roundabout and the short length of proposed dualling cannot begin to solve the existing capacity problems - even before another minimum 3100 new homes are constructed. The developer's insistence that 'their developments need only has to consume their own smoke', is an affront to those that have to use these roads and risk their lives in doing so, and cannot and must not be allowed to continue. The VALP itself at table 16 'Protected and Supported Transport Schemes' states that these duamng works are 'Long Term by 2033 TBC'. WPC ask what on earth has happened to the Government mantra I before E (Infrastructure before Expansion)? The potential short length of dualling cannot begin to address the rat running through Whaddon village to Stony Stratford, Wolverton, North MK (and the Kiln Farm, Wolverton Mill, Wymbush, Stacey Bushes and Linford Wood employment areas) and can only exacerbate the Newton Longville/Stoke Hammond bypass rat running problems which similarly impact on Whaddon. The obvious impact of this potentially one half km (500m) of dualled section, if undertaken, can only be to 'push out' and 'extend' queuing times well beyond the existing Whaddon roundabout towards Buckingham, and encouraging even more rat running through Whaddon village. 49. In recent MKC and AVDC plans, both a 'Park and Ride site' and a 'Traveller site' have been promoted respectively by individual Councils, close to the Bottledump roundabout. Are these now confined to history as being not required, or are sites likely to be placed elsewhere? It would appear that cross boundary discussion has simply not addressed issues that have previously been on the agenda. Perhaps now that MKC appears to have made the strategic decision to cross the M 1 motorway looking ahead to 2050, they expect AVDC to provide land for the Park and Ride? What strategic longer term planning .) discussions have been held between the two authorities, and what are the conclusions? More likely, WPC expect to witness a continuation of the fieldby field 'nibbling' that pays no regard to 'joined up thinking' or 'sensible planning strategy', which has sadly been the pattern in recent years since the original 'city boundaries' were breached a few years ago. 50. The Inspector will understand the importance of these crucial highway issues, and the importance of revised Policy Tl which states "The Council will seek to ensure that new development proposals willdeliver highway and transport improvements to ensure that new housing and employment does not create a severe impact on the highway and public transport network". There is a very strong argument that Whilst the SC development is 'in limbo', and until such time as the expected appeal hearing concludes and the disputed highway concerns are resolved in respect of those 1855 homes, then SP is either the wrong location, or at least premature. The MKC refusal decision notice on the access to Salden Chase reads " That in the opinion of the Local Planning Authority there is insufficientevidence to mitigate the harm of this development in terms of increased traffic 31 flow and impact on the highway and Grid Road network, with specific reference to Standing Way and Buckingham Road, thus this will be in contravention of Policies CTl and CT2 (Al) of Plan:MK." Standing Way is of course the A421 beyond Bottledump heading east into MK. As this response is written, it is not known whether the developers of Salden Chase will appeal MKC's access refusal, or what AVDC's next move will be. Potentially, an appeal could take 6 -18 months for an Inspector to determine, and the decision is far from certain. Equally, can AVDC guarantee the delivery of these 1855 homes at Salden Chase within the plan period - indeed, can AVDC rely on this quantum of houses to be included within the current VALP at all with the uncertainty that hangs over the site? WPC's point is that whilst this uncertainty continues It would be very wise to select a site, or sites that were readilya vailable without such deeply worrying constraints. 51. The SA does not address other very important highway questions raised by Whaddon residents during this consultation, nor do the MM's. WPC believe they deserve answers, because developments of this size affect communities, individual lives, impacting on residents well being and own future 'plan-making'. Simple questions but ones that need answering now. What is the future of Shenley road, and will it be closed completely? If not, residents can expect a longer and much more tortuous journey to their destinations, perhaps through even larger housing estates, which has an impact on safety. This solution would result in much higher levels of traffic heading towards Stony Stratford and North MK including the employment areas at Kiln Farm, VVymbush, Bradwell Abbey, Stacey Bushes etc., all of which contribute to the Whaddon rat running problems. "What is the future of Coddimoor Lane?" - Perhaps a full closure of Coddimoor Lane would mean that everybody uses the tortuous new Shenley Road route into MK or to gain access to the A421? More likely is a 'traffic calming' solution, designed to make rat running even more tortuous - but this will not work in practise, as has been proven by the existing traffic calming scheme - drivers are not deterred by obstacles, it's all about time! "Perhaps closing Shenley Road making it 'cycles only' would mean Coddimoor Lane becoming the only way into Whaddon from the A421 and visa-versa?" ...... but that would surely worsen the rat-running to an intolerable level? Perhaps keeping the 'status quo', but that simply adds to the year on year problems .) experienced by MK expansion over many years. It is not just the problem of being a rat run with increasing levels of HGV's, but that also of speed, and impatient drivers who are adding to the increased road safety concerns. Overtaking within the recently added 40mph length (beyond the 30 mph zone) is now a regular occurrence, and congestion around the school is leading to more and more disputes between parents and those rushing to work. AVDC are affecting lives in Whaddon by selecting SP, and in doing so are almost certainly changing a rural community for the worse, without as yet any serious thought or answers to the inevitable consequences, and how to solve them. This is more than simply 'bolting on' a stand alone extension to MK, These issues are too important to be left to chance at a later detailed planning stage and require resolutions, and answers now. Serious concerns are being expressed by affected residents and the Inspector now has the duty and opportunity to do what AVDC should have done much earlier by insisting that someone must provide sensible answers to really difficultproblems or alternatively to allocate a site that offers better and more acceptable transport, traffic and safety solutions. 32 The Inspector might consider visiting Stock Lane or High Street, Whaddon on a weekday morning or evening during peak travel times, - the more inclement weather, the better! 52. Coddimoor Lane currently joins the A421 at a very busy roundabout. Traffic congestion into MK is a major problem at busy times and many accidents have occurred in this vicinity (both on the A421 and along Coddimoor Lane) in recent years. The roundabout is already hard to access at peak times during the day and even worse if bad weather is factored in, because the backing up traffic extends further west towards Buckingham. 53. Whaddon needs to know exactly how, when and where the new site will be accessed from. The North-East Aylesbury Vale Policy map excludes Woodpond Farm abutting the site on the A421. Is this correct or have AVDC plotted this incorrectly as well as wrongly determining the length of proposed dualling? Whatever happens there will be major disruption/closures on the A421, and the diversions will impact on Whaddon, as has happened many times already. The A421 is already heavily overloaded at peak times, ) and it is clear to many that any dualling (if considered necessary) must extend at least to the existing Whaddon roundabout (and possibly beyond towards Buckingham) to avoid further 'backing up of traffic, which inevitably leads to impatient drivers rat-running through Whaddon. Parents will find it increasingly difficult when delivering and collecting their children to and from the Village Primary School and playgroup. These major decisions and 'further trafficinvestigations' should have been explored and assessed within the SA, but sadly they were not. Further traffic studies providing reliable and up to date data must be undertaken with the results and mitigation methods (if practicable) considered BEFORE the site is allocated in the Local Plan, and MUST NOT be allowed to wait until the later Supplementary Planning Document or detailed planning stages. 54. Both AVDC in the Proposed Submission Draft VALP (paragraph 3.18 on p.34) and MKC in the Proposed Submission Plan:MK (paragraph 1.19 on p.5 and Strategic Objective 4 on p.8) indicate a willingness to work together with surrounding authorities in relation to cross boundary issues such as strategic infrastructure projects including highways and transportation. WPC question whether sufficient effective engagement has actually taken place? SECTION 5: EATONLEYS, GREAT BRICKHILL, - (BLETCHLEY and FENNY STRATFORD), Why an extension to this site is the preferred alternative for at least 1150 houses. 55. INTRODUCTION, Many of the points listed below are referred to in greater detail in previous paragraphs. This is a summary of those issues already discussed. 56. Bucks C.C., in response to an AVDC request, have stated "The D54 scenario - with Shenley Park removed and 1200 dwellings at Eaton Leys has the least impact on the Buckinghamshire highway network". (enquiry document no:- ED215A) Why have AVDC chosen to ignore this advice? 33 57. EL, even to an untrained eye, is a totally obvious and logical 'infill site' that would sensibly 'round off' the eastern side of MK. The total site, (including that which lies in MKC district and is currently being developed with some 450 houses by Barratt Homes), lies within and is fully contained by and within the A4146 Fenny Stratford bypass, meaning that there is no encroachment into open countryside. Infilling this remaining area would define a permanent edge to the east side of the city. The edge would be far more meaningful than just a 'long lasting, defensible boundary', which has little meaning and certainly no permancy whatsoever, as previously confirmed by an AVDC Planning Policy specialist officer, who confirmed long lasting, as being 'only until the next Plan review'. 58. The MKC/AVDC administrative boundary cuts the full EL site roughly in half. Just under half the total site, including the historic monument lies in the MKC district, but the larger part stands within AVDC. The AVDC part of the site lies within the Brickhills Local Landscape Area, despite the A4146 having been constructed through it some years ago. Investigations reveal that the MKC part of the site has never enjoyed similar designation, despite it having little or no material difference in Landscape terms. The original AAL boundary in the AVDC district was defined by road and County boundaries only, so there appears to be no logical reason why a relatively small area should not now be removed, especially as the recent A4146 wide road could become the new revised edge to the AAL. 59. MKC have recently granted planning consent for some 450 new homes on their half of the site , which is separated by a simple hedge line only. WPC believe this was originally 600 dwellings, but the figure has been reduced to reserve a site for a school - if required. Why. given this scenario, will AVDC not remove the site in their district from the AAL Landscape designation and consider this site for 1150 new homes, because after all there is no difference in landscape terms between the two sites, and the opportunity to open up further tracts of river frontage to join onto the Barratt site and extend the Waterhall Park linear park and POS area, significantly outweighs the damage caused by the loss of a small area of AAL that has very little impact on surrounding views - into or out of the site? 60. Building work has very recently commenced on the MKC half of the site by Barratt Homes. An earlier planning application to build homes on the AVDC half of the site in 2015 was withdrawn due to lack of AVDC support, despite indications that no obstacles to development existed .... Why? Is it possible that local politics interfered with good and proper planning decisions? Following the MKC decision, there would be minimal impact on the remaining Brickhill Local Landscape Area due to the site containment and A4146 roadside hedgerows and trees, together with the recently completed development at Newton Leys, which has a greater impact on long distance views from the Brickhill Conservation Area than EL would (as is suggested in the SA). 61. Common sense dictates that obvious infillsjtes should be chosen beforeirresponsibly and irreparably despoiling virgin counteyside, especially when the preferred SP allocation site entails crossing the North Bucks Way- an established, physically strong and defensible landscape barrier, that many believe is worth keeping and indeed strengthening. 34 62. The whole EL site already enjoys close links to Fenny Stratford amenities and Bletchley Railway Station. New and improved footpath and redway links are planned, or are already being enhanced, including a new redway connection along Watling Street into Fenny Stratford, and a new redway/cyclepath bridge from the Barratt site which will further improve access into Bletchley and it's railway station. If that part of the Eaton Leys within AVDC were chosen, a second new bridge would surely be constructed providing improved connectivity by further cycle and pedestrian access through the Waterhall Park to Bletchley and the nearby secondary school. Much has been written or talked about 'Bletchley Regeneration' - these two sites together could surely help this ambition and be considered for, and contribute towards, the ongoing 'Overall Regeneration Plan'. WPC ask if such areas of regeneration might be favourably looked at by the appropriate decision makers, to consider and award financial support? 63. There are excellent trafficroutes to CMK, the A4146 Stoke Hammond/Leighton Buzzard bypass, Ml motorway, A5 trunk road and Bletchley. 64. Railway stations are easily accessible with Bletchley just 3.5km away and Bow Brickhill 3km., whilst Leighton Buzzard and MK Central are also easily accessible. 65. A primary school site would be made available, with secondary stage students attending existing schools where there are free places. Obviously housing numbers at this site are too low for a new upper school to be included, but in such circumstances WPC believe that Bucks CC would accept a financial contribution in lieu, so that improvements could be made at existing schools that stand on large sites with expansion potential. 66. Waterhall Park running along the entire western side of the combined AVDC and MKC Eaton Leys site is already a major leisure resource for the area. The current Barratt Homes development will begin to provide full access to the opposite banks of the River Ouzel as a valuable extension to the MK park system which will connect into the Scheduled Ancient Monument heritage site running alongside Watling Street. WPC would point out 'the obvious' being that development of the AVDC site would complete full riverside frontage giving full public access for the first time to both banks of the River Ouzel to the east of the Grand Union Canal. This very important public open space would then surely be passed to Parks Trust to complete their existing interests in this area, thereby guaranteeing its future administration, maintenance and upkeep by way of a properly funded endowment from the developers. This would greatly improve biodiversity and guarantee its future as an important wildlife and recreational corridor, and enable the clearing and landscaping on the opposite bank (which, by walking the current footpath on the west bank, is obviously needed) allowing for additional planting and greatly improved habitats for wildlife . WPC believe this is a tremendous and early opportunityto extend the MK Linear Park system beyond its current boundaries and 'ticks all the right biodiversity and landscape boxes' in that respect, which is a clearly stated MKC ambition. 67. WPC are not in a financial position to be represented by professional Landscape advisors who might fully understand landscape importance and mitigation, but recognise that landscape is a subjective subject and different people view landscape in different ways. 35 WPC would encourage the Inspector - as we are sure he will - to walk the three competing sites and make up his own mind, but WPC's reading of policy NE5 on page 274 of the 'VALP Proposed Submission Plan (2017) as Proposed to be Modified (2019)' document suggests that even if the AAL is justified on that remaining part of undeveloped Eaton Leys, the policy is not drafted to be an 'In Principle Objection' and as such should not be regarded as a refusal reason, especially if mitigation overcomes any adverse impacts. Recalling that the Original Brickhills AAL was drawn covering a very large area that used and relied on the old/original A4146 road to Stoke Hammond and Leighton Buzzard as its southern boundary and a County boundary as its northern boundary the AVDC logic not to allocate this site on landscape grounds seems perverse in the extreme. 68. AVDC's reference to 'strategic flood risk' being a key part of their site appraisal evidence, would appear to relate to this EL site as it is the only one with river frontage. The exploratory planning application 4 years ago raised a 'no objection' response from the Environment Agency and Lead River Authority, so perhaps AVDC should explain their 'concern', because when looking at the worst case flood risk scenario, WPC believes there is still sufficient room to accommodate the 'at least 1150' homes required by VALP. 69. Referring once again to delivery uncertainty and the question of prematurity, the allocation of EL, in the short term with highway infrastructure already approved or in place, will allow time for sensible advance planning/highway solutions to be factored into the emerging 'Expressway' plans, which depending on the eventual route could then bring a further Salden Chase extension area into the equation. If this appraised land to the west of the Whaddon Road and the existing consented site, were then developed, it could possibly help support and fund a Newton Longville 'Ring Road' by way of a Bottledump roundabout to new expressway link, which would definitely help Whaddon's rat running (i.e.if SP is not built) and completely solve Newton Longville's worsening trafficproblems at a stroke. 70. BCC have suggested that at some future date the A4146 may need dualling. Such an undertaking would be far easier in the short/medium term if indeed it is required at all, especially as there is a large stand off (separation) between the A4146 and the proposed EL development site, that could be safeguarded for this purpose, rather that perhaps creeping further into the Brickhill AAL to the east of the site. THEREFORE, why was an extension toEaton Leys notconsidered the most suitable site to be allocated into VALP? SECTION 6 : SALDEN CHASE, NEWTON LONGVILLE. Why this site should be considered as a possible 'reserve' tor anocat;ngat least 11sonew homes, 71. The Development Control Committee at AVDC have already approved Planning permission for some 1855 new homes at Salden Chase (north-east) and have delegated responsibility to Officers to finalise approval subject to the completion of outstanding legal Section 106 matters. If the 'at least 1150 new homes' formed a south-west extension to 36 the 'approved in principle site', then a combined site of well over 3000 homes would be feasible. This would enable better land use and concentrate all the sustainable requirements of major development into one area, ensuring easy access to 'on site' employment, local shopping and community facilities, public open space and recreational areas and even potentially a secondary school. 72. WPC understands that an almost £2 million contribution is being made to the MK University Hospital from the already 'approved in principle' site. This figure could easily be increased to £3-4 plus million - but in fairness, a financial contribution to the MK Hospital will apply to any newly allocated site in AVDC that is close to the MK boundary. 73. 3000 plus homes could possibly guarantee that all stages of education, including Pre-School, Primary and Secondary might be feasible on one site. This would be a much safer solution allowing 'walking to school' rather than crossing the A421 from Shenley Park, and might prove crucial in school planning terms as there are currently no spaces in ) the local upper schools, with the situation likely to get worse. 74. Better and more effective transport links, highway management and traffic calming solutions, could be designed and maximised. Looking ahead, a greater concentration of homes in this location could 'pave the way' and set aside 'contribution funding' for a greatly needed Newton Longville by-pass ..... perhaps depending on the final chosen route of the Oxford - Cambridge Expressway. The Inspector has effectively said that this matter is best left to an early review of the Plan, but schematic drawings of a potential Expressway route, seen by WPC, suggest that a safeguarded strip could be reserved through the SC site for this purpose if required. The lack of forward planning and joined up thinking between adjoining Authorities is disappointing, but this site may offer such future potential if there Is the political will to explore the opportunities, working constructively together to achieve them. (see also para 69) This could be explored further at a hearing. 75. After some 10 years of negotiations AVDC have resolved to grant planning consent for 1855 new homes at SC, and are just waiting on the lengthy and tortuous process of ) completing legal agreements before a consent can be finally issued. Physical work on site could therefore commence very soon after detailed planning consent is granted meaning that all 1855 homes (granted) and 1150 (added) could be guaranteed to be delivered within the Local Plan period up to 2033 (14 years from now). This delivery however remains subject to planning permission being granted by MKC on the highway access element of the overall scheme that Is located within their district. It is possible that following the recent refusal, a revised application, or an appeal and/or legal challenge might frustrate this process and could take several months to resolve. Even then a successful resolution Is not guaranteed - (see bullet point 'distribution of 106 monies' under the SP section below). 76. The southern part of the site adjoins the 'to be re-opened' East-West railway line. Whilst there is no current requirement for a new station or 'halt', the opportunity would exist especially if the location were initially 'ear marked' for public open space or amenity land.This opportunity is not available at SP or indeed EL. 37 77. 'On plan', and like SP, an extension to SC represents a clear outward intrusion into open countryside without any obvious clear and defensible outer boundary, and unlike EL cannot be described as 'rounding Off'. If however the site were to be selected now or at some future date, then the triangular 'dog leg' in the south west corner must be deleted. If developed, this would represent unacceptable coalescence with the hamlet at Chase Farm, a collection of some 16 rural dwellings on the site of a previous old Insemination Farm and worker cottages, all of which fall within the Whaddon Parish. 78. It is suggested that an extension to Salden Chase would be reliant upon services being provided from the main site and accordingly it could not deliver the total number of homes within the plan period. Whilst this seems an important point to consider, could the essential services be put in earlier to overcome this possible constraint, because after all the same issues, such as extending foul sewer connections etc must also apply to SP? THEREFORE, why did AVDC not consider an extension to Salden Chase as the most suitable site tor lnctuslon within the VALP? 79. SPATIAL DEVELOPMENT- IN RESPECT OF FINANCIALCONTRIBUTIONS. WPC contend, and have done so consistently over many years that the question of financial contributions, and the proper sharing thereof, especially where developments stand along joint district boundaries are a crucial element, and should be a fundamental consideration when evolving Local Plans are being constructed and made. It is very easy, as MKC have done within their adopted Plan MK, to include a policy regarding planning, integration etc (policy SD15). but the question of infrastructure and services cannot and must not be left to the authorities to negotiate and make decisions at a later date. There must be sensible policies in place and guidance within the Local Plan system, which does not allow for inappropriate challenges by the landowner, developer or both, which could impact on the amount, cost and time delivery of infrastructure and essential community services. Without such policies, and clear understanding of such important issues, disputes will occur and the public will be the losers - as is often the case - with undelivered, late or abandoned hard and social infrastructure for the residents of new estates. Without meaningful cross boundary discussion (not apparent in VALP between AVDC & MKC - especially when considering contributions arising from Salden Chase). WPC predict that confusion, frustration, anger and intransigence between councils will fester and probably worsen. This will lead to inevitable delays in construction starts and lack of progress on site, which in turn will invite hostile developer led planning applications to be submitted, which will be far more dangerous for all concerned, especially if they are promoted on land that has not been identified as being suitable for development. To understand this, consideration should be given to comments made by elected members, councillors and members of the public at the Salden Chase planning application access debate, at MK Council offices on 7 November 2019, (15/00619/FUL) which included "We will do our utmost to protect our residents from a neighbouring, although not neighbourly authority", and "This is a great deal for AVDC which shaftsMilton keynes". When summarised such comments spell out :- 'that the new residents of the 38 1855 houses will cause untold problems, putting all MK services under strain, including pressure on GP surgeries and other essential services without paying into MK Council through their council tax which will all go to AVDC. To put this into context, MKC's Director of Growth,Economy and Culture said at the meeting "so called 106 payments had been robustly debated with AVDC, but nothing was forthcoming. Additionally, although AVDC initially did not want to make a hospital contribution, after strong negotiation approximately £2 million was agreed". Mention of the £20,000 per house MK Tariff System was made by a couple of elected MK members (which from 1855 new houses would provide £37,100,000 for new and existing infrastructure and services). AVDC still operate the Section 106 style of collecting infrastructure payments, which to some degree depends on the assistance of, and satisfactory negotiations with, the developer and the type of land deal that may have been negotiated. Securing public services, POS, community facilities, health services etc. is a far too important subject and what has happened, and continues at SC highlights an area where severe imbalance of financial collection and distribution could occur. WPC understand that AVDC fully expect to investigate the question of Community Infrastructure Levy (CIL) once the Local Plan is adopted at which time public consultation will occur, but until such time as AVDC and MKC agree a sensible way forward, the future of these sites in terms of housing delivery must be in question. WPC suggests that sensible and joint solutions must be found and quickly, because otherwise the spatial distribution of housing and the proper and fair distribution of infrastructure monies will be in jeopardy. The decision to place houses directly alongside MK, without these crucial issues being resolved, places the sustainability credentials of both SC and SP in serious doubt. Whilst doubts remain about the access and deliverability problems at SC, and whilst the Crest Homes development at SP remains in the VALP at this time, then these divisive debates will continue, and as one MK member said "MKC should approach the boundary commission for an urgent review". Whilst AVDC assure WPC in their FAQ's, that this will not happen, WPC can see this argument 'rumbling on', especially when a further potential £36,000,000 is 'up for grabs' (or would be under the MK tariff system) if Crest Homes develop up to 1800 houses as they want to at the SP site. WPC strongly believe that these comments and issues should be explained, and investigated further at a new hearing because such uncertainty can only lead to more confusion and delays, and ') an unsafe Local Plan. Not only that, but WPC are sure that as this response is being written, the Developer Consortium promoting SC are probably preparing their 'appeal challenge' against MKC's decision to refuse the highway element of their planning application for 1855 homes, and the outcome may not be known until probably June 2020 at the earliest (i.e. a minimum 6 months to prepare, discuss, and Inspector to arbitrate). The outcome is far from certain, which could again lead to delays which could severely compromise the deliverability of these crucial sites 'close to or adjoining' MKC district boundary. Interestingly this suggests that EL, which is not dependant on MKC approving the highway element of the development should be developed early, instead of SP. Yes, both AVDC and MKC will still need to hold meaningful discussions - especially on the 'development financial contributions' arising from this site, but these look easier to resolve at EL, especially on POS matters involving the future ownership, and long term maintenance etc. Put very simply, and as WPC write this submission there is to this council's knowledge 'NO CROSS BOUNDARY AGREEMENT FOR ANY AGREED FORM OF MECHANISM 39 TO SECURE OR SHARE DEVELOPER FINANCIAL CONTRIBUTIONS ARISING FROM DEVELOPMENTS ADJOINING MK, AND THIS HAS BEEN A FAILURE OF MEANINGFUL CROSS BOUNDARY DISCUSSION BETWEEN TWO ADJOINING AUTHORITIES, ON THIS VITAL INGREDIENT, ESPECIALLY WHEN CONSIDERING GOVERNMENT AND NPPF ADVICE'. In WPC's view this makes the VALP unsound, and probably unlawful, especially in such crucial circumstances. These fundamental issues should have been discussed and agreed long ago, and cannot now be resolved during a 6 week consultation period. The reopened Hearing Sessions must provide an opportunity for residents to cross examine both AVDC and MKC on these vital issues which will ultimately impact on every resident hoping to use essential services like highways, police, fire, ambulance, health care, household waste sites etc. 80. SPATIAL DEVELOPMENT - IN RESPECT OF HIGHWAY CAPACITY. Nigel Weeks, the Council's traffic expert, during the consideration of the MKC Salden Chase access planning application stated that 'he sympathised with members and residents over the trafficlevels on Buckingham Road A421, but it was Government guidance that mitigation plans do not take current levels of congestion into account, and the developers only have to provide ways of coping with the amount of traffic that their schemes would add to the network' (i.e. in this case a scheme of 1855 new houses at Salden Chase). Put simply, new developments need only to consume their own smoke! This raises the fundamental and very serious question as to whether or not any more new homes should be constructed, which rely on the A421 for access, until such time as the existing over capacity concerns are dealt with by the Highways Agency in conjunction with the approving authorities. lo summary It is illogical and completely unnecessary to expand the MK City boundary into Shenley Park at the current time. Why cross a strong defensible bridleway boundary such as the heavily wooded/hedged North Bucks Way into beautiful and much valued open unspoilt rolling countryside - when there are two more appropriate, and easier to develop alternative sites available at Salden Chase and particularly Eaton Leys. Delivery of these 'at least' 1150 new homes within the Local Plan period to 2033 is crucial (i.e. within the next 14 years). If Shenley Park is approved in this VALP, and then falters at some stage - which could easily happen given the ongoing Salden Chase problems, the highway studies yet to be undertaken, the complex negotiations yet to take place with M KC (to ensure the new development fully accords with their already adopted Plan:MK (policy SD15), and the uncertainty around the proper sharing of infrastructure monies arising from development - AVDC (or the new Bucks Unitary Authority) will leave themselves wide open to hostile, developer-led, planning applications where the new homes can perhaps be delivered quicker and on time. AVDC have recently lost some 650 homes on 3 much smaller sites so it can easily happen, and clearly does, if important issues are not fully understood and dealt with at an early stage. WPC understands that Eaton Leys has a planning history and is almost ready to go -'oven ready' as The new Prime Minister would say, giving delivery certainty within this Local Plan period. J1 should and must be noted that within the MKC council chamber, during the recent debate there was clear and intentional condemnation by members about process, and comments that the Salden Chase site and Shenley Park sites should not be allowed, as they simply did not 40 financially contribute sufficient to the economy of MK, and there was serious doubt that they would, or could comply with Policy SD 15 of the recently adopted Plan:MK. To unnecessarily desecrate unspoilt countryside now - which might ultimately (given much longer term forward thinking and planning) form part of a huge MK parkland setting - is nonsensical and Indefensible. especially given M KC's recent unequivocal cross party agreement affirming its commitment "to protecting and promoting biodiversity, pledging to leave our natural environment in a better state than we found it." WPC cannot understand AVDC's logic, and the AECOM sustainability Appraisal, in arriving at the conclusion they have, by recommending Shenley Park as the preferred site, and cannot accept this decision without further detailed analysis and discussion . .A reopening of the Inspector's Hearing Sessions, hopefully with both AVDC and MKC present, to debatethe complex issues and cross examine the evidence upon which AVDC's decision was made, Is the only acceptable way forward. END -14 December 2019 -Wbaddon Parish council, 41