9 Reasons To Say No

This is a summary of the evidence that has been put together by reading all of the documentation presented by the AVDC and their agencies. It takes 9 points, and for each of them outlines the clear evidence.

Remember that all of this information used to compile this list is readily available for everybody to read and make up their own minds...

1. The AVDC Officers Recommended The SGA On Re-examination

  • The report to AVDC cabinet in March 2008 contained the following recommendation: “The re-examination of the evidence base for the direction of growth has confirmed that, on balance, the southern growth arc provides the best technical outcome across the range of topics assessed.”
  • Nothing has materially changed since AVDC officers chose the SGA as their preferred option.

2. The Sustainability Appraisal Findings Cannot Be Ignored

  • The Sustainability Appraisal is a regulatory requirement in the planning process.
  • The October 2008 Sustainability Appraisal report summarises the SGA as the most sustainable option, having the most positive impacts and fewer negative impacts than the other two options.
  • The Government Planning Inspectorate states: “It is likely that Sustainability Appraisal (SA) work will be a key piece of evidence....If the strategy chosen is not endorsed by the SA the reasons for the choice of strategy contrary to the SA will need to be fully justified. Failure to do so is likely to result in a finding of unsoundness.” [Local Development Framework : Lessons learnt examining development plan documents – issued June 2007].

3. It Would Be Absurd To Develop On The Most Biodiverse Sites

  • The report to AVDC cabinet of March 2008 stated that the Aylesbury East site (now site G) at Broughton “contains six sites locally designated for their ecological importance.”
  • The AVDLP Inspector’s Report acknowledged the area’s intrinsically high ecological value and concluded that “development of this area would result in serious damage to, and the possible destruction of its most valuable habitats and significant harm to its overall ecological value....mitigation would be inadequate against this loss.”
  • The Jacobs site G ecology report concludes: “The option of integrating development with the Broughton Crossing area would lead to a significant decrease in existing biodiversity.”
  • The Government’s Planning Policy Statement 9 Biodiversity and Geological Conservation states: “In taking decisions, local planning authorities should ensure that appropriate weight is attached to designated sites of national and local importance; protected species; and to biodiversity and geological interests... The aim of planning decisions should be to prevent harm to biodiversity and geological conservation interests. When granting planning permission would result in significant harm to those interests, local planning authorities will need to be satisfied that the development cannot reasonably be located on any alternative sites that would result in less or no harm”.
  • The SGA would have a much lower impact on ecology and is therefore a viable alternative site.
  • The Jacobs ecology report says: “There are 8 or 9 badger setts on site C primarily in the south west and south east of the site” i.e. near Watermead and Bierton. It goes on to say: “The badger population would be unlikely to survive....they are protected due to welfare considerations”. Natural England guidelines state: “Development should not be permitted unless it is possible to take steps to ensure the survival of badgers in their existing range”.

4. It Would Be Unwise To Ignore A Previous Government Inspector’s Report

  • The Government Inspector has previously rejected in the firmest of terms any development at Broughton for ecological reasons, flooding risks and an illogical intrusion into open countryside. These issues remain.

5. Why Take A Risk With Flooding?

  • The Sustainability Appraisal states that the AVDLP Inspector cast doubt upon the acceptability of any essential flood mitigation measures in the vicinity of site G.
  • The Inspector also stated “the developer's drainage proposals would have a dramatic, detrimental impact on ecology by disrupting frequent shallow flooding”
  • The report to cabinet last March said: “The ADVLP Inspector questioned the viability of a 1,600 dwelling scheme on this site (site G). Given the very strong concerns of the ADVLP Inspector in terms of ecology, flood risk and viability, the deliverability of this site is questionable.”

6. More Vehicles On The Road If EGA Or Hybrid Chosen

  • AVDC’s traffic modelling report shows that the SGA performs significantly better than other growth options in terms of sustainable transport .
  • The SGA would generate fewer car trips per day than the other two options – 4,500 less than the hybrid and 700 less than the EGA by 2026. This is due to the fragmented nature of the proposed EGA and hybrid arcs and the better opportunities for walk, cycle, bus and rail routes in the south.
  • The A413 Buckingham road would become clogged into and out of town with the extra traffic from site C on top of the Buckingham Gate development. Only 16% of traffic needs to bypass Aylesbury so a northern link road (A413-A418) would not compensate.

7. The Eastern Link Road Argument Is Flawed

  • The consultation document implied that the eastern link road (ELR) is contingent on the eastern arc - there is no evidence to support this.
  • There is no material difference in total road costs if two southern arc park & rides versus the 3 eastern arc park & rides are taken into account. The resulting difference is equivalent to £300 per home – less than 0.2% of the estimated average house price.
  • We believe that the developers of site C have not committed to providing any funding for the ELR because they would have to fund the northern link roads.
  • If the hybrid option is chosen in order to obtain some ELR funding from site G developers, the developers in the south are likely to reduce their commitment to essential infrastructure funding because they will have lost some housing.
  • The report to cabinet in April 2008 states: “A variant on the SGA is the southern and eastern option, which in effect distributes some of the growth from the southern arc to the east. This has the benefit of mitigating some of the impacts on the communities to the south, however casts questions over what this does to the viability of the remaining elements of the SGA”.

8. The Impact On Bierton And Watermead Communities Would Be Worse Than On Southern Communities

  • The report to cabinet in April 2008 stated that the potential impact of the SGA on Stoke Mandeville, Weston Turville and Bishopstone was a concern. However, it also concluded that “southern sites have the opportunity to better link with the existing communities and integrate with them.”
  • The report to cabinet in March 2008 stated that sites D, E and F (SGA) would each offer the opportunity to provide large open space. In contrast, at site C, there would be “no possibility for access to large open space within acceptable distance.”

9. The Southern Arc Is More ‘Practical To Provide’

  • The report presented at the AVDC cabinet in March 2008 stated that, for site C, “deliverability could be an issue due to the cost of the northern link road and third party land issues.”
  • At the Aylesbury East site (now site G) there was “concern over viability if required infrastructure to be funded” and “poor integration into Aylesbury due to distance.”
  • Sites D, E and F (SGA) were all “easy to integrate into Aylesbury”, were “practical to provide” and had “minimal impact on landscape and ecology”.

Conclusion

  • AVDC’s evidence demonstrates that the SGA is the best option in terms of ecology, landscape, utilities, transport, sustainability, coalescence and flood risk, and therefore provides the best overall option for the direction of housing growth at Aylesbury.
  • There is an inherent danger that if the SGA is not put forward, the Government Inspector will find the decision ‘unsound’.

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