Hampen Fields 2012 Consultation Response

Hampden Fields planning application: 12/00605/AOP

I am writing about the proposal now before Aylesbury Vale District Council (AVDC) to build 3,200 homes, a nursing home, a retail development, commercial premises and other services on land between the A41 Aston Clinton Road and the A413 Wendover Road.  

Since this planning application was submitted to AVDC, I have been contacted by more than 150 constituents who have expressed their opposition to the proposal.  Unusually, no constituent has contacted me to express support for the proposal although I am of course aware that Aylesbury College is one of the consortium partners that has proposed this development.  Normally, I do expect at least some constituents to dissent from the majority opinion on a planning matter.  This was certainly the case over the Arla development on which I received representations from constituents both supporting and opposing the scheme and even on HS2 I have had a very small number of constituents who have contacted me to express support for the plan. 

I have studied carefully the arguments put forward to me by my constituents about this particular planning application.  I have also taken note of some of the comments which have been made direct to AVDC and published online by the Council.   In recent weeks I have also had meetings with the Chairman of Weston Turville Parish Council and the Chairman of the Hampden Fields Action Group as well as with local District Councillors.

I am writing now to ask you to take fully into account the opinions expressed by my constituents in objecting to this scheme in the officers’ analysis of the proposal and in your presentation of advice to the Strategic Planning Panel.  I would also ask that all members of the Panel consider very carefully and sympathetically the arguments that my constituents have put forward.

The chief concerns expressed by my constituents have been over the coalescence of Aylesbury and Weston Turville, the likely traffic impact of this proposed development, the impact on education and health services in the locality and the question of whether this proposal, if permitted, would seriously pre-empt the new Aylesbury Vale Local Plan which is being developed under the new procedures laid down in the Localism Act. 

It is clear to me both from my reading of documents presented to AVDC by the applicant and from the DCLG’s new National Planning Framework that a central consideration in assessing this planning application must be whether it can reasonably described as sustainable development.   As you will know, the principle of sustainable development has been referred to many times by the Prime Minister and CLG Ministers when speaking in Parliament and outside.  When pressed on what is meant by “sustainable development”, Ministers have responded by making reference to the definition set out in the Brundtland Report.  As you will know, the definition of sustainable development is summarised in Brundtland as development which provides for the needs of the present while safeguarding the interests of future generations and the definition is supposed to be applied in a way which takes into account the fact that human needs, for example for housing or for new infrastructure, need to be taken into account alongside and in balance with considerations about the natural environment.  

I have noted that the applicants make their case very much in terms of sustainable development.  They argue in particular that the development is both justified and sustainable because Aylesbury needs more housing and argue too that this particular proposal is sustainable in transport terms because it would offer easy access to modes of transport other   than roads and would provide a development that was in terms of transport links well integrated with the existing town of Aylesbury.

It seems to me that if the concept of sustainable development is to mean anything then it must require a development proposal to be analysed not only as a self-standing plan but also on the basis of its impact upon existing residents, community identities and local services.  In addition, such an analysis needs to take account of future new developments that have already been planned for and approved.  If this is not done then it seems to me that sustainability ceases to have much meaning.   There is a clear implication in the application documents that the applicants themselves accept this principle because they emphasise how in their view the Hampden Fields development would be well integrated with the rest of Aylesbury and in particular with bus routes, existing rail services, pedestrian routes and cycleways. 

This is a very large development which, if approved, will have a substantial impact on both Aylesbury and Weston Turville for many years to come.   The construction phase itself would last for up to 20 years and the creation of a new area of development as big as Wendover (a point made by Wendover Parish Council in its own submission to AVDC) will have a permanent impact upon the patterns of transport in the area, on community identity and on public services.  I believe therefore that it is essential that a scheme that is of such significance for the future of Aylesbury Vale should be subjected to detailed and rigorous analysis and challenge.

My constituents have put forward to me both in writing and verbally a range of arguments which suggest that the case that this proposal can be described as sustainable is seriously flawed.   Let me go through the main arguments in a little more detail.

Coalescence

Constituents in Weston Turville feel particularly strongly that giving permission for the Hampden Fields development to go ahead would in practice mean accepting that Weston Turville would lose its distinctive village identity and become in effect a suburb of Aylesbury.  The applicants of course argue that this is not the case and that there would be a green belt of land left between the new edge of Aylesbury and Weston Turville but, having looked at the plans which they submitted to AVDC, I find it hard to accept that a green belt of no more than one field’s width would really be sufficient for that distinction to be maintained. As I note below in my comments on the traffic impact of the scheme, I also fear that there is a significant risk in these proposals that Main Street, Marroway and New Road in Weston Turville would be turned into a rat-run between the Aston Clinton Road and the Wendover Road. 

Maintaining and strengthening community identity seems to me an intrinsic part of sustainable development.  The very fact that the Government’s entire new planning framework is built on the basis that a local planning authority must consult and build up its plan from parish and neighbourhood level up to district level reinforces this point. 

Aylesbury has been a fast growing town for more than 20 years. Significant growth is going to continue under plans already approved by AVDC.  One of the challenges for policy makers is how to manage growth in a way that does maintain and if possible strengthen rather than lose the local sense of place and community identity.  I believe that avoiding the coalescence of Aylesbury with Weston Turville, and for that matter with Aston Clinton and Stoke Mandeville, should be an important element in the District Council’s planning policy and I am not persuaded that this principle is met by this application.

Traffic & Transport

The impact of the Hampden Fields proposal on local traffic has been a consistent theme of representations from constituents to me.  

I have looked at the documents and forecasts given by the applicants to AVDC.  From those, it is clear that main roads and in particular key junctions around Aylesbury are already operating at or close to full capacity.  We already have a designated air quality management zone along the A41 near the junction with Oakfield Road, a sign that in this part of Aylesbury, European as well as national standards on air quality are not being met.

The argument made by the applicant is that the impact of this proposal on local traffic patterns would be manageable.  Although I make no claim to being a technical expert, I find this defence of the proposal flawed and deeply unconvincing.

For a start, the modelling which the applicant has carried out rests on the basis of this being a self-standing proposal.  That seems to me to fly in the face of reality which is that any proposal and above all one on this scale ought to take full account of changes to traffic patterns that will arise as a consequence of other developments in and around Aylesbury, of demographic trends and of developments elsewhere in the area (such as the growth of Milton Keynes) which will inevitably have an impact upon Aylesbury’s road system.  The modelling makes great play of the prospective ease and attractiveness to new residents in Hampden Fields of walking routes to the town centre, cycle routes and rail links from Stoke Mandeville station.  This argument appears to me both to have some technical flaws and to fail to take into account how people will actually behave.  On the technical side, the traffic model appears to work on the basis that Stoke Mandeville railway station or any other destination such as Aylesbury town centre will be attractive to reach on foot or bicycle because it is only a relatively short distance from Hampden Fields.  The argument seems to rest on judging the attractiveness of those modes of transport by the distance of the designated destination from the closest point of the Hampden Fields development.  Yet this development, if it goes ahead, is going to be three kilometres wide and it is simply not likely to be the case that, for example, someone living close to the Aston Clinton Road will chose to walk or cycle to Stoke Mandeville station. Equally, the further out towards Weston Turville a resident lived, the more likely he or she would be to use a car in order to get into the centre, let alone the north, of Aylesbury.

The model assumes that at peak hours there would be only 0.7 vehicle movements per house.  Since most houses in the development would have more than one adult living there, I find this implausible.   It is a good thing that the application proposes some development for employment as well as for residential purposes but I think it would be a mistake to make assumptions about the proportion of new residents of Hampden Fields who work within walking distance of home.  Even if many of  the new residents started off in that position the nature of the jobs market these days mean that people often shift their place of employment but for family reasons, especially if their children are settled in a good school, want to avoid moving house.  So I think that the pattern of travel to work is likely to be very diverse as indeed is the pattern of travel to work in and out of Aylesbury today. 

It also seems to me that while people might walk from Hampden Fields to Aylesbury town centre to go the theatre or the cinema, they are going to drive to visit the supermarket or any of the other large retail centres in the town.  Similarly I think we would find that while parents might well walk with primary school age children to the school gate, they would then need to drive to their place of work in order to get there on time. 

I thought too that the traffic modelling submitted by the applicants was too sanguine about the likely impact of the development upon the roads running through Weston Turville.   As AVDC’s members and officers will know, the use of Marroway, Main Street and New Road as a rat run has been an issue of some concern in Weston Turville for many years and indeed led to the successful campaign for the installation of traffic calming measures in the village.  Anyone who uses either the A41 or the A413 during peak hours knows that the traffic on those roads at that time is very busy indeed.  I think it is almost inevitable that drivers using either of those main roads who finding traffic congestion getting too great would, once the new link road was built, try to use it as a cut-through to get to the other main route.   I think too that it is almost inevitable that some of this traffic, whether emanating from one of the major roads or from the new development itself, would try to cut through Weston Turville village in order to find a way to avoid congestion.  For example, drivers might well be tempted to go through Weston Turville village to take the lane up alongside Halton airfield in order to avoid congestion.  I do not see in the applicants’ documents any detailed analysis of these traffic risks which would have a significant impact on the quality of life of residents in Weston Turville. 

I was surprised to see that the applicants have not proposed making any contribution towards an eastern link road to provide a bypass from the A41 around the edge of Aylesbury.   This eastern link road has for some years been seen by both the County and District Councils as essential for the sustainable development of Aylesbury, taking into account not only the development proposed and agreed for the town itself but also to deal with the impact of increased residential and commercial development in neighbouring settlements such as Leighton Buzzard and Milton Keynes.  Hampden Fields, if approved, would have a significant impact upon traffic within and around Aylesbury and it therefore seems to me to be essential for any development plan to include some kind of contribution to the sustainable development of the town as a whole including helping to provide for the eastern link road.

Schools

A development of 3,200 new homes would inevitably led to considerable pressure upon school places and I have consulted Buckinghamshire County Council about their assessment of what this impact would be. 

Buckinghamshire County Council has told me that a development on this scale would generate a need for new places at primary, secondary and special schools alike.  In the case of primary schools, the County Council thinks that the need would be for two new schools along the lines proposed by the developer or as an alternative three slightly smaller new primary schools.  In terms of secondary school places, the County Council estimates that the development would create a need for 651 upper school places and 373 new grammar school places while there would also be a need for special school places for an additional 31 pupils. 

Inevitably, these figures can only be estimates but I note that in the case of the most recent development around Aylesbury, namely Fairford Leys, the existence of a good quality primary school has led to more parents and prospective parents choosing to move into the locality than had been expected, with a consequent higher demand for primary school places than had been anticipated by the County Council’s original modelling.  On the basis of that precedent it seems to me that the County Council’s estimates for Hampden Fields may if anything err on the low side. 

Looking at what the developers have proposed to meet this demand, I see that the applicants propose to provide land for two primary schools but not buildings.  In the case of secondary school accommodation, the applicants talk about making a financial contribution towards off-site secondary school provision or alternatively providing land but reducing by a commensurate amount its contribution to other public goods related to the development.  There is no specific provision proposed for special school places.

I do not see that what is being offered meets the test for sustainable development.  Surely if we have estimates for the numbers of new school places needed then it would be reasonable to expect the developers to make provision not only for the land but for the buildings that would be needed to accommodate these new school pupils in each sector of education. 

NHS

Many constituents have also expressed concern about health provision.  I note that the developers propose to provide land for a GP surgery and primary care centre.  This is welcome, however, as with schools I note that the proposal is to provide land only and not buildings.  This seems to me to be inadequate. 

The applicants are not proposing to contribute towards any increase in provision that would be needed for hospital care.  I have asked Buckinghamshire Hospitals Trust for their comments but at the time of writing have not yet received these.   Stoke Mandeville hospital and Wycombe hospital are already under considerable pressure.  A new settlement of 3,200 homes will inevitably add to that pressure and, since the chief demand for NHS care comes from infants and old people, the inclusion in the Hampden Fields scheme of a large nursing home will surely place additional demands on the local hospital.  I am disappointed that there appears to be no analysis of this new demand and feel that this is again a flaw in the applicants’ proposal and again suggests that it cannot be regarded as meeting the test for sustainable development. 

Local Plan

One theme that has run consistently through the representations made to me by my constituents has been that it is wrong for this and other developer-led proposals to be approved now when the Localism Act has recently become law and AVDC is in the throes of putting together a new Local Plan based upon the public consultation required by the new legislation and the new National Planning Framework.  I was struck too by the fact that the comments to me on school places by Buckinghamshire County Council said that it would be essential for there to be some flexibility in plans for future school provision since they would not know until all outstanding planning applications had been determined and until AVDC had completed and adopted its new Local Plan exactly how many school places, and of which type, would be needed and where in or around Aylesbury those school places needed to be located.  This strikes me as a further argument for regarding an application on this scale as being premature and saying it that it really ought to be considered in the broader context of an agreed Local Plan which can take into account the many different pressures for new housing, for new public services and for conservation and provide coherent statement of planning policy for Aylesbury as a whole, based upon up to date evidence about local need.

The study of housing need by GL Hearn on which AVDC’s old core strategy was based, estimated that the District Council area would need to provide between 4,500 and 14,000 new homes by 2031.  My understanding is that current plans already approved provide for 10,000 of those new homes.  This means that Hampden Fields, if approved, would effectively complete and pre-empt that entire process under the old planning targets.  Residents of Weston Turville have said to me that they think that there is a case for some fairly small scale organic development of Weston Turville within the village perimeter and that paradoxically the chances of this kind of development being approved in future would be reduced were the District and Aylesbury areas housing plans to be swallowed up by one single big development at Hampden Fields.  What is true of Weston Turville is presumably also true of other villages and small towns in Aylesbury Vale. 

I do not quarrel with the argument made by the applicants that Aylesbury Vale, including the town of Aylesbury, will need to make provision for some additional housing.  I know from my own constituency caseload that there is a need for housing.  In part this is driven by demographic trends: more elderly people living independently for longer; more young people leaving home to live independently before settling down with a family, and more divorces and separations leading to the creation of additional households even on the assumption of a constant population number.  On top of that, the population of the United Kingdom is at present growing and one point that businesses have made to me over the years is that in order to attract new firms to relocate to Aylesbury, the town will need to be able to provide a mix of housing which will provide attractive homes to key employees and their families.  But it is surely an essential part of sustainable development that decisions about housing and planning should be taken on a coherent basis rather than piecemeal in response to what amount to large scale speculative proposals by development consortia.  I also believe in the principle as embodied in the Localism Act that it should be for local authorities to determine, on the basis of evidence, the needs and the ambitions of people in their area for both residential and commercial development.   So to say as I do that Aylesbury Vale will need some new housing should not exempt this application from rigorous analysis and challenge and a requirement that the applicants demonstrate in a way which I do not believe their documentation does, that they meet the sustainable development test.

The applicants’ planning statement argues that the creation of more than 5,500 new jobs in the Aston Clinton Road MDA and the Arla development is an important justification for a housing development this large to the South of Aylesbury. The MDA has been available for development for some years already but market conditions mean that development has not yet happened and there is no sign yet of renewed interest in early development taking place. So I cannot see the harm that would be done by leaving the question of housing demand caused by the MDA to be determined over the next 12 months by the Local Plan process. The applicants appear to assume that the MDA would create 2,500 jobs and the Arla development 3,000. This latter figure is far higher than the 700 jobs which Arla itself has said would be created at its dairy, or the 1500 which might be created if the land adjacent to the dairy were used by some of Arla’s suppliers and related companies.

Aylesbury College

I also acknowledge that one important beneficiary of this development proposal would be Aylesbury College which proposes to invest its share of the capital receipt in better facilities at its Oxford Road campus.  I believe that Aylesbury College is an asset to the town and the district as a whole and that further improvements to the Oxford Road campus would be in the interests of this and future generations of young people and employers in Aylesbury.  But there is not in the applicants’ documentation any evidence as to the proportion of capital receipts that would accrue to the College nor of the relationship of that sum, however great or small, to the College’s requirements for future development at Oxford Road.  In any case, the same point applies here as applies to the question of housing need, that the application, especially one on this scale, needs to be tested rigorously. 

My conclusion is that the arguments put forward by my constituents in opposing this scheme are cogent and that in a number of significant respects the evidence and argument presented by the applicants is flawed and does not justify approval of this application.