Application Number: 10/01056/CONS CONSULTATION RESPONSE

Transcription

1 Application Number: 10/01056/CONS CONSULTATION RESPONSE CONSULTATION FROM AYLESBURY VALE DISTRICT COUNCIL ON AN OUTLINE PLANNING APPLICATION WITH ALL MATTERS RESERVED EXCEPT FOR ACCESS FOR A MIXED-USE SUSTAINABLE URBAN EXTENSION FOR UP TO 5,311 MIXED TENURE HOMES (C3) TO THE SOUTH WEST OF MILTON KEYNES, WITH THE FOLLOWING: AN EMPLOYMENT AREA OF 7.4HA INCLUDING: UP TO 31,200M2 OF EMPLOYMENT FLOORSPACE (CLASSES B1A, B1B, B1C AND B2); UTILITIES AND RENEWABLE ENERGY INFRASTRUCTURE (SUI GENERIS); THE RELOCATION OF A COMMERCIAL RECYCLING CENTRE ON A SITE OF UP TO 1 HA (SUI GENERIS); AND A SITE FOR A HOUSEHOLD RECYCLING CENTRE ON A SITE OF UP TO 1 HA (SUI GENERIS). A NEIGHBOURHOOD CENTRE OF 5.25 HA INCLUDING: A RESERVE SITE FOR A RAILWAY STATION (SUI GENERIS); UP TO A 5,500M2 FOOD RETAILING SUPERMARKET (CLASS A1); UP TO 2,000M2 (A1 RETAIL, A2 FINANCIAL AND PROFESSIONAL SERVICES, A3 RESTAURANTS / CAFES, A4 DRINKING ESTABLISHMENTS AND A5 HOT FOOD TAKE AWAYS); UP TO 2,000M2 SMALL SCALE COMMERCIAL (B1A AND B1B) USES; UP TO 274 OF THE MIXED TENURE RESIDENTIAL UNITS (C3); UTILITIES AND RENEWABLE ENERGY INFRASTRUCTURE (SUI GENERIS); UP TO A 220M2 THAMES VALLEY POLICE ONE STOP FACILITY (SUI GENERIS); AND UP TO 11,250M2 A COMMUNITY LIBRARY (D1), PRIVATE CRÈCHE (D1), COMMUNITY / RELIGIOUS WORSHIP / INSTRUCTION FACILITY (D1) AND HEALTH (D1), LEISURE (D2). TWO LOCAL CENTRES AND A SMALL MIXED USE CENTRE ON A TOTAL OF 1.78 HA INCLUDING: UP TO 2,435M2 (A1 RETAIL, A2 FINANCIAL AND PROFESSIONAL SERVICES, A3 RESTAURANTS / CAFES, A4 DRINKING ESTABLISHMENTS AND A5 HOT FOOD TAKE AWAYS); UP TO 2,420M2 COMMUNITY FACILITIES (D1), PRIVATE CRÈCHES (D1) AND HEALTH (D1), LEISURE (D2), AN EMERGENCY / AMBULANCE CALL POINT (SUI GENERIS); UTILITIES AND RENEWABLE ENERGY INFRASTRUCTURE (SUI GENERIS); UP TO 90 OF THE MIXED TENURE RESIDENTIAL UNITS (C3); UP TO 2,000M2 SMALL SCALE COMMERCIAL (B1A AND B1B) USES; AND UP TO 700M2 VETERINARY PRACTICE (SUI GENERIS). PROVISION OF 19 HA OF LAND TO PROVIDE EDUCATION FACILITIES (SITES FOR FOUR PRIMARY SCHOOLS WITH ANCILLARY EARLY YEARS PROVISION AND ONE SECONDARY SCHOOL AT Salden Chase, Whaddon Road, Newton Longville FOR Salden Chase Consortium Target: 14th July 2010 Ward: Emerson Valley Adjoining Ward: Whaddon Parish: Shenley Brook End & Tattenhoe PC Adjoining parishes: West Bletchley PC; Bletchley & Fenny Stratford TC 1 (103)

2 Report Author/Case Officer: Nicola Wheatcroft / Diane Webber Contact Details: nicola.wheatcroft@milton-keynes.gov.uk diane.webber@milton-keynes.gov.uk Team Leader: Alan Mills Contact Details: INTRODUCTION AND SUMMARY Milton Keynes Council (MKC) has been consulted by Aylesbury Vale District Council (AVDC) on this outline planning application. AVDC is responsible for consulting on and determining this planning application. The purpose of this report is to agree the Council s response to the planning application, focussing particularly on the impact that the proposal will have on the borough. At Full Council on 8 June 2010, MKC resolved to oppose the current planning proposals for Salden Chase, commenting that:.. the Council calls upon Government to assist Milton Keynes Council as a matter of the greatest urgency in: 2c opposing the unnecessary and inappropriate proposal before Aylesbury Vale District Council to build over 5300 houses on land at "Salden Chase" to the South West of Bletchley, which would place a considerable burden upon the infrastructure of Milton Keynes and Bletchley in particular; and.. 3c gives a commitment to oppose the expansion by stealth of Milton Keynes beyond its existing boundaries, and to make specific representations to Aylesbury Vale District Council opposing the "Salden Chase" proposals currently before them; Whilst the resolution of 8 June confirms the council s position in principle to this application, there is a requirement for MKC to formally comment on the detail of the planning application so that AVDC can take these views into account when determining the application. Should the application be refused and the developers exercise their right of appeal, the views expressed by MKC and other third parties will be taken into account. AVDC s original target date for the determination of this application was 19th August However an extension of time until 16th September has been agreed with the applicants. Due to concerns over the transport assessment submitted with the application however, the Highways Agency has imposed a holding direction directing AVDC that planning permission should not be granted until 8 October 2010 at the earliest. AVDC has previously stated (at a Milton Keynes Partnership Committee on 8 June) that it is unable to progress the planning application until both the AVDC Core Strategy and SPD have been approved. However the situation has now changed as AVDC s Full Council on 8 September agreed that the 2 (104)

3 Core Strategy and consequently the SPD should be withdrawn entirely. Due to the advanced stage of the Aylesbury Vale Core Strategy, the Secretary of State s approval is required for the withdrawal. It is currently unclear at this stage what this will mean for AVDC s timescale for the determination of the planning application but MKC s views on the application should be agreed and sent to AVDC as soon as possible. 1.1 THE SITE Salden Chase is a 280 hectare parcel of land roughly rectangular in shape located to the south west of Milton Keynes. The northern boundary of the SDA is defined by the A421 and the southern boundary by the currently disused Oxford to Bletchley railway line which forms part of the East-West rail proposals. The site is located to the immediate south of Snelshall West and to the west of Far Bletchley. Further south beyond the railway line lies the settlement of Newton Longville. The western edge of the site follows field boundaries between Thrift Wood to the north and Salden Wood to the south. 1.2 THE PROPOSAL The outline application (with all matters reserved for subsequent approval except access) seeks planning permission for a mixed use sustainable urban extension for up to 5,311 homes. The proposed development is for 79 homes less than the 5,390 dwellings identified in the South East Plan and the AVDC Core Strategy as land with an estimated capacity of 79 dwellings is currently outside the control of the applicants. The access points into the site from both the Bottledump and Tattenhoe roundabouts on the A421/H8 lie outside Aylesbury Vale district. The Bottledump roundabout falls within the Urban Development Area where Milton Keynes Partnership have development control powers and Tattenhoe roundabout fall within the MKC area. The applicants have also stated that they intend to submit further planning applications for off-site highway works to these roundabouts to MKP and MKC. At the time of preparing this report no applications have been received. The proposed development includes the following works: An employment area of 7.4ha including o Up to 31,200m2 of employment floorspace (Use Classes B1a, B1b, B1c and B2; o Utilities and renewable energy infrastructure (sui generis use class); o The relocation of a commercial recycling centre on a site up to 1ha (sui generis use class); o A site for household recycling centre on a site up to 1ha (sui generis); A neighbourhood centre of 5.36ha including 3 (105)

4 o A reserve site for a railway station (sui generis); o Up to a 5,500m2 food retailing supermarket (Use Class A1); o Up to 2,000m2 retail (Use Class A1), financial and professional services (A2), restaurants/cafes (A3), drinking establishments (A4), hot food takeaways (A5); o Up to 2,000m2 small scale commercial uses (Use Classes B1a and B1b); o Up to 274 of the mixed use tenure units; o Utilities and renewable energy infrastructure (sui generis); o Up to a 220m2 Thames Valley Police one stop facility (sui generis); o Up to 11,250m2 community library (D1), private crèche (D1), community/ religious/instruction facility (D1), health (D1), leisure (D2), and an emergency/ambulance call out point (sui generis); Two local centres and a small mixed use centre on a total of 1.78ha including o Up to 2,435m2 retail (Use Class A1), financial and professional services (A2), restaurants/cafes (A3), drinking establishments (A4), hot food takeaways (A5); o Up to 2,420m2 community facilities (D1), private crèche (D1), and health (D1), leisure (D2), an emergency/ambulance call out point (sui generis); o Utilities and renewable energy infrastructure (sui generis); o Up to 90 of the mixed use tenure units; o Up to 2,000m2 small scale commercial uses (Use Classes B1a and B1b); o Up to 700m2 veterinary practice (sui generis); The provision of 19ha of land to provide education facilities (sites for four primary schools with ancillary early years provision and one secondary school with a post 16 facility; Ground remodelling; the proposal includes a storm water management system, incorporating source control, open channels and infiltration/detention systems, including ditches, balancing ponds and lakes. These will result in changes to the sites topography ha of multi functional green infrastructure including: parkland, sports and recreational facilities, play areas, wildlife areas, a range of strategic open spaces including new landscaping, a wildlife area, woodland, allotments, foul and surface water drainage networks (including Strategic Urban Drainage Systems and lakes); Associated highway infrastructure including two spur roads, primary streets, residential streets, pedestrian footpaths and cycle routes; Public transport infrastructure including a community reserve site of up to 2ha for a park and ride site for up to 500 vehicles and car parking for all uses. 4 (106)

5 Off site highway works are proposed on land outside the application boundary. These would include the introduction of 6 signalised junctions in place of existing roundabouts in Milton Keynes and the signalisation of a further 2 roundabouts. 2.0 RELEVANT POLICIES (The most important policy considerations relating to this application) 2.1 National and Regional Policy National Policy: PPS1 - Delivering Sustainable Communities PPS3 - Housing PPS 6- Employment PPS9 - Biodiversity PPG13 - Transport PPG 15 - Planning and the Historic Environment PPS22 - Renewable Energy PPG24 - Planning and Noise PPS25 - Development and Flood Risk Regional Policy: The South East Plan was revoked on 6 July Local Policy With the revocation of the South East Plan, the Development Plan for this development now comprises the adopted Aylesbury Vale Local Plan. The emerging Aylesbury Vale Core Strategy allocates a site for the development of 5,390 homes. A draft Supplementary Planning Document for the site has also been consulted on by AVDC with the intention that, once adopted, it will form part of the Aylesbury Vale LDF. Aylesbury Vale Local Plan Adopted in January 2004; covers the period to The proposal in the South East Plan (now revoked) for large scale development south-west of the city post dates the adoption of the local plan. There is therefore no site allocation for this development but a number of the saved local plan policies will be relevant for AVDC when considering the planning application. Aylesbury Vale Core Strategy, submission version AVDC s Full Council on 8 September, 2010 resolved to seek permission of the Secretary of State to withdraw the Core Strategy and, with it, the draft SPD for Salden Chase. By way of background however, the submission version of the Core Strategy includes Policy CS4 (North East Aylesbury Vale SDA) which allocates a site for 5,390 dwellings to the south west of Milton Keynes in line with the policies in the South East Plan. Milton Keynes Council made a number of objections to the submission Core Strategy which were discussed at the now suspended 5 (107)

6 examination. There has been no indication from the Inspector as to his views on this policy. Milton Keynes Local Plan, Adopted in December As with the Aylesbury Vale Local Plan, the proposal in the South East Plan (now revoked) for large scale development south-west of the city post dates the adoption of the local plan Policy S1 General Principles Policy S6 - Bletchley Policy D1 Impact of development proposals on locality Policy D2A Urban design aspects of new development Policy D2 Design of buildings Policy D4 Sustainable Construction Policy T1 The transport user hierarchy Policy T3 & T4 Pedestrians and cyclists Policy T5 Public transport Policy T7 Park and Ride Policy T9 The road hierarchy Policy T11 Transport assessments and travel plans Policy H4 - Affordable housing Policy H9 Housing mix Policy H12 Sites for travellers Policy TC1 Character & Function of the shopping hierarchy Policies PO1 & PO2 Planning Obligations Milton Keynes Core Strategy, pre-submission version, February 2010 Following the pre-submission publicity period in February and the subsequent abolition of the South East Plan, the MK Core Strategy is currently being reviewed and a revised version is due to be approved for pre-submission publication at Full Council on 14 September A verbal update on the Core Strategy status and revised policies of relevance to this proposal will be given to the Development Control Committee at the meeting. 3.0 RELEVANT PLANNING HISTORY (A brief outline of previous planning decisions affecting the site this may not include every planning application relating to this site, only those that have a bearing on this particular case) 3.1 There is no planning history of relevance to this current application. 4.0 CONSULTATIONS AND REPRESENTATIONS (Who has been consulted on the application and the responses received) 4.1 Local residents and stakeholders These were consulted on the application directly by Aylesbury Vale District Council. 4.2 Parish Councils AVDC asked MKC to consult the affected local councils within Milton Keynes on the planning application. West Bletchley Parish Council and Bletchley and 6 (108)

7 Fenny Stratford Town Council have sent their comments on the planning application to AVDC already, and these are summarised below for Members information: West Bletchley Parish Council (WBPC): The parish council strongly objects to the development on the grounds that: Any new development west of Bletchley would place an unacceptable burden on the A421 which is already operating beyond its capacity The development would result in an unacceptable increase in traffic levels, to the detriment of West Bletchley The proposal fails to take account of the grid road system The loss of green and open space Lack of information as to how the additional burden on Bletchley s infrastructure and facilities would be mitigated The site is no longer a suitable location for development given the abolition of the Regional Spatial Strategies. WBPC has already made comments on the AVDC Core Strategy and draft SPD. Both documents are considered to be flawed, especially in terms of lack of engagement. As these documents are still under review, the planning application is considered to be premature. Bletchley and Fenny Stratford Town Council: The council s view is that This site remains completely unsuitable for this type of development with a series of problems without suitable solutions. It is not sufficient to want development without considering the consequences. This opportunist proposal does nothing to enhance the area and does not meet the criteria for sustainable and enlightened developments. Consequently this Council is opposed to the development and considers that the proposals should be rejected. Detailed comments and objections on a range of issues including transport; design and place shaping; community facilities; funding; development standards; drainage. 4.3 Internal Consultees MKC officers consulted colleagues in key departments across the authority. Their detailed observations are discussed in the Considerations section (Section 5.0) below. 7 (109)

8 5.0 CONSIDERATIONS (The analysis of the issues which are critical, material, considerations and/or of greatest concern to objectors for the Committee to weigh up before making a decision) 5.1 POLICY ISSUES Strategic policy context: The planning application has been submitted in advance of the resolution of the AVDC Core Strategy examination and the policy context for this site is therefore incomplete and lacking clarity. MKC made objections to both the AVDC Core Strategy and the draft supplementary planning document for Salden Chase. In the absence of a final report from the Inspector on the Core Strategy, these objections remain unresolved. 5.2 Furthermore, since the planning application was submitted, there have been a number of important announcements and changes to the planning context for this site, the repercussions of which are still developing and make the planning policy context for this site somewhat fluid at present. The key changes and announcements are set out in detail in Appendix A, but in summary are: Secretary of State states his intention to revoke the Regional Spatial Strategies (RSS) by letter dated 27 May Resolutions made by MKC on 8 June 2010 on the growth of Milton Keynes and specifically in respect of the SW SDA. the publication of an interim report by the Inspector on the Aylesbury Vale Core Strategy on 11 June 2010, and a subsequent letter from the Inspector suspending the examination for the time being. the abolition of the RSS (including the South East Plan (SEP)) on 6 July 2010 A statement from AVDC on 14 July noting that the revocation of the South East Plan strikes to the heart of the allocation at Salden Chase Decision made by AVDC Full Council on 8 September to seek the permission of the Secretary of State to withdraw their Core Strategy. 5.3 The revocation of the RSS has removed the policy justification for the site that was originally enshrined in the South East Plan and has had a fundamental impact on the emerging AVDC and MKC Core Strategies. Although the AVDC Core Strategy is relevant to the consideration of the planning application, any weight given to it is substantially diminished by the recent announcement from AVDC that the council intends to seek permission to withdraw the document. MKC responded to the revocation of the South East Plan in the decisions taken at Full Council on 8 June. 5.4 Should permission to withdraw the AVDC Core Strategy not be forthcoming from government, the revocation of the RSS will have considerable implications for the document. The Inspector holding the examination into the AVDC Core Strategy recognised this in publishing his interim report. The 8 (110)

9 interim report however makes no specific mention of the Inspector s likely approach to the objections raised by MKC and other parties to Policy CS4 and the allocation of Salden Chase. The Inspector s subsequent decision to suspend the examination will delay further the resolution of these issues and makes the submission and consideration of this application even more premature. 5.5 It is important to note advice from Communities and Local Government published alongside the letter revoking the RSS that evidence used in the preparation of an RSS can be a material consideration. It is considered that this is relevant to this development given that the principle and general location of growth to the south west of Milton Keynes has been discussed and established over many years through the Milton Keynes South Midlands Sub Regional Strategy (MKSM SRS); the MK2031 growth strategy and the preparation of the South East Plan (SEP). Indeed, MKC s position on the AVDC Core Strategy has been to support the principle of growth in this location but to qualify this with specific and detailed concerns. This approach is maintained in the council s decisions on 8 June in which Members expressed their concerns about and opposition to the current proposals for Salden Chase. 5.6 The draft SPD has not been progressed and there has been no feedback on the responses received during the consultation on the document and on the likely outcome of those responses. It is not therefore possible to assess the planning application against this document at this stage. 5.7 In conclusion therefore, the abolition of the SEP and AVDC s decision to seek the withdrawal of its Core Strategy has removed the policy basis for the Salden Chase development. Even if permission to withdraw their Core Strategy is denied to AVDC, the policy context for this development remains incomplete and subject to outstanding concerns from MKC and others. Without knowing the outcome of the Core Strategy examination in respect of this site and seeing the final version of the SPD, it is difficult and premature to consider how the planning application meets the policy requirements. In its response to the planning application consultation therefore, the council should advise AVDC that it may wish to make further comments once the policy context is resolved. 5.8 TRANSPORT In submitting the outline planning application to AVDC, the applicants stated that they would also be submitting full planning applications for off-site highway works to the Tattenhoe roundabout (application to be made to MKC) and the Bottledump roundabout (application to be made to MKP). These planning applications have not been submitted at the time of preparing this report and it is therefore difficult to understand how, on the application form, the outline planning application can be described as having all matters reserved except for access. 5.9 Where a development requires works to be carried out on the existing 9 (111)

10 adopted highway, an agreement will need to be completed between the developer and the relevant Highway Authority under Section 278 of the Highways Act In the case of Salden Chase off-site highway works are proposed to 10 roundabouts within Milton Keynes. If planning permission is granted for Salden Chase, MKC would not be able to oppose the off-site highway works under S East-West Rail: One of MKC s original reasons for supporting the principle of growth in this general location is the contribution that the site could make to the delivery of the East-West rail link. More detail is however required from the applicants on the level and timing of contributions that are intended for the project and it will need to be demonstrated that these are both realistic and achievable. The applicant will also need to work closely with the promoters of the re-opened East-West Rail link to facilitate delivery of the proposed new station facility and ensure that potential noise from a reopened East-West Rail is mitigated in order to avoid undue impact on the development within the site. The draft SPD requires a site of 6ha for the railway station whereas the land use budget for the planning application includes a reserve site for the station within the neighbourhood centre which in total only extends to 5.25ha. It is therefore questionable whether all of the uses intended for the centre can be accommodated and what impact this will have on the deliverability of the station Bletchley Transport Study: Work is currently underway on a Bletchley transport study in response to local concerns of traffic issues in the Bletchley area, The study will assess the inherent pressures from developments within and around Bletchley and will provide a clear direction for taking forward transport improvements in a coherent manner against an agreed need. The need to consider the findings of the study in the transport proposals for Salden Chase was referred to in MKC s representations to the AVDC Core Strategy examination. The findings of the transport study will be used to inform further comments from this council on the transport aspects of the current proposals for Salden Chase Bletchley Southern By-pass: MKC has, in its objections to the AVDC Core Strategy and draft SPD for Salden Chase, asked for consideration to be given to the provision of the Bletchley southern by-pass in connection with this application. Whilst the inclusion of a reserve of land to protect a route for a possible future by-pass is welcomed, the Transport Assessment accompanying the planning application does not come to the conclusion that the construction of the bypass would deliver such benefits as to justify its delivery HIGHWAYS ISSUES Additional information has been requested by the Highway Engineer. The information, which includes grid road junction test information, was submitted to Buckinghamshire County Council and MKC in mid-august and is still being reviewed. However, an initial assessment suggests that the information is still 10 (112)

11 incomplete and does not address all of the concerns raised. Consequently, at this stage it is not possible to conclude whether the proposed off-site works are necessary and/or appropriate Detailed comments: Mode Shift Assumptions This is one of the most fundamental areas of concern. The Transport Assessment analyses potential trip generation from the proposed development across the various travel modes. The methodology used takes some journey to work information from local census data (for Emerson Valley Ward) and adjusts it for use in Salden Chase Data for other trip types (social, leisure, retail etc.) and modes (walk, cycle etc.) are then derived from the TRICS database, which is a nationally recognised assessment tool. Once the total number of trips has been determined (all purposes and all modes), these figures are then further adjusted to reflect a shift in mode away from the car to more sustainable modes Whilst this approach is consistent with best practice and government guidance, the extent to which mode-shift can be achieved must be considered very carefully in the local context. The agents have looked at initiatives from around the country that achieve mode shift away from the car. Whilst there is nothing fundamentally wrong with this approach, they have essentially cherry-picked the schemes with better results and have not taken into account the transferability of the results to MK (no account of population size, site location, public transport characteristics, town centre parking charges etc.) Single Point of Connection to MK and Lack of Adequate Access Strategy The current proposals for the development of Salden Chase have only one point of connection (for vehicles) to the rest of MK. Whilst several accesses are shown to the site (from Tattenhoe and Bottledump roundabouts and from an intermediate junction off the H8) any traffic using these 3 points will have to pass through the Tattenhoe roundabout junction one way or another. The agents maintain that they have modelled this junction and can make it work by carrying out improvements. The Council s Highway Engineer has doubts about this, but even if that is the case, it is difficult to accept that a major area of expansion containing over 5000 dwellings should be connected to the rest of Milton Keynes through only one point on the network. Whilst the applicant argues that this junction can be made to work as a technical exercise, it is considered that it is not appropriate to connect a major expansion area to a major town at a single point. Furthermore, it should be borne in mind that this point of connection is also the A421, a strategic east-west route and that it already forms one of the major connection points between West / Far Bletchley and the major road network The issue of point of access has repeatedly been raised as a concern during pre-application discussions and the provision of two additional links have been requested, one from Bottledump roundabout to H7 and the other from 11 (113)

12 the site to Newton Leys. The agents state that these have been tested but do not provide sufficient benefit to weigh against the cost of their provision The applicant stated that a further planning application would be submitted to MKC and MKP to cover the elements of the access works within Milton Keynes. This application has still not been received and as a result the site has only one access point that can be provided in accordance with the full proposals at Bottledump Roundabout The works to Tattenhoe Roundabout and Buckingham Road can not be completed without the further application and as a result the only access available at this point would be a relatively low-key junction on to Buckingham Road. This is clearly unacceptable and is a reason for objection in its own right The applicants also propose a further left-in and left-out access to the H8 halfway between Tattenhoe and Bottledump roundabouts. This junction is also outside of the current red line and could not be provided as part of any approval of Salden Chase by AVDC. It also requires the planning application to MKC / MKP Public Transport / Park and Ride There have been discussions about the way public transport will serve this site and about the provision of a Park and Ride site within Salden Chase. Whilst the applicant was willing to discuss Public Transport services, commitment to the Park and Ride site was not forthcoming. At this point in time the applicant has made land available within Salden Chase for a Park and Ride site, but is not willing to build it or fund services to/from it Despite the ambitious mode shift targets mentioned above, the applicant is not committing to making large contributions to providing the types of bus services that would help to deliver the step change in travel behaviour that the Transport Assessment suggests might happen. A much firmer commitment to funding Public Transport is needed Impact on West & Far Bletchley Whilst a great deal of data collection, analysis and modelling has been carried out, the level of detail for the Bletchley area remains quite low. General assumptions that little or no change to traffic within Bletchley as a result of Salden Chase do not seem logical or realistic. Whilst other destinations such as CMK and employment areas may attract more trips and whilst the grid roads may carry the bulk of these trips, the impact on local roads, such as Buckingham Road, Whaddon Way, Tattenhoe Road, Newton Road and Shenley Road need to be properly analysed Modelling at the City-wide level does not necessarily reflect access to schools and services on Buckingham Road and Whaddon Way. Nor does it reflect the potential for journeys from outside MK to transfer from Whaddon Road, which passes through Salden Chase, to Newton Road, which doesn t. 12 (114)

13 5.26 Impact on Rural Areas This also relates to the issue above. The impact of the development on journeys in the rural areas around Salden Chase is not fully understood. This may result in changes such as the shift from Whaddon Road to Newton Road mentioned above and other similar shifts in people s journeys. Buckinghamshire County Council is very concerned about this issue and it is understood that their view remains that the Transport Assessment does not adequately address it Off-site Highway Works This is perhaps one of the most contentious areas of the proposals. There are two issues of greatest concern, first is the nature of the works and second is the funding and delivery of the works themselves The applicant currently proposes, amongst other minor works, Public Transport provision and works within Aylesbury Vale, that the following alterations are made to junctions within Milton Keynes to accommodate the Salden Chase development. Junction Bottledump Roundabout (A421/Whaddon Road) Tattenhoe Roundabout (H8/V1) Windmill Hill Roundabout (H8/V2) Emerson roundabout (H8/V3) Elfield Park Roundabout (H8/V4) Bleak Hall roundabout (H8/V6) Shenley Roundabout (H7/V3) Medbourne Roundabout (H5/V3) Oxley Park Roundabout (H6/V2) Knowlhill Roundabout (H6/V4) Proposals Enlargement of Roundabout and signalisation Enlargement of Roundabout and signalisation Removal of Roundabout and full signalisation Removal of Roundabout and full signalisation Removal of Roundabout and full signalisation Removal of Roundabout and full signalisation Removal of Roundabout and full signalisation Removal of Roundabout and full signalisation Removal of Roundabout and full signalisation Removal of Roundabout and full signalisation 13 (115)

14 5.29 Attached is a plan that shows the proposed works within Milton Keynes as listed in Table 10.2 of the Transport Assessment. It can be seen that there are eight junctions where the traffic consultant deems it necessary to remove the roundabout altogether and replace it with signals and there are two junctions where the roundabout is to be enlarged and signalised (the two closest to the site). There are also four locations where carriageway widening is identified The removal of eight roundabouts and replacement with traffic signals is a significant step and will fundamentally alter the character and nature of the grid road network. As yet the applicant has not demonstrated that these works are necessary as they have not provided adequate evidence that other forms of improvement could not work at the junctions It may be that as a technical exercise it can be proven that these works are necessary to deal with the traffic. At that point a decision would have to be made as to whether that particular impact of the development could be accepted, for example either to accept the loss of the roundabouts or to accept traffic delays and congestion. For now the most appropriate course of action may be to object to the development on the grounds that neither of these two situations is acceptable Funding and Delivery of Highway Works Table 10.2 in the Transport Assessment shows that only 4 of the 10 junction improvements (including alterations to the carriageway) are proposed to be funded by the developer. The other 6 are identified as being funded by the Milton Keynes Partnership tariff It is also important to note that the applicant is not proposing to provide any contribution to Park & Ride other than to make some land available for it. No funding for the facilities or the bus services is offered. In addition, the Public Transport proposals have no funding commitment either The absence of any assurance on the funding of off-site highway works and the potential reliance on third party sources of funding is not considered acceptable on a development of this scale and nature. It raises considerable concerns about the delivery of these elements of the scheme and the prematurity of the application URBAN DESIGN MATTERS The Design and Access Statement follows the guidance contained within the DCLG Circular 01/2006 and has been well written and graphically documented 5.36 Response to Context It is considered that the proposed development has responded well to the existing context particularly with respect to protecting the Weasel Lane Ridgeline, the extension of the Loughton Brook Linear Park, 14 (116)

15 lower densities toward the rural edge and Far Bletchley and the primary access points being off existing Tattenhoe and Bottledump Roundabouts. It has also (albeit in a different form ie Primary Streets and not grid roads) extended the concept of a frame into the development thereby extending the MK road network. Other existing topographical features, existing rights of ways, footpaths and utilities have been well utilised to inform the overall structure. It demonstrates the important connection of the site to the Milton Keynes context and explains how the underlying structure of MK is reflected in the layout of Salden Chase. An important principle in MK is to provide pedestrian/cycle connections between adjacent grid squares. In this sense it is important to pursue the suggestion in paragraph 3.58 that a pedestrian/cycle connection under the H8 linking Salden Chase and Tattenhoe Park is investigated Developing the Structure and Design Evolution This has been well considered and has been informed by the Development Area, Strategic Ridge and Views, Strategic Valleys and Water Management, Edge Treatments and Key Points of Connection. Regarding Edge Treatments. For example, to mitigate against noise from the H8 and rail line, open space corridors are incorporated to mitigate against noise regarding the H8 a typical MK grid road reserve is incorporated. Impact on existing properties in West Bletchley are mitigated through new housing have back gardens backing onto existing gardens which also improves security. Within the development, neighbourhood and local centres, community facilities, employment, green infrastructure and residential development have been well considered and located to minimise such things as walk distances and improve legibility 5.37 Design The description, sketch and concept behind the neighbourhood centre is good. Ideally more buildings should be around the station rather than car parks as proposed but it is accepted that in order for the neighbourhood centre to also serve the primary street, it is not big enough to extend all the way down to the station, hence the car parks around the station Issues with Application Lack of Vision It is not clear what the Vision is is there a Unique Selling Point that makes it different to any other urban extension? Density While the Design and Access Statement (DAS) does say densities will range between 10 and 100dw/ha, which is supported, the Density Parameter Plan shows an enormous amount of the site at a very narrow range between 30-35dw/ha with very little proposed at 15 (117)

16 densities below 30dw/ha (the key is confusing in that the density range of 15-30dw/ha appears to be totally excluded form the development. The result of such a large proportion at between 30-35dw/ha means that a very monotonous development may potentially result. Grid road spur off Tattenhoe Roundabout This dual carriageway is problematic because it, in effect cuts off the local centre from the Park and Ride for easy pedestrian movement between the two mutually reinforcing public facilities. It does, however, reflect the grid road pattern of Milton Keynes. Primary Street The cross section shown is very urban and hard a verge should be included which is to be interspersed with on street parking. Redways should also be included along this street. It is not clear how the 3 lanes will work it seems in effect that for the majority of the primary street it will be a single carriageway in each direction with a 3 rd lane in places for turning etc. Whaddon Road bus gate Because there are such few north south connections (only 2 the primary street) that connect development either side of the Weasel Lane corridor, the bus gate for Whaddon Road should not be located between the Bottledump roundabout and neighbourhood local centre. This will allow a 3 rd street to be an important north-south road across Weasel Lane corridor. Primary Street Network / Structural Secondary Street This has moved away from earlier versions which showed a complete loop of the Primary Street why has the northern portion parallel to the H8 been downgraded to a Structural Secondary Street. The Structural Secondary Street appears to be an important street yet there is no specific guidance on its cross section (as occurs for the Primary Street). Similar guidance which fixes the key principles should be included. Redways No mention of these as an extension to MK, they should be included along the primary street in particular. Location of Neighbourhood Centre This location at the bottom end of the development is only viable if the rail station goes ahead. If it does not go ahead, the neighbourhood centre will be located in a place that gets very little passing traffic. Conversely the majority of passing traffic occurs toward the Bottledump and Tattenhoe Roundabout which would be a better location for the neighbourhood centre where it can attract the most passing traffic. 16 (118)

17 Location of Primary School 3 This should be located like all the other schools so it has a frontage onto the Primary Street (Structural Secondary Street) rather than introverted within residential uses Appearance While the DAS is correct in not outlining architecture details, because the development represents an urban extension to MK, it should take cognisance of the vision/ethos of MK as a forward looking, innovative, unique and modern 21 st century city and the appearance of buildings particularly in prominent locations such as along the primary street should reflect this ECOLOGY The habitat surveys demonstrate the development area is mainly farmland of little existing biodiversity significance. The most important habitat features are the tree-lined watercourse (WC3) and Weasel Lane with its associated trees and hedges. These are both retained as open space/green infrastructure corridors, as are many hedges. This is satisfactory However, is the treatment, of several designated sites of high biodiversity significance immediately adjoining the study area is not satisfactory. This is reflected in the Design and Access Statement which effectively ignores them. Moreover the application form wrongly states there are no designated sites or significant habitat features on or near the site. The application form is incorrect and therefore this matter should be resolved at the earliest opportunity, certainly prior to determination of the application Treatment of adjacent wildlife sites The Environmental Impact Assessment (EIA) Study Area boundary is drawn tightly to coincide with the development boundary and exclude these adjoining sites. Consideration of off-site impacts is essential for an effective EIA and the potential impacts on proximal designated wildlife sites should have been flagged at scoping stage. It is well understood that large urban developments in the countryside place increased pressure in surrounding areas, through increased demand for access. In extreme cases, habitats are degraded and agriculture made non-viable. Indirect pressures include noise, lighting, pets (dogs and especially cats), rubbish, camping, motorcycling, etc. Indeed, the Environmental Statement notes the possibility of increased informal access and recreation pressure on any unsecured area of open space within the vicinity of the study area Proposals for Thrift/Broadway Woods include a buffer zone ( Thrift/Broadway Woods Transitional Area ) within the green infrastructure corridor. However, this will not absorb all increased demand, and increased public access along the public bridleway through these woods is anticipated (Salden Wood has no public access rights and is across the disused railway). Ultimately it is for owners to secure their woods against trespass, and arguably the developer can do no more. However, it is essential to remove the proposed housing site within the green infrastructure belt: 17 (119)

18 5.43 It is important that the disused railway forming the southern boundary of the application area is assessed because it is of county importance for several nationally declining butterflies. Survival of butterfly colonies on the disused railway is relevant to Milton Keynes. Some of the critical species also survive in small numbers at the Blue Lagoon Local Nature Reserve in Bletchley, adjacent the same railway. If meta-populations (genetic linkage) of these species embraced both sites, extinction at Salden Chase could hasten extinction within Milton Keynes The application fails to take into account fully the potential impact on the railway if it is not brought back into use. The railway makes a 2.5km edge with the development including two schools and the local centre. The response to this juxtaposition is inadequate on two counts: It is inevitable the railway will become an area of illicit recreational space (ES ). Such sites typically attract problem usage e.g. fires, dumping (including alien plants), rubbish, motorcycling, dog-fouling or substance abuse. These may degrade the habitat and lead to demands to tidy up. There is no specific proposal to recreate and extend the railway habitats into the adjacent parkland corridor, including where that parkland is interrupted by schools and the local centre. This would provide alternative habitat if the railway were re-opened, and link the two Local Wildlife Sites. Such an outcome requires highly specialised treatment to recreate and maintain brownfield conditions very different from that applied to most parks fronting new residential areas In order to address the above concerns, the following amendments to the scheme have been suggested by the Council s Countryside Officer: Of the 70m wide parkland strip along the railway, a minimum of 25m should be allocated for construction of brownfield habitats targeted at particular butterfly species. A similar strip should be taken out of the school playing fields and if possible adjacent the local centre. There should be discussion with Network Rail over the treatment and management of the railway, short- and long-term. This should include issues of fencing, public access, habitat management and the reversion of the site should disposal ever arise Other layout issues The proposed green infrastructure corridor linking Thrift/Broadway Woods to Salden Wood on the western edge of the development is a positive part of the scheme. This will contribute to fulfil both Milton Keynes Green Infrastructure Strategy and the aims of the Whaddon Chase Biodiversity Opportunity Area 18 (120)

19 in the Bucks & Milton Keynes Biodiversity Action Plan. However, in the northwest the inclusion of an isolated housing site within the corridor seriously weakens any gains whether for biodiversity or amenity. In particular, bird and mammal species requiring large, undisturbed woodland territories (e.g. buzzard, raven, red kite, tawny owl, badger) could be deterred by associated disturbance (including cats and dogs) and woodland bats such could be deterred by lighting The Public Open Space links through the built area are good in principle, especially the retention of Weasel Lane, watercourse WC3 and the creation of a buffer zone along the railway and north to south through Phase 1. Overall, however, there is there is insufficient detail to justify that all these will be effective wildlife habitat and corridors. Defects include: Some links are very narrow, so unable to form a continuous link including diverse habitats in their cross-section. The network is substantially interrupted by playing fields, which are very poor wildlife habitat. There is no recognition of the existing Whaddon Rd with its verges and hedgerows though the latter are among those identified of conservation value The railway buffer zone is interrupted by two schools and the local centre occupying about 30% of its length 5.48 The proposals to remove existing ponds (P1 P4). P1 coincides with a proposed balancing pond, and P2, P3 are close to proposed open space corridors. Only P4, one of the larger and more persistent ponds is definitely overlain by development. The assumption is that these ponds will be more than adequately replaced by balancing ponds. However, balancing ponds are exposed to pollution and extreme flow regimes or level changes, which may reduce suitability for some species e.g. the protected species great crested newt. It is desirable to retain or recreate some stable, off-stream ponds, so P1 P4 should be retained and improved if possible. The above points need to be addressed in the application and a "biodiversity design code for both open space and built development should be established against which individual reserved matters applications can be assessed Phasing of open space and green infrastructure It is envisaged the development, if permitted would be carried out on a phased basis over a number of years. A major weakness of a phased implementation would also apply to open space and green infrastructure, with the most valuable feature, the Eco-Park and green infrastructure corridor linking Thrift/Broadway woods to Salden Wood, being in the final phase. This is fundamentally unsatisfactory, especially for woodland or hedgerow planting. First, such features require time to establish and mature, and for colonisation by flora and fauna. Planting should take place well in advance of 19 (121)

20 adjacent development, to minimise human pressure at this critical time. Second, the green infrastructure is conceived as a buffer between the development and off-site habitats. To achieve this it must be, at the time of first human occupation, attractive, legible, resilient, and offer effective wildlife cover. Therefore the open space and should be established as advance infrastructure and not phased Survey Requirements Surveys must be ongoing over the life of the scheme, both to obtain current information (e.g. where required for licensing) and in response to changes in wildlife distribution or the regulatory environment. Given the limited biodiversity interest, most survey work to date is sufficient for an outline application. The bat survey has some major deficiencies sufficient to justify an objection to the scheme. No bat survey was carried out of premises to be retained though excluded from and islanded within the development (Bletchley Leys Farm and The Leys). Hence the absence of bat roosts which might depend on the study area for foraging or commuting is not established. Similarly, no bat survey was performed at the adjoining ancient woodlands, Thrift/Broadway Woods County Wildlife Site and Salden Wood Local Wildlife Site. There is no overall bat activity survey of the development site which, in addition to identifying main commuting routes or foraging areas, could have pointed to such off-site roosts. The survey of two buildings with some bat roost potential, B10 and B13 at Weasels Lodge was a one-off late-season event (30 th September 2009) which on both counts fails to meet accepted standards 1 and does not justify the assertion (ES ) that no licence would be needed for demolition. A sample of trees with bat roost potential was surveyed (ES ) but the percentage is not stated. Further, there was no dawn swarming survey, recommended for trees. Hence the potential impact of the development on bats, which are strictly protected species, was not fully assessed. Moreover the application is misleading to state no protected species were found on the site as badgers and great crested newts occur immediately adjacent with badger holes on site, grass snake and adder were seen at an excluded property within the site, as were bats despite an out-of-season survey Green infrastructure. The Green Infrastructure (GI) approach is broadly accepted and shows the principles address the GI needs for north Aylesbury Vale (Priority Action area 1) from The Bucks GI Strategy March Elements that are not clear however are the consideration of the ecological matters identified within comments from the Council s Countryside Officer and how pedestrian connections of the GI areas outside the application boundary will be 20 (122)

21 achieved. These must be explained further as part of the GI: Open Space/Landscape Framework. The open space structure follows sound landscape structuring principles; however the contents within the open space will require some further clarification: Allotments: Minimal information provided apart from indicative locations shown on the drawings & allotments will be provided. The application must clearly indicate that allotments fill follow AVDC provision standards and distributed within correct population catchments areas. The location of the proposed allotment within the south east corner of the site s open space is very close to existing allotment provision within Chepstow Drive Local Park. Sustainable Urban Drainage System: the principle is supported; however, the detailed design needs to be carefully considered. Play Areas: Only minimal information provided. Play must be explained in further detail and this must demonstrate the play area type (LEAP/NEAP) and their distribution and sizes accordance with AVDC or recognised play policies. Play areas require a large space, so they are a fundamental element in the open space structure & must be not be considered at a later stage. The inclusion of the housing island within the western open space linear park extension is not supported. The design evolution for the location of the island is shown within the DAS (Page 39) and appears to be the response of retaining a footpath and watercourse network though the proposed linear park extension. The visual impact of the adjacent Thrift & Broadway (detailed as Ancient Semi Natural Woodland) would also be dramatically compromised, especially from southerly views. Trees/Hedges A comprehensive tree survey following recognised survey guidance (BS ) supports the application. Tree & hedges are essential to incorporate within new development sites (for structuring open space, maintaining & enhancing ecology, dividing housing etc), but it is difficult to assess the retention of these appropriate features, if the details are shown on a drawing without the development layout Relationship to Milton Keynes Whilst Salden Chase is located within Aylesbury Vale, its proximity to Milton Keynes means that the new development, if permitted, would function as an extension of the built area of Milton Keynes. It is therefore imperative that the development is designed to reflect the character and nature of Milton Keynes. 21 (123)

22 Some efforts have been made to reflect the key characteristics of the city such as the inclusion of a linear park around Loughton Brook. However, the absence of any clear identity and character for Salden Chase means that the development will just have the appearance of any residential housing estate. It is considered that the vision of Milton Keynes with an emphasis on high quality, modern and different architecture, as emphasised in the emerging Core Strategy, should be acknowledged as part of this development The scheme proposes footpaths and cycleways but does not incorporate the concept of redways. This is a key element of the residential areas in Milton Keynes, which clearly identifies cycle routes and should be included as part of the Salden Chase development One of the most identifiable characteristics of Milton Keynes is the grid road network. Grid Roads are defined in the emerging Core Strategy as: 'urban clearways with laybys for bus-stops, with no direct building frontages and no at-grade pedestrian crossings. Some are dualled, and the remainder normally have land reserved for future dualling.. They have substantial landscaping for biodiversity, sound screening and CO2/emissions absorption, usually incorporating a Redway. Collectively, they form a resilient, interconnected network with roundabouts at most gridway intersections, serving both public and private transport.' The proposal puts forward the concept of Primary Streets based on a layout of roads in a net to replicate the layout of the grid road network. However, the character of the grid roads with wide landscape buffers and no direct frontage buildings is not proposed. There are arguments for and against grid roads in this location, the immediately adjacent areas are not residential areas with grid roads (Bletchley, golf course and Snelshall) and recent developments in the expansion areas have moved away from the concept. However, grid roads do typify the majority of Milton Keynes and the emerging Core Strategy places emphasis on the grid system (Policies CS11 and CS13). It is therefore considered that the development will not fully integrate with and reflect Milton Keynes without the grid road system and it should be provided Paragraphs above refer to potential off site highway works that would be carried out if planning permission was forthcoming for the Salden Chase development. These works consist of the removal of eight roundabouts within Milton Keynes and the signalisation of a further two. At present the applicant has failed to demonstrate that these works are necessary and that other forms of junction improvements could not work. Further information and a robust justification for the off-site highway works is still required. That aside, if permission was granted for the scheme (either by AVDC or at appeal) the principle of these works would be established and other than detailed technical matters, MKC would not be able to oppose the loss of the roundabouts. Potentially the removal of so many roundabouts in the south western part of the city would have a significant impact on the character and nature of the grid road system and Milton Keynes as a whole. It would be potentially one of the greatest changes to the existing road system 22 (124)

23 in Milton Keynes. The retention of the grid road network is one of the requirements of the emerging Core Strategy and all new developments should look to retain the existing grid road system. In this case members need to consider if the additional information is provided and the technical objections are satisfied whether they still wish to object to the proposal on the basis of the loss of roundabouts. On the basis of significant alterations to the character and form of the grid road system and the impact this will have nature of Milton Keynes as a whole It is anticipated that local residents who live in the development will use many of the services and facilities provided by Milton Keynes and not Aylesbury Vale. Therefore, it is considered that the development should make a contribution to improve the local infrastructure. This is discussed in more detail in the paragraphs on S106/ Developer Contributions below Flooding and water management There are concerns within Bletchley that the development at Salden Chase will worsen existing flooding problems along the Jubilee Brook as the southeastern corner of the site drains into that watercourse. Milton Keynes Council officers responded to a Flood Risk Assessment (FRA) scoping request earlier in the year and requested that a strategic and integrated drainage approach should be an integral part of all objectives. It was considered that the scoping report was not sufficiently clear on this nor did it look beyond the site boundaries of Salden Chase or consider the development s strategic water management context The Environment Agency objects to the current planning application on the grounds that the FRA submitted with the application does not comply with the requirements set out in Annex E, paragraph E3 of Planning Policy Statement 25 (PPS 25) and does not therefore, provide a suitable basis for assessment to be made of the flood risks arising from the proposed development. Due to the method that the FRA uses to assess flood risk the Environment Agency is of the view that it could have significantly underestimated the amount of surface water runoff from the site. One result of this could be to lead to an unacceptable increased flood risk for residents of Milton Keynes. Officers share the Environment Agency s concerns and object to the current proposals as they have failed to adequately address the issue of flood risk for residents of Bletchley and Milton Keynes Noise The Council s Environmental Health Officer questions why the proposed employment B1/B2 uses are located within the development site adjacent to the residential and amenity areas of Tattenhoe, rather than adjacent to the existing employment uses of Snelshall. The commercial areas of Snelshall involve 24 hours warehousing operations, distribution centres and industrial food processing. There are also proposals for a Lorry Park. These uses are inconsistent with the environmental quality required by residential areas. 23 (125)

24 5.60 Before any decision is made concerning this Application, an Acoustic Survey should be carried out by a duly competent person, assessing the environmental noise impacts on, and from, the development site. The assessment report should contain test methodology and results (with all supporting data) together with a suggested detailed schedule of noise mitigation and insulation works Proposed Travellers Site (Policy H12, Milton Keynes Local Plan) Whilst the planning application lies outside the area covered by the MKLP, there is a potential conflict between the current proposals and Policy H12 which allocates land for a travellers site to the south-eastern side of the Bottledump roundabout. The proposed travellers site immediately adjoins Salden Chase, but has not been acknowledged in the documents accompanying the planning application Immediately to the south of the proposed travellers site lies a proposed area of open space into which are integrated surface water attenuation features (ponds) and beyond that an employment site where buildings up to 15 metres in height are proposed. There is no information in the planning application to indicate that consideration has been given to the juxtaposition of the travellers site with the layout and design of this part of the Salden Chase development. AVDC should be asked to ensure that the development gives due consideration to the potential travellers site Energy Strategy The Energy Strategy submitted with the application acknowledges that more work needs to be done on finance to determine what is actually deliverable. This primarily relates to the implementation of a community energy network, which will have high initial capital costs. The report seems to suggest that a site wide approach would be the most sensible solution for the whole development, but that the early phase could meet the required standards on a home by home basis The report acknowledges that allowances have been made in the framework for site wide solutions to be delivered. However, it does not set out what these allowances need to be, so it is not possible to assess whether these have actually been included in the masterplan. At this early stage therefore, a reserve site should be included within the proposals to provide land for a potential site wide solution The report also acknowledges that the layout of the area needs to be influenced by the need to maximise energy efficiency of building design (i.e. orientation). This is not really covered in the Design and Access Statement. There is a reference to maximising passive solar gain in the context of a sustainability statement that is to be prepared in the future in conjunction with the local authority and stakeholders but nothing to suggest that it has been proactively planned for at this stage. If this isn t taken into account, the developers may find it difficult to deliver the required level of savings in the 24 (126)

25 later years of the development in a cost effective manner The report seems to suggest the most efficient approach would be biomass Combined Heat & Power. There is a however a question as to whether there is a good enough supply of biomass to make this realistic Whilst therefore there is some useful information about the energy strategy for this development, there is a lack of detail and a failure to follow through the findings of the study into the design and layout of the site Retail The Salden Chase retail impact study (RIS) has been prepared in the context of the draft Milton Keynes Retail Capacity and Leisure Study and not the final study produced in February The applicant s study assumes that Salden Chase will not be completed and fully occupied until This is a long timescale over which to attempt to forecast the impact of the scheme. Five years or a maximum of ten years is more usual. The accuracy of the forecasting towards the second half of the development period is, therefore, questionable The amount of convenience floorspace proposed is greater than the guideline figure of 3,500 sq m of floorspace assumed in MK Retail Capacity and Leisure Study. (Para 6.14) which advised the Council to adopt a flexible stance on the scale of new food store provision reflecting the local circumstances of particular applications,and the specific quantitative and qualitative benefits of proposals that come forward A major concern is the impact of the development on the Council s aspirations to regenerate Bletchley (MKLP Policy TC1) and objectives for MKLP policies TC14-TC17. No mention made in the applicant s Retail Impact Study (RIS) of the Central Bletchley Regeneration Strategy, adopted as Supplementary Planning Guidance on 20th July The applicant s RIS needs to consider not only the individual impact of the Salden Chase scheme on surrounding centres but also the cumulative impact of other store proposals. In Appendix 5 of the RIS it acknowledges that 27 units (17%) are vacant in Bletchley town centre including the 2900 sq m Coop store but then goes on to refer to Bletchley as relatively healthy town centre in our opinion regardless of what is provided at Salden Chase, Bletchley does and will continue to provide a positive retail experience for its immediate catchment. This is considered to be an overly optimistic statement and is at variance with the evidence of the high level of shop vacancies which, in your officers view, suggests that Bletchley town centre is not performing particularly well Employment provision The development proposes an employment area of 7.5ha, including employment floorspace (use classes B1a, B1b, B1c, and B2), utilities and 25 (127)

26 renewable energy infrastructure, commercial and household recycling centres. Jobs will also be created in the proposed neighbourhood centre and two local centres. The planning statement concludes that the scheme provides for employment land and a level of retail and associated uses within the proposed network of district and neighbourhood centres, appropriate to the scale of new housing proposed The Employment Land Assessment (ELA) submitted with the planning application refers to the GVA Grimley SDA study (April 2008) which assumed total land requirements for employment sectors within the SDA as 15.32ha (5.12ha offices, 2.75ha industry and 7.45ha for distribution). However, the ELA concludes that provision should be made for a total of 7.5ha (2ha offices and 5.5ha for industrial). This is a significantly reduced employment allocation, albeit in line with the draft SPD to which MKC objected. The amount of available on-site employment land is further compromised by the commitment to provide a household waste and recycling centre on a site of at least 1ha within the employment area The ELA suggests that the shortfall in employment from that planned for in the GVA Grimley Study could be accommodated in the existing neighbouring development at Snelshall or in the newly allocated employment area in the Eastern Expansion Area of MK. Employment land in these areas is however required to provide employment opportunities for existing and permitted homes, and should not be used to meet a shortfall from new development proposals. In relying on the availability of sites outside the application area to offset the shortfall, this approach is unsatisfactory and does not justify a significantly reduced on-site employment allocation In addition, 7.5ha of employment land represents just 2.7% of the overall site area. This should be considered against the overall position in the rest of the city where, as a rough guide, 14% of all land is intended for employment uses The Employment Land Assessment submitted with the application would benefit from further work to identify the amount of employment land by sector including likely job generation and density assumptions, information on the balance between strategic and local jobs and the likely level of off-site job creation needed to serve the development and the extent to which Milton Keynes job target ratio of 1.5 jobs per new home is likely to be achieved Capacity of site to accommodate all development The ability of the Salden Chase site as allocated in the AVDC Core Strategy to accommodate all necessary development was discussed at the examination. The same concerns apply to the current planning application. Comparing the proposed land use budget for Salden Chase with other urban extensions in Milton Keynes, there is a concern that the amount of land available for some uses is unacceptably limited. Specific issues include; 26 (128)

27 Green Infrastructure the proposals show that around one third (33%) of the site area is allocated for green infrastructure. This compares to the urban area of Milton Keynes where around 40% of the urban area is used for green infrastructure. There is a further concern that the intended multifunctionality of the green infrastructure at Salden Chase especially the intention to use green space to store and manage surface water, means that that the usability of the open space could be compromised further reducing the total amount of open space available for residents.. These issues were also raised in MKC s comments on the draft SPD. Employment comments above note that there seems to be a shortfall on the amount of employment proposed for the development. It is worth comparing this site to the expansion areas in Milton Keynes, particularly the Western Expansion Area where 17ha of employment land is allocated (4.6% of the total site area). In comparison, the 7.5 ha of employment land designated for Salden Chase represents just 2.7% of the total site area. Arguably, Salden Chase, with its direct access to the A421 is strategically better located than the WEA and so a higher level of employment land would be justifiable. Densities in local centres It is unclear that everything planned for the local/ district centres can be accommodated on site. For example, para 2.4 for the Design And Access Statement states that the 2 local centres and a small mixed use centre are proposed to provide a total of up to 1.78ha gross. Alongside all of the other uses intended for these areas, there is provision for up to 2 reserve sites for renewable energy centres each of which requires1ha of land; so two of which would require 2ha which exceeds the total gross land allocation of 1.78ha. There does not therefore appear to be sufficient land set aside to meet all of the competing uses for these areas. Without details of what the renewable energy centres will entail it is difficult to assess how they will relate to the other uses, especially residential and whether buffer areas of separation from sensitive uses will be required On a similar but separate issue, given the scale of this proposed development and the long timescale for it to be built out, it would be beneficial to include some reserve sites to build-in some contingency and flexibility and to meet future, as yet unplanned needs. This approach has worked successfully in Milton Keynes in the past including in the western and eastern expansion areas. Although we would, therefore, like to see the principle of providing reserve sites included in these proposals there seems to be little if any capacity to provide them given the above concerns about the capacity of the site Links between Salden Chase and Far Bletchley Concern has been expressed by local residents that the new link shown between the Salden Chase site and Hamilton Lane must be a pedestrian /cycle link only. Although this is explained in the Design and Access Statement, the Primary Movement Network plan shows a secondary street within Salden Chase running west to east towards the boundary of the site with the Racecourses properties. This street does however stop short of the 27 (129)

28 site boundary and is downgraded to carry just pedestrians and cycles into Hamilton Lane The response to AVDC should emphasise the need for the link to carry pedestrian or cycle traffic only. SECTION 106/ DEVELOPER CONTRIBUTIONS 5.81 Work has been carried out by AVDC, Bucks County Council and MKC to agree an infrastructure schedule for Salden Chase. The schedule had been prepared with the involvement of a wide range of local authority and public sector service providers and was intended to enable to range of infrastructure requirements to be identified, costed and discussed with the developers. A successful workshop was held on 26 May 2010 at which local authority service providers came together to discuss their needs and the most effective ways of providing services for the new development In the hiatus that followed the Secretary of State s announcement on 27 May that he intended to abolish the RSS, joint work on the infrastructure schedule has ceased. Should this development proceed, MKC see it as a prerequisite that the dialogue with AVDC and other stakeholders be reinstated so that a comprehensive infrastructure schedule can be achieved which will be fit for purpose to serve the proposed development within Aylesbury Vale as an urban extension of MK. Ongoing work will be required to co-ordinate crossboundary delivery of services where these represent the most effective form of provision. The work carried out to date has, however, identified a number of infrastructure and funding issues of relevance to this planning application: 5.83 Highway funding issues: As discussed in the Highways Issues section above, the applicants have made a very poor commitment to the funding of off-site highway works, public transport and park and ride. Table 10.2 of the Transport Assessment shows that only 4 of the 10 junction improvements are proposed to be funded by the developer. The other 6 are identified as being funded by the tariff. The applicant is not proposing to provide any contribution to Park & Ride other than to make some land available for it nor is funding for the facilities or the bus services is offered. In addition, the public transport proposals have no funding commitment either Need for improvements to facilities in Bletchley town centre, including car parking and transport links to it: Development to the south-west of Milton Keynes has long been seen as providing a boost to the regeneration of Bletchley. The MK2031 Growth Strategy refers to one of the benefits of the proposed growth strategy as support for regeneration and investment in key centres, including CMK and Bletchley. A contribution should therefore be sought for further investment and improvement in facilities within Bletchley town centre to meet the needs of the new residents of Salden Chase Short term impacts, at the early stage of development: during the early stages of the development, until the on-site facilities are provided, there may be short term pressures on facilities in Milton Keynes which should be reflected in the 28 (130)

29 S106 agreement. For example these include: Education: although Bucks County Council is the local education authority, there may be pressure for Milton Keynes schools to absorb some pupils from Salden Chase at the early stage of development before the on-site schools are provided. Waste: the Draft Heads of Terms indicates that there is a commitment to set aside at least 1ha of employment land to provide a Household Waste Recycling Centre. The sentiment is welcomed, although the loss of further employment land is of concern. However, until the onsite provision is made there will be increase pressure on Milton Keynes recycling centres Health services: until the GP surgery is provided on-site residents will have to make use of existing GP facilities. Libraries and community facilities, on-site provision may lag behind housing completions, placing pressure on MKC facilities such as the libraries in Westcroft and Bletchley and community facilities such as Tattenhoe Pavillion Longer term and ongoing pressures on Milton Keynes services: due to the location of Salden Chase it is inevitable that the majority of residents will look to Milton Keynes and Bletchley for many services and facilities not available on site. This will place additional pressure on those services and the council wishes to ensure that S106 funding will be available to create additional capacity where possible. For example: Higher education: due to the relative proximity of Salden Chase to Bletchley and the potential accessibility that East-West rail would provide, Milton Keynes College s Bletchley campus is likely to be the provider of choice for post-16 students not in school sixth forms, rather than Aylesbury College. The college has identified investment requirements in response to the projected increase in demand for Bletchley and MK College as well as the University Centre MK. Leisure facilities: demand for swimming and sports centre facilities will need to be met off-site and this is likely to increase pressure on the existing facilities at Bletchley Leisure Centre. Further discussions would be needed between the leisure teams at AVDC and MKC. Sport England comments that the additional population will create significant additional demand for indoor sports facilities and recommends that the exact nature of this demand should be established. Cemetery/ crematorium: a contribution is sought towards the new crematorium which although now provided, is not fully funded from the tariff or growth fund. In terms of the location of a cemetery/burial ground, it is assumed that the nearest cemetery to be used by Salden Chase residents would be the Selbourne Ave Cemetery in West Bletchley. The further development of this site and the development of the West Flank cemetery are currently unfunded. Museum facilities: it is understood that AVDC will require a contribution towards museums and archives to develop a showcase facility relevant to the area. MKC has its own archive and museum plans and as 29 (131)

30 residents, schools and community organisations from this area will be accessing those services, funds will be required to support those MKC facilities to enable outreach to this development, and potentially out of a library or other local centre. Community development: the community development approach developed with the Milton Keynes Council for Voluntary Organisations for the expansion areas using Tariff money provides a good example of community support and arrivals work in new development. Given the potential confusion for new residents of where to go for services and assistance (AVDC, Bucks County Council or MKC) it is considered that community development will have a key role to play here. 6.0 CONCLUSIONS (The officer advice to the Development Control Committee on the appropriate decision, based on the policies of the Development Plan, taking into account the issues detailed in the report) 6.1 From the issues raised in Section 5 above it is clear that there are wide ranging concerns about the planning application for Salden Chase which, together with the resolution made by MKC on 8 June, lead to a conclusion that MKC cannot support the current proposals for Salden Chase. 6.2 However, should the development go ahead, it will be essential to reinstate the joint working arrangements between MKC, AVDC and Bucks County Council to fully consider the cross-boundary impacts that the development will have and plan for infrastructure and the effective delivery of services to new residents. 6.3 Once agreed, the concerns raised in this report should be referred to AVDC to assist that council in its determination of the planning application. There is a distinction to be made between those concerns which are serious enough to lead to MKC to objecting to the proposals and other issues which need to be commented on and borne in mind should the scheme progress. 6.4 Further to the Councils resolution of the 8 June, Members are advised that MKC should object to the following aspects of the Salden Chase planning application: a) The application is considered to be premature in that it has been submitted in advance of the finalisation of the AVDC Core Strategy and draft SPD. Events have now overtaken this issue, and the abolition of the South East Plan and the subsequent decision of AVDC to seek permission to withdraw its Core Strategy removes any approved policy context to support this development. b) Although acknowledging that evidence prepared to support an RSS can be a material consideration, it is considered that the support that this evidence might give to locating a growth area to the SW of MK does not overcome the many issues, gaps and concerns with the current proposals. c) The information supplied in support of this planning application does not adequately address the transport impacts of the development. Insufficient 30 (132)

31 information has been provided to allow the Council to properly assess the impacts of the development on the transport network in Milton Keynes. In particular, there is insufficient information and justification for the off-site highway works that have been identified. d) The planning application and in particular the supporting Transport Assessment does not provide sufficient assurances that the level of infrastructure and transport provision needed to support the proposals will be funded by the applicant. In some cases the applicant clearly identifies third-party sources of funding. e) The development is connected to the rest of the road network in Milton Keynes at a single point Tattenhoe Roundabout. Given that this single connection point is part of the A421 and is one of the major connections between Bletchley and Milton Keynes, it is not appropriate that it should also have to accommodate 100% of the traffic and public transport movements between Salden Chase and Milton Keynes. f) The proposal as submitted does not include an appropriate or adequate access strategy to allow movement to and from the site to take place adequately and with safety and convenience. Land outside the outline application site would be required to provide the central access to Standing Way (H8) and to accommodate a properly laid out and adequate access to Tattenhoe Roundabout. g) The design of the proposals fails to adequately reflect the vision and ethos of Milton Keynes which would be appropriate for an urban extension to the city and fails to include redways and grid roads which are a key characteristic of Milton Keynes. h) The ecological surveys accompanying the application and the environmental assessment are inadequate to assess the impact on species, including bats, badgers and newts. i) The study area of the environmental assessment is drawn too tightly around the site area and fails to consider the strategic context of the site and the immediate off-site impacts that the development will have. j) The intention to phase the provision of landscaping and open space is not acceptable open space should be delivered as advance infrastructure as it takes time to become established. k) The application fails to adequately address the issue of flood risk for residents of Bletchley and Milton Keynes. l) The timescale over which the retail impacts of the development are assessed is unduly long and potentially inaccurate. The Retail Impact Study accompanying the planning application fails to adequately assess the impact that Salden Chase will have on Bletchley town centre and MKC s aspirations for regeneration of that area. m) The proposals provide insufficient land for employment uses, with only 2.7% of the total site area designated for such uses, compared to around 14% typical across the Milton Keynes urban area. n) The application has failed to demonstrate that there is sufficient land within the site area to accommodate all necessary development. This could either lead to pressure for higher residential densities should the scheme progress or the need to seek off-site provision of key facilities. 31 (133)

32 6.5 The following comments should also be taken into consideration: The protection of a reserve site for a future potential link road between the A421 and the A4146 (the Bletchley southern bypass) is welcomed and must be maintained should the development proceed. Concern at juxtaposition of residential development on Salden Chase with the existing employment uses to the north at Snelshall which brings potential for noise and disturbance. Before the application is determined, an acoustic survey should be carried out assessing the environmental noise impacts on, and from, the development site. The impact of the development on the proposed travellers site at Bottledump roundabout needs to be properly addressed. In terms of energy, whilst the Energy Strategy accompanying the application includes some useful information about the energy strategy for this development, overall there is a lack of detail and a failure to follow through the findings of the study into the design and layout of the site. This would need to be addressed should the development proceed. The link between Salden Chase and the established residential area of Far Bletchley via Hamilton Lane should be restricted to carry pedestrian or cycle traffic only. The detailed layout should remove the proposed housing within the open space linear park area within the western corner of the site. Should this development proceed, it is a prerequisite that the dialogue with AVDC and other stakeholders be reinstated so that a comprehensive infrastructure schedule can be achieved and developer contributions agreed. Ongoing work will be required to co-ordinate cross-boundary delivery of services where these represent the most effective form of provision. The above objections and comments should be referred to AVDC, together with a copy of the full committee report as background. 7.0 RECOMMENDATION That Committee considers and agrees the objections and comments set out in paragraphs 6.4 and 6.5 and elsewhere in this report as MKC s response to Aylesbury Vale District Council (AVDC) on the planning application for 5,311 dwellings at Salden Chase, south west Milton Keynes. That, the response to AVDC includes the resolutions taken by MKC at Full Council on 8 June 2010, that.. the Council calls upon Government to assist Milton Keynes Council as a matter of the greatest urgency in: 2c opposing the unnecessary and inappropriate proposal before Aylesbury Vale District Council to build over 5300 houses on land at "Salden Chase" to the South West of Bletchley, which would place a considerable burden upon 32 (134)

33 the infrastructure of Milton Keynes and Bletchley in particular; and.. 3c gives a commitment to oppose the expansion by stealth of Milton Keynes beyond its existing boundaries, and to make specific representations to Aylesbury Vale District Council opposing the "Salden Chase" proposals currently before them; That the response should advise AVDC that MKC may wish to submit further comments on the planning application should the policy context change further or should any further technical detail for example on the transport assessment, be provided by the applicant. 33 (135)

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35 APPENDIX A DETAILED POLICY CONTEXT As discussed in Section 5.0, (Considerations) in the main report, the policy context for this site is fluid at present due to changes in the planning system at a national and regional level and their implications for local strategic policies. The key changes are: the abolition of the Regional Spatial Strategies (including the South East Plan) on 6 July 2010 Resolutions made by MKC on 8 June 2010 on the growth of Milton Keynes and specifically in respect of the SW SDA. the publication of an interim report by the Inspector on the Aylesbury Vale Core Strategy on 11 June 2010, and a subsequent letter from the Inspector suspending the examination for the time being. A statement from AVDC on 14 July noting that the revocation of the South East Plan strikes to the heart of the allocation at Salden Chase Decision made by AVDC Full Council on 8 September to seek the permission of the Secretary of State to withdraw their Core Strategy. The above issues are discussed in more detail below: Revocation of Regional Spatial Strategies (RSS) At the time the application was submitted, the key policy basis for the development was the South East Plan (SEP). Policies H1 and MKAV1 established housing targets for the Milton Keynes growth area and Policy MKAV2 required the provision of a Strategic Development Area (SDA) of 5,390 dwellings as a sustainable urban extension to the south-west of Milton Keynes, to be located in Aylesbury Vale. The concept of a south west extension to Milton Keynes has previously been established through the Milton Keynes and South Midlands Sub-Regional Strategy (MKSM SRS) and the Milton Keynes Growth Strategy (MK 2031). With the revocation of the RSS, the development plan for this site now comprises the adopted Aylesbury Vale Local Plan and the emerging Aylesbury Vale Core Strategy. A draft SPD for the site has also been the subject of consultation and, once adopted, will form part of the Aylesbury Vale LDF. Advice from Communities and Local Government (CLG) on 6 July 2010 noted that evidence that informed the preparation of the revoked regional strategies may be a material consideration in the determination of planning applications, depending on the facts of the case. MKC resolutions on the Growth of Milton Keynes, 8 June 2010 There are two specific references to the current proposals at Salden Chase in the decision notice from Full Council on 8 June 2010: That the Council calls upon Government to assist Milton Keynes Council as a matter of the greatest urgency in: 34 (136)

36 2c 3c opposing the unnecessary and inappropriate proposal before Aylesbury Vale District Council to build over 5300 houses on land at "Salden Chase" to the South West of Bletchley, which would place a considerable burden upon the infrastructure of Milton Keynes and Bletchley in particular; and.. gives a commitment to oppose the expansion by stealth of Milton Keynes beyond its existing boundaries, and to make specific representations to Aylesbury Vale District Council opposing the "Salden Chase" proposals currently before them; Aylesbury Vale Core Strategy and examination The submission version of the CS, includes an allocation of a site for 5,390 dwellings to the south west of Milton Keynes (referred to as the North East Aylesbury Vale SDA). Policy CS4 sets out a number of requirements for the SDA, including the provision of employment, infrastructure, local services and flood mitigation measures in addition to the residential development. At Cabinet on 21 July 2009, MKC supported the principle of a growth area to the south west of Milton Keynes, as being consistent with the South East Plan; the Milton Keynes Growth Strategy and the emerging Milton Keynes Core Strategy. MKC however raised a number of detailed objections to the proposals in the Core Strategy covering the following broad issues: lack of weight given to the strategic context and identity of the SW SDA; joint working arrangements; transport impacts infrastructure requirements, including capacity of the site place-shaping principles; infrastructure and delivery and the site allocation process. The Core Strategy was subject to an examination in February April 2010 and included a specific session on the south west Milton Keynes SDA at which the above objections were discussed. Inspector s interim report on the AVDC Core Strategy The Inspector published an interim report on 11 June 2010 and asked for views on the implications for the core strategy of: 1) the revocation of the South East Plan 2) changes to PPS3 regarding the definition of brownfield land and abolition of the minimum density requirement for new housing and 3) his preliminary comments on the proposed strategy for the growth around Aylesbury town (these do not directly affect the proposals for the SW SDA (Salden Chase). 35 (137)

37 Milton Keynes Council s response to the interim report was agreed by Cabinet on 16 July. The response refers to the Council s decisions on 8 June and suggests that any future development to the south west of Milton Keynes should be the subject of joint work and agreement between MKC and AVDC. In advance of those discussions taking place, the council considers that it is premature to maintain the allocation of the Salden Chase site in the AVDC Core Strategy. Additionally, the implications of the abolition of the South East Plan are such that it would be appropriate to reopen the Core Strategy examination to allow for a full and open discussion by all interested parties. A statement made by the AVDC Cabinet portfolio holder for planning on 14 July addresses the impact of the abolition of the RSS. The district council acknowledges the need for growth, but welcomes the opportunity to determine its own level of growth. A reference was made to the allocation of land for the SDA (Salden Chase) - the scrapping of the South East Plan strikes to the heart of the necessity for this allocation. The Inspector wrote to all respondents to the core strategy again on 10 th August. He acknowledges that AVDC wishes to undertake further work to assess appropriate levels of growth for the district and as a result he has concluded that the core strategy examination should be suspended for the time being. He wishes to hold a further session, probably in January 2011, to discuss district-wide housing figures. MKC s objections to the AVDC Core Strategy in respect of Salden Chase therefore remain unresolved at present with no indication from the Inspector as to his likely conclusions. AVDC Growth debate, 8 September AVDC s Full Council on 8 September voted unanimously to seek the permission of the Secretary of State to withdraw their Core Strategy. Should this be granted then AVDC will start the process of preparing a new Core Strategy in due course. Wider policy issues: Salden Chase (North East Aylesbury Vale) Masterplan and Delivery SPD The preparation of an SPD for Salden Chase is referred to in the AVDC Core Strategy. It is intended to help the determination of planning applications by providing up to date guidance about its requirements and quality standards and to assist developers when preparing detailed proposals. AVDC published the draft SPD for consultation for 6 weeks from 20 January The SPD addresses the vision, site context and key development principles for the site including sustainability, movement, flooding and drainage and green infrastructure. It includes a concept plan and outline land use budget and sets out the approach to phasing and the provision of infrastructure. At Cabinet on 16 February 2010, MKC agreed the key issues for Milton Keynes arising from, the SPD which were then set out in more detail in the council s final response to AVDC. The key issues are: 36 (138)

38 lack of emphasis within the SPD to the role of the SDA as a sustainable urban extension to Milton Keynes and Bletchley the need for a clear vision to establish the role and function of the site and the development standards to be applied. Travel and transport, including the need to stress reducing the need to travel; the transport assessment needs to deal with existing issues in the context of the impact of the new development. Sustainable construction and renewable energy standards for the development should reflect those applied in Milton Keynes. Allowance should be made for reserve sites for energy centres Community support and development: the MK approach to support and arrivals work delivered by the MK CVO in the Milton Keynes expansion areas should be rolled out into the SDA. Infrastructure provision standards should reflect those applied in Milton Keynes; phasing of key infrastructure, eg schools will require careful crossboundary liaison. Ongoing engagement with the surrounding communities is required to progress the SPD; a stakeholder group should be established. AVDC has stated that it will not be in a position to progress the SPD until the issues affecting the Core Strategy are resolved. As noted above, should AVDC resolve to withdraw its Core Strategy then no further work would be carried out on the SPD. The comments made by MKC on the draft SPD do, however, serve as a record of some of the council s detailed concerns about the development of Salden Chase which remain applicable to the consideration of the current planning application. Milton Keynes Core Strategy The pre-submission version dated February 2010 included Policy CS6 for the South West SDA which seeks to identify and address the impacts that the development will have on Milton Keynes and Bletchley. The Core Strategy was published for presubmission comment in February 2010 with submission planned for August. However, as a result of the revocation of the SEP and to reflect the decisions made by MKC on the motion for the growth of Milton Keynes on 8 June, the core strategy is now being refreshed. A refreshed version of the Core Strategy is to be discussed at LDF Advisory Group on 8 September with the intention of it then being referred to Full Council on 14 September for approval to go out to pre-submission consultation and subsequently submission. A verbal update of the current status of the Core Strategy and changes to relevant policies will be given to the Development Control Committee at the meeting. 37 (139)

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41 40 (142)