APP 01

Application Number: 16/02451/FUL

Demolition of all existing buildings and replacement with the erection of 184 residential dwellings comprising 172 one and two bedroomed apartments and 12 townhouses, 112 sqm of community use (D1) and 215 sqm of flexible use across A1, B1a or D2, provision of private open space and landscaping, provision of an internal vehicular network and associated highway works and car parking

AT Land To The South of Princes Way and West of Albert Street, Bletchley

FOR Remitone Properties Limited, Octavia Homes (Bletchley) Limited, and Investec Bank PLC

Target: 13th December 2016 (Extension of Time: 11th April 2017)

Ward: Bletchley Park Parish: Bletchley & Fenny Stratford Town Council

Report Author/Case Officer: Adam Smith Senior Planning Officer Contact Details: 01908 252499 [email protected]

Team Leader:: Katy Lycett Interim DM Manager West Team Contact Details: 01908 252313 [email protected]

1.0 INTRODUCTION (A brief explanation of what the application is about)

1.1 The main body of the report set out below draws together the core issues in relation to the application including policy and other key material considerations. This is supplemented by an appendix which brings together planning history, additional matters and summaries of consultees’ responses and public representations. Full details of the application, including plans, supplementary documents, consultee responses and public representations are available on the Council’s Public access system www.milton- keynes.gov.uk/publicaccess. All matters have been taken into account in writing this report and recommendation.

1.2 This application is referred to the Development Control Committee for determination as more than one third party letter of objection has been received; Bletchley and Fenny Stratford Town Council has expressed concerns regarding the detail of the scheme; and Councillor Webb has objected to the application.

1.3 The Site

The application site is located in Bletchley Town Centre. It is neighboured by Princes Way and a retail park to the north; Albert Street and two storey terraced dwellings to the east; South Street, a bus station and associated car parking to the south; and Saxon Street and the railway to the west.

1.4 The application site is divided into two parts by the applicant: Bletchley View North and Bletchley View South. The two parts of the site are separated by a single storey Burger King fast food outlet and associated parking.

1.5 Bletchley View North is occupied by the Enigma Tavern, which is a community facility as defined in the Development Plan and the National Planning Policy Framework (2012), and its associated parking. The public house is located on the corner of Princes Way and Saxon Street and is a single storey building with first floor accommodation in the roof space. It is presently closed and has suffered from vandalism, with the applicant recently securing demolition consent for the building under permitted development rights. The site benefits from mature landscaping to the boundaries with Princes Way, Saxon Street and Albert Street.

1.6 Bletchley View South is occupied by a relatively modern retail outlet style building which is single storey in height. The retail building is located to the west of the site fronting Saxon Street with parking to the eastern side of the site. Bletchley View South is lined by trees to the eastern and western boundaries which are the subject of a Tree Preservation Order.

1.7 The Proposal

The application seeks planning permission for the demolition of the existing public house and retail unit and the redevelopment of the site for a residential led mixed use development including 184 residential dwellings, 112 sqm of community use (Use Class D1), and 215 sqm of flexible use across Use Classes A1, B1a or D2, provision of private open space and landscaping, provision of an internal vehicular network and associated highway works and car parking.

1.8 Bletchley View North would comprise town houses fronting Albert Street and two blocks of flatted units curving around Princes Way and Saxon Street all connected by a first floor amenity deck with ground floor/under croft parking. In addition, a ground floor commercial unit is proposed to the south west corner of the building fronting Saxon Street. The town houses would be three storeys in height and would have their own dedicated gardens on the amenity deck. The flatted blocks would have a maximum height of 10 storeys including the ground floor/under croft parking.

1.9 The breakdown of the proposed units and parking for Bletchley View North comprises as follows: . 116 residential units comprising 110 apartments (16 x 1 bed and 94 x 2 bed) and 6 x 3 bed townhouses, which equates to 283 dwellings per hectare. . 105 sqm commercial unit (Use Classes A1, B1a or D2) . 103 parking spaces

1.10 Bletchley View South would also have three blocks of accommodation comprising a run of back-to-back town houses incorporating a community facility with flats above to the eastern side of the site and two flatted blocks to the west of the site. The town houses and community facility with flats above would be three storeys in a height but would include a third floor roof terrace. The flatted blocks would be separated by a first floor amenity deck with ground floor/under croft parking. The two flatted blocks would have a maximum height of 8 storeys including the ground floor/under croft parking.

1.11 The breakdown of the proposed units and parking for Bletchley View South comprises as follows: . 68 residential units comprising 62 apartments (26 x 1 bed and 36 x 2 bed) and 6 x 3 bed townhouses, which equates to 219 dwellings per hectare. . 110 sqm commercial unit (Use Classes A1, B1a or D2) . 112 sqm of community use (Use Class D1) . 61 parking spaces

1.12 The submitted plans also show works within the highway including the narrowing and provision of parking along South Terrace (9 spaces), a new shared cycle/pedestrian route along the frontage with Saxon Street and landscaping.

2.0 RELEVANT POLICIES (The most important policy considerations relating to this application)

2.1 National Policy

National Planning Policy Framework (2012)

Paragraphs 6, 7, 8 and 14 - Presumption in Favour of Sustainable Development Paragraphs 11-16: Presumption in favour of sustainable development Paragraph 17: Core Planning Principles Section 1: Building a Strong Competitive Economy Section 4: Promoting Sustainable Transport Section 6: Housing Section 7: Design Section 8: Promoting Healthy Communities Section 10: Meeting the Challenge of Climate Change & Flooding Section 11: Conserving and Enhancing the Natural Environment Paragraph 173: Ensuring Viability and Deliverability Paragraphs 187 &187: Positive Approach to Decision Taking Paragraphs 196 & 197: Determining Applications Paragraphs 203-206: Conditions and Obligations

The Planning (Listed Buildings and Conservation Areas) Act 1990: Section 66 and 72.

In addition, the National Planning Practice Guidance is a material consideration.

2.2 Local Policy

Milton Keynes Core Strategy ( Adopted 2013) – Policies:

CSA: Presumption in Favour of Sustainable Development CS1: Milton Keynes Development Strategy CS4: Retail and Leisure ProvisionCS CS10: Housing CS11: A Well Connected Milton Keynes CS12: Developing Successful Neighbourhoods CS13: Ensuring High Quality, Well Designed Places CS14: Community Energy Networks CS15: Delivering Economic Prosperity CS17: Improving Access to Local Services) CS18: Healthier and Safer Communities CS19: The Historic and Natural Environment CS21: Delivering Infrastructure

Milton Keynes Local Plan 2001-2011 (Adopted 2005) – Saved Policies:

D1: Impact of Development Proposals on Locality D2A: Urban Design Aspects of New Development D2: Design of Buildings D4: Sustainable Construction E11: Small Business Units HE5: Development Affecting the Setting of a Listed Building HE6: Conservation Areas NE2: Protected Species NE3: Biodiversity & Geological Enhancement T1-T5, T9, T10, T11 and T15: Transport H3-H5: Affordable Housing H7: Housing on Unidentified Sites H8: Housing Density H9: Housing Mix S6: Bletchley TC15 - TC17: Bletchley Town Centre TC19: Housing in Town, District and Local Centres C1: location of Community Facilities C2: Loss of Community Facilities P04: Percent for Art Supplementary Planning Guidance/Documents

Supplementary Planning Guidance/Documents

The Central Bletchley Regeneration Strategy (April 2004) New Residential Development Design Guide (April 2012) Parking Standards (January 2016) Sustainable Construction (April 2007) Affordable Housing SPD (March 2013) Social Infrastructure Planning Obligations (September 2005) Planning Obligations for Education Facilities (December 2005) Planning Obligations for Leisure, Recreation and Sports Facilities (2005)

3.0 MAIN ISSUES (The issues which have the greatest bearing on the decision)

3.1 The main issues for the consideration of this application comprise as follows: . Principle of development . Community facility . Design and density . Landscaping and trees . Heritage . Residential amenity . Land contamination . Parking and highway safety . Flood Risk and drainage . Ecology . Sustainable construction . Planning obligations and affordable housing . Conclusion and planning balance

4.0 RECOMMENDATION (The decision that officers recommend to the Committee)

4.1 It is recommended that planning permission be granted subject to the conditions set out in Section 6 of the report and a Section 106 Legal Agreement to secure planning obligations.

5.0 CONSIDERATIONS (An explanation of the main issues that have led to the officer Recommendation)

5.1 Principle of development

The application site is located within the settlement boundary of Milton Keynes wherein housing is acceptable in principle under Saved Policy H7 of the Milton Keynes Local Plan 2001-2011 and Core Strategy Policy CS1. The proposal will add to the housing provision in a sustainable location and thereby add to the Councils overall supply of housing land in line with Saved Policies S1 and H7 of the Local Plan and saved Policy CS1 of the Core Strategy.

5.2 In addition, the site also falls within Bletchley Town Centre wherein mixed use development is acceptable in principle under Saved Policies TC15, TC16, TC17 and TC19 of the Local Plan 2001-2011.

5.3 Furthermore, Core Strategy Policy CS8 details that Bletchley Town Centre will be a key area of change in the Borough where new development, including housing, will help regenerate these older centres and encourage sustainable patterns of travel. Moreover, Saved Policy S6 of the Local Plan has objectives which include upgrading Bletchley Town Centre as a focus for the regeneration of the town as a whole. These policies therefore recognise the need for regeneration proposals in Bletchley.

5.4 The Bletchley Regeneration Strategy (2004) and the comments of Urban Design, indicate that the application site presently comprises a poor gateway to Bletchley Town Centre. The Bletchley Regeneration Strategy (2004) envisages that the site will come forward as an opportunity site on which to create new retail accommodation and a series of phased residential developments. No large retail use has however subsequently progressed on the site, possibly due to the subsequent retail expansion at Denbigh, however the proposal includes a mix of uses which broadly meet the aims of the Regeneration Strategy. Moreover, it is considered that the proposal offers an opportunity to revitalise and act as a catalyst for further investment in Bletchley Town Centre, both through increased population and footfall and also creating a high quality environment in accordance with the aforementioned Policies and Regeneration Strategy.

5.5 The redevelopment of the site for a residential-led mixed use scheme on the site is therefore supported in principle under the development plan, with the regeneration potential of the scheme considered to give rise to significant benefits.

5.6 Community facility

The National Planning Policy Framework (2012, paragraph 70) outlines that a public house is a community facility and that planning decisions should guard against the unnecessary loss of valued facilities, so as to enhance local communities. Saved Policy C2 of the Local Plan and Policy CS17 of the Core Strategy are in accordance with the NPPF with Saved Local Plan Policy C2 stating that planning permission will be refused for proposals that involve the loss of an existing community facility unless:

(i) There is no longer a need for the facility for any type of community use, or

(ii) An acceptable alternative facility can be provided elsewhere.”

5.7 The existing public house is closed, comprises one of a number of town centre public houses and has not presently been listed as an Asset of Community Value such that its value to the local community is questionable. Furthermore, the applicant has recently gained consent under permitted development for the demolition of the public house. Notwithstanding this, the applicant is proposing an alternative community facility in the form of a Use Class D1 unit within the Bletchley View South part of the site. Therefore the proposal accords with Saved Local Plan Policy C2 and Paragraph 70 of the National Planning Policy Framework (2012).

5.8 Design & Density

Saved Policies D2, D2A and H8 of the Milton Keynes Local Plan 2001 – 2011 and Core Strategy Policies CS13 and CS18 seek high quality design and appropriate density that relates well to the surrounding area and for proposals to design out opportunities for crime. Further, the Core Planning Principles in Paragraph 17 of the National Planning Policy Framework state that planning should always seek to secure high quality design.

5.9 The application site is currently occupied by 1/1.5 storey buildings separated by a single storey Burger King building. However, the site presently represents a poor quality gateway to Bletchley Town Centre and the existing small scale of development is not typical of Bletchley. Bletchley consists of predominantly 2-5 storey buildings with residential developments expected to achieve an average net density of 40 dwellings per hectare to relate well to the character of the surrounding area as detailed in Saved Policy H8 of the Local Plan.

5.10 The site is neighboured by two storey terraced housing running along Albert Street and also Stevenson House, a 10 storey flatted block with ground floor commercial units, to the far side of the bus station.

5.11 Urban Design advise that Stephenson House acts as an important influence/precedent and that the application will provide an urban context for Stephenson House by locating it within a cluster of taller buildings. Furthermore, Urban Design detail that the high density is appropriate for a town centre location and that the proposal responds well to the surrounding context, with 3 storey development adjacent to the existing two storey terrace houses on Albert Street and the tallest elements furthest away from this frontage where there is no existing development in close proximity. Urban Design also advise that the scale, height and contemporary design of the scheme will immediately give it its own identity, with architectural detailing and setback penthouse apartments helping to create an individual identity for each block, break up the mass of the development and give it a domestic feel. Although, it is considered that high quality materials are important to achieving a successful development on site.

5.12 The layout of the development is such that Urban Design state that it will better define and provide a more continuous frontage to Saxon Gate, Princes Way, Albert Street and South Terrace with a clear distinction between public and private spaces. While there are limited ground floor active frontages onto Saxon Gate and Princes Way due to the need to accommodate parking, as identified by Urban Design, there would still be good surveillance of the public realm from the upper floors which include balconies with numerous pedestrian entrance enlivening the streets and a positive frontage to the bus station has been achieved.

5.13 Overall, Urban Design conclude that this is a high quality development with a strong identity that will help ‘celebrate’ a key gateway into Bletchley and provide an opportunity to revitalising and act as a catalyst for further investment in Bletchley Town Centre. As such no objections are raised to the design and layout of the scheme with regards to Saved Policies D2 and D2A of the Milton Keynes Local Plan 2001 – 2011 and Core Strategy Policies CS12 and CS13 and the New Residential Development Design Guide SPD.

5.14 Landscaping and Trees

Saved Policy D2 of the Milton Keynes Local Plan 2001 – 2011 details that proposals should include landscaping that integrates with the surrounding area.

5.15 The Senior Landscape Architect welcomes the inclusion of podium gardens and advises that further details of the planting for these, and ground level planting, should be addressed by condition together with details of boundary treatments.

5.16 The Senior Landscape Architect requests that the proposal be amended on a number of grounds including to secure on site play provision, climbers and walls shrub on a cable system or green walls and the retention of more of the existing trees on the site, such as the Tree Preservation Order trees which run along South Terrace and part of Albert Street.

5.17 In terms of play provision, the site falls below the thresholds in Saved Local Plan Policy L3 and relevant SPG for on-site provision and it would not therefore be reasonable to require the inclusion of such a facility.

5.18 The potential for climbers and green walls can be explored as part of the landscaping details to be submitted pursuant to a condition should planning permission be forthcoming. Although, the potential for green walls may be limited on this site due to viability constraints and the financial implications and maintenance liabilities from such a feature.

5.19 Turning to trees, the Arboricultural Officer notes that about a hundred existing trees including all of the 18 trees protected by a Tree Protection Order would be removed to accommodate these proposals. However, the Arboricultural Officer advises that the majority of the existing trees are not of great merit as individuals, although collectively they help to define the character of the locality including providing vertical green elements that delineate the transport corridors and providing screening. Furthermore, he suggests that a landscaping condition should seek replacement planting on a 1 for 1 basis using the same diversity of species. However, given the scale and extent of the proposed development, it is considered that a landscaping condition would be unlikely to achieve such a level of planting and there is some harm therefore arising from the loss of trees on the site. Although, the applicant has provided amended plans showing tree planting in the highway verge on Albert Street to seek to seek to recreate the linear arrangement of landscaping. In addition, the tree loss has also arisen in part due to amendments to the scheme to provide a shared pedestrian / cycle route to the Saxon Street frontage, which provides a benefit arising from the development (as detailed in the highway section below). Furthermore, given the town centre location of the site, whilst the proposal would not be able to re-create the existing landscaping character of the site, the site is considered to be a poor quality gateway to the town centre (as detailed in the Design section above) and there would be scope to provide landscaping which is appropriate for a town centre environment.

5.20 Overall, whilst there would be some harm from the extent of the loss of trees on site, it is considered that landscaping appropriate to a town centre environment could be achieved on site and no objections are therefore raised with regards to Saved Policy D2 of the Local Plan.

5.21 Heritage

Sections 66 and 72 of the Planning (Listed Buildings and Conservation Areas) Act 1990 place statutory duties on local planning authorities to pay special regard to the desirability of preserving listed buildings or their setting or any features of special or architectural or historic importance which it possesses and special attention to the desirability of preserving or enhancing the character or appearance of a conservation area. Saved Policies HE5 and HE6 of the Local Plan and Policy CS19 of the Core Strategy also seek to protect designated and non-designated heritage assets from adverse impacts of development.

5.22 Bletchley Conservation Area, which includes a number of listed buildings and also Bletchley Park, is located to the west of the site beyond the railway line. The submitted archaeological assessment includes an assessment of the visibility of the development on these heritage assets and, given the separation, finds that there would be very limited visibility. As such, and given special regard and considerable weight and importance to the impact of the development on the setting of the listed buildings and conservation area in accordance with Sections 66 and 72 of the Planning (Listed Buildings and Conservation Areas) Act 1990, it is concluded that the development would not have an adverse impact on the setting of the listed buildings or conservation area.

5.23 Residential Amenity

Saved Policy D1 of the Milton Keynes Local Plan 2001-2011 details that planning permission will be refused for development where it would adversely affect residential amenity of neighbouring properties. In addition, the New Residential Development Design Guide SPD (2012) provides guidance on achieving acceptable levels of amenities for future occupiers. Further, the core planning principles in the National Planning Policy Framework (Paragraph 19) details that planning decisions should seek to secure a good standard of amenity for all existing and future occupants of land and buildings.

5.24 In terms of the residential amenities of neighbouring properties, the development is set sufficiently away from Stephenson House to not impact on the amenities of occupiers of this flatted development.

5.25 To the east of the site, No.’s 42-54 (Evens) Albert Street face towards the application site across Albert Street and No.’s 1-17 (Odds) Earls Close back onto Albert Street. The proposed development would clearly be visible from these neighbouring terraced properties. However, given the separation afforded by Albert Street and that the scheme has been designed to step up in scale away from Albert Street towards Saxon Street, it is considered that the proposal would not appear unduly prominent or overbearing or give rise to unacceptable loss of privacy. In addition, the application has undertaken daylight and sunlight calculations having regard to the BRE Guidance and this has found that daylight and sunlight would not be unacceptably affected. The comments of residents and the Environmental Health Officer regarding the impact of construction works are noted and it is considered that these matters can be controlled by a construction management condition. As such, subject to the aforementioned conditions, it is considered that the proposal would not unacceptably impact on the residential amenities of neighbouring properties.

5.26 Turning to the amenities of future occupiers, the flatted units in Bletchley View North and the western blocks of Bletchley View South would all be served by balconies and would also benefit from access to garden areas on podium decks. All the town houses on Bletchley View North would be served by their own garden areas on the podium deck and the town houses in Bletchley View South would have roof top gardens. As such, and given the town centre location, it is considered that an acceptable level of outdoor amenity space would be provided for future occupiers.

5.27 The applicant’s Daylight and Sunlight Assessment has been undertaken with regard to the BRE Guidance and found that, in all but one location, daylight within the proposed accommodation would be acceptable and that the layout has been designed to ensure that the majority of locations would benefit from sunlight. As such, it is considered that objections could not be sustained regarding the level of daylight and sunlight received by future occupiers of the site.

5.28 In respect of privacy for future occupiers, the separation distances between the blocks in Bletchley View North would be a minimum of 6.5 metres and in Bletchley View South would be a minimum of 11.5 metres. In addition, the gardens for the town houses would be overlooked to some extent by bedroom windows in the adjacent flatted blocks. However, given the town centre environment, it is considered that the level of privacy afforded by the development for future occupiers would not be unacceptable.

5.29 The Environmental Health Officer and Network Rail have indicated the potential for the proposed residential units to be impacted by noise from the adjacent railway. In addition, the Environmental Health Officer also details the potential for the proposed commercial units to have noise impacts on future occupiers of the development. These matters however can be addressed by condition should planning permission be forthcoming.

5.30 Overall, it is considered that the proposed development would not adversely affect the amenities of neighbouring residents and an acceptable level of amenity would be achieved for future occupiers of the site. As such, no objections are raised with regards to residential amenities and Saved Policy D1 of the Milton Keynes Local Plan 2001-2011.

5.31 Land Contamination

The Strategic Protection team has reviewed the submitted Geo-environmental Assessment and raises no objections subject to conditions to secure intrusive investigations of the site and remediation where appropriate should planning permission be forthcoming.

5.32 Parking and Highway Safety

Saved Policy T10 of the Milton Keynes Local Plan 2001-2011 relates to highway safety and details that proposals will be refused for development if it would be likely to generate motor traffic that would exceed the highway capacity of the local road network or cause significant risk of accident. In addition, Saved Policy T15 of the Milton Keynes Local Plan 2001-2011 and the new Milton Keynes Parking Standards Supplementary Planning Document (2016) set out the parking requirements for proposed developments. The National Planning Policy Framework (2012) also details in Paragraph 32 that development should be prevented or refused on transport grounds where the residual cumulative impacts of development are severe.

5.33 In terms of parking provision, the application site is split across Zones 2 and 3 parking areas under the Parking Standards, however given their close proximity it is considered that it reasonable to treat the whole site as Zone 2. The table below outlines the parking requirements of the proposed residential development in accordance with the Council’s Parking Standards

Parking Standard Total Requirement Total Allocated Unallocated Allocated Unallocated 1 and 2 bed flats 172 1 0.33 172 57 3 bed house 12 2 0.33 24 4

1 space per Tandem 0 2 tandem 0

TOTAL - - 196 61

5.34 The proposed development would have 172 (78%) allocated and 9 unallocated car parking spaces for the residential uses, which is a shortfall of 24 (12%) allocated and 52 unallocated spaces against the parking standards, and no parking for the commercial units. The Parking Standards detail developments are expected to meet the standards, but also sets that proposals will be considered on their merits having regard to local circumstances and the needs of the specific development detailing that:

“Where a proposal departs from the parking standards, Transport Statements and Assessments would be expected to include the following items:

• Surveys of parking capacity and occupancy levels on surrounding streets and parking areas. • Consideration of likely trip generation and parking accumulation for the proposed development evidenced as appropriate. • Details of how the parking will be managed and how that will mitigate any under-provision”.

5.35 The applicant has submitted a Transport Assessment and this places significant emphasis on the sustainability of the application site, highlighting that it lies immediately adjacent to Bletchley bus station and is 700m walking distance from Bletchley railway station, the later providing access to regular services on the West Coast mainline and in the future the MK hub for East- West rail.

5.36 The Transport Assessment also addresses census data which shows that the average car ownership in this area is 0.88/household and that 38% of households do not have access to a private motor car. Additionally the 2011 census data shows that 59% of trips to work are by car and 7% of trips are made as a car passenger. The same table shows that 30% of residents travel to work by sustainable means.

5.37 In addition, the applicant has carried out a car parking stress survey to explore the availability of car parking in the vicinity of the application site and this has found some availability in car parks within a 5-10 minute walk. The applicant has also suggested that the scheme to be subject to a parking management strategy condition.

5.38 In considering parking, Saved Local Plan Policy TC19 is also relevant and this relates to town centres and states that:

‘Residential development proposals in these areas should provide fewer on- site car parking spaces than the Council’s maximum standards for housing development.’

5.39 The Senior Highway Engineer details that his main concern with this application is the shortfall in allocated car parking and that the application is very finely balanced from a parking perspective. However, having considered the sustainability of the site at length, the Senior Highway Engineer advises that it is difficult to find many sites in Milton Keynes that could be measured as more sustainable due to the close proximity to the bus and train station and town centre and as such it would be difficult to defend at appeal. In addition, he notes the application has parallels with another similar application in CMK that was recently approved. Therefore, due to the sustainability of this particular site, it is considered that objections could not be sustained in this instance on parking grounds.

5.40 Turning to traffic impact, having regard to the likely trip generations for the proposal and junction modelling in the Transport Assessment, the Senior Highway Engineer advises that the proposal would not have an adverse impact on the local highway network such that mitigation is required.

5.41 The application also includes highway works such as the narrowing of South Terrace in order to provide a safer crossing point for both pedestrians and cyclists and the applicant has a Stage 1 Road Safety Audit in support of these works. The Senior Highway Engineer raised no in principle objections to these works and advised that all matters regarding issues on the public highway will be examined within the S278 highway technical audit of the proposed development.

5.42 The application has also been amended to include a shared cycle/pedestrian route along the Saxon Street frontage. The latter has been requested by the Cycling Officer to connect to the V7 Super Route. It is therefore of strategic significance to the cycle network to link Bletchley into the rest of the Super Route network and is a benefit arising from the development and this would be secured as part of the section 106 legal agreement.

5.43 To conclude on parking and highway safety grounds, whilst there would be a shortfall with regards to the Parking Standards, on balance it is considered that an objection could not be sustained on parking grounds due to the highly sustainable of this particular site which is located next to a bus station, in a town centre, and very close to railway station. Furthermore, the proposal would not give rise to highway safety issues. As such, no objections are raised with regard to Saved Policies T10 and T15 of the Milton Keynes Local Plan 2001-2011, Milton Keynes Parking Standards Supplementary Planning Document (2016), and Paragraph 32 of The National Planning Policy Framework (2012).

5.44 Flood Risk and Drainage

Whilst the application site falls within Flood Zone 1 and is less than a hectare in size, it is a national requirement for developments of ten dwellings or more to ensure that sustainable drainage systems for the management of run-off are put in place, unless demonstrated to be inappropriate.

5.45 The Local Lead Flood Authority (LLFA) has assessed the submitted Outline Drainage Strategy, which proposes the use of green roofs and permeable paving to reduce surface water runoff, and advises that the submitted details are acceptable subject to conditions. Furthermore, the Environment Agency and Anglian Water raise no objections subject to a conditions relating to foul water drainage.

5.46 Ecology

Saved Policies NE2 and NE3 of the Milton Keynes Local Plan 2001 – 2011 and Core Strategy Policy CS19 seek to protect wildlife and protected species and encourage biodiversity enhancements. This is supported by the NPPF which aims to conserve and enhance biodiversity (Paragraph 118).

5.47 The application is accompanied by Preliminary Ecological Appraisals (PEA) and a bat survey. The Countryside Officer has reviewed the submitted PEAs and Survey and raises no objections to the scheme subject to appropriate biodiversity mitigation and enhancement conditions. No objections are therefore raised with respect to protected species and biodiversity under the NPPF and development plan policies NE2, NE3 and CS19.

5.48 Sustainable Construction

Saved Policy D4 of the Milton Keynes Local Plan 2001 – 2011 and the Sustainable Construction Supplementary Planning Document (2007) requires all new development exceeding 5 dwellings to incorporate sustainable construction including renewable energy and carbon offset provision. Core Strategy Policy CS14 also encourages proposals for over 100 homes to consider the use of community energy networks and, where feasible, to connect to an existing local energy network.

5.49 The applicant explores the feasibility of community energy networks and connecting to a local energy network in the submitted Energy Strategy Report. In addition, this report details that photovoltaic panels would be incorporated within the development to achieve the requirement for 10 per cent renewable energy and this could be secured by a condition should planning permission be forthcoming. There is also a policy requirement for a financial contribution for carbon offsetting, this matter is however affected by the viability of the scheme and it is addressed further in the Planning Obligations section below.

5.50 Planning Obligations and Affordable Housing

Planning Obligations are required in accordance with Milton Keynes Core Strategy Policy CS21, Saved Policies H4, D4 and PO4 of the Milton Keynes Local Plan 2001 – 2011 and the following relevant Supplementary Planning Documents (SPDs)/Guidance (SPGs):

• Affordable Housing SPD (2013) • Education Facilities SPG (2004) • Leisure Recreation and Sports Facilities SPG (2005) • Social Infrastructure SPD (2005) • Sustainable Construction SPD (2007)

5.51 Saved Policy H4 of the Milton Keynes Local Plan 2001 – 2011 and The Affordable Housing SPD seeks 30% Affordable Housing with a tenure mix of 25% Affordable Rent (at a range of rental levels up to 80% including 5% of the development at levels broadly equivalent to Social Rent) and 5% Shared Ownership. This mix breaks down to 46 Affordable Rent and 9 Shared Ownership for the proposed development.

5.52 Turning to financial contributions, the Section 106 calculator provides an initial estimate of the likely section 106 contributions arising from the aforementioned SPD/Gs and policies. The initial Section 106 calculation for the current proposal is set out below:

Education: Contribution Total Early Years £100,600.55 Primary pupils £497,085.09 Secondary pupils £535,009.99 Post 16 pupils £116,045.81

Leisure Recreation & Sports: Provision Cost Maintenance Cost Playing Fields £76,123.97 £65,109.60 Local Play £113,941.80 £81,025.28 Neighbourhood Play £108,516.00 £138,900.48 Community Hall £33,593.66 n/a Local Parks £14,468.80 £20,979.76 District Parks £28,937.60 £41,959.52 Swimming Pool £45,863.67 n/a Allotments £13,564.50 n/a Sports Hall £16,865.33 n/a

Social Infrastructure: Contribution Library £35,810.28 Adult Continuing Education £17,000.84 Crematorium/Burial Grounds £14,468.80 Museums and Archives £25,320.40 Health Facilities £247,778.20 Waste Management £40,874.36 Waste Receptacles £18,400.00 Social Care - Day Care £8,681.28 Social Care - Older Persons Housing £53,172.84 Emergency Services £7,957.84 Voluntary Sector £30,022.76 Milton Keynes University £114,303.52 Milton Keynes College £40,512.64 Inward Investment £30,022.76 Public Art - 1% (Estimated) £124,820.00

Carbon Offsetting: Contribution Carbon Neutrality (Estimated) £62,410.00

Total Contribution: £2,920,147.92 Per unit Contribution: £15,870.37

5.53 The initial section 106 calculation is however only an estimate and needs to be subject to consultations with key stakeholders to ensure that that the contributions are compliant with CIL Regulations 122 and 123, which include the restrictions on the pooling of planning obligations. Local authorities cannot pool more than five s106 financial contributions together (dating back to April 2010) to pay for a single infrastructure project or type of infrastructure.

5.54 In addition, viability is a key consideration when taking into account what Planning Obligations are to be sought from development. The National Planning Practice Guidance (NPPG) is a material consideration in the assessment of the application and provides the following guidance in relation to viability:

“In making decisions, the local planning authority will need to understand the impact of planning obligations on the proposal. Where an applicant is able to demonstrate to the satisfaction of the local planning authority that the planning obligation would cause the development to be unviable, the local planning authority should be flexible in seeking planning obligations. This is particularly relevant for affordable housing contributions which are often the largest single item sought on housing developments. These contributions should not be sought without regard to individual scheme viability. The financial viability of the individual scheme should be carefully considered in line with the principles in this guidance (Paragraph: 019 Reference ID: 10- 019-20140306).”

5.55 Furthermore, the National Planning Policy Framework (2012) emphasises the duty to ensure development viability is not threatened. Indeed, Paragraph 173 of the National Planning Policy Framework (2012) states that:

“Pursuing sustainable development requires careful attention to viability and costs in plan-making and decision-taking. Plans should be deliverable. Therefore, the sites and the scale of development identified in the plan should not be subject to such a scale of obligations and policy burdens that their ability to be developed viably is threatened. To ensure viability, the costs of any requirements likely to be applied to development, such as requirements for affordable housing, standards, infrastructure contributions or other requirements should, when taking account of the normal cost of development and mitigation, provide competitive returns to a willing land owner and willing developer to enable the development to be deliverable.”

5.56 In addition, Paragraph 205 of the National Planning Policy Framework (2012) states that:

“Where obligations are being sought or revised, local planning authorities should take account of changes in market conditions over time and, wherever appropriate, be sufficiently flexible to prevent planned development being stalled."

5.57 As such, when the viability of a scheme may be affected by the application of Planning Obligations, the Local Authority should take these considerations into account to ensure the scheme is not prevented from being delivered.

5.58 The applicant has submitted a viability appraisal on the basis that the scheme could not afford to deliver any Affordable Housing and could only contribute around £150,000 as a financial contribution. This was assessed by Officers and Kirkby Diamond, the consultant appointed by the Council to provide an independent review of the viability of the development. The independent consultant has found that there is scope to provide some section 106 financial contributions and potentially affordable housing and as a result the applicant has offered the following two options in respect of the Section 106 requirements:

Option 1 – 100% Private Housing

. The Nursery remains within the appraisal, however given MKC’s initial response to this comprising part of the S106 offer we have assumed that the value of this (circa £120k) will be captured by the client and will not form part of the S106 offer; . Profit revised from 22% on GDV to 20% on GDV

The output of the appraisal is a S106 cash sum of £1.233m which is phased semi-annually over construction period.

Option 2 – Onsite Affordable Provision

. Assumptions largely as above, however Block B Remitone (16 units) is developed for affordable housing. This equates to an 8.7% affordable housing provision; . Profit revised from 22% on GDV to 19% on GDV (blended rate to take account of the affordable element at 6% on GDV)

The output of the appraisal is a S106 cash sum of £487,000 in addition to the affordable housing provision.

5.59 Discussions with service providers and CIL Regulation 122 and 123 compliance testing were ongoing at the time of drafting this report. Therefore, the final position following discussions with service providers will be in an Update Paper to the Development Control Committee together with the final version of the viability report from the independent viability consultant and the officer recommendation for obligations to be secured by a Section 106 agreement should planning permission be granted.

5.60 Conclusion and Planning Balance

To conclude, the development is acceptable in principle under the Development Plan. The National Planning Policy Framework in paragraph 7 details that the purpose of planning is to contribute to the achievement of sustainable development and an assessment against the three dimensions of sustainable development is set out below.

5.61 The proposal would perform an economic role through the provision of construction activity in the local area, which would provide employment in the short term. It would also create investment in the local and wider economy through the construction stage and the significant number of new residents using local shops and services. Moreover, it is considered that the proposal has the potential to be a significant catalyst for the revitalisation and regeneration of Bletchley Town Centre.

5.62 Turning to the social dimension, the proposal would provide 184 residential units which would make a significant boost to the supply of housing in the Borough. In addition, whilst the existing public house would be lost, the community value of this particular public house is questionable and the proposal would in any event include a replacement community facility.

5.63 Finally, with respect to the environmental consideration, whilst the proposal would result in the loss of a significant proportion of vegetation and trees within the site (including trees the subject of a tree preservation order), some replacement planting and biodiversity mitigation measures can be secured by condition. Moreover, the existing site represents a poor quality gateway to the town centre and the proposal has the potential to rectify this with a strong identity that will help ‘celebrate’ a key gateway into Bletchley. In addition, 10 per cent of the energy from the development would be from renewable energy.

5.64 The acceptably of the level of parking proposed is considered to be finely balanced in this instance, however given the highly sustainable town centre of the site, next to a bus station and very close proximity to a railway station it is considered that it is not objectionable. Furthermore, the proposal would provide a highway benefit through the inclusion of a shared cycle/pedestrian route along the Saxon Street frontage to connect to V7 Super Route and therefore help link Bletchley into the rest of the Super Route network.

5.65 Overall, having weighed these matters, it is considered that the proposal would comprise sustainable development and it is recommended that planning permission be granted subject to the conditions set out below and a section 106 Legal Agreement to secure planning obligations to be detailed in an Update Paper to the Development Control Committee.

6.0 CONDITIONS (The conditions that need to be imposed on any planning permission for this development to ensure that the development is satisfactory. To meet legal requirements all conditions must be Necessary, Relevant, Enforceable, Precise and Reasonable )

1) The development hereby permitted shall be begun before the expiration of three years from the date of this permission.

Reason: To comply with Section 51 of the Planning and Compulsory Purchase Act 2004.

2) Prior to the commencement of the development hereby permitted, a Construction Management Plan shall be submitted to and approved in writing by the local planning authority. The approved Construction Management Plan shall be adhered to throughout the construction period and include provision for the following:

i. The parking of vehicles of site operatives and visitors ii. Loading and unloading of plant and materials iii. Storage of plant and materials used in constructing the development iv. The erection and maintenance of security fencing/hoardings and lighting v. Welfare and other site facilities vi. Working hours and delivery times vii. Measures to control the emission of dust, dirt, noise and vibrations during construction viii. Measures to respond to the construction works related comments raised in the 30.11.2016 consultation response from Network Rail.

Reason: For the safety and convenience of users of the highway and to protect the amenity of neighbours during the construction process in accordance with the provisions of Saved Policy D1 of the Milton Keynes Local Plan 2001-2011.

3) Prior to the commencement of the construction of the development hereby permitted, a detailed design including attenuation storage, interceptor and hydrobrake drawings and written confirmation of the discharge rate as agreed by the receiving drainage body, for a surface water drainage scheme shall be submitted to and be approved in writing by the local planning authority. The management and maintenance plan shall include a detailed timetable for the implementation of the surface water drainage scheme. The approved drainage scheme shall subsequently be implemented and retained thereafter in accordance with the approved details.

Reason: To ensure satisfactory and sustainable surface water drainage to prevent the increased risk of flooding on or off site in accordance with the Written Ministerial Statement issued on 18 December 2014 in relation to sustainable drainage systems.

4) Prior to the commencement of the construction of the development hereby permitted, details of the proposed finished floor levels of all buildings and the finished ground levels in relation to existing ground levels shall be submitted to and approved in writing by the Local Planning Authority. The development shall be carried out in accordance with the approved levels.

Reason: To ensure that development is carried out at suitable levels in accordance with Saved Policies D1 and D2A, of the Milton Keynes Local Plan 2001-2011.

5) Prior to the commencement of the construction of the development hereby permitted, a Phase II intrusive investigation of ground conditions to determine the likelihood of any ground, groundwater or gas contamination of that part of the site shall be undertaken and the results of this survey together with a strategy for any remedial action deemed necessary to bring the site to a condition suitable for its intended use shall be submitted to and approved in writing by the local planning authority. Any remedial works shall be carried out in accordance with the approved strategy and validated by submission of an appropriate verification report to the local planning authority prior to first occupation of any part of the development. Should any unforeseen contamination be encountered in that phase or part of the development the local planning authority shall be informed immediately. Any additional site investigation and remedial work that is required as a result of unforeseen contamination shall be carried out to the written satisfaction of the local planning authority.

Reason: To ensure that the site is fit for its proposed purposed and any potential risks to human health, property, and the natural and historical environment, are appropriately investigated and minimised.

6) Prior to the commencement of the development hereby permitted, a wastewater strategy shall be submitted to and approved in writing by the Local Planning Authority. The development shall be carried out in accordance with the approved details.

Reason: To prevent environmental and amenity problems.

7) Prior to commencement of the construction of the development hereby permitted, a method statement for soft and hard landscaping works within the root protection areas of all existing trees and hedgerows to be retained shall be submitted to and approved in writing by the local planning authority. The development shall be carried out in accordance with the approved details.

Reason: To protect existing trees and hedgerows during the construction process in accordance with Saved Policies D2 and NE3 of the Milton Keynes Local Plan 2001-2011.

8) All existing trees and hedgerows to be retained shall be protected during the construction phase in accordance with the provisions of BS 5837:2012 ‘Trees in relation to design, demolition and construction-Recommendations’.

Reason: To ensure that there is adequate tree protection measures in accordance with Saved Policies D2A and NE3 of the Milton Keynes Local Plan 2001-2011.

9) Prior to the commencement of the construction of the development hereby permitted above ground floor slab level, details of all external materials including details of the car parking cladding, balconies, windows and brick detailing shall be submitted to and approved in writing by the Local Planning Authority. The development shall be carried out in accordance with the approved details.

Reason: To ensure a satisfactory appearance of the development and in accordance with Saved Policies D1, and D2A of the Milton Keynes Local Plan 2001-2011.

10) Prior to the commencement of the construction of the development hereby permitted above ground floor level, a noise assessment and mitigation scheme shall be submitted and approved in writing by the local planning authority. The development shall be carried out in accordance with the approved mitigation details.

Reason: To safeguard the amenities of future occupiers in accordance with Saved Policy D1 of the Milton Keynes Local Plan 2001-2011.

11) Prior to commencement of the construction of the development hereby permitted above ground floor slab level, an energy assessment demonstrating how the renewable sources can contribute to a minimum 10% reduction of the scheme’s total CO2 emissions shall be submitted to and approved in writing by the local planning authority. The development shall be carried out in accordance with the approved details.

Reason: To ensure the 10% carbon reduction requirement of Saved Local Plan Policy D4 is achieved.

12) Prior to the commencement of the construction of the development hereby permitted above ground floor slab level, a soft and hard landscaping scheme shall be submitted to and approved in writing by the Local Planning Authority. The scheme shall show the numbers, types and sizes of new trees and shrubs to be planted and their location in relation to proposed roads, footpaths and drains together with planting details. The landscaping scheme shall be carried out in accordance with the approved details within twelve months following commencement of development or in accordance with a timetable that shall have previously been submitted to and approved in writing by the local planning authority. Any trees or shrubs removed, dying, severely damaged or diseased within five years of planting shall be replaced in the next planting season with trees or shrubs of such size and species as may be approved in writing by the Local Planning Authority.

Reason: To safeguarding the character of the area and in the interests of biodiversity in accordance with Policies D2 and NE3 of the Milton Keynes Local Plan.

13) Prior to the construction of the development hereby permitted above ground floor slab level, a Biodiversity Enhancement Scheme including the use of native plant species and a minimum of 40 swift bricks to be integrated into the building together with a delivery shall be submitted to approved by the Local Planning Authority. The development shall be carried out in accordance with the approved details.

Reason: To ensure development includes biodiversity enhancement measures in accordance with saved Policy NE3 of the Milton Keynes Local Plan 2005.

14) Prior to the commencement of the construction of any of the dwellings hereby approved above ground floor slab level, details of external lighting including security lighting shall be submitted to and approved in writing by the local planning authority. The plans shall show lighting proposed in accordance with BS5489 standards and detail how the presence of bats in the area has been taken into account. The development shall thereafter be carried out in accordance with the approved details.

Reason: To ensure that the development does not detract from residential amenity and the appearance of the locality and in the interests of ecology and crime prevention in accordance with Policies D1, and D2A, and NE3 of the Milton Keynes Local Plan 2001-2011 and CS19 of the Core Strategy.

15) Prior to the occupation of the development hereby permitted, full details of all of means enclosures to be erected within the site shall be submitted to and approved in writing by the local planning authority. The development shall be carried out in accordance with the approved details.

Reason: To protect the appearance of the locality, safeguard residential amenity and in the interest of crime prevention in accordance with Policies Policy D1 and D2 of the Milton Keynes Local Plan and Policy CS19 of the Core Strategy

16) The dwellings shall not be occupied until the parking spaces for the development have been provided in accordance with the approved plans and a management plan for the allocation of parking spaces that has previously been submitted to and approved in writing by the local planning authority. The car parking shall be permanently retained and operated in accordance with the approved details thereafter.

Reason: To ensure adequate parking provision at all times so that the development does not prejudice the free flow of traffic or the safety on the neighbouring highway in accordance with the provisions of Policy T15 of the Milton Keynes Local Plan Adopted 2001-2011

17) The development shall not be occupied until the refuse stores and bicycle parking have been provided in accordance with the approved plans. The refuse stores and bicycle parking shall be permanently retained thereafter.

Reason: To ensure that adequate parking and refuse facilities are provided to serve the development in accordance with saved Policy T3 of the Milton Keynes Local Plan.

INFORMATIVE: The applicant will be required to enter into a s.278 agreement for works within the highway. The applicant should contact the Council’s Highways Adoptions Team for advice on the information required to complete this process and for technical approval for the roads and footways.

INFORMATIVE: The applicant’s attention is drawn to the consultation response of Anglian Water which provides advice to the applicant regarding matters including the Anglian Water assets crossing the site.

INFORMATIVE: The applicant’s attention is drawn to the guidance in the Countryside Officers consultation response and the submitted Preliminary Ecology Assessment regarding mitigation measures for protected species.

Appendix to 16/02451/FUL

A1.0 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)

A1.1 There have been two recent screening opinions covering the whole of the site as detailed below:

16/00407/EIASCR Screening opinion request in respect of proposed development of 190 residential units across two sites EIA not required 12.04.2016

16/02476/EIASCR Screening opinion in respect of proposed development of 190 residential units, up to 350 square meters of flexible use including (D2) community and office use (A1 or B1(a)) across two sites EIA not required 23.11.2016

A1.2 Bletchley View North The following previous applications are relevant for Bletchley View North:

17/00029/DEMNOT Demolition of Enigma Tavern building and outbuildings and timber palisade fencing Prior approval not required 07.02.2017

12/00745/FUL Change of use of 11 car parking spaces to carwash and valeting service (retrospective) Refused 28.03.2014

MK/908/93 Erection Of Public House With Associated Restaurant, Managers Accommodation, Car Parking And Off-Site Highway Improvements Permitted 07.12.1993

MK/1052/82 Continued use as a bus depot Permitted 16.12.1982

Bletchley View South The following previous applications are relevant for Bletchley View North:

07/00781/FUL Erection of glazed canopy, raised external area with entrance steps and ramp, relocation of trolley bay, removal and reconfiguration of loading bay and lift and various external alterations to elevations Permitted 28.06.2007

MK/250/83 Erection Of Retail Warehouse Ancillary Works Shop & Offices (Approval Of Details) Permitted 03.05.1983

MK/1066/82 Erection Of Retail Warehouse Ancillary Workshop And Offices (Outline) Permitted 22.12.1982

A2.0 ADDITIONAL MATTERS

(Matters which were also considered in producing the Recommendation)

A2.1 None

A3.0 CONSULTATIONS AND REPRESENTATIONS (Who has been consulted on the application and the responses received. The following are a brief description of the comments made. The full comments can be read via the Council’s web site)

Comments Officer Response

A3.1 Parish - Bletchley & Fenny Stratford Noted It was resolved to comment to MKC that in principle the Town Council Please refer to para 5.8-5.13 (Design and supported development of the sites included in the application but in terms Density) and 5.32-5.43 (Parking and of this specific application had concerns about the heights of the buildings, Highway Safety) the adequacy of the parking and vehicular access for the number of units. It was suggested that if the height of each block was reduced by one storey and additional parking places were provided the proposed development would be more acceptable to the Town Council.

A3.2 Ward - Bletchley Park - Cllr Clancy No comments received.

A3.3 Ward - Bletchley Park - Cllr McKenzie No comments received.

A3.4 Ward - Bletchley Park - Cllr Wales No comments received.

Ward – Bletchley East - Cllr Webb Noted

I strongly support the objections from residents. I have spoken with many this year and who would live in the shadow of these unwanted flats blotting out their environment causing major traffic flow issues, robbing Bletchley of yet more car parking spaces which will have a severe outcome for our high street retail- - we already lost Princes Way car park and all of Albert Street’s will also be lost. This is only the tip of the iceberg for the plans for all this land. It will become the slums of the future, inadequate parking local residents spaces throughout the side roads will be taken up with visitors overflow, what about the youngsters there is no green space to play in this part of the town no outdoor play equipment, no clubs, no night life unlike CMK boredom ASB would set in the High Street would be the place to hang around causing a gang culture. The site is highly over developed the ideal rebuild would be to complement the high street with retail units with one or two storey residential above and the result would be less traffic hell, retail enhancement additional homes and far more pleasing to the eye. The soil/sewer infrastucture is Victorian how would or will it cope with the demands that would be imposed on it.

A3.5 MKC Urban Design (Comments on original submission) Noted Please refer to para 5.8-5.13 (Design and This is a Town Centre site where mixed use high density residential Density) development would be expected. This is reinforced by the site being in a highly sustainable and accessible location adjacent to a bus station, redways and within easy walking distance of a train station. The adopted Local Plan and Central Bletchley Regeneration Strategy SPG both identify the site for mixed use residential development.

The existing site is identified within the Bletchley Regeneration Strategy as having a poor quality environment and undermining the ability of achieving a high quality gateway into Bletchley. In my view this development will not only improve the quality of the existing area, eliminating all its existing issues, but will create a high quality gateway to the town centre which I believe could act as a catalyst for further regeneration within the town centre.

The application helps meet the following urban design policy:

1. It responds well to the surrounding context with 3 storey development adjacent to Albert Street and the adjacent existing housing with the tallest elements furthest away from this frontage where there is no existing development in close proximity. Stephenson House acts as an important influence/precedent and this is taller that the tallest proposed part of the application. It is my view furthermore that the application will provide an urban context for Stephenson House by locating it within a cluster of taller buildings. 2. The layout is such that there is a clear distinction between public and private space 3. The layout of the development is such that it will better define and provide a more continuous frontage to Saxon Gate, Princes Way, Albert Street and South Terrace 4. Numerous pedestrian entrances are proposed onto these above mentioned streets which will help enliven and animate these streets 5. While there are limited ground floor active frontages onto Saxon Gate and Princes Way due to the need to accommodate parking, I believe there will still be good surveillance of the public realm from the upper floors which include balconies to all apartments. 6. The differing character between BV North and South and architectural detailing has helped break down the mass of the development giving it a more domestic character/feel.

Notwithstanding my broad urban design support for the scheme I do however have the following concern that I would like to see addressed:

1. Overlooking from Block B in BV North of the adjacent townhouse rear gardens 2. Boundary fence along northern edge of BV South should be high quality wall (not timber fence) as it will be highly visible

Furthermore, I would like clarification on the following:

1. The purpose and design of the footpath directly south of the proposed commercial / community unit in Block A of BV North. It needs to feel clearly public or clearly private 2. What the nature and extent of the (projecting) brick detail will be on some of the side elevations that have limited fenestration and what elevations will this occur on 3. The nature of the boundary treatment to (screen) the ground floor parking in Block A, BV North when viewed from Saxon Gate/Princes Way, to the northern edge of BV South when viewed from the Burger King site and the Albert Street frontage (the Landscaping Plan in the DAS appears to show grass only which is not appropriate in my view). While the landscaping plan in the DAS appears to show new planting along the northern edge of BV South this isn’t clear on the application plans for BV South so clarification is required on this boundary treatment as it appears quite a hard edge otherwise 4. While I don’t believe I have any concern with the relationship between the townhouses in BV North and the adjacent existing houses along Albert Street, the relevant sections and plans should include these existing houses (as is done for BV South) 5. Does the boundary ‘fence’ extend the full length of the northern boundary of BV South ie does it extend to the front /side of the ground floor community use facing Albert Street? 6. Have the colours of window frames been agreed or is this conditioned?

A3.6 Urban Design (Comments on additional details provided by applicant) Noted I am satisfied with the responses and changes made. My only 2 comments are:

1. Details of the brick coping should be sought 2. Window frame and brick samples should be secured by condition

Conservation Officer Noted No comments

Archaeological Officer Noted While it is very welcome to see an application accompanied by an Please refer to para 5.21-5.22 (Heritage) appropriately detailed archaeological assessment in line with NPPF 128, I do not regard this site to be of significant archaeological potential. As such I offer no further comment or recommendations.

Landscape Architect Noted The inclusion of podium gardens is welcomed. These should be green multi- Please refer to para 5.14-5.20 (Trees) functional active spaces with the flexibility to be used for community activities and safe places for families to play. Further details of the podium and ground level planting will need to be submitted for approval.

Suggested changes: - Alternative tree species - The cross-sections and elevations should indicate landscape growth after 5 years. - The buildings will be very imposing on the street and existing terrace housing; more work is needed to better integrate the height and mass of the development within its context. Currently there will be no structural landscaping between the development and residents of Albert Street terraced homes, or to soften the appearance of or views from the buildings to/from South Terrace, Saxon Street, and Princes Way. - The proposed layout should include the retention of TPO trees and protection measures for trees to be retained should be shown - The inclusion of climbers and wall shrubs on a cable system would be a positive addition to this development proposal or alternatively a green wall.

Further clarification required: - Proposed tree planting is indicated in highway verge along Albert Street, but it is unclear how will this be secured - The landscape master-plan does not match the podium drawings - ‘Trees’ are indicated in podium areas when realistically these will be small ornamental trees or large shrubs. - Overall there will be a significant reduction in the number of trees on site post-development and this application must therefore be referred to the Arboricultural Officer. - Play provision on-site is not proposed.

If approval of planning permission is to be recommended then it must be subject to conditions to approve a landscape scheme, site specific tree planting details, play provision and boundary treatments. Also tree protection conditions (details to be provided by the tree officer).

Landscape Architect (Comments on additional details provided by applicant) Noted The landscape masterplan is difficult to read but changes can be secured by way of a landscape scheme condition attached to consent.

In terms of the protection for existing trees, there are many existing trees on adjacent land which overhang the development site and where root protection areas are not shown. Respecting RPAs are a critical factor for retaining trees successfully on building sites and I request that due to the number of trees impacted by the development proposals (and the number of TPO’d trees proposed for removal) that the sensitive treatment of trees to remain should be a priority. The RPAs of existing trees on or adjacent to the site should be overlaid on all site layouts.

In addition, changes to the proposed red route / redway along Saxon Street may potentially impact on a group of existing trees through which the current path passes, therefore any changes should be carefully considered.

In terms of vertical landscaping to soften the appearance of the building façade. It is agreed that the landscape scheme condition shall include approval of the form and details of vertical landscaping to the building façade.

In terms of tree planting indicated in the grass highway verge along Albert Street outside of the redline boundary; I suggest that the redline boundary is amended to secure this tree planting unless there is an alternative preferable mechanism that will achieve the same.

Due to the constrained town centre location no local parks or play area is proposed within the scheme. However it would be reasonable to seek financial contributions for off-site facilities based on the principle of improving provision nearby. The site falls outside of the catchment of any existing play areas which is not ideal. Nevertheless the nearest LEAPs are 0.6-0.7km (as the crow flies) west of the site located north of Downing Close or east of Cottingham Grove. One of these sites should be considered for local park and play area improvements.

In addition a boundary treatment plan will need to be approved and can be secured by way of a condition attached to consent

Landscape Services Manager - Trees Noted About a hundred existing trees of about 10 species including all of the 18 trees protected by TPO will be removed to accommodate these proposals. This is unfortunate as the TPO trees are to the margins of the site and so accommodating at least the better specimens should not be too onerous.

While a lot of the existing trees are not of great merit as individuals, as groups they do define the character and feel of Albert Street and Princes Way and to a lesser extent Saxon Street by forming vertical green elements that delineate the transport corridors and act as an effective screen between those roads and the retail premises within the sites. This proposed development should have recognised this and endeavoured to retain and augment these features or recreate them with new tree planting where it is not possible to retain.

Unfortunately instead of having such a landscape buffer, the dwellings will be hard up against the edge of the main roads and roundabout.

The proposed loss of trees will have a considerable negative impact upon the visual amenity, biodiversity and carbon-sink potential of the locality, therefore the landscaping scheme should include replacement tree planting on at least a 1 for 1 basis using the same diversity of species. Full details of that tree planting are to be submitted for approval.

Where trees to be retained are of poor quality it would be sensible to take this opportunity to remove them and secure replacements that will be of better quality and be planted in improved soil.

Where hard surface construction is to take place in tree root protection areas the use of nil-excavation raised construction techniques should be used in preference to root removal, for instance use of cellular confinement systems.

Countryside Officer Noted The proposed development will replace predominantly car parking areas Please refer to para 5.46-5.47 (Ecology) and two buildings. Existing biodiversity assets include many trees and relatively small areas of amenity grassland and scrub.

The Ecological Appraisal findings include that the Bletchley View North site’s broadleaved plantation provides nesting and foraging opportunity to birds and foraging opportunities for bats, but not roosting opportunities to bats. Also the site’s Scrub habitat provides no more than limited nesting and foraging opportunity for birds due to the small ground coverage of the habitat on-site and the site’s amenity grassland was considered to be of low biological interest due to the short sward height, which affords little value to fauna species.

Regarding protected animal species, likely to be encountered on the site, i.e. nesting birds and bats, the Ecological Appraisal recommends in all vegetation clearance works should be undertaken outside the bird nesting season and restrictions on artificial lighting.

In addition, the submitted bat survey found no bats emerging or re-entering the on-site buildings and low levels of bat activity in the area.

Development of the site will present opportunities to satisfy the requirements of the NPPF and of Milton Keynes Councils policy NE3.

In such a high density town centre residential development, the challenge of meeting local and national policy regarding biodiversity can considerable, especially regarding the creation of a ‘designed’ landscape that relates to built forms. This process being all the harder at this site, due to the loss of large numbers of semi-mature, native trees.

The Landscape Master plan indicates that the areas of ‘green’ space are likely to be greater post development compared to before development. However, much is to be composed of ornamental species that be will likely to be of lower overall ecological benefit, than the existing trees 78 individuals and one group of trees to be removed, according to the Arboricultural Implications Report.

Effort has been made to include ecological benefit in the form of the ‘Meadows area’ (Podium Deck). However, I would question the viability of this area, regarding ecological benefit, firstly its native species composition is not stated and secondly I would expect it to become an intensively used and probably frequently mown informal play area, so largely negating any potentially ecological gains.

In my previous comments at pre-application stage I sought the inclusion of green roofs, but these are not mentioned within the application documents.

To assess the effect on biodiversity, the development proposals should be subject to the DEFRA Impact Assessment Biodiversity Calculator methodology to inform avoidance, mitigation and compensation actions

My previous comments at pre-application stage regarding bird nesting bricks being built into, not fixed onto the buildings have not been addressed within the application documents. The provision of bird nesting bricks would be likely to compensate for the loss of nesting sites in the sites existing trees and shrubs. It would be appropriate to site ten swift bricks in, (not on) each of the two northern site blocks and the two blocks of apartments set on the southern site (40 Swift bricks in total).

Environmental Health Manager Noted I refer noise as a planning consideration. Please refer to para 5.23-5.30 (Residential Amenity) I note the supporting Noise Impact Assessment by ACCON Environmental Consultants dated July 2016. A noise measurement study was carried out, but the measurement period was only for three hours on one specific day. This is not ideal, and the consultants state that at the time, a secure noise monitoring position was not available. Given there are several noise sources affecting the site, there is an argument for requiring a more representative measurement period. For example, only audible event from the railway and railway sidings has been included in the assessment, which is an under- representation.

This site is comparatively noisy for Milton Keynes. Therefore, several noise mitigation measures are required. In order to achieve acceptable internal noise levels, all residential habitable rooms will be required to be fitted with acoustic glazing. In order to achieve acceptable external noise levels, a communal “podium” garden area is required to be enclosed by a 2 metre high solid barrier.

The D2/B1A uses have not been fully assessed in the Report.

Therefore, I can only comment in part, and at this stage would recommend that any consent is subject to:-

1. Full on-plot noise mitigation measures to be specified to the approval of the LPA before the scheme commences. The measures should be commensurate to a representative noise climate. 2. No commercial uses to be permitted until further noise assessment has been carried out 3. Construction hours to develop the site, be limited to Monday – Friday 08:00 to 18:00; Saturday 08:00 to 13:00. No construction working on a Sunday or Public Holiday

Environmental Protection Team Noted Thank you for providing me with a copy of the Phase 1 Geo-Environmental Please refer to para 5.31 (land Assessment in respect of the demolition of Former Enigma Tavern Site and contamination) development of the Land to South of Princes Way, Bletchley. I agree with the conclusions of the report that, due to the previous commercial/industrial use of the land and the introduction of receptors sensitive to the potential ground contamination, an intrusive investigation needs to be carried to fully characterise the site. Therefore, in accordance with NPPF I recommend that the following condition be applied to any grant of planning permission for this site.

Highways Development Control Noted Summary Please refer to para 5.32-5.43 (Parking and The applicant proposes a development of high density apartments and Highway Safety) doesn’t provide car parking to the current Milton Keynes Parking standards. Cycle parking is provided to an acceptable standard.

The development doesn’t impact on the local highway network to a degree such that mitigation measures are required.

Layout Detailed plans and cross sections have now been received that show the proposed building interfaces with the existing shared cycle/pedestrian route. These show that the buildings do not encroach onto the highway.

This area has been the subject of a meeting with the applicant to discuss potential improvements to the shared route as called for by the cycling officer with my support. As a result the applicant has agreed to improve the shared route as part of the proposed development. The details are being finalised and the work can be included as part of a S106 package.

The applicant has now shown the retention of the pedestrian route along the north side of South Terrace.

The submitted plans show a narrowing of South Terrace in order to provide a safer crossing point for both pedestrians and cyclists. I have no objection to this as the current South Terrace is one-way (eastwards) and the proposed narrowing is not unreasonable. Details of crossing points are awaited.

Parking Previous contradictory information on this matter has now been clarified by the applicant.

The accommodation schedule shows that the development will comprise 184 dwellings comprising 172 apartments (1 and 2 bedroom) and 12, 3 bedroom town houses. The application also includes small areas of commercial/retail development.

In early pre-application discussions it was agreed that even though the application site is split across zone 2 and 3 parking areas, (as defined in the 2016 Milton Keynes car parking standards) the area within the red line boundaries would be treated as zone 2 in respect of the application of the car parking ratios.

Bletchley View North comprises 110 apartments and 6, 3 bedroom town houses. The table in the car parking standards show that this element of the proposal could provide 122 allocated and 38 unallocated spaces. The development proposes a provision of 102 allocated spaces with 6 of those spaces being for the 3 bed town houses (1 space each).

Bletchley View South comprises 62 apartments and 6, 3 bedroom town houses. The tables in the car parking standards show that this element of the proposal could provide 74 allocated spaces and 23 unallocated spaces. The development proposes a provision of 70 allocated spaces.

The total provision of 172 allocated and 9 unallocated car parking spaces is less than could be provided by the current parking standards with a shortfall of 24 allocated spaces (1 space only for each of the 3 bedroom townhouses) and a provision of 9 unallocated car parking spaces against a possible 61 spaces from the parking standards.

There is no provision of powered two-wheeler vehicles and no provision for parking of electric vehicles with associated charging points. I consider that both of these could be provided.

The supporting information provided as part of the planning submission makes no reference to how the parking spaces will be allotted. It would be useful to understand how the applicant/developer intends to provide allocated parking on a ‘per/unit basis’. If it was made clear that certain prospective tenants would not be offered car parking and that was part of any lease agreement then that would indicate that tenancy for those units would not at least place an unknown burden on the allocated parking. A condition then allowing the local authority to evidence the lease agreement for the individual units could be imposed on any planning application. There is a precedent for this arrangement.

The applicant has carried out a car parking stress survey to explore the availability of car parking in the vicinity of the application site including Queensway. This covers both a weekday (Thursday) and a Saturday.The survey does show some availability in car parks in this area of Bletchley. All of the areas surveyed are within a 5-10 minute walk of the application site. However, the applicant has not included the new Multi-Storey Car Park on the site of Bletchley Leisure Centre which is a 7 minute walk from the development.

The documentation submitted in support of the planning application places significant emphasis on the sustainability of the application site.

It lays immediately adjacent Bletchley bus station and is 700m walking distance from Bletchley railway station. 12 bus services operate through the bus station and provide service intervals of between 1 every 8 minutes and 1 every 2 hours.

The 2011 Census data in the table below (the table shows a typographical error in the area it refers to) shows that the average car ownership in this area is 0.88/household and that 38% of households do not have access to a private motor car. Additionally the 2011 census data shows that 59% of trips to work are by car and 7% of trips are made as a car passenger. The same table shows that 30% of residents travel to work by sustainable means.

The 2016 parking standards state: “These revised standards accord with this guidance. (NPPF, 2015) Developments are expected to meet the standards in this SPD but proposals will be considered on their merits having regard to local circumstances and the needs of the specific development”.

The standards go on to say that “where a proposal departs from the parking standards, Transport Statements and Assessments would be expected to include the following items: -

• Surveys of parking capacity and occupancy levels on surrounding streets and parking areas. • Consideration of likely trip generation and parking accumulation for the proposed development evidenced as appropriate. • Details of how the parking will be managed and how that will mitigate any under-provision”.

The planning application has considered the sustainability of the site and the fact that it lays immediately adjacent Bletchley bus station and is 700m walking distance from Bletchley railway station. 12 bus services operate through the bus station and provide service intervals of between 1 every 8 minutes and 1 every 2 hours. Bletchley Rail Station provides regular services on the West Coast main line with services into London (Euston) in the region of 30 minutes travel time. This may take on even more significance when East-West rail services are fully functioning and of course Bletchley is the MK hub for East-West rail.

This planning application has parallels with another similar application in CMK that was recently approved. The car parking in that instance was restricted and didn’t provide for a parking space for every apartment.

As with that application the applicant here intends to produce a strategy for parking management at the proposed development. I would expect this to provide clear advice to potential purchasers of the apartments regarding whether or not they will be provided with a parking space. The purchaser is then making a choice on that basis if that is an important consideration. This will ensure that the allocated parking is not oversubscribed.

The applicant has provided parking for the development in line with current car ownership levels as indicated by the 2011 census output for this area. This shows that car ownership is 0.88vehicles/household.

Additionally, Local Plan Policy TC19 (Housing in Town, District and Local Centres) states: ‘Residential development proposals in these areas should provide fewer on-site car parking spaces than the Council’s maximum standards for housing development.’

This development is very finely balanced from the highway and more specifically, parking perspective.

Traffic Impact The applicant has provided information regarding the likely trip generation for the proposal which I have examined and concur with. The applicants have also stated that they carried out junction modelling for the following junctions: - • Albert Street/Development site access. • Albert Street/South Terrace. • Albert Street/Princes Way ; and • Saxon Street/Princes Way. The assessment of junctions covers a period 5 years post development (2026).

All information provided shows that the junctions operate within capacity for both the 2021 and 2026 future years with no significant queuing.

The analysis of Princes Way/Saxon Street (Princes Way roundabout) for 2026, shows that it will be operating over capacity. However this is largely due to the growth of background traffic. The introduction of the development traffic at this junction accounts for only 1% of the total traffic at this junction and this can therefore it can be considered that the development has an insignificant effect.

The supporting documentation for this application includes a Stage 1 Road Safety Audit. This together with the designer’s response has been examined by road safety colleagues. Recommendations have been made but there is no action against these items within the designer’s response. Colleagues have made comments regarding the reversing of vehicles within the site and for the retention of existing pedestrian routes within the site. All matters regarding issues on the public highway will be examined within the S278 highway technical audit of the proposed development.

Conclusion My main concern with this application is the shortfall in allocated car parking and I have given this considerable thought.

In doing that I judge that it would be difficult to defend an objection to this application should it result in a planning appeal. There are not many sites in Milton Keynes that could be measured as being more sustainable in transport terms. Indeed it could be judged that due to the close proximity of the bus and rail stations that the application site is more sustainable from the highway perspective than parts of Central Milton Keynes (Zone 1 within the parking standards).

In considering planning proposals, NPPF paragraph 32 states that ‘Development should only be prevented or refused on transport grounds where the residual cumulative impacts of development are severe’.

For the reasons stated this development is very finely balanced from the highway and more specifically, parking perspective.

Having considered the sustainability of the application site against the shortfall in parking I feel it would be difficult to defend an objection at an appeal were this application refused for highway reasons.

Whilst I would prefer to have car parking in accordance with the standards it is clear after such detailed discussions with the applicant that no additional parking is on offer and so with some reluctance I raise no objection to planning permission being granted subject to conditions.

Local Lead Flood Authority Noted No objections subject to conditions requiring detailing drawings and written confirmation of the discharge rate as agreed by the receiving drainage body.

Drainage Board Noted No comments.

Anglian Water Noted A foul sewerage condition is recommended should the LPA be minded to grant planning approval

Environment Agency Noted We have no objection to this application

Network Rail Noted The proposal is just over the highway to the east of Bletchley Railway Station, therefore, Network Rail would comment.

(1) If vibro-compaction machinery / piling machinery or piling and ground treatment works are to be undertaken as part of the development, details of the use of such machinery and a method statement must be submitted to the Network Rail Asset Protection Engineer for agreement.

(2) With a development of a certain height that may/will require use of a tower crane, the developer must bear in mind the following. Tower crane usage adjacent to railway infrastructure is subject to stipulations on size, capacity etc. which needs to be agreed by the Asset Protection Engineer prior to implementation.

(3) The proposal must not impact access or egress from or to the railway station.

(4) All drainage must be directed in the direction away from the operational railway.

(5) The LPA and the developer (along with their chosen acoustic contractor) are recommended to engage in discussions to determine the most appropriate measures to mitigate noise and vibration from the existing operational railway to ensure that there will be no future issues for residents once they take up occupation of the dwellings.

Network Rail is aware that residents of dwellings adjacent or in close proximity to, or near to the existing operational railway have in the past discovered issues upon occupation of dwellings with noise and vibration. It is therefore a matter for the developer and the LPA via mitigation measures and conditions to ensure that any existing noise and vibration, and the potential for any future noise and vibration are mitigated appropriately prior to construction.

Cranfield Airport Noted No comments received.

National Grid Noted No comments received.

Sustainable Construction Noted No comments received.

Housing Strategy (Affordable Housing) Noted Housing’s view is:

1) The development requires 30% Affordable Housing units as per the Local Plan Policy H4 and the Affordable Housing SPD 2013. http://www.milton-keynes.gov.uk/planning-and-building/planning- policy/adoption-of-the-affordable-housing-supplementary-planning- document. 2) The Council’s Plan 2016-20 approved at Council 8 June 2016 has the Key Priority: “Housing - supporting work on a progressive Plan:MK focussed on affordable housing, economic growth, investment and future prosperity of Milton Keynes for everyone and more strongly implementing the current 30% affordable housing requirement for new homes and to review that percentage in line with current needs;” 3) The application proposes the following in the Planning Statement, Para 8.6. “Unit Mix and Tenure – the proposed unit mix for smaller dwellings is considered as being appropriate for the Town Centre context and helps in meeting the identified need for 9,000 one and two bedroomed properties required in Milton Keynes between 2011 – 2031.5 Pending ongoing negotiations on the nature of affordable housing contributions sought, there may be scope for the provision of affordable housing within the scheme.” The application should provide 30% Affordable Housing as per current policy - any reduction in 30% will need a Viability Statement assessed by the Council’s appointed valuer and approval by Development Control Committee members. 4) The Tenure Mix should be at least 25% Affordable Rent (at a range of rental levels up to 80% including 5% at a level broadly equivalent to Social Rent) and 5% Shared Ownership. For this application, the mix breaks down to 46 Affordable Rent and 9 Shared Ownership. 5) The proposed Affordable Housing house size mix should be in line with current affordable housing need and policy; predominantly 2bed, and then a mix of 3bed, 1bed and 4bed properties as appropriate for the site and development. 6) The Council needs Affordable housing for Rent for households in housing need – it had 528 households placed in temporary accommodation of which 164 were in B&B at 2 October 2016.

Planning Obligations The Planning Obligations section of this report has been drafted in collaboration with the Senior Planning Obligations Officer.

Local Residents The occupiers of the following properties were notified of the application:

. 10 - 54 (evens) Albert Street Bletchley Milton Keynes . 1 - 7 (odds), 11 - 13B (odds), 17 – 21 (odds) Regent Street Bletchley Milton Keynes . 1, 3, 5-11 Dukes Drive Bletchley Milton Keynes . 1 - 18 Earls Close Bletchley Milton Keynes . Lidl United Kingdom Limited Princes Way Bletchley . Railway Depot Goods Yard Station Yard Saxon Street Bletchley . Burger King Albert Street Bletchley . Bus Station Saxon Street Bletchley

In addition, site notices were posted and an advert placed in the newspaper to publicise the application.

Fifty three representations of support have been received which include Noted the following points: - At last this eye sore of an area has a chance to be upgraded. - Any improvement to Bletchley should be supported - The development is much needed - Anything to bring footfall to the town is welcomed. - The proposal would continue the regeneration of Bletchley - Proposal would help businesses grow in Bletchley - Bletchley needs more parking, businesses, market and homes - Parking will be a big issue for this application - Education needs are important

Twenty three representations of objection have been received which Noted include the following points: . The sheer number of properties in such a small space is cramming and an overdevelopment of the site. . The development is too dense. . The height is inappropriate; such large buildings would be totally out of keeping with neighbouring properties. . Stephenson House is not an appropriate reference point for the development; Stephenson House is an eye sore that is entirely out of scale with its neighbours and does not justify another architectural blot on the landscape. . The gardens and rooms in properties on Albert Street will be overlooked resulting in an unacceptable loss of privacy. . Properties on Earl Close would also be overlooked and the peaceful enjoyment of homes and gardens would be lost. . Properties on Albert Street will overshadowed and have a loss of light as a result of the development. . The size and siting of the development would result in an overbearing impact on neighbouring properties, including properties on Albert Street and Earl Close. . Development may be visible from Oxford Street. . Concerned at the volume of traffic that will generated during construction and once completed; Albert Street is already busy and congestion and this will be exacerbated with resulting highway safety issues . The traffic and congestion study is based on software modelling and not evidence from site visits or commercial traffic; an addition 173 cars would introduce a significant increase in traffic. . Parking is already difficult in Albert Street and the addition of 184 homes with insufficient parking will worsen the situation causing highway safety issues . The proposal fails to meet the Parking Standards in an area of already congested parking. . The proposal would result in the loss of the dwindling car park provision for existing residents and visitors; this will encourage people to shop elsewhere. . Car parking in the town is already at crisis points . Refuse collection vehicles would block the access roads. . Concerned that the apartments, like Stevenson House, will not be well maintained resulting in issues relating to vandalism, rubbish and vermin. . There would be an aesthetic and environmental impact for the loss of mature trees (some of which are protect by TPOs); the submitted arboricultural report notes that there would be a significant arboricultural impact. . The proposed landscaped would not compensate residents for the inappropriate mass of the proposed development. . There would be a loss of wildlife on the site. . There is no play provision for children. . Construction activity would impact detrimentally on neighbouring properties. . High rise apartment blocks in the UK are a social failure with Stevenson House comprising a fine example . The development would have an adverse impact on social infrastructure including local shops, doctors surgeries and dentists . The scheme would not the support town and would create more problems than it fixes, such as parking. . The development does not take into account the fixing the links project. . Infrastructure is needed before development . Proposal would prejudice an opportunity to link with a remodelled railway station. . Concerned that the proposal is phase 1 of a much larger development. . Should the application be approved, a parking scheme should be condition together with a construction management plan