Woburn Sands Town Council

WOBURN SANDS TOWN COUNCIL Memorial Hall, 4 High Street, Woburn Sands, Milton Keynes, MK17 8RH Clerk: Mrs L. J. Stapleton Telephone: Milton Keynes 585368 (24 hrs.) www.woburnsands.org.uk

14th June 2016

Application 15/02319/FUL Amended Phases 5 and 6 of Nampak site.

Before commenting in detail about this application, these contextual points must be made:

A. This is the final phase in a development on the former Plysu/Nampak/Mayer Parry site, the Development Brief for which was written in 2003 and subsequently adopted into the Local Plan as supplementary planning guidance in 2004. It cannot be viewed as a new development as it is simply the completion of one which commenced some years ago. B. Parklands is not a separate, stand-alone, estate as other estates in the urban sectors of Milton Keynes. It is an addition to the already well established and long standing community of Woburn Sands, a small town within the rural sector of Milton Keynes whose character and identity must be maintained as residents of Parklands become part of Woburn Sands. (See WS Neighbourhood Plan) C. Taylor Wimpey's outline application for these phases and phase 4 were the subject of an Appeal in 2010; the Appeal was dismissed. The Inspector's comments remain highly relevant. The application for phase 4 was the subject of numerous meetings between MKC officer, TW, and ourselves and the plan which was finally submitted for Phase 4 met with our approval and was subsequently passed by Development Control. Whilst appreciating the removal of the unnecessary additional play area and provision of more parking for the Sports Hall, Woburn Sands Town Council still strongly objects to this amended application.

1. The reduction of Employment Space. 1.i. At the Appeal in 2010, it was accepted by MKC that the original 6.8 ha of Employment space on this whole site should be reduced to 3ha. At the hearing this was further reduced to just 1.3 ha. The current application reduces this still further to just 0.44 ha. Such a loss of employment opportunities undermines the function of Woburn Sands as a sustainable key settlement in the rural south east of Milton Keynes and is against Policy WS8 of our Neighbourhood Plan. 1.ii The changed location of the employment space away from the railway line to an area with residential properties on the opposite side of the road as well as above them, is entirely unsuitable. The whole point of the allocation alongside the railway with a substantial buffer separating the employment units from the residential properties was to provide separation between the residential properties and employment units. The current application provides no separation whatsoever. (See Appeal comment 29). 1.iii TW commissioned Louch Shacklock to undertake the marketing of the employment site. The accuracy of their reporting has to be questioned in light of some glaring errors, notably that "The town of Woburn Sands is located in the western flank of Milton Keynes" (Letter dated 12 August 2015). The report continues on the assumption of this location in the west when it examines the market for employment opportunities in Milton Keynes, so little if any credence can be attached to the report's assertions. It later in the same letter quotes the A5130 as a "trunk road" which it definitely is not, and states that Shelton House, the towns's largest office building "has been converted into residential property". This is completely untrue as the building is now occupied by a major firm of solicitors. The credibility of the entire report on the marketability of the employment units is in our opinion therefore highly suspect. 1.iv. As indicated in the Louch Shacklock report on the marketing of the site for employment, this has been "actively" done since Jan 2015 so it is on the assessment of just 6 months marketing that it now declares the reduction of employment units is justifiable. Furthermore, as per the site signage erected and all the evidence of their marketing, it was always for the development of the whole site to be developed for B1 usage, not for individual units within it. No attempt to ascertain the demand for an individual unit seems to have been made, and the only one mentioned is from Asplands Medical Centre who approached Louch Shacklock at this Council's prompting. The report states that no locally based interest has been indicated, but to the best of our knowledge, no such marketing ever took place. 1.v. In his letter dated 15 Sep 2015, Jeremy Woolf of Woolf Bond Planning, states the applicants willingness to accept alternative uses such as A1 in place of B1 usage of employment areas. Woburn Sands Town Council has consistently opposed the use of units on Parklands for retail purposes because it would undermine the viability and vitality of the existing premises in the High Street and Station Road and is against policy WS9 of the Neighbourhood Plan. There is already a well-stocked newsagent and convenience store and hairdresser very close to the development on the main road and any units within Parklands would only attract Parklands residents since they would not be on a visible main road location. The Town Council, would not, however, object to the alternative usage for a health centre extension to Asplands Medical Centre, nor indeed to a dentist within the employment units. 1.vi. It is unclear from the plans if suitable access to a B1 usage is provided to these ground floor units other than at the front entrance which appears to be merely a reception area. Ease of loading and unloading goods would be essential for a B1 usage and this could not be obtained via the front entrances. The provision of a loading bay at some distance from the employment units as proposed on the opposite side of the road is entirely unacceptable. 1.vii. The assertion in Jeremy Woolf's letter that the residents do not want B1 employment units is based on a narrow response of just 17 occupants of Parklands properties, hardly a justification for the removal of most of these, given the population of the whole of Woburn Sands including the other 375 properties occupied in Parklands when this response was received. 1.viii. In conclusion on the reduction of employment space, this Town Council objects to the reduction, the changed location and the possible usage away from B1 and seriously questions the whole marketing strategy of the site and consequent assertion that there is no demand for B1 usage. The sustainability of the whole community requires the 1.3ha of the employment land.

2. Number of Dwellings 2 i. Before the commencement of building of homes in Parklands by Taylor Wimpey, there were 980 dwellings in Woburn Sands, according to the Woburn Sands Neighbourhood Plan. Phases1 - 4 will add a further 487 to that number. At the 2010 Appeal, Taylor Wimpey were seeking to add a further 303 to the 280 of phases 1 & 2, giving a total in Parklands of 583. The Inspector's view of this "substantial influx of dwellings and people.....has the potential to materially harm the equilibrium and identity of the town and its community" ( point 21). If the current application is allowed, the addition of 86 dwellings to the now built/ being built land at Parklands, the total will become 573. This will still, in our opinion, be too many, as it represents an increase approaching a 60% addition to the pre Parklands size of the town, probably even greater in terms of population numbers. This number cannot readily be absorbed into an old rural settlement without changing its character substantially. The facilities of the town are insufficient and it will become nothing but a commuter settlement, rather than a sustainable key settlement. The Vision as stated in the Neighbourhood Plan will be immediately threatened. 2 ii. Taylor Wimpey suggest, in order to justify this large influx of dwellings, that the MK Core Strategy is out of date. However, it is a Core Strategy covering a period up to 2026, with a requirement by an Inspector to update it earlier with Plan:MK, a process about to enter its next Public Consultation phase. Woburn Sands Neighbourhood Plan, fully compliant with the Core Strategy, covers the same period up to 2026, with a commitment to review it after 5 years ( ie in 2019) in light of Plan:MK. This Town Council does not, therefore, accept the justification given by the applicant for this large number of additional homes. 2 iii. Furthermore, as has been widely quoted in both the Neighbourhood Plan and the Site Allocation Plans of MKC, Woburn Sands has already contributed sizeably to the requirement for housing in the rural sector, and in effect will have contributed even more with the permission now granted for 53 more homes immediately on our northern boundary and which will use the overstretched facilities of the town.

3. Type of Dwellings. 3 i. As part of their justification for the number of dwellings, Taylor Wimpey quote the substantial need for affordable housing nationally. Yet here they are offering a mere 9% of the total in phase 5/6 as affordable. Since Milton Keynes requirement is for 30% affordable, this neither conforms to MKC's policy, nor does it support Taylor Wimpey's own justification for this application. 3 ii. The proportion of flats is particularly unacceptable to Woburn Sands Town Council. More than half the new dwellings in this application are for flats, a disproportionately high figure in any development, and most particularly so in this case. The Inspector's views on high proportions of flats here is abundantly clear in point 22. It is entirely unsuitable for a small rural town which before the Parklands development had just 14% of properties in flats. Under this application, phases 4, 5 and 6 would result in 33% of the properties as flats. This along with the 40% flats in phases 1 and 2, would be totally against the Inspector's and Town Council’s views, leading as the Inspector said to "the potential to weaken or destabilise the community". 3.iii The amended application decreases the number of smaller 3 bed homes in favour of more 4/5 bed properties: exactly the converse of what is needed.

4. The Density of Dwellings. 4 i. As a result of points 2 and 3 above, the density of dwellings in this application is too high. The Development Brief in place when Taylor Wimpey bought the site stated a maximum density of 40 dph. The subsequent Core Strategy brought the figure for Woburn Sands down to 35 dph. Yet here we have a density of 73 dph in phase 5 and 37.3 in phase 6. Phases 1 & 2 are at a density of 46 dph, phase 3 at 53dph and phase 4 at 37 dph. As the Inspector said in point 27, the main reason for the high densities is the proportion of flats. The Town Council would want the overall density of the completed site to be no more than 40dph and preferably nearer 35 dph. After all, before Parklands, the density in Woburn Sands was 28dph, and this is what contributes sizeably to its character which we would wish to maintain (Neighbourhood Plan Vision statement).

5. The Scale, Massing and Sustainability of Buildings 5. i The now staggered roofline of the crescent shaped block of flats is a marginal improvement but insufficient to remove the general objections to the block. 5 ii. The height of the rest of the buildings in phase 5 which front Summerlin Drive will make this spine road into an unattractive and dark route with tall buildings both sides of the road. This was not the intention in the Development Brief where tall buildings were to be limited to Station Road frontage and in the centre of the site overlooking the lake, i.e. locations with an open frontage opposite. 5 iii. Whilst a 2 storey building in phase 5 closest to the listed building of the Station House may be said to enhance its setting, the 3 storey block of flats N, behind the listed building will do no such thing. 5 iv. There is a disappointing lack of solar panels in this application. All south and west facing roofs should have these panels attached at the construction phase, and water butts installed in the back gardens. It is disappointing that this was not required in Phases 3 and 4 and we would hope to see them reinstated as a condition in this phase has happened, at our suggestion, in phases 1 & 2.

6. Impact on Highways and the level Crossing. 6 i. Woburn Sands Town Council is very aware that one of the major concerns in the local community about any additional house building is the impact this will have on vehicles numbers through the town. Traffic has undoubtedly increased through Woburn Sands since the days of the plastics factory on this site. Not only has Milton Keynes expanded considerably and the Cranfield University engineering sites similarly thus generating a very big increase in local traffic, but the constant assumption by the Transport Consultants that, in the days of it being a factory more traffic was generated, is incorrect. When the factory was under Plysu at the peak of its production here, the majority of the workforce was local and many walked or biked to work there. In addition, all HGV's from the factory were under strict instruction never to use Woburn Sands High Street as a means of access/ egress. 6 ii. No detailed analysis seems to have been made of the new developments currently expected in the vicinity which will contribute to further increases: 53 dwellings at Wain Close just to the north of Woburn Sands, 3000 new homes in the SLA north of Wavendon and straddling the A5130. All additional housing in this area brings with it more traffic and this 86 will add more to that. 6 iii. There are errors and unjustified assumptions in the Consultant's report: There is now no police station or butchers shop in Woburn Sands High Street within 10 and 12 minutes walk as claimed. The bland statement that research indicates occupiers of flats and affordable housing generate lower trip rates is unsubstantiated, and the more questionable given this site's position in a rural area of Milton Keynes. The assertion that any new employment facilities will draw the workforce from this residential development rather than further afield is also unsubstantiated. 6 iv. Perhaps the most significant omission is the failure to recognise the impact of the expansion of East West Rail. This is scheduled to double the number of trains per hour over the level crossing from 2022 and for further closures as the line attracts freight traffic. Electrification at a later stage will increase rail traffic still further. It is worth noting Network Rail's letter of objection to the small development at Old Signal Yard just opposite this site on the other side of the level crossing because of its close proximity to the level crossing junction. 6 v. Milton Keynes Council in conjunction with Network Rail have recently undertaken a detailed analysis of traffic over the level crossing. This must be taken into account by the Consultants and looked at closely by the MKC transport planning department before this application is considered further.

7. Use of Open Space and lack of Buffer Zones. 7 i. The close proximity of residential development to the railway line with merely a fence to separate track and platforms from small rear gardens is unacceptable. In the 2010 Inspector's report, a 5 meter buffer was recommended between B1 employment uses and residential properties. The noise from a railway, and one which is expanding, will probably be greater than any employment in this category would have generated, yet no buffer of trees is provided. 7 ii. It is worth noting that it is standard practice of Network Rail to have a clause inserted in any such development close to a railway that ensures the developers are responsible for a period of 20 years to settle any claims for compensation awarded to properties affected by a railway and its expansion. 7 iii. There needs to be a contribution in lieu of removed play area towards other recreational facilities 7 iv. Also of concern is the level of the water in the Central Lake. This has gone down a considerable amount since the building of this estate. It is not clear if this is deliberate as a means of flood protection or accidental, and the Town Council would like a detailed report on this before any further permissions are granted. 7 v. The amount of green space within these final phases seems very limited especially given the very high density of Phase 5. Trees are a key feature of the town's conservation status, and whilst this site does not fall within the Conservation Area, more trees would be welcome in order to maintain its setting.

8. Inadequate Parking Spaces. 8 i. It is unclear if the allocated parking spaces concur with the draft new parking standards of MKC which should be adhered to. It appears that garages may have been counted as parking spaces, which, quite rightly, MKC to not allow. 8 ii. MKC has consistently objected to large rear parking courts and those of Phase 5 are unlikely to be acceptable. The visitor spaces on the road along the phase 5 will be used by residents in preference to the rear parking courts. 8 iii. There does not seem to be any provision for employment parking usage for block N. 8 iv. In several earlier discussions with Taylor Wimpey, the idea of a shared car parking area was discussed, spaces which could be used by rail users and overflow from the community facilities of the Summerlin Centre and Sports Hall. This needs to be incorporated into the parking scheme. 8 v It is important to note that the most frequent complaint by existing residents of Parklands is the inadequacy of parking spaces and the consequent congestion on the estate's roads. In a small town on the edges of Milton Keynes, away from the facilities of the city centre, it is vital that more spaces are allocated as car ownership will be higher than in the urban area. 9. The Sports Hall. 9 i. Whilst the Town Council welcomes the provision of the Sports Hall, we would appreciate some further discussion about the internal lay out. Is a cycle area within the building really the best use of the space? This space could be a vital addition to the storage or even for some showers with another look at the layout within the building. 9 ii. It needs to be noted that in the Development brief, 0.5 ha was to be allocated for community facility alongside the Summerlin Centre; it needs to be checked that this this amount of land has now been allocated. 10. Statement of Community Involvement. 10 i. Two consultations were organised by Taylor Wimpey on this application. The press release announcing the first stated 15 affordable units were being included and that the phases were off Greensand View, both statements are incorrect since they only include 9 affordable units and the development is off Summerlin Drive. 10 ii. The first consultation on November 2014, was attended by 68 people and 29 response forms were completed. The most frequent comments expressed concern over the number of flats. The consultation feedback form was highly biased in favour of support for the reduction of commercial units (question 2) 10 iii. The second consultation followed via a letter only to Parklands residents with a yes/no response sought via e-mail. 17 replies were received. These predominantly supported the reduction in employment.. 10 iv. Clearly, Taylor Wimpey have chosen to give far more weight to the smaller and limited survey to justify the substantial reduction in employment land, ignoring the views of the wider community. 10 v. This application also ignores concerns expressed in the consultations over the high density resulting primarily from the high number of flats, justifying this by stating that these merely continue the theme of the earlier phases and completely contrary to the Inspector's comments that the final phases should redress the balance of dwelling types, thus reducing the density, (Points 22 and 28). Whilst it is true that Phase 4 and this new one for phase 6 are of slightly lower densities, that of phase 5 is massively over the required density. 10 vi. We conclude, therefore, that the Statement of Community Involvement is at best limited, and at worst highly misleading.