ITEM 5

Application Number: 15/00223/CONS

Outline planning application with all matters reserved except for access for a mixed-use sustainable urban extension on land to the south west of Milton Keynes to provide up to 1,885 mixed tenure dwellings; an employment area (B1); a neighbourhood centre including retail (A1/A2/A3/A4/A5), community (D1/D2) and residential (C3) uses; a primary and a secondary school; a grid road reserve; multi-functional green space; a sustainable drainage system; and associated access, drainage and public transport infrastructure

AT Land South of The A421, West of Far Bletchley, North of The East West Rail Link

FOR Aylesbury Vale District Council

Ward: Tattenhoe Parish: Shenley Brook End & Tattenhoe PC

Report Author/Case Officer: Sarah Hine Contact Details: 01908 252283 [email protected]

Team Leader: Sarah Evans Team Leader Strategic Business Unit Contact Details: 01908 253326 [email protected]

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

1.1 The Site

The application site is land to the South of the A421 (Standing Way) to the west of Far Bletchley, North of the East West rail link.

1.2 The Proposal

Milton Keynes Council (MKC) has been consulted by Aylesbury Vale District Council (AVDC) on this outline planning application. AVDC is responsible for consulting on and determining this planning application. The purpose of this report is to agree the Council’s response to the planning application, focussing particularly on the impact that the proposal will have on the borough.

The details of the application contain the following elements:

an employment area (B1). Site area 2.07 ha, a neighbourhood centre including retail (A1/A2/A3/A4/A5), site area 0.67 ha, community (D1/D2), site area 5.2 ha and residential (C3) uses (up to 1885 dwellings); a primary and a secondary school; a grid road reserve; multi-functional green space; a sustainable drainage system; and associated access, drainage and public transport infrastructure

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

2.1 National Policy

National Planning Policy Framework paragraph 2012

14 Presumption in Favour of Sustainable Development 32 Transport Statements 39 Parking 47 identify a 5 year housing land supply with an additional 5% buffer 49 relevant policies for the supply of housing are out-of-date if the LPA cannot demonstrate an adequate five year supply 50 Mix of housing 51 Change of Use To Residential 56, 57, 60, 61,63,64 Design 7, 109 and 118 – Biodiversity Enhancements 69 Crime 70 Deliver Social, Recreational and Cultural Facilities the Community Needs 96 Take account of land form, layout, building orientation, massing and landscaping to minimise energy consumption 98 Sustainability 103 Flood Risk 109 Conserving and Enhancing the Natural Environment 112 Take account economic and other benefits if best and most versatile agricultural land 117 Minimising Impacts on Biodiversity and Geodiversity 118 Conserve and Enhance Biodiversity 111 Reuse of Brownfield Land 121 Ground Conditions 123 Noise 125 Light 196-198 Determining Applications 203-204 Planning Obligations

2.2 Local Policy

Adopted Milton Keynes Core Strategy 2013

CSA NPPF – Presumption in favour of sustainable development CS1 Milton Keynes Development Strategy CS6 Place-Shaping Principles for Sustainable Urban Extension in Adjacent Local Authorities CS10 Housing CS11 A Well Connected Milton Keynes CS12 Delivering Successful Neighbourhoods CS13 Ensuring High Quality Well Designed Places CS18 Healthier and Safer Communities CS19 The Historic and Natural Environment CS21 Delivering Infrastructure

2.3 Adopted Milton Keynes Local Plan 2001-2011(Saved Policies)

S3 City Expansion Areas S10 Open Countryside S12 Linear Parks D1 Impact of Development Proposals on Locality D2 Design of Buildings D2A Urban Design Aspects of New Developments D4 Sustainable Construction HE1 Protection of Archaeological Sites NE1 Nature Conservation Sites NE2 Protected Species NE3 Biodiversity and Geological Enhancement NE4 Conserving and Enhancing Landscape Character T2 Access For Those With Impaired Mobility T3,T4 Pedestrians and Cyclists T5 Public Transport T10 Traffic T15 Parking Provision T17 Traffic Calming H1 Land Allocated for Housing H2- H5 Affordable Housing H8 Housing Density H9 Housing Mix L3 Open Space Standards of Provision PO4 Percent for Art

2.4 Supplementary Planning Guidance/Documents

Milton Keynes Parking Standards 2016 Planning Obligations SPG for Education Facilities (2004) Planning Obligations SPG for Leisure, Recreation and Sport Facilities (2005) Social Infrastructure Planning Obligations (2005) The Milton Keynes Drainage Strategy - Development and Flood Risk Supplementary Planning Guidance Sustainable Construction (2007) Affordable Housing (2013) New Residential Development Design Guide (April 2012)

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

3.1 a) Working co-operatively on strategic matters b) Impact on the Highway c) Working Co-operatively With Adjoining Authorities d) Impact on and relationship with Milton Keynes e) Urban design matters f) Planning obligations and S106 Contributions

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

4.1 It is recommended that Milton Keynes Council Local Planning Authority object to the application as outlined in Section 6 of this report.

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

5.1 Working Co-operatively With Adjoining Authorities

Paragraph 178 of the National Planning Policy Framework (NPPF) states that public bodies have a duty to co-operate on planning issues that cross administrative boundaries, particularly where strategic issues are involved. It is expected by the Government that joint working on areas of common interest should be undertaken.

5.2 The applications were originally submitted in July 2015 and since this date there has been ongoing dialogue and work with Aylesbury Vale Council on the proposal. Topic meetings have taken place at regular intervals looking at key issues such as highways and S.106 matters engaging with key consultees, stakeholders and the applicants. It is considered that whilst Milton Keynes Council Local Planning Authority recommend an objection to this proposal the requirement to work co-operatively with adjoining authorities as specified in the NPPF has still been met.

5.3 Impact on the Highway The Aylesbury Vale (AVDC) application is in outline form with all matters, except access, reserved for determination at a later date. As access is not a reserved matter it must be given full consideration. It is noted that matters such as the internal site layout and car parking standards will be for AVDC to determine.

5.4 The application is for the approval of the accesses to facilitate the development on land in Aylesbury Vale. Two vehicular accesses are proposed within the Milton Keynes administrative area; one being a left-in only access from the A421, the other is a new roundabout junction on Buckingham Road. (A third vehicular access is proposed to Whaddon Road within Aylesbury Vale.)

5.5 Saved policies D1 (i) and (vi), T10 and T15 of the Local Plan and CS13 of the Core Strategy require the decision maker to have particular regard to any additional traffic generation a development may cause and the resulting impact on the surrounding road network/parking provision/access.

5.6 The submitted Transport Assessment (TS) has demonstrated that the development (in AVDC) is able to be accommodated on the highway network. Improvements to junctions within Milton Keynes are proposed and, subject to agreeing a financial contribution, appear acceptable to mitigate the development.

5.7 The two accesses proposed within Milton Keynes have been tested and have been Safety Audited. The accesses are considered acceptable in highways terms.

5.8 Proposals for public transport and connections to the walking and cycling networks are acceptable but their implementation needs to be secured.

5.9 A section 106 agreement and conditions would be required to ensure that appropriate highway works are carried out at the right time and to the right standards. A Section 278 agreement will ultimately cover the works within the public highway.

5.10 Consequently there is no highway objection to this application subject to securing the works, improvements and funding referred to.

5.11 Impact on and relationship with Milton Keynes The current application is located within Aylesbury Vale and AVDC are the determining Authority for the application. However, the proximity of the application site to Milton Keynes means that the new development, if permitted, would function as an extension of the built area of Milton Keynes. It is therefore imperative that the development is designed to reflect the character and nature of Milton Keynes.

5.12 One of the most identifiable characteristics of Milton Keynes is the grid road network. The application includes a safeguarded route for a grid road from Tattenhoe roundabout in the north to the railway line in the south. In addition, the inclusion of large areas of open space and green links through the site are reflective of the linear park network in Milton Keynes. It is considered that whilst the development will not fully integrate with and reflect Milton Keynes the current scheme does reflect and relate to the character of built development in Milton Keynes.

5.13 The close proximity of the site to Milton Keynes bordering the southern boundary of the administrative boundary, means that the residents of the development will use Milton Keynes for day to day activities such as waste disposal, libraries and shopping. It is the Councils view that the proposal should mitigate this impact and this is discussed in more detail below.

5.14 Policy CS6 of the Core Strategy sets out the principles for considering sustainable urban extension to Milton Keynes which are wholly or partly within the administrative boundary of a neighbouring authority. A strategic approach has been taken by the applicant with regard to the preparation of the scheme and in terms of the assessment of highway matters and design have been made. It is considered that the proposal broadly meets the requirements of Policy CS6 and therefore no objection is raised on this matter.

5.15 Urban Design Matters

All matters are reserved except for access, but based on what has been submitted and in particular the Development Framework Plan and Illustrative Masterplan the Urban Design Officer considers that this application would fit well as an urban extension to Milton Keynes and complements many of the grid squares in MK for example with the inclusion of the grid road reserve and underpasses, redway (along primary street) as well as the high provision of open space. The central primary street proposed also mirrors many other primary streets that “loop” through established MK estates such as Shenley Brook End, Shenley Lodge and Old Farm Park/Browns Wood.

The full comments from the Urban Designer are included in the appendix.

5.16 S106 Matters

The Development proposals indicate that certain infrastructure required to support the development will be provided on site. In addition to these on site facilities, Milton Keynes Officers consider that additional offsite contributions are required in order to mitigate the impact of this proposal given the proximity of the Development to Milton Keynes.

5.17 It is assumed that the following facilities will be provided on site, and Milton Keynes Council should be a party to the Section 106 agreement to ensure these are provided on site as not to create an adverse impact on existing MK provision:

Primary & Secondary Education Playing Fields and Pavilion Local Play & Neighbourhood Play Facilities Community Facilities (including meeting places) Allotments Sports Hall GP Health Facilities

Waste Collections and Waste Receptacles.

For those requirements which cannot be accommodated on site, 5.18 contributions payable to Milton Keynes Council have been requested. The list

below sets out our expectations for offsite contributions, and have been

calculated in accordance with the Milton Keynes adopted Supplementary

Planning Guidance and Documents:

5.19 Education: Education provision is a particular concern for MKC. Our education department has stated that they anticipate the development would be situated to the west of the Lord Grey liaison group as well as The Saplings and Daisychain children centre catchment area. We would estimate a yield of 110 children per year group from the 1885 dwellings. The proposal outlines a new primary school as part of the development plans. In Milton Keynes, there have been small decreases in demand for primary places in this area, the current projection estimates a surplus of 15 places by 2022. As we estimate a yield of 110 children per year group, we would advise that the primary school provided on site within AVDCs administrative area is designed and built to a specification that could to accommodate a minimum of 3 FOE (90 children) at each year group.

5.20 The proposal outlines a new secondary school as part of the development plans. Bletchley as an area is experiencing huge demand for secondary places growing year on year. The most recent projections estimate a deficit of 195 secondary school places by 2022 in the Bletchley area. The additional impact of the new development would result in a deficit of over 300 places per year group. Therefore we would advise that the proposed secondary school is of sufficient size to accommodate the pupil yield from the development as the secondary schools in MK will not have capacity to accept any pupils from the SWMK development.

5.21 The following list represents the areas that we would expect to see contributions towards to mitigate the impacts on the service and infrastructure these residents will likely use within Milton Keynes;

5.22 Early Years: £1,310,641.01 It is not clear from the Design and Access Statement whether Early Years provision is being accommodated on site. As discussed, it is extremely unlikely that residents will travel into Aylesbury to utilise such services, and as such we would be seeking a contribution in line with our Education Facilities SPG which has been calculated as £1,310,641.01. The demand for Early Years provision is compounded by the need to provide 30 hours free provision for 3+ year olds which comes in to effect in 2017 and the additional pressures this will bring notwithstanding the impacts of this development if permitted.

5.23 Library Facilities: £419,413.50 In line with Milton Keynes Council’s Social Infrastructure SPD, contributions towards the provision of library facilities are sought. The SPD calculates this contribution to be in the region of £419,413.50.

5.24 The proposed development of 1850 dwellings in the south of Bletchley in the future will have an impact on library provision for this area. The current library is already the second busiest library in Milton Keynes after the Central Library currently attracting around 100,000 people per year. Following an extensive review of MK Libraries in 2015 “Sharing Responsibilities for Libraries: More than a library” was adopted by cabinet in January 2016 as MK Libraries strategy moving forward. In this document it lays out the future vision for libraries to become community hubs serving as spaces for education, learning and events as well as somewhere they can meet, attend activities and from where community groups can operate. The reconfiguration of the existing building in 2017 is the first phase of implementing this strategy. We anticipate the refurbished library will rejuvenate the service and attract even greater numbers of customers to use the facilities. With the expansion of the Bletchley population with the building of more dwelling in the area, future expansion of the library would be required to provide adequate library provision going forward into the future. 5.25 Health Facilities: £1,451,001.25. It is expected that a GP surgery is to be provided on site in accordance with the specification and requirements set out by the NHS England and Milton Keynes Clinical Commissioning Group (CCG), however there will also be an impact on acute/hospital facilities as a result of this development. Given the proximity of the development to Milton Keynes and the services located here, we expect that the impact of this development will directly affect MK Hospital.

5.26 Milton Keynes CCG as the commissioner of healthcare to the population of Milton Keynes has commented as follows to MKC and AVDC on this application, and this response is copied below.

“Milton Keynes CCG commissions health care services for its people within the Milton Keynes area. Its geographic area of responsibility covers all the wards in Milton Keynes Local Authority plus the wards of Great Brickhill and Newton Longville which are in Aylesbury Vale therefore this includes health responsibility for the footprint of this planning application. MK CCG is largely (95%) co-terminus with Milton Keynes Council and currently has a registered population of 262,000”.

5.27 The development in question (1,885 dwellings) will result in approx. 4,524 additional residents (based on 2.4 occupancy) and would affect several existing GP surgeries in Milton Keynes – Drayton Road, Hilltops, Parkside, Westcroft and Whaddon surgeries. None of these GP practices currently include the South West Milton Keynes development within their practice boundaries and do not have capacity to absorb this population increase.

5.28 For secondary care provision it is likely that the majority of residents would expect to use Milton Keynes University Hospital NHS Foundation Trust for their care. Considering the scale of this proposed development it is certain that existing NHS provision will not have the capacity to absorb the likely impact and additional health provision will be required.

5.29 Milton Keynes CCG feels that in order to mitigate the impact of the above development we seek a contribution towards additional health facilities which would include a land allocation and a charge per dwelling in line with the tariff adopted by Milton Keynes Council (2.7 of the Social Infrastructure Planning Obligations SDP, which can be found at http://www.milton- keynes.gov.uk/planning-and-building/planning-policy/social-infrastructure- planning-obligations ) We also request clarification from both Aylesbury Vale and Milton Keynes Councils as to the process by which the health requirements for this planning application will be discussed and agreed.

5.30 The contribution therefore sought for Secondary (Hospital) healthcare would be 50% of SPD figure which equates to £1,451,001.25.”

5.31 NHS England have commented as follows:

“The development of 1,885 dwellings will result in approx. 4,524 additional residents (based on 2.4 occupancy) and this impact cannot be accommodated in the existing surgeries in Milton Keynes. Closest GP surgeries to the proposed development are:

Westcroft MC According to our records they currently occupy a floor area of 606m2 NIA (net internal area). Their patient list as of 1 April 2016 was 13,609. Department of Health’s Principles of Best Practice, a surgery with 14,000 registered patients is recommended to have 870-909m2 NIA (net internal area) of floor space, which is significantly more than they currently occupy. It should also be noted that the Principles of Best Practice is only concerned with the GP core services and does not provide size guidance for extended services, which most surgeries are offering.

Water Eaton HC Our records indicate that they currently occupy a floor area of 351m2 NIA (net internal area). Their patient list as of 1 April 2016 was 6,536. Principles of Best Practice stated that a surgery with 6,000 registered patients is recommended to have 434-454m2 NIA (net internal area) of floor space, which is more than they currently have.

Whaddon MC According to our records they currently occupy a floor area of 718m2 NIA (net internal area). Their patient list as of 1 April 2016 was 12,232. Principles of Best Practice stipulate that a surgery with 12,000 patients should have 796-832m2 NIA of floor space, which again is more than this surgery currently has.

Parkside MC According to our records they currently occupy a floor area of 720m2 NIA (net internal area). Their patient list as of 1 April 2016 was 10,545. Principles of Best Practice state that a surgery with 10,000 patients should have 724-757m2 NIA of floor space, which is approximately the same of slightly more than the practice currently has.

5.32 Considering the above, also the scale of this proposed development, distance, and most importantly, other significant developments planned in the area (e.g. Newton Leys 2,000 dwellings, 350 of which fall under Aylesbury Vale DC), NHS England needs to take a more holistic view. There is no doubt that existing provision will not be able to absorb the likely impact and for this reason an additional health facility will be required on site.

5.33 In order to mitigate the impact of the above development, we seek the provision of additional health facilities on site to include the provision of a site to accommodate a 6-GP surgery, the construction of the GP surgery to NHS England specifications. We also support the CCG in their request for a contribution per dwelling in line with the Social Infrastructure SPD adopted by Milton Keynes Council (2.7 of the Social Infrastructure Planning Obligations SPD, which can be found at http://www.milton-keynes.gov.uk/planning-and- building/planning-policy/social-infrastructure-planning-obligations ) towards secondary healthcare facilities for Milton Keynes Hospital.”

5.34 It is therefore considered that an offsite contribution towards the MK Hospital in addition to the provision of a 6 GP surgery to be constructed on site is required to ensure the impact of the development on health care can be suitably mitigated and the residents of the development accommodated.

5.35 Waste Management: £478,724.50 Again, it is extremely likely that the residents of SWMK would utilise the Household Waste and Recycling Centres in Milton Keynes for all bulky waste and household waste disposal other that the kerbside collections which was expect AVDC will be responsible for. As such, a contribution in line with the Social Infrastructure SPD is required for Waste Management to facilitate the provision of recycling centre facilities and MKC is keen to understand how the kerbside waste and recycling will be managed as not to create undue impacts on Milton Keynes Council.

5.36 Emergency Services: £93,203.00 The Emergency Services that will serve this site will be Milton Keynes based and as such a contribution is sought in line with MK Council’s Social Infrastructure SPD towards the provision of Emergency Services, split between the Ambulance Service and Fire Service. I understand Thames Valley Police have approach AVDC separately with their requirements, and as such we would support their separate request (within reason) for a separate contribution towards Policing.

5.37 Voluntary Sector: £351,629.50 In line with the MK Council Social Infrastructure SPD, contributions are sought for Voluntary Sector projects to facilitate the integration of new communities with the existing. This is going to be of particular importance for SWMK residents, who will be separated from Milton Keynes by the administrative boundary however will for all intents and purposes live in Milton Keynes and rely on MK for the vast majority of their day to day requirements, such as shopping, leisure, health and transport. In the expansion areas, the Voluntary Sector contribution has been used to provide community mobilisers to assist the residents integrate into the community and to take part in a range of community and voluntary activities to ensure the development is incorporated into the existing area. Given this development is a bolt on to Milton Keynes; this is of increased importance because the residents from this development will look to Milton Keynes rather than Aylesbury for access to all services and community projects.

6.0 Recommendation

It is recommended that Milton Keynes Council Local Planning Authority object to the consultation from Aylesbury Vale District Council, as an adjoining Local Authority to the planning application for the following reason:

- The application fails to take account of the level of services and facilities required to meet the day-to-day needs of its future residents and fails to make a proportionate contribution towards an increase in the capacity of existing facilities within Milton Keynes to satisfy these increased demands and to mitigate the impact of the proposed development on existing services and infrastructure in Milton Keynes. It is therefore considered that the proposal fails to meet the statutory test for the use of planning obligations in accordance with Regulation 122(2) of the Community Infrastructure Levy Regulations 2010. Policy CS6 of the Core Strategy and Paras. 203-204 of the National Planning Policy Framework

The response should also advise AVDC that MKC may wish to submit further comments should the policy context change further or should any further detail, for example relating to planning obligations, be provided by the applicant.

Appendix to 15/00223/CONS

Appendix A1 A1.0 Relevant Planning History

Appendix A2 Consultation responses Consultation responses have been received from the following organisations: A2.1 Newton Longville Parish Council A2.2 Shenley Brook End and Tattenhoe Parish Council A2.3 West Bletchley Council A2.4 Senior Urban Design Officer A2.5 Passenger Transport A2.6 Housing Officer A2.7 Network Rail A2.8 Development Plans A2.9 Countryside Officer A2.10 Education Sufficiency A2.11 Highways Development Control A2.12 NHS England A2.13 Waste Strategy A2.14 COBRA A2.15 Local Residents Appendix to 15/00223/CONS

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 10/01056/CONS Outline planning application with all matters reserved except for access for a mixed-use sustainable urban extension for up to 5,311 mixed tenure homes (C3) to the south west of Milton Keynes, with the following: an employment area of 7.4ha including: up to 31,200m2 of employment floorspace (Classes B1a, B1b, B1c and B2); utilities and renewable energy infrastructure (sui generis); the relocation of a commercial recycling centre on a site of up to 1 ha (sui generis); and a site for a household recycling centre on a site of up to 1 ha (sui generis). A neighbourhood centre of 5.25 ha including: a reserve site for a railway station (sui generis); up to a 5,500m2 food retailing supermarket (Class A1); up to 2,000m2 (A1 retail, A2 financial and professional services, A3 restaurants / cafes, A4 drinking establishments and A5 hot food take aways); up to 2,000m2 small scale commercial (B1a and B1b) uses; up to 274 of the mixed tenure residential units (C3); utilities and renewable energy infrastructure (sui generis); up to a 220m2 Thames Valley Police one stop facility (sui generis); and up to 11,250m2 a community library (D1), private crèche (D1), community / religious worship / instruction facility (D1) and health (D1), leisure (D2). Two local centres and a small mixed use centre on a total of 1.78 ha including: up to 2,435m2 (A1 retail, A2 financial and professional services, A3 restaurants / cafes, A4 drinking establishments and A5 hot food take aways); up to 2,420m2 community facilities (D1), private crèches (D1) and health (D1), leisure (D2), an emergency / ambulance call point (sui generis); utilities and renewable energy infrastructure (sui generis); up to 90 of the mixed tenure residential units (C3); up to 2,000m2 small scale commercial (B1a and B1b) uses; and up to 700m2 veterinary practice (sui generis). Provision of 19 ha of land to provide education facilities (sites for four primary schools with ancillary early years provision and one secondary school OBJCAA 11.11.2010

10/01680/CONS Construction of 350 dwellings, dentist surgery, playing field, allotments, associated landscaping, access and infrastructure (Consultation from Aylesbury Vale District Council) OBJCAA 22.10.2010

14/00018/CONS Neighbouring Authority Consultation for Construction of four wind turbines up to a maximum height of 115 metres (to vertical blade tip) with ancillary infrastructure including substation, access tracks and crane hardstanding and temporary storage compound for period of 25 years NOBCAA 21.02.2014

15/00178/CONS Outline application relating to the erection of nine dwellings relating to access and layout only, involving the demolition of the existing house and outbuildings OBJCAA 13.03.2015

15/01637/CONS Outline application with access to be considered and all other matters reserved for the erection of six 2-storey dwelling houses involving the demolition of the redundant barns and outbuildings alongside the retained Dagnall House NOBCAA 27.07.2015

15/01638/CONS Outline planning application with all matters reserved for the demolition of all existing farm buildings (except the existing farmhouse) and the development of up to 1800 dwellings including affordable housing; a local centre to include retail and a community centre; one 1 form of entry primary school; one 2 forms of entry primary school; associated highway infrastructure including two proposed vehicular accesses with the A4146; two proposed pedestrian and cycle bridges crossing the River Ouzel; multi-function public open space to include an extension fo the Linear Park network, informal amenity open space, children's play space, open space incorporating the Scheduled Monument, playing fields, allotments, surface water attenuation and strategic landscaping; and associated services and utilities infrastructure PCO

15/02094/CONS Change of use of land to use as a quad bike track with associated facilities (part retrospective) OBJCAA 24.09.2015

Consultation Responses

A2.1 Newton Longville Parish Council Housing Supply and Need According to Milton Keynes Council’s (MKC) own official documentation, it has enough land for the strategic expansion plan: • The MKC document “Assessment of Five Year Land Supply 2016 - 2021 (June 2016)” says quite clearly “Milton Keynes has a very good record of ensuring there is a significant land supply available across the Borough. This remains the case with land for nearly 22,000 homes already in the development pipeline, over 14,500 of which have some form of planning consent.” • “This is a sufficient quantity of land available to deliver the overall Core Strategy target by 2026, and is felt to put Milton Keynes in a very strong position when compared to other authority areas where land supply may be a constraint to housing delivery. Of particular importance is the fact that a number of major strategic sites where development has been delayed over recent years have now commenced development and are reacting to strong market demand.” If Milton Keynes has enough land, which clearly it does, why on earth is SWMK trying to build another small town that is neither in the AVDC nor Milton Keynes’ strategic expansion plans? This development is plainly nothing more than naked opportunism by profit hungry speculators. The location of the proposed development is nonsensical. It will destroy high quality arable land and flood the roads with thousands of extra vehicle movements every day, thus increasing the risk of traffic accidents as well as the inevitable rapid deterioration of the road infrastructure. We believe that housing should be built where it is needed not where speculators want to impose it. The government passed the Localism Act in 2011, and this gives villages the ability to create a Neighbourhood Plan, which in turn feeds into a Local Plan. This is meant to ensure that development is done in accordance with local needs and wishes. • On 10 Oct 16, Sajid Javid the Secretary of State for Communities and Local Government said “Neighbourhood plans are a key part of the Bill. Not all planning takes place at local authority level. Neighbourhood development plans, which were introduced in 2011, have proved to be extremely effective. Far from being a so-called nimby’s charter, some neighbourhood groups with plans in force have planned for housing numbers above the number set by the local authority for that area. Those communities have, on average, planned for 10% more homes. Neighbourhood planning gives residents and businesses greater certainty about developments in their area, ensuring that they have a choice on how best to meet local housing needs.” • Sajid Javid “The honourable gentleman will know that once a neighbourhood plan is adopted, it becomes statutory and is taken into account when planning decisions are made. It is not a question of a local authority overruling a neighbourhood plan; once it is adopted, it is part of the local plan, so they are part of the same package, when it comes to making those decisions. Local authorities do not have the right to overrule a plan once it has been adopted.” Our Neighbourhood plan is still being worked on, so SWMK Consortium is being premature in trying quickly to get permission to build houses on land we have identified should be preserved as arable land; to avoid coalescence with Milton Keynes and nearby villages, and to preserve our quality of life. We urge AVDC and MKC to note The Secretary of State’s comments and allow us to complete our Neighbourhood Plan without having this awful sword hanging over our heads. • Housing to meet an accommodation need from the south of Aylesbury Vale should be provided close to Aylesbury. There are poor transport links from here to Aylesbury. Anyone using the A421 and local surrounding village roads early in the morning or late in the afternoon know how congested the roads have become. Adding another small town’s worth of commuter traffic on the road will see the traffic flow not be so much as a flow as a trickle, adding to pollution and local carbon footprint with no offsetting measures. Traffic and Highways As a Villager, I have a huge concern that insufficient attention has been paid to the realities of the local traffic flows. Some of our key concerns are as follows: • Whaddon Road from Bottledump Roundabout to Newton Longville is a narrow rural road. It is not suitable for one of the only two exits to the proposed development. • Bletchley Road from the very narrow Railway bridge into the village already attracts many HGV and speeding motorists. Not mention the land currently being developed on the old brick work site and the extra traffic this will bring. It’s just an accident waiting to happen. There will be blood on your hands. The idea of having three entrances and only two exits to what will be, in effect a small town has to be seen as absurd. Imagine the queues of traffic trying to join the A421 at 7.30 AM, or return at 5.30 PM. • SWMK are trying to treat this road as if it were of MK grid road standard when it is not, and they have made no offer to upgrade the road. • Where are the cycle and pedestrian links to Newton Longville and beyond? SWMK appear to be peddling the myth that this proposed development is within Milton Keynes’ boundaries whilst ignoring Aylesbury Vale and Buckinghamshire. Perhaps they hope no one will notice? Well, we have. • Whaddon Road and Stroke Road cannot currently cope with the likely increase in traffic from the proposed development. The developers have proposed and designed so-called traffic calming measures for Newton Longville. However this has taken place without any local consultation. Long experience tells us that such traffic calming will inevitably reduce road capacity and increase traffic problems. This will only get worse as many thousands of vehicles choke and crowd the roads in and out of the village. If the proposed traffic calming is introduced the situation will be far, far worse. It will increase air pollution and noise as well as the risk of accidents to pedestrians due to frustration waiting at the proposed chicanes. From the photos used in the proposed traffic-calming scheme it appears to be crystal clear that no-one conducting the so-called traffic assessment has actually visited our village. Instead, images have been used from Google Street View, some out of date. Google Maps traffic is not an accurate method of analysing traffic flows and volume. Use of it for this is not a methodology supported by Google. This smacks of incompetence, inefficiency, laziness and a quite possibly deliberate attempt to massage the figures to hide the true nature of the huge volumes of traffic in, through and out of Newton Longville. • Furthermore, the consultants have plainly not taken account of the crossroad in the village being a staggered junction that means it is not as simple to negotiate as a crossroads. • We have asked to see SWMK’s raw traffic data. They have refused. Why? If they have nothing to hide, then why hide it? There is likely to be significant road traffic from the proposed development towards Leighton Buzzard station as the train service to London is better there than from Bletchley and is at a significantly lower cost than from Central Milton Keynes. This will increase massively the flow and number of cars on the narrow roads in, through and out of our village. This fact has been conveniently ignored or overlooked by the consultants/developers. • The proposed bus service is entirely inadequate and not fit for purpose – ridiculously it offers no links to Newton Longville or anywhere generally within Aylesbury Vale. We are appalled that some of the traffic and collision detail used by the consultants are from 2014 and therefore now two years out of date. They most definitely do not reflect current traffic flows through Newton Longville, which reaches some 5000- two-way vehicle movements per day. Since the Newton Leys development, the traffic through our village has become horrendous, with a large volume of traffic to and from Newton Leys as well as from the A4146. The proposed new development will see thousands of cars and lorries all trying to use the one road through Newton Longville between the A4146 and A421. It is frankly ridiculous to propose a priority T junction on Whaddon Road when MK Council is closing right-turn exits from grid squares in MK because of safety: there have been requests from coroners to amend traffic turning as a result of deaths at such junctions. • There is insufficient evidence to show how the current congestion at peak periods along the A421 in both directions will be dealt with. • The so-called sophisticated traffic models produced by the consultants/developers might suggest there will be no congestion at Bottledump Roundabout – but clearly they have not ever used the roundabout at peak periods. Major changes would be needed at the roundabout to cope with any such development. This will be expensive, time consuming and even worse will massively; disrupt an already congested main arterial route. • MVAS data shows 22% increase in traffic flowing through the village between September 2015 and February 2016 - as has been clearly shown in our village magazine. • The undulating nature of Whaddon Road The developers entirely fail to take proper account of the current road layout. When leaving the village using Whaddon Road towards the A421, there are blind bends going up to the Victorian railway bridge. This is a narrow hump-back bridge. The views on approaching from either side are severely restricted and lorries routinely cross the centre line as they transit the bridge. The road continues up-hill to a sharp left hand bend and then down-hill on an undulating road which has several blind dips before reaching the Bottledump Roundabout. To add many more vehicles trying to join this busy and congested road means that accidents, injuries and deaths are inevitable. Landscape and Visual Assessment • There is not enough information to show how the development will be screened from existing housing, particularly houses on the ridge. • It is utterly unacceptable and frankly ludicrous to have to wait 15 years or more for any proposed trees to mature and give adequate screening of the proposed development from Newton Longville, Newton Leys and Bletchley. • The proposed height of buildings so close to Newton Longville and Bletchley will mean a loss of skyline and landscape value for local people, and those using public footpaths and the national cycle route. • To suggest that simply because the land has no special designation means it can be built ignores the aesthetic value to local people – and furthermore it is good quality arable land. • Newton Longville is currently surrounded by open countryside which separates it from Milton Keynes and provides a green buffer from the urban sprawl. • A site close to Aylesbury has recently been rejected by the Secretary of State for not leaving a satisfactory green buffer between the village and Aylesbury. In Appeal APP/J0405/A/14/2219574 it was said: “The Secretary of State agrees with the Inspector that Bierton is a village surrounded by countryside and not joined to Aylesbury and that the proposed development would cause Bierton to lose its separate identify.” • The edge of the site is less than 300 metres from the first dwelling in Newton Longville. • The ludicrous idea of moving the Milton Keynes Boundary Walk into the development to run alongside Whaddon Road completely changes the characteristic of this unique walk around the boundary of MK. It is the equivalent of putting a footpath next to a motorway, • Converting rural footpaths into urban walkways massively changes the character of the area and removes the opportunity to enjoy a walk or cycle in the open countryside. • The development will create light, noise and air pollution. Schools • There is not enough detail about schools, including information about how they will be funded, built and run. • There will also be an adverse impact on Newton Longville village school. • The schools will be in Buckinghamshire. Therefore, traffic will be accessing the schools from other areas of Buckinghamshire, and not from Milton Keynes. The highways impact of this has not been considered – it will increase pressure on the roads and might lead to difficulties in parking in the village, especially at peak times. • Pedestrian access to the schools from surrounding villages, including Newton Longville, has not even been considered. What do these developers think local children will do? Walk along the 60 mph Whaddon Road? If the answer to that is ‘yes’; they are failing in the duty to provide safe passage for pedestrians. If the answer to that is ‘no’, it means yet more traffic on the roads.

Health • The building of over 2,000 houses (this site plus the Neighbourhood Plan led new housing in the village) will impact severely on local health services. The local CCG (Clinical Commissioning Group) have made very clear that the existing local surgeries do not have any spare capacity to absorb the population increase. • Waiting times at already hard-pressed GP surgeries and MK Hospital will increase dramatically. For secondary health care, the majority of residents will plainly expect to use MK Hospital, as there is no other similar facility close by. The CCG say existing NHS provision will not have the capacity to absorb the impact of several thousand more people and additional health provision will be required. With the pressure on NHS funding, where is the money going to come from? This problem is made more acute as the proposed development is in neither the AVDC nor MKC strategic expansion plans. • The developers offer a possibility, but not a legal guarantee, of a site for a new GP surgery. What is the point of a possible site if there is no guaranteed money to build or fund it? • Although they are willing to provide some land for a health centre they are not offering any funding for the building, or to pay ongoing costs.. • How will the developer guarantee to mitigate the impact of this development and ensure provision of the additional health facilities needed? Burial Ground • There is no provision for suitably located burial provision to serve the site. Allotments • There is not enough provision for the number of houses proposed. Emergency Services • The draft AVDC Local Plan refers to the need for provision of police, fire and ambulance services. How does the developer intend to provide or fund these? Commercial and business premises/Employment Land • This seems to have been thrown into the application without any thought. Building offices here are likely to mean they would stand empty. • It is clearly too far from Aylesbury to meet the need for offices there. • It is the wrong location for offices in Milton Keynes as CMK is a much better location followed by the older towns and some existing centres. There is a surplus of offices at present. I strongly object to this Appalling and utterly Absurd planning application, and find myself exasperated by your ignorance of villager’s wishes and the constant threat of erosion to our way of life. If this application was passed it would cause horrendous implications for our village and to our quality of life with this horrible concrete monstrosity on our doorstep. I am Furious with the flagrant disregard and inadequate consideration being given to our very real concerns which will have a massive impact on our access to key services. We want to keep our village as a village, not part of a concrete sprawl Leave our village in peace and allow our Neighbourhood Plan to be developed. The massive lack of infrastructure means the whole area will suffer (Bletchley and surrounding villages) Newton Longville wishes to remain Newton Longville, not become part of an expanded South West Milton Keynes, an expansion that is neither needed, nor wanted, and is certainly not fit for purpose. Your pathetic attempt to justify an unneeded, unwanted expansion that will serve only further to clog the roads, destroy our Village way of life and increase pressure on already scarce resources. You will find that we are very passionate in the defence of our village. Surely you can see that this would cause huge pressure on already overworked emergency services and NHS that the whole country is desperately trying to keep hold of in adverse conditions. Rigorous examination of the SWMK proposal has highlighted some deep and systemic flaws and your fundamental assumptions are wrong, and therefore the whole plan is discredited by inaccuracy, undermined by mistakes, and should therefore with respect clearly be rejected. Unwanted; Unnecessary; Underhand; Unacceptable coalescence; Unacceptable encroachment of Milton Keynes towards the outlying villages You should feel ashamed of yourselves if this planning was to be approved as it is clearly a case of not listening to the people who actually vote and fund you and a fragrant disrespect of my and many other people’s concerns and issues.

A2.2 Shenley Brook End and Tattenhoe Parish Council Aylesbury Vale District Council Planning Application SWMK formerly known as Salden Chase

Shenley Brook End & Tattenhoe Parish Council covers eight grid squares four of which Tattenhoe Park, Tattenhoe, Emerson Valley and Furzton border the A421.

The proposed development would place an unacceptable burden on the transport infrastructure in particular the already congested A421. Any increase in use of the A421 would inevitably lead to traffic using the alternative route of V1 and H7, which is already a very congested route at peak times, through our parish to gain access into the centre of Milton Keynes and the V3 to gain access to the newer areas of the Western flank to the north of us.

There has been a lot of discussion about a new A421 expressway and until the route of this is decided we feel that no further development should be allowed in this area as this could affect all development decisions especially in this South West Corner of Milton Keynes.

The draft plan includes reference to S106 agreements and a Community Infrastructure Levy to fund essential services. We do not believe that developer’s contributions will sufficiently fund the transport infrastructure requirement without considering the rest of the essential services such as schools and health care. We have already seen in Newton Lees that a doctor’s surgery has been built but is sitting empty as there is no money to staff and run it. The Doctors surgeries and schools in our Parish are already oversubscribed and the Primary health care and hospital provision in Milton Keynes is already under pressure. We are aware that residents from the village of Whaddon in AVDC area already access the doctor’s surgery at Westcroft. The schools in our Parish are full and all are having extensions built to cater for the existing population and the expected increase in housing of approximately another 2.500 properties in the future.

The use of facilities such as the Household Recycling centre at Bleak Hall in Milton Keynes by residents of the proposed development is also a problem. Leisure particularly sports facilities are under particular pressure in our parish where it is extremely difficult for local clubs to find sports fields to hire and youth and elderly services provided by our parish are oversubscribed. Taking into account that Tattenhoe Park which has outline planning permission for almost another 2,000 properties still has to be built, also directly abutting the A421 it is impossible to see how further development straddling the county border should even be considered.

The infrastructure for any development would need to be in place as soon as the first residents moved in as they could certainly not be accommodated across the border in Milton Keynes. This coupled with the transport problems leads us to object most strongly to this development going ahead.

A2.3 West Bletchley Council West Bletchley Council, having reviewed the amended proposal, reaffirms its formal OBJECTION to these planning applications. The objection relates to both the principle of development and detail of the proposals; the particular reasons include the following:

1. The principle of a development at the site is not supported by any adopted development plan or supplementary planning document; 2. The proposed development would place an unacceptable burden on the transport infrastructure; 3. The proposed grid road that would follow the route of a known gas main is not shown to be technically viable nor that such a proposal does not represent a health and safety risk to existing / future residents or users of the road; 4. The proposal would result in the loss of a significant amount of best and most versatile agricultural land; 5. Unreasonable draft Heads of Terms that do not reflect the way a real world timetable operates nor does it allow sufficient flexibility to account for an uncertain commercial market; 6. The impact on local services; 7. The location of the proposed allotments; 8. The adverse visual impact and poor mix of house-type; 9. The proposed inclusion of open space within the site of the proposed secondary school.

The objections that are summarised above are explained in more detail below and for your convenience use the same numbering.

1. It is acknowledged that the application site and the principle of the proposed development were being considered and advanced in past adopted and draft development plans, and the MK Core Strategy accepts that a development in this location may be forthcoming. However, there is no up-to- date development plan that allocates the site for future development or even confirms it is in principle acceptable. Indeed there is no draft plan that identifies the site as a potential or preferred allocation.

Paragraph 2.24 of the applicant’s Planning Statement (re: application 15/00314/AOP) states the withdrawn Draft VAP should be afforded no weight, therefore the revoked, superseded or un-adopted development plans and Technical Studies that were not subject to public consultation or scrutiny at Inquiry that previously advocated the possibility of a development at the application site, should be similarly afforded no weight. The site should not therefore be considered to be one where the principle of development has been established and agreed.

2. West Bletchley Council maintains that the proposed development would place an unacceptable burden on the transport infrastructure. The Council is in the process of commissioning transport consultants to undertake further evaluation of the new transport data provided and reserves the right to submit further information in support of its objection.

3. The application proposes that the land that follows the route of an intermediate pressure gas main shall be reserved for the potential future grid road. It is unclear whether the presence of the gas main means the construction of a grid road is viable. West Bletchley Council would like a standing objection to be noted unless the applicant can demonstrate with technical detail, which is independently verified, that the proposal does not pose unacceptable risk to health and safety. As a minimum the detailed construction methodology for the grid road and the necessary safety precautions relating to the gas main should be submitted and agreed in advance of the application being determined.

4. A further standing objection relates to the fact that the proposal will result in the loss of a significant amount of ‘best and most versatile agricultural land’ (BMVAL). Irrespective of the fact, there is confusion within the application documents concerning the amount of BMVAL that will be lost - dependent on which part of the application documents you trust as being accurate, it is said the proposal will result in the loss of either 16 hectares OR nearly 20 hectares BMVAL, which equates to 11% of the application site (excluding that forming the proposed means of access) OR approximately one-seventh of the total application site, therefore it remains a matter that AVDC should seek to clarify - this is not an insignificant amount of high quality agricultural land that would be permanently lost. This planning application should not override the intentions of designating such land as BMVAL; it is a finite resource and once lost it cannot be replaced and the application therefore should be refused. West Bletchley Council does not infer it would support an amended proposal, however, unless the BMVAL can be shown to be protected, this particular standing objection will remain in place.

In respect to the impact on agricultural land the application includes somewhat arbitrary “Impact Magnitude Definitions” (Table 6.1 of the Environment Statement), which it says have been produced following discussions with “other agricultural consultants and officers from the Department for the Environment, Food and Rural Affairs” (paragraph 6.10). It is unclear what form these discussions actually took nor the veracity or reasonableness of the arbitrary definitions. It is suggested that AVDC therefore must seek clarification from the applicant on this point so that the “impact magnitude” it assigns to the proposed loss of BMVAL can be independently judged, and, if necessary, a new set of criteria or weighting can be applied. The “impact magnitude” at the applicant’s Table 6.1 is dictated by the amount / area of BMVAL that would be lost and currently says there would only be a “slight negative” impact, but if the ‘amount’ thresholds were altered the impact grading could be amended up or down. Currently West Bletchley Council’s concern is that because the weighting has been decided arbitrarily by the applicant it is not surprising its Environment Statement states the impact would be so slight.

5. The Draft Heads of Terms must be revised to reflect the need for a greater period of marketing of the proposed employment area and neighbourhood centre before alternative uses are allowed to be considered. A prime example of why a longer period is required can be seen in the Oakgrove mixed-use but residential led development in Milton Keynes, where despite significant housing completions / occupations on site and a large amount of housing and affluent residents immediately adjoining (e.g. Middleton, Monkston, Monkston Park), numerous commercial units remain unoccupied. West Bletchley Council strongly opposes the Draft Heads of Terms, which it views as the applicant’s tactic to further maximise the profitability of the site and seek a residential use of the proposed commercial space, and all at the expense of local residents. The opportunity for local employment and community facilities could be lost due to the unreasonable and excessively short timescales being proposed by the applicant.

The units contained within the proposed Neighbourhood Centre should be protected from change of use in perpetuity unless it is proven any new use would serve the needs and/or interests of the new community. Far Bletchley is currently the urban / rural fringe of this part of Milton Keynes and is currently served by a very small solitary Neighbourhood Centre containing one shop. The proposed development would become the new urban / rural fringe and it would be that bit further away from Central Milton Keynes and the Bletchley District Centre, therefore, it is even more imperative to protect proposed services from changes of use that would adversely affect the sustainability of the development, whether in the short or long term.

On the topic of the Draft Heads of Terms it is currently unclear, and clarification is sought, to whom ownership and or responsibility for the management of the proposed community building will be transferred. Furthermore, is there to be funding towards the management and maintenance of the building for a period following final completion of the wider proposed development?

6. West Bletchley Council remains concerned that the development would place unnecessary and unsustainable stress on the existing infrastructure and services of both Milton Keynes and nearby settlements within Aylesbury Vale. This should be regarded as a priority issue for both Councils of Aylesbury Vale District and Milton Keynes, particularly as it is unclear as to the level and extent of monies that should be sought as a developer contribution and to whom it should be paid to address the inevitable additional demand and associated stress arising from an influx of new residents. The amendment to include provision for an 8GP Practice within the employment area creates further concern. Firstly in that this use is incorrectly defined as employment and secondly that the s106 Heads of Terms does not provide the timetable for delivery of it or protection of the allocated land from re-use should it not be delivered within the specified timeframe.

It is further noted that the applicant highlights that it proposes the allocation of the application site in the Vale of Aylesbury Local Plan (July 2016). The applicant, however, is notably silent in respect of the “provision of..police, fire and ambulance services and social care” which the emerging plan states should be delivered in such a development. 7. West Bletchley Council objects to the layout of the proposed development as illustrated in the submitted master plan. The proposed development is promoted by the applicant as one that is self-contained and sustainable however the location of the allotments remains in the northern corner of the application site, a considerable distance from the majority of future residents. It remains unclear what grading the agricultural land is for the current siting of the allotments, and that in addition to being centrally located and accessible to all future residents, it would be advantageous if it were located on Grade 3a “best and most versatile” land. It is noted that these points have not been addressed by the current revisions and that the allotment space has, in fact, been reduced, creating a further point of objection.

8. Paragraph 5.33 of the Design & Access Statement says the employment buildings would be a maximum of 12 metres. This is very tall for buildings that paragraph 5.10 of the same Statement states would be Class B1 and likely to comprise small ‘starter’ office units. In addition, paragraph 5.36 of the Design & Access Statement states the majority of residential dwellings will be up to 10 metres to ridge height, and it is likely that the majority of residential buildings will be largely 2 or 2.5 storeys in height. This again seems an excessive height for an area that would become the new urban / rural fringe of Milton Keynes. There is no precedent for such excessively tall residential buildings in this part of Milton Keynes or Aylesbury Vale. Not only does the proposed housing not reflect the rural hinterland location, but the suggested mix would not meet the needs of a wider community. Currently the size and height of the housing would seem to be directed towards the affluent and those with families.

The proposed housing to the South and West should generally be smaller in height and scale to reflect the transition to the countryside and Newton Longville. The proposal would see a development whose buildings do not reflect the character and appearance of the immediate and wider area and would result in significant adverse visual impact. Nor is the proposed mix of house types likely to result in a sustainable and balanced community.

We note new information included within the Design & Access Statement (page 32, Figure 5.10 and page 33, Figure 5.10a) and the Environment Statement – Non-Technical Summary (para. 5.17) relating to proposed wood land planting. Figures 5.10 and 5.10a indicate boundary planting will rise to 15 metres and that this will easily screen the houses that are shown to be 8 metres in height. Together they suggest views of the development from the direction of Whaddon Road and Newton Longville will be substantially screened, but one must first accept that this is based on an assumption that the trees will reach 15 metres in height and that the houses will be only 8 metres in height. However, we know that the application states that at the closest point to the West and South boundaries the houses will be up to 10 metres in height and within the site they will rise to 11 metres and this is significantly different to what has been shown visually. The application is largely in outline with matters of detailed design and layout reserved therefore it is wrong to attach too much weight to what has been shown in Figures 5.10 and 5.10a. Furthermore, one must also take account of the fact the assessed landscape impact (para. 5.17 of the Environment Statement – Non-Technical Summary) is 15 years after completion of the development, therefore, it will be many years before the trees provide effective screening of all the new buildings. One must also allow for time lag between the commencement of the development and its completion e.g. perhaps 5+ years (lifetime of the development) plus 15 years (after the development is complete). Taking account of the above we challenge the applicant’s statement that the landscape effects would be ‘moderate adverse’ and having consideration of the ‘banding’ at para. 2.18 of the Landscape & Visual Impact Assessment (LVIA) argue the contrary in that it is a significant “major” impact. Within the LVIA there are photographs that have been taken to represent ‘views’ in and around the application site. Those labelled A, B, C, H, K, L, M and O are the most pertinent. Many of them show largely undisturbed views of a landscape from Newton Longville involving a green horizon. The photos also reveal that the Far Bletchley housing in these distant views is largely invisible, due to a combination of distance and the well-established vegetated edge to this urban location. Closer views in the direction of Tattenhoe show how prominent the industrial buildings appear. Given the above, it is contended that the development of a large expanse of green fields / green buffer with buildings up to the maximum stated heights and in such relative close proximity to Newton Longville will have a deleterious impact on the landscape value for local people and those who use public footpaths and Whaddon Road. The landscape is considered to be of high ‘value’ to local people and its loss would harm their amenity. We cite, in support of this objection, appeal reference APP/J0405/A/14 /2219574 (Land East of A413 Buckingham Road and Watermead, Aylesbury), which was dismissed in part because of the harm that would be caused by a development of circa 1,500 dwellings to the setting and heritage of Bierton in Aylesbury Vale. It was decided that despite AVDC not having a 5 year Housing Land Supply the harm that would be caused did not outweigh the advantages of the proposal. The Secretary of State recovered the appeal and at paragraph 15 it is stated: “The Secretary of State agrees with the Inspector that Bierton is a village surrounded by countryside and not joined to Aylesbury and that the proposed development would cause Bierton to lose its separate identify (IR7.51). He further agrees that the proposed green infrastructure would effectively tie Watermead to Bierton and is likely to be perceived as a complementary element of the new housing development and as such be a further agent of coalescence (IR7.55).” We contend that the subject application would have a similar impact on and harm the setting of Newton Longville.

1. The Land Use Parameter Plan and para. 3.1 of the Environment Statement – Non-Technical Summary refer to the 1.69ha. of land that is now shown to be given to the proposed secondary school (the land is located between the west side of Far Bletchley and east boundary of the proposed school). On the Plan it is described as “Open Space” but it is green hatched and therefore different to the blue hatch of the school building and the solid blue of the remainder of its grounds. The Environment Statement – Non-Technical Summary (para. 3.1, 2nd bullet) states that the green hatched land is an ecological corridor and land affected by archaeological constraints. Taking the aforementioned into account we question what value this 1.69ha. of land will contribute to the proposed secondary school. If it is shown on the Land Use Parameter Plan in a different colour banding to the school then what is its practical purpose or value? Is the applicant simply trying to pass on the maintenance and financial liability of the 1.69ha. because it has no development value. This matter should be addressed. If it is to be separate to the school’s usable curtilage, but it is still expected to maintain the land, this should be reflected in the financial contribution negotiated as part of the S.106 agreement.

A2.4 Senior Urban Design Officer

Relationship and contextual ‘fit’ with Milton Keynes

1. It has reflected the Milton Keynes context by including a grid road reserve as an extension of the V1 as well as retained planting along the H8 2. The layout also protects the amenity of residents at the western end of Far Bletchley through the inclusion of buffer planting and school playing fields along the eastern boundary. The south eastern residential block (the only one to the east of the grid road reserve) furthermore is also of just 2 – 2.5 storey in height and low densities of 20-25dph which will minimise any impact on the adjacent Far Bletchley. 3. The extent of open space provided and its interconnected linear / corridor nature bears a close resemblance to the network of open spaces that permeate Milton Keynes. I believe the development will have a strong landscape character – typical of Milton Keynes 4. The internal ‘looping’ spine street (primary route) is similar to that which exists in many estates in MK e.g. Tattenhoe, Monkston, Shenley Brook End, Westcroft, Browns Wood etc 5. Proposed densities and building height are also appropriate in the context of adjacent Far Bletchley and Tattenhoe as well as the agreed densities and building heights for Tattenhoe Park

Other comments

6. Existing site features have been well used to help structure the entire development 7. The rural character of Whaddon Road is protected through extensive planting along the south western edge 8. The overall development is well integrated into the surrounding area with 3 proposed vehicular access points – this will help spread traffic flows into the surrounding network 9. The layout is legible with a clear street hierarchy dominated by the internal public transport loop 10. The location of the Neighbourhood centre, 2 schools and employment areas on the public transport focussed primary route is logical from an accessibility point of view 11. The location of the central east west aligned spine of open space along Weazel Lane is logical and supported. This location of open space will also protect views from the south (the Weazel Lane ridge won’t have houses on it and hence be visible from the south) 12. The disposition of densities is supported with highest densities along the public transport primary route and lowest densities towards the southern edges and adjacent to Far Bletchley being supported

In summary I have no objection on urban design grounds

A2.5 Passenger Transport

• Subject to detailed design and Road Safety Audit, Passenger Transport supports the approach identified for bus routing and stopping within the develop. • The routing proposed within the Mouchel report is not supported by MKC Passenger Transport. Services should be compliant with Table 6.1 (p39) of MKC's Bus Strategy (2008). • As with similar sized developments in Milton Keynes, the journey time into CMK should be less than 30 mins and as direct as possible. Service 8 is now split west of Westcroft and serves both Oxley Park to the north-west and the contracted service to Kingsmead South/Tattenhoe Park to the south-west, making this unviable. • Further investigation into a direct service is required, which MKC Passenger Transport would be happy to discuss.

A2.6 Housing Officer AVDC Affordable Housing Policy Interim Position Statement Jun 14. Relevant MKC Policies: Milton Keynes Council Local Plan Priority Housing Policy H2, Affordable Housing Policies H3-H5, Housing Mix Policy H9 Milton Keynes Core Strategy adopted July 2013 Policy CS10 Housing MKC Affordable Housing SPD March 2013

AVDC Affordable Housing Policy Interim Position Jun 14 – requires that 30% affordable housing is provided on sites of 25 or more dwellings or sites of 1ha or more. In the Planning Statement, the applicant is proposing up to 30% Affordable Housing subject to viability testing. Need clarification on the overall numbers – AVDC lists the proposal for up to 1885 dwellings while the applicant cites a maximum of 1855 dwellings - will give 30% Affordable Housing requirement as either 566 dwellings or 557 dwellings. MKC Affordable Housing SPD 2013 requires 30% Affordable Housing on new residential developments of 15 or more dwellings - the tenure mix should be 25% Affordable Rent (5% at broadly equivalent Social Rent levels) and 5% Shared Ownership. There is a shortage of Affordable Housing for Rent in Milton Keynes and the Council had 91 households in B & B accommodation at 11 March 2015.

A2.7 Development Plans

Relevant planning policies within this Council’s Core Strategy to evaluate and assess this proposal [to be determined by Aylesbury Vale District Council (AVDC)] are policy CS11 dealing with transport but mostly Core Strategy policy CS6 (Place-shaping Principles for Sustainable Urban Extensions in Adjacent Local Authorities). To assess the suitability of this proposal you should compare the criteria of this policy (a table may be useful) against the specific details of this proposal.

At a Council meeting on 25th March 2015 Milton Keynes Council (MKC) objected to the earlier Salden Chase proposal and highlighted the potential impact of that development on city infrastructure and services.

Public consultation on the draft Vale of Aylesbury Local Plan (VALP) which identifies this site for potential development closed on the 5 September 2016. Draft VALP policy D3 (Delivering Sites adjacent to Milton Keynes) envisages this site being developed in accordance with a Master Plan and other guidance produced by AVDC and requiring the provision of the services, infrastructure and facilities necessary for it.

MKC believes that if AVDC decide through the VALP that this site should be developed then joint working by this Council with AVDC on a Master Plan and other guidance for this site is more likely to achieve a high quality development than approving this planning application.

Additionally, it would be premature for AVDC to approve this outline application before AVDC have had an opportunity to consider representations on the VALP including this Council’s representations and before any specific concerns that this Council has about the impact and effects of this development on wider city infrastructure and facilities have been addressed

Notwithstanding the strong arguments that this Council advances for this planning application not being approved ahead of the draft VALP. If AVDC approves this application, AVDC and any other relevant organisation should assure themselves that:-

Any infrastructure proposed within this development is provided

That the infrastructure provided within the proposal is not only sufficient to cater for the needs generated by this development but that it is future proofed so if future residential development occurs, infrastructure and facilities could be expanded to cope with increased demand.

This development should not sterilise broader long term development options for Milton Keynes

This development should not prejudice the future provision of strategic infrastructure. E.g. The East –West Rail proposal adjoining this site or the National Infrastructure Commission’s work on the proposed Express Way between Oxford, Milton Keynes and Cambridge.

Any effect on the wider city resulting from this development should be mitigated.

Finally, if AVDC approve this application AVDC should work with this Council to explore how the development may benefit the city. For example would any affordable housing provided within this development be available to help address the lack of affordable dwellings and homelessness problems within the city.

A2.8 Network Rail Network Rail has no objection in principle to the above – but due to the proposal being next to Network Rail land and critical railway infrastructure, Network Rail would wish to see specific reference made to the topics covered by our consultation response in the decision notice. Network Rail has a statutory obligation of ensure the availability of safe train paths and as such we are required to take an active interest in any development adjacent to our infrastructure that potentially could affect the safe operation of the railway.

When designing proposals, the developer and LPA are advised, that any measurements must be taken from the operational railway / Network Rail boundary and not from the railway tracks themselves. From any existing railway tracks themselves to the Network Rail boundary fence, will include critical infrastructure (e.g. cables, signals, overhead lines, communication equipment etc) and boundary treatments which might be adversely impacted by third party proposals unless the necessary asset protection measures are undertaken. No proposal should increase Network Rail’s liability.

The developer/applicant must ensure that their proposal, both during construction, after completion of works on site and as a permanent arrangement, does not affect the safety, operation or integrity of the operational railway / Network Rail land and our infrastructure. The works on site must not undermine or damage or adversely impact any railway land and structures. There must be no physical encroachment of the proposal onto Network Rail land, no over- sailing into Network Rail air-space and no encroachment of foundations onto Network Rail land and boundary treatments. Any future maintenance must be conducted solely within the applicant’s land ownership.

(1) The developer docs state: “5.6 The southern boundary of the site is defined by a disused railway line that lies on a well-treed embankment.” The existing railway line to the southern boundary is the (OXD) Oxford Branch (Oxford to Bletchley) and is land in Network Rail ownership. It is also part of the East-West Rail Phase 2 proposals.

Whilst the dwellings are set back from the railway line the developer is proposing to include (as shown on the masterplan) six attenuation ponds adjacnet to or in close proximity to the railway line.

Network Rail will need to be satisfied that the proposed attenuation ponds will not import an increased risk to our operational infrastructure. At this stage Network Rail cannot support the layout and design of the attenuation ponds due to these concerns. Before the LPA consider issuing any planning consent the developer will need to directly contact Network Rail to discuss the surface water attenuation drainage works and the works will need to be agreed with Network Rail.

If the developer and the LPA insists on a sustainable drainage and flooding system then the issue and responsibility of flooding and water saturation should not be passed onto Network Rail and our land. The NPPF states that, “103. When determining planning applications, local planning authorities should ensure flood risk is not increased elsewhere,” We recognise that councils are looking to proposals that are sustainable, however, we would remind the council in regards to this proposal in relation to the flooding, drainage, surface and foul water management risk that it should not increase the risk of flooding, water saturation, pollution and drainage issues ‘elsewhere’, i.e. on to Network Rail land.

The developer will need to provide the following information regarding the sustainable drainage on site, which will need to be agreed with Network Rail before any construction commences in this matter:

• Network Rail will not accept liability for water from the proposal area draining towards the railway. • Network Rail requires details of the excavation works of the ponds as this represents a change in ground levels adjacent to the existing operational railway. • The applicant will need to supply details of the construction methodology of the ponds. • Details of who will maintain the ponds once they have been installed. • Details of what mitigation methods are to be included within the ponds construction to prevent water flowing down in the direction of the railway or seeping into the ground. Water must not drain in the direction of the operational railway boundary. • Network Rail is concerned by the ponds proximity to our boundary and we would need reassurance that the ponds will not seep water into the soil resulting in the risk of flooding, soil slippage, pollution being imported onto Network Rail land.

Network Rail would need to be informed of and agree to any alterations to ground levels, de-watering or ground stabilisation and we would need to agree the works on site to ensure that there is no impact upon critical railway infrastructure.

Network Rail also has three culverts registered along the affected length, all of which are “unlocated”. Network Rail will need to understand where the water from the attenuation ponds is draining to.

In the first instance the developer is asked to contact [email protected].

(2) A BAPA (Basic Asset Protection Agreement) will need to be agreed between the developer and Network Rail. The developer will be liable for all costs incurred by Network Rail in facilitating this proposal, including any railway site safety costs, possession costs, asset protection costs / presence, site visits, review and agreement of proposal documents and any buried services searches. The BAPA will be in addition to any planning consent.

The applicant / developer should liaise directly with Asset Protection to set up the BAPA.

For major works / large scale developments an Asset Protection Agreement will be required with further specific requirements. [email protected]

(3) The developer is to submit directly to Network Rail a Risk Assessment and Method Statement (RAMS) for all works to be undertaken within 10m of the operational railway. Network Rail would need to be assured the works on site follow safe methods of working and have taken into consideration any potential impact on Network Rail land and operational railway infrastructure. Review and agreement of the RAMS will be undertaken once a BAPA has been set up between Network Rail and the applicant/developer. The applicant /developer is to submit the RAMs directly to: [email protected]

(4) Any landscaping along the existing railway boundary should be undertaken with regard to the attached Network Rail vegetation planting matrix.

We would draw the council’s and developer’s attention to the Department of Transport’s ‘Transport Resilience Review: A Review of the Resilience of the Transport Network to Extreme Weather Events’ July 2014, which states, “On the railways, trees blown over in the storms caused severe disruption and damage on a number of routes and a number of days, particularly after the St Jude's storm on 28th October, and embankment slips triggered by the intense rainfall resulted in several lines being closed or disrupted for many days…… 6.29 Finally the problem of trees being blown over onto the railway is not confined to those on Network Rail land. Network Rail estimate that over 60% of the trees blown over last winter were from outside Network Rail's boundary. This is a much bigger problem for railways than it is for the strategic highway network, because most railway lines have a narrow footprint as a result of the original constructors wishing to minimise land take and keep the costs of land acquisition at a minimum.”

Network Rail has a duty to provide, as far as is reasonably practical, a railway free from danger or obstruction from fallen trees. Trees growing within the railway corridor (i.e. between the railway boundary fences) are the responsibility of Network Rail. Trees growing alongside the railway boundary on adjacent land are the primary responsibility of the adjoining landowner or occupier. All owners of trees have an obligation in law to manage trees on their property so that they do not cause a danger or a nuisance to their neighbours. This Duty of Care arises from the Occupiers Liability Acts of 1957 and 1984. A landowner or occupier must make sure that their trees are in a safe condition and mitigate any risk to a third party. Larger landowners should also have a tree policy to assess and manage the risk and to mitigate their liability.

(5) The proposal area is currently agricultural land/fields. The proposal represents a change of use of the land.

If not already in place, the developer must provide, at their own expense, a suitable trespass proof steel palisade fence of at least 1.8m in height adjacent to Network Rail’s boundary and make provision for its future maintenance and renewal without encroachment upon or over-sailing of Network Rail land. Network Rail’s existing fencing / wall must not be removed or damaged and at no point either during construction or after works are completed on site should the foundations of the fencing or wall or any embankment therein be damaged, undermined or compromised in any way. Any vegetation on Network Rail land and within Network Rail’s boundary must not be disturbed. Any fencing installed by the applicant must not prevent Network Rail from maintaining its own fencing/boundary treatment.

Any existing Network Rail fencing at the site has been erected to take account of the risk posed at the time the fencing was erected and not to take into account any presumed future use of the site, where increased numbers of people and minors may be using the areas adjacent to the operational railway. Therefore, any proposed residential development imports a risk of trespass onto the railway, which we would remind the council, is a criminal offence (s55 British Transport Commission Act 1949). As the applicant has chosen to develop a proposal next to the railway, they are requested to provide a suitable trespass proof fence to mitigate any risks imported by the proposal.

Network Rail is a publicly funded body and it would not be reasonable to require Network Rail to fund boundary works, fencing and boundary enhancements necessitated by third party commercial development adjacent to the railway.

Network Rail’s Asset Protection Engineer will need to review the fencing to ensure that no works to the foundations undermine or destabilise Network Rail land, or encroach onto Network Rail land.

The applicant is reminded that any works close to the Network Rail boundary, and any excavation works are also covered by the Party Wall Act of 1996. Should any foundations, any excavations or any part of the building encroachment onto Network Rail land then the applicant would need to serve notice on Network Rail and they would be liable for costs. An applicant cannot access Network Rail land without permission (via the Asset Protection Team) and in addition to any costs under the Party Wall Act, the applicant would also be liable for all Network Rail site supervision costs whilst works are undertaken. No works in these circumstances are to commence without the agreement of the Network Rail Asset Protection Engineer.

We would request a condition is included in the planning consent as follows: “Prior to occupation of the dwellings the developer is to provide a suitable trespass proof fence adjacent to the boundary with the railway.” Reason: To protect the adjacent railway from unauthorised access

Should the council obviate Network Rail’s request for a trespass proof fence and decide that an acoustic fence is more suitable then we would have the following comments.

Acoustic fencing / close boarded fencing that is proposed to be installed along the boundary with Network Rail is a cause for concern. Therefore the acoustic fence and its foundation design would be subject to the Network Rail Asset Protection Engineer review. Any acoustic fencing should be set back from the railway boundary such that the fence and its foundations can be constructed and maintained wholly within the applicant’s land ownership footprint.

Over the height of 1.8m, Network Rail would have to consider the impacts of wind loading on the fence. There is the potential for the fence to topple over and fall onto or towards the operational railway and damage Network Rail’s existing boundary treatments, safety critical lineside equipment as well as the issue of falling into the path of trains using the line. De-stabilisation of land, soil slippage and railway fencing foundations being undermined should also be considered as potential areas impacted by a high acoustic fence.

We would request a condition is included in the planning consent as follows: Condition: “Prior to the commencement of the development, acoustic fencing mitigation measures shall be submitted to the Local Planning Authority and Network Rail.” Reason: To protect the adjacent railway boundary.

(6) 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.

To note are: • The current level of railway usage may be subject to change at any time without prior notification including increased frequency of trains, night time train running, heavy freight trains, trains run at weekends /bank holidays. • Maintenance works to trains could be undertaken at night and may mean leaving the trains’ motors running which can lead to increased levels of noise and vibration. • Network Rail also often carry out works at night on the operational railway when normal rail traffic is suspended and often these works can be noisy and cause vibration. • Network Rail may need to conduct emergency works on the existing operational railway line and equipment which may not be notified to residents in advance due to their safety critical nature, and may occur at any time of the day or night, during bank holidays and at weekends. • Works to the existing operational railway may include the presence of plant and machinery as well as vehicles and personnel for project or emergency works. • The proposal should not prevent Network Rail from its statutory undertaking. Network Rail is a track authority. It may authorise the use of the track by train operating companies or independent railway operators, and may be compelled to give such authorisation. Its ability to respond to any enquiries regarding intended future use is therefore limited. • The scope and duration of any Noise and Vibration Assessments may only reflect the levels of railway usage at the time of the survey. • Any assessments required as a part of CDM (Construction Design Management) or local planning authority planning applications validations process are between the developer and their appointed contractor. • Network Rail cannot advise third parties on specific noise and vibration mitigation measures. Such measures will need to be agreed between the developer, their approved acoustic contractor and the local planning authority. • Design and layout of proposals should take into consideration and mitigate against existing usage of the operational railway and any future increase in usage of the said existing operational railway. • Works may be carried out to electrify railway lines and this could create noise and vibration for the time works are in progress. • Railway land which is owned by Network Rail but which may be deemed to be ‘disused ‘ or ‘mothballed’, may be brought back into use. Any proposals for residential development should include mitigation measures agreed between the developer, their acoustic contractor and the LPA to mitigate against future impacts of noise and vibration, based on the premise that the railway line may be brought back into use.

(7) 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. • All works shall only be carried out in accordance with the method statement and the works will be reviewed by Network Rail. The Network Rail Asset Protection Engineer will need to review such works in order to determine the type of soil (e.g. sand, rock) that the works are being carried out upon and also to determine the level of vibration that will occur as a result of the piling. • The impact upon the railway is dependent upon the distance from the railway boundary of the piling equipment, the type of soil the development is being constructed upon and the level of vibration. Each proposal is therefore different and thence the need for Network Rail to review the piling details / method statement. Maximum allowable levels of vibration - CFA piling is preferred as this tends to give rise to less vibration. Excessive vibration caused by piling can damage railway structures and cause movement to the railway track as a result of the consolidation of track ballast. The developer must demonstrate that the vibration does not exceed a peak particle velocity of 5mm/s at any structure or with respect to the rail track.

(8) All roads, paths or ways providing access to any part of the railway undertaker's land both temporary and permanent, shall be kept open at all times (24/7, 365 – around the clock) during and after the development. • The proposal must not encroach onto any Network Rail access road, paths or ways of access to any part of Network Rail land. This also includes emergency vehicles ability to access and exit Network Rail land. • The applicant is reminded that each Network Rail has a specific right of way and as such any developer is requested to contact the Network Rail Operational Property Services Team to discuss the impact of the proposal upon our access.

(9) Where a proposal calls for the following adjacent to the boundary with the operational railway or running parallel to the operational railway: • Hard standing areas • Turning Circles • Roads, public highways to facilitate access and egress from developments Network Rail would very strongly recommend the installation of suitable high kerbs or crash barriers (e.g. Armco Safety Barriers).

This is to prevent vehicle incursion from private land and public rights of way impacting upon the safe operation of the railway.

We would draw the LPA and developer’s attention to the Department of Transport’s, ‘Managing the accidental obstruction of the railway by road vehicles,’ (2003) for reference. The developer is advised to provide a risk assessment (RVI) to determine what protection should be given to the railway and its boundary as a result of placing roads, parking spaces or turning circles adjacent to railway land.

The Road Vehicle Incursion (RVI) Risk should be considered by the developer in conjunction with the LPA and the Highways team. A risk assessment will provide a clear framework for any mitigation measures necessary when constructing a proposal that includes vehicle parking or vehicle movements adjacent to the railway.

A2.9 Countryside Officer The provision of more information, regarding landscaping in the Design & Access Addendum that includes provision for the creation of ‘ecology links’ is welcome. However, more information will need to be provided regarding the ecological quality of proposed new habitats, such as that proposed in Fig 5.10 where the woodland planting includes, just ‘Woodland Mix and Woodland Edge Mix’.

Information on proposed species will need to be provided, regarding trees, shrubs and ground flora, including seed, plug planting a bulb mixes. Similar information will need to be supplied regarding other woodland planting areas, proposed areas of orchard and wetland features including SUDS. These will need to relate positively to the Natural Environment Partnership ‘Forward to 2020’ Buckinghamshire and Milton Keynes Biodiversity Action Plan; Table 1. Priority habitat creation and restoration targets for Buckinghamshire and Milton Keynes from 2010 – 2020 and also NPPF paragraph 117 promote the preservation, restoration and re-creation of priority habitats . . .

The applicant will need to show how the proposed development will not result in biodiversity losses by using DEFRA Impact Assessment Biodiversity Calculator methodology http://heritage.warwickshire.gov.uk/files/2013/06/Guidance-for- Biodiversity-Impact-Assessment-calculator-v18.pdf to inform avoidance, mitigation and compensation actions that will ensure compliance with NPPF policies.

New biodiversity assets will need to be sustainable in the long term, having sustainable long term funded management strategies.

Sustainable new biodiversity assets, will also need to include built into buildings assets, specifically bat and bird boxes and Hedgehog passes between gardens.

Along with sustainability regarding management, new areas of Green Infrastructure that include biodiversity assets will need to be sustainable regarding their long term existence. The question has to be asked, regarding some of these areas, for example the southwestern woodland strip, located adjacent to the Whaddon Road.

Will future development to the southwest, require the widening of the Whaddon Road into that woodland strip?

Is this green infrastructure feature, sustainable within the context of a larger area wide urbanisation?

An additional question would be; how can large scale piecemeal development of the area to the southwest of Milton Keynes, include substantial areas of strategic Green Infrastructure, including a ‘country park’ that will contribute to a high quality environment, for the areas new residents?

More information will need to be provided regarding the ecological quality of proposed new habitats and built into buildings biodiversity assets, including bat and bird boxes.

The applicant will need to show how the proposed development will not result in biodiversity losses to ensure compliance with the NPPF.

New biodiversity assets will need to be sustainable in the long term and have sustainable long term management strategies.

A2.10 Education Sufficiency I believe AVDC are out for consultation at the moment. I understand that there will be a coordinated response from the LA and Paul had asked me to pick up my previous comments regarding education provision. Please can I ask for the below to be incorporated in such a response:

I have reviewed the areas that this development borders and considered the impact on existing educational provision in Milton Keynes. In regards to early years this development predominantly borders The Little Owls children’s centre reach area and the Daisy Chain children’s centre reach area. Our setting place planning framework projects a shortfall of free early education provision in both of these areas, and this is supported by high occupancy rates within sessional and full day care provision in these areas. Additional development on the borders of these reach areas would therefore place additional pressure on existing Milton Keynes places. We would therefore request that early years provision was considered as part of this development.

In relation to school places I note there is a plan to deliver a 3FE primary on this site. This is calculated using a lower planning model than Milton Keynes. Bucks may want to reconsider whether this development will respond differently to their traditional model as we would project closer to a 4FE rather than a 3FE at primary based on the size of the development.

A2.12 Highways Development Control

This response primarily relates to the MKC application 15/00619/FUL; however, some of the comments made will assist the MKC response to AVDC for application 16/02515/CONS.

The MKC application is solely for approval of the accesses to facilitate the development on land in Aylesbury Vale. Two vehicular accesses are proposed within the MKC administrative area; one being a left-in only access from the A421, the other is a new roundabout junction on Buckingham Road. (A third vehicular access is proposed to Whaddon Road within Aylesbury Vale.)

The planning application is accompanied by a Transport Assessment (TA) and a Travel Plan (TP). The TA has been revised and resubmitted. A review of the revised TA is provided as an appendix to this response. It is understood that the Council’s transport team has reviewed the TP.

It is understood that the AVDC application is Outline with all matters, except access, reserved for subsequent approval. In addition, matters such as the internal site layout and car parking standards will be for AVDC to determine. As a result, this response does not include comments on those issues. However, given that the site is essentially an extension to Milton Keynes it is highly advisable to integrate infrastructure such as Redways with MKC’s normal standards. This should from part of the response to AVDC.

Summary of TA review The revised Transport Assessment sets out the amended access strategy and reflects recent discussions related to the assessment of traffic impacts and transportation issues.

The methodology used within the TA is considered acceptable and the TA is deemed to be sufficiently robust for assessing local transport impacts. Sustainable modes have been considered as part of the assessment as has the use of Travel Planning techniques.

The assessment of traffic impacts resulted in the testing of 12 key junctions within Milton Keynes. Of those 12, 3 junctions were shown to have material impacts in terms of additional queuing and/or delays. Improvements to those 3 junctions have been proposed and cost estimates are awaited at the time of writing this response.

The TA concludes that there are no severe impacts as a result of the proposed development and that therefore the proposals should not be refused on highway and transport grounds. On technical grounds it would be difficult to disagree with this conclusion, subject to securing the following: Funding for the mitigation works at the junctions (costs yet to be agreed) New / additional public transport improvements and funding Full implementation of the Travel Plan

The TA review notes that the two access points within MKC are to the required design standard, have been subject to Road Safety Audit and the modelling shows that they will operate within capacity.

Access Strategy As referred to above, the site is to be served by 3 points of vehicular access, from Buckingham Road, Whaddon Road and the A421 (Standing Way). The access from Standing way is left-in only i.e. there is no exit onto the A421, nor is there an entry from the northern (eastbound) carriageway. This limitation is as a result of the proximity of the access to the underpass structure and resulting Safety Audit concerns.

While this restriction may seem significant the revised TA has assessed the impacts and concludes that they are not material. The revised access proposals do not impact on proposed public transport provision.

Dedicated cycle and pedestrian access into the north and northeast of the site is provided via Weasel Lane and a single connection to the Redway running along the northern boundary of the site. This is not ideal as it is unlikely to reflect the desire line of pedestrians and cyclists and does not minimise walking and cycling distances to the rest of MK. Furthermore, access to/from the employment area and neighbourhood centre is lengthy and tortuous as a result.

An additional direct Redway link should be provided between the A421 Redway crossing of Buckingham Road and the employment area / neighbourhood centre. Not providing this link is likely to result in cyclists using the road infrastructure instead.

Comments for AVDC Application (16/02515/CONS) In general, the street layout is acceptable in transport terms. Optimising public transport usage and cycling / walking requires the highest densities of development to adjoin these routes as well as local facilities and schools. This does not appear to be achieved throughout the site.

The secondary school is located to the east of the ‘grid’ road reserve, whereas the remaining development is located to the west. Whilst school catchments are flexible and pupils will not be limited to those in the new dwellings, it is disappointing that this is proposed. In the future the implementation of any upgrade to the road provision this reserve is intended to allow could be significantly hampered by the need to provide safe crossing(s) to the school.

The Masterplan relies on Weasel Lane and its crossing of the new ‘grid’ road to provide non-vehicular access to the Secondary School. This crossing needs to be controlled and Weasel Lane needs to be provided with improved surfacing and street lighting. (it is not clear whether Sustrans has been consulted, but they should be contacted as Weasel Lane forms part of their national network).

Section 106 and Conditions It is assumed that there will be a section 106 agreement associated with this application (15/00619/FUL) and that this agreement will secure funding for the highway improvements that are proposed in Milton Keynes.

The s.106 should also cover Redway provision and connections as referred to above (namely connections to the A421 Redway, the old A421 itself and the new link to Buckingham Road). These connections will require improvements to surfacing, lighting and signage amongst other things.

Phasing and timing of infrastructure provision should also be covered either by condition or on the section 106 agreement. The approval of this needs to ensure that cycling and walking infrastructure is provided in advance of each area of development being occupied.

The access works and some parts of the Redway connections will need to be covered by an agreement under Section 278 of the Highways Act; this can be referenced in the s.106.

Conditions should also be imposed for the following: 1. Creation of any temporary accesses to site compounds / storage yards and any construction accesses. Details should be submitted and approved prior to commencement. 2. Construction of the A421 and Buckingham Road accesses. Details to be submitted and approved prior to commencement.

Conclusion The TA has demonstrated that the development (in AVDC) is able to be accommodated on the highway network. Improvements to junctions within Milton Keynes are proposed and, subject to agreeing a financial contribution, appear acceptable to mitigate the development.

The two accesses proposed within Milton Keynes have been tested and have been Safety Audited. The accesses are deemed to be acceptable.

Proposals for public transport and connections to the walking and cycling networks are acceptable but their implementation needs to be secured.

A section 106 agreement and conditions are required to ensure that appropriate highway works are carried out at the right time and to the right standards. A Section 278 agreement will ultimately cover the works within the public highway.

Consequently there is no highway objection to this application subject to securing the works, improvements and funding referred to.

TRANSPORT ASSESSMENT REVIEW

SOUTH WEST MILTON KEYNES REVIEW OF UPDATED TRANSPORT ASSESSMENT

OVERVIEW

In February 2015 a planning application was submitted for a mixed use urban extension on land to the south west of Milton Keynes (reference 15/00223/CONS). This application was accompanied by a Transport Assessment which was deficient in a number of ways. Since that time a new Transport Consultant (Mouchel) has taken over the transportation elements of the application and there have been detailed discussions ongoing over a number of months on the transport related issues between the main parties. (At the same time other aspects of the application have been similarly discussed by the applicant and relevant officers.) As a result of all these discussions a new application (16/0215/CONS) was validated in August 2016. This new application is expected to take on board the results of the various discussions and as part of the application an updated Transport Assessment has been submitted. A Travel Plan also accompanies the application. The purpose of this note is to provide comments on the application and the updated Transport Assessment. It is not the formal Consultee Response which will follow shortly.

THE APPLICATION

Briefly the application is all matters reserved except for access for a mixed use urban extension on land to the south west of Milton Keynes. It will provide: i) Up to 1855 dwellings. ii) Employment area. iii) Neighbourhood centre including retail. iv) Primary and secondary school. v) Grid road reserve. vi) Green space. vii) Three vehicular access points. viii) Improved public transport provision. ix) Connections to the local pedestrian and cycle routes.

It is relevant to note that the majority of the site is in Aylesbury Vale who will therefore be the Local Planning Authority for determining the main planning application. However, two of the three vehicular access points are in Milton Keynes and so their suitability is for Milton Keynes Council to decide. In addition of course, Milton Keynes Council is a key consultee on the impacts of the development, including transport, in Milton Keynes. Because of this the ongoing discussions on transport matters have involved close co-operation and discussion between Stirling Maynard Transportation (SMT) as the Council’s Transport Advisors on this application, Officers at Buckinghamshire County Council as the Highway Authority in Aylesbury Vale and Jacobs as Buckinghamshire County Council’s Transport Consultant.

Each of the main transport areas will be discussed briefly in turn below:

Sustainable Travel

It is relevant to note at this point that a Travel Plan has been submitted with the application. Review of this document is outside SMT’s brief and has been reviewed by Officers within Milton Keynes Council. It is understood they were happy with the Travel Plan submitted with the 2015 application.

Walk/Cycle

Pedestrian infrastructure within the development will be for reserved matters but an illustrative Masterplan has been provided and the Transport Assessment states a commitment to the provision for high quality infrastructure. Key links include:

A connection with the existing redway on the northern side of A421 Standing Way as well as other recreational routes, and via the existing pedestrian/cycle route running along the line of the old Buckingham Road route south of the current A21 dual carriageway:

across A421 close to Bottle Dump Roundabout via the existing subway; across A421 to Snelshall West via the existing subway; and via Tattenhoe Roundabout.

A connection to the existing redway network via a new pedestrian/cyclist/equestrian route along Whaddon Road, including a new ‘Pegasus’ combined crossing to the south of Bottle Dump Roundabout and the access to Pearce Recycling.

To Buckingham Road, approximately 600 metres to the south of Tattenhoe Roundabout, via NCR 51 on Weasel Lane, and via a new access to the site between this point and Tattenhoe Roundabout.

To Hamilton Lane, Far Bletchley, on the eastern boundary of the site, via cycleway/footway.

At four locations to the south and west of the site, via existing bridleways/footpaths NLO/19, MUR/15, WHA/15 and WHA/16.

Public Transport

Ongoing discussions have taken place between the applicant and Arriva. The current proposals are to extend the 8 Service and an indicative route has been shown in the Transport Assessment (Figure 5.1 Page 63). The details are yet to be finalised but it is envisaged that three buses per hour will serve the application site and three will serve Oxley Park. Six additional buses will be required for which the Transport Assessment states three will be developer funded, 1.5 by the application site and 1.5 by the Oxley Park development. It is understood the Public Transport sections of Milton Keynes Council will scrutinise these proposals so no more detailed comment is passed here other than to observe that three buses an hour would be a reasonable level of service. It is of course important that funding to secure the routes is in place.

The Transport Assessment places great emphasis on Travel Demand Management. As previously stated, the Travel Plan is outside the scope of this note but it is relevant to observe that, notwithstanding the proposed new pedestrian and cycle infrastructure and the improved public transport provision together with a reasonable level of day-to-day facilities actually on the site, this is still a large development on the edge of Milton Keynes.

Traffic Impact

Access

There are three vehicular points of access, namely: Whaddon Road Buckingham Road A421 Standing Way

This is as the original application and has been consistent throughout the discussions but the detail of the access points has evolved over time.

The proposed access at Whaddon Road is the one outside Milton Keynes Council and in Aylesbury Vale. The proposed junction is a priority junction with a ghosted right turn with a single lane minor road approach with a long flare to two lanes. Detailed drawings have been provided. The final design as proposed follows a Road Safety Audit and comment by Buckinghamshire County Council resulting in extending the length of the ghost island reservoir. Visibility to Buckinghamshire County Council’s required standards is provided.

The A421 is a left in only junction allowing access to the development from A421 westbound only and no exit for traffic leaving the site. A left in / left out junction was planned in the original application but this has been amended following concern over weaving and merging traffic on the A421. The deceleration lane as proposed meets the standards of DMRB (the Design Manual for Roads and Bridges). Safety barriers have been included in the design following comment in the Road Safety Audit. The design does not compromise the location of the adjacent underpass which connects pedestrian and cycle routes with the redway on the north side of the A421.

The original application proposed a complicated gyratory arrangement for the access onto Buckingham Road which was signalised. Both Milton Keynes Council and Buckinghamshire County Council expressed concern about the over complication of this junction and the provision of signals in the area. The new proposal is for an at grade roundabout providing a much more conventional type of junction. The junction provides two new roads from within the site, minimum amendments to the alignment of Buckingham Road, retains the existing redway on the northern side of Buckingham Road and provides a new ‘Toucan’ crossing for pedestrians/cyclists on the western arm between the new roundabout and the A421 and a second new Toucan Crossing where the new road crosses Weasel Lane. The junction does not compromise the Grid Road reserve corridor as the junction could be amended if a major link along this corridor were ever to come forward.

Road Safety Audits with Designer’s Response are submitted for all three access points and capacity tests show there is sufficient traffic capacity at each to accommodate the predicted level of traffic.

Traffic Impact

Capacity analysis of the impact of the proposals clearly has to cover roads in Milton Keynes and Aylesbury Vale and in this case the approach to the two Authority areas is different.

Within Milton Keynes the analysis is based on the Milton Keynes Traffic Model. This forecasts traffic flows on the network for 2031 assuming all the planned development takes place. Whilst the use of a traffic model for detailed analysis must be treated with caution, in the case of Milton Keynes with its extensive plans for growth in identified areas, there is no real alternative for a robust analysis. It was therefore agreed at an early stage that the model would form the basis for the traffic impact analysis.

For the roads in Aylesbury Vale, principally the A421 to the west, the traffic model is less robust as the model was specifically produced to model the urban area of Milton Keynes. Buckinghamshire County Council therefore requested a more traditional approach to the testing of their junctions based on traffic counts and TEMPRO growth factors to establish forecast base traffic flows.

For Milton Keynes the model was run for 2031 planned development and then again with the proposed development in place. In the first place the access points were tested and it was confirmed they would all operate within their theoretical capacity.

In original scoping discussions in late 2013, a total of 14 junctions were identified as worth testing for impact from the development, namely:

Whaddon Crossroads (in Buckinghamshire) Bottle Dump Roundabout (in Buckinghamshire) Tattenhoe Roundabout Kingsmead Roundabout Westcroft Roundabout Windmill Hill Roundabout Emerson Roundabout Furzton Roundabout Elfield Park Roundabout Bleak Hall Roundabout A5 Bletcham and Caldecotte Roundabouts (Highway England) A5 Redmoor Roundabout (Highways England) A5 Portway Roundabout (Highways England) A5 Abbey Hill Roundabout (Highways England)

Of these the first two are outside Milton Keynes and were subsequently analysed using the approach agreed with Buckinghamshire County Council. The remainder were tested using output model flows in the standard junction capacity model programme.

On this basis three junctions were identified as suffering a material or severe impact which would require mitigation, namely:

Emerson Valley roundabout – H8/V3 Elfield Park roundabout – H8/V4 Bleak Hall roundabout – H8/V6

It is relevant to note that for the A5D junctions detailed analysis was discussed with Highways England as the A5D is a trunk road and they agreed no mitigation was necessary.

For each of the three junctions above, local improvement schemes were developed to reach a “nil detriment” solution where the performance of the junction is as it would have been without the development or the improvements. The full cost of these improvements will be derived (to include all costs including design, supervision, contingencies etc.) It was agreed with officers at the Council that the most sensible approach, to maintain flexibility in the future, would be for the developer to provide the total cost of the improvement in the form of a contribution. It should be noted that at this stage the costings have not been agreed.

A separate exercise was carried out to test the impact of the planned development within Bletchley. This again involved using the model with, in the first instance, a comparison of actual and modelled flows to confirm using the model within Bletchley and away from the grid road network was an acceptable approach. An analysis was then undertaken of the link capacity along Buckingham Road and the performance of the Buckingham Road / Sherwood Drive roundabout.

The link capacity analysis is based on the guidance in TA79/99 (produced by the Department of Transport). This states a high level of acceptable capacity for urban roads but as it is the Department’s guidance it has to be afforded considerable weight. On this basis, with the development in place, Buckingham Road operates within theoretical capacity apart from a very short length where mitigation is not possible as it could involve reducing the footpath width. The Sherwood Drive roundabout is shown to operate within capacity. Finally a more simple analysis on other key junctions in Bletchley confirmed only modest increases in traffic through these junctions.

Outside of Milton Keynes the need for mitigation to several junctions along the A421 is identified and this is approached in the same way as for the Milton Keynes junctions, namely a payment equivalent to the necessary nil detriment improvements. There is also an analysis of impact on the local villages. This shows only minor impact although discussions are taking place regarding a potential traffic calming scheme in Newton Longville as the village experiences the highest increase in flow.

FINAL COMMENTARY

Based on the above, the Transport Assessment concludes there are no severe impacts as a result of the proposals and it should not therefore be refused on highway and transport grounds. On technical grounds it would be difficult to reject this conclusion but is must be stressed:

i) Funds for the mitigation works at the junction must be agreed and secured. ii) The proposed public transport improvements must be secured. iii) The Travel Plan (reviewed by others) must be implemented in full.

It should also be noted with particular reference to the Council that the two access points within the Authority are to the required design standard, have been subject to Road Safety Audit and will operate within capacity.

A2.13 NHS England Please note that our department is only able to comment on the primary care, i.e. GP services provision. For the community and secondary care provision, I note Rebecca Green has responded separately and to confirm NHS England concur with this response.

The development of 1,885 dwellings will result in approx. 4,524 additional residents (based on 2.4 occupancy) and this impact cannot be accommodated in the existing surgeries in Milton Keynes. Closest GP surgeries to the proposed development are:

Water Eaton HC Our records indicate that they currently occupy a floor area of 351m2 NIA (net internal area). Their patient list as of 1 April 2016 was 6,536. According to the Department of Health’s Principles of Best Practice, a surgery with 6,000 registered patients is recommended to have 434- 454m2 NIA (net internal area) of floor space, which is more than they currently have. It should also be noted that the Principles of Best Practice is only concerned with the GP core services and does not provide size guidance for extended services, which most surgeries are offering.

Whaddon MC According to our records they currently occupy a floor area of 718m2 NIA (net internal area). Their patient list as of 1 April 2016 was 12,232. Principles of Best Practice stipulate that a surgery with 12,000 patients should have 796-832m2 NIA of floor space, which again is more than this surgery currently has.

Parkside MC According to our records they currently occupy a floor area of 720m2 NIA (net internal area). Their patient list as of 1 April 2016 was 10,545. Principles of Best Practice state that a surgery with 10,000 patients should have 724-757m2 NIA of floor space, which is approximately the same of slightly more than the practice currently has.

Considering the above, also the scale of this proposed development, distance, and most importantly, other significant developments planned in the area (e.g. Newton Leys 2,000 dwellings, 350 of which fall under Aylesbury Vale DC), NHS England needs to take a more holistic view. There is no doubt that existing provision will not be able to absorb the likely impact and for this reason an additional health facility will be required on site.

In order to mitigate the impact of the above development, we seek the provision of additional health facilities on site to include the provision of a site to accommodate a 6-GP surgery, the construction of the GP surgery to NHS England specifications. We also support the CCG in their request for a contribution per dwelling in line with the Social Infrastructure SPD adopted by Milton Keynes Council (2.7 of the Social Infrastructure Planning Obligations SPD, which can be found at http://www.milton- keynes.gov.uk/planning-and-building/planning-policy/social-infrastructure- planning-obligations ) towards secondary healthcare facilities for Milton Keynes Hospital.

We also request clarification from both Aylesbury Vale and Milton Keynes Councils as to the process by which the health requirements for this planning application will be discussed and agreed (e.g. through a collaborative s106 process including both Local Authorities).

A2.14 Waste Strategy

I have had a look at this planning application, which is as you know, in Aylesbury Vale.

From a waste management point of view we would be concerned that the properties in this area would be users of our community recycling centres particularly Bleak Hall. Bleak Hall site is the smallest of our CRC’s but is the nearest site for nearly half the existing MK population and already suffers from queuing at busy times. At the moment we do not have any other sites on the western side of Milton Keynes for development of CRC’s and have been seeking a suitable site in this vicinity for a while.

We have not factored an extra 1885 homes into any of our waste management plans and are concerned at the extra pressure on Bleak Hall site. In addition we will have to find the funding to dispose of the extra waste that is deposited at Bleak Hall. This could be around an extra 600 + tonnes a year at a disposal cost nearing £100/tonne.

A previous planning application on this site incorporated a household waste and recycling centre into the site which would have been much more suitable – the waste arising could have been managed by Bucks CC appropriately.

A2.15 COBRA

Ref. 15/00223/CONS - Outline Planning permission to develop land to the South West of Milton Keynes This paper has been prepared after consultation with residents, specifically in the area covered by the Mill Residents’ Association, and with members of the Consortium of Bletchley Residents’ Associations (COBRA), who jointly represent a large proportion of Bletchley residents. It is important to say we are not opposed to development of this site per se. We maintain that it is simply too early to assess its merits within the proposed time scale. Residents feel strongly that the application submitted by the South West Milton Keynes Consortium, as it stands, is unacceptable for the following reasons: Infrastructure before Expansion “Infrastructure before expansion”—I before E—has been key to our success. We are now expanding beyond the originally designed size of Milton Keynes, both in the physical footprint and in the number of people. We are now growing beyond these planned boundaries and this is putting pressure on infrastructure and services, which has been crucial in placing Milton Keynes as the most successful and fastest growing new city in the country.”1 Although the site falls within the boundary of Aylesbury Vale and is included in the draft VALP, the impact will be felt mainly in Bletchley and MK to which new residents will turn for health provision, education, leisure and communication links via road and rail to reach employment. Highways The proposed 1885 households are likely to result in at least 2262 extra cars or vans on the roads.2. Clearly this will have a huge impact on Bletchley in particular without an enhanced infrastructure to support it. The improvements to the site access referred to in the package of formal revisions are simply not enough to compensate for the additional congestion these extra vehicles will generate. Provision for “sufficient land to facilitate the Bletchley Southern Bypass” does not ring true, given that no detailed design or formal policy exists to support it. This is not “future-proofing”, it is merely an example of putting the cart before the horse. Healthcare Using an average household size as 2.5 people, 1885 homes in SWMK will house 4,700 people. This will require 12 extra GPs (not the mere

1 Iain Stewart, MP in his submission to the NIC Consultation, 1 August 2016. 2 Source: Office for National Statistics 2011 Census, average cars or vans per household 1200 per 1000 households possibility of a future 6 mentioned in the planning application) and 14 extra hospital beds.3 We are fully aware that decisions about healthcare provision will be made by NHS England and the MK Clinical Commissioning Group. However, dismissing this issue as irrelevant to the MK/AVDC boundary is deliberately missing the point. It does not invalidate residents’ deep concerns about additional pressure on our fully- stretched hospital, and the fact that the surgeries close to the proposed development site are not accepting new patients. The precedent at Newton Leys, where Section 106 money has eventually been used to build an empty health centre, with no funding for staff, does little to allay these concerns. We note also that provision of a 6GP surgery is only a possibility at this stage anyway. Education Using the MK Core Strategy school place planning model, we can expect that at least 80 places per year group will be required once the SWMK Development is complete. Although a primary school and possibly a secondary school are included in the plans, they would appear to be inadequate to meet demand even if they are eventually built. Furthermore we know from experience, for example at Newton Leys, that new schools are provided at least 5 years after building commences, so there is growing pressure on neighbouring schools meanwhile. Duty to Co-operate requirement under the Localism Act, 2011. A cursory reference to Plan MK fails to recognise that the development does in fact jeopardise a potential benefit common to all four of the Plan MK strategic directions – namely, the extension of strategic green space and linear parks, a large part of which will be swallowed up by this development. Pushing the application through hastily to influence future development direction options to the Consortium’s advantage does not instil confidence. On a more local scale, we have the examples at Newton Leys of how this so-called duty to co-operate across boundaries affects residents. It also seems that despite being neighbours Milton Keynes Council and Aylesbury Vale District Council are not working together effectively. There have been several planning applications for much needed community facilities located in the AVDC part of the Newton Leys site, not being considered through a lack of joined up thinking. Strategic Context and Timing This application is entirely developer-driven and as such it is unacceptable. Still worse, it appears that it is being pushed forward with undue haste, presumably in an attempt to predetermine the outcome of both Plan MK and the Vale of Aylesbury Local Plan (VALP). Plan MK preferred options will not be available for public consultation until next spring, by which time AVDC hopes that VALP will have been approved. Since both of these emerging local plans are strategic in their context, scope and timescale, it surely makes no sense to approve in the meantime an application that attempts to validate development adjacent

3 Sources: EC Report 2014 UK National average 2,71 GPs per 1000 peoples; OECD Report 2011 3 beds per 1000 people to Milton Keynes “by the back door”. Furthermore, the application takes no account of the work being undertaken by the National Infrastructure Commission, the Oxford to Cambridge Expressway Strategic Study, and ignores the MK Futures 2050 Commission Report which identifies the 6 major development projects that will make “A Great City Greater”, specifically Milton Keynes becoming Hub of the Cambridge-Milton Keynes-Oxford Arc. As it stands, this proposed development does not contribute to making “A Great City Greater”. In the long term, development on the site covered by this plan, if planned properly, could be beneficial to the development Milton Keynes as well as helping to resolve the national housing shortage. But this is not a quick fix and should not be considered for planning permission without an approved strategic framework mentioned above. In the absence of a relevant strategic context this is precisely the sort of developer-led, piecemeal approach that we may well live to regret. In conclusion, I reiterate that residents of the parts of Bletchley that COBRA represents are not anti-growth. We do not support an ill-timed, piecemeal approach nor approval of enormous housing developments which threaten the open spaces and environmental benefits of our existing design. We are genuinely worried about ill-planned growth compromising the qualities that have made Milton Keynes the success it is.

A2.16 Local Residents

As of the 4th of November 2016 62 Public Representations had been received.

Below is a summary of the most common objections received in reference to planning app 15/00223/CONS.

1. Land supply 2. Traffic 3. Infrastructure 4. Landscape 5. Schools 6. Health 7. Relating factors 8. Further reasons for public objections (Bletchley) 9. General comments

Land Supply Issues Raised

• Many public representations heavy outline that MK has sufficient quantity of land available for the housing target 2026. There is no need for another small town swamping nearby villages.

• The Public objections centre around the Five year land supply – “why are SWMK trying to build another small town? Not in the ADVC or MK strategic expansion plan”. Public view = driven by profit hungry developers.

• The location will destroy high quality arable land and flood our already congested and unsuitable roads with 1000’s of extra vehicles.

• Neighbour plan still being worked on – SWNK premature.

• Local people enjoy the space and do not want to be crammed into a built up area.

Traffic

• Road traffic from the proposed development towards Leighton Buzzard station. This will increase massively the flow and number of cars on the narrow roads. This fact has been conveniently ignored or overlooked by the consultants/developers.

• We are appalled that some of the traffic and collision detail used by the consultants are from 2014 and therefore now two years out of date. They most definitely do not reflect current traffic flows through Newton Longville, which reaches some 5000- two-way vehicle movements per day. Since the Newton Leys development, the traffic through our village has become horrendous, with a large volume of traffic to and from Newton Leys as well as from the A4146. The proposed new development will see thousands of cars and lorries all trying to use the one road through Newton Longville between the A4146 and A421.

• Traffic assessment - images have been used from Google Street View, some out of date. Google Maps traffic is not an accurate method of analysing traffic flows and volume - incompetence, inefficiency, laziness and a quite possibly deliberate attempt to massage the figures to hide the true nature of the huge volumes of traffic in, through and out of Newton Longville. • We have asked to see SWMK’s raw traffic data. They have refused. Why? If they have nothing to hide, then why hide it? • Air pollution and risk of accidents from the increase of car is a common concern of the public.

Infrastructure

• Whaddon Road from Bottledump Roundabout to Newton Longville is not suitable for one of the only two exits to the proposed development. • Bletchley Road from the very narrow Railway bridge into the village already attracts many HGV and speeding motorists • The idea of having three entrances and only two exits to what will be, in effect a small town has to be seen as absurd. Imagine the queues of traffic trying to join the A421 at 7.30 AM, or return at 5.30 PM. • The proposed bus service is entirely inadequate and not fit for purpose – ridiculously it offers no links to Newton Longville or anywhere generally within Aylesbury Vale. • Whaddon Road – Bottledump roundabout is a narrow rural road and clearly not suitable for increased traffic. There is no offer to upgrade the road. • Issues relate around traffic calming measures will not work – i.e. choke/crowd roads – Whaddon road cannot cope. • The proposed bus service is entirely inadequate with no links to Newton Longville or Aylesbury. • Generally, roads and footpaths will be destroyed - Public objection

Landscape • There is not enough information to show how the development will be screened from existing housing, particularly houses on the ridge houses 300m from development (Newton Longville). • Public (Newton Longville, Newton Leys and Bletchley) unhappy to wait 15 years or more for mature and give adequate screening of the proposed development from • Newton Longville and Bletchley will suffer a loss of skyline • Loss of good quality arable land. • Newton Longville is currently surrounded by open countryside which separates it from Milton Keynes and provides a green buffer from the urban sprawl – development negatively affects this. • A site close to Aylesbury has recently been rejected by the Secretary of State for not leaving a satisfactory green buffer between the village and Aylesbury. In Appeal APP/J0405/A/14/2219574 it was said: “The Secretary of State agrees with the Inspector that Bierton is a village surrounded by countryside and not joined to Aylesbury and that the proposed development would cause Bierton to lose its separate identify.” • The Milton Keynes Boundary Walk into the development to run alongside Whaddon Road completely changes the characteristic of this unique walk around the boundary of MK. It is the equivalent of putting a footpath next to a motorway. • Converting rural footpaths into urban walkways massively changes the character of the area and removes the opportunity to enjoy a walk or cycle in the open countryside. • The development ruins good-quality agricultural land. It is a valuable local amenity, with a tranquil footpath and cycle-way, which clearly defines the border between the city of Milton Keynes and the Aylesbury Vale village of Newton Longville

• The development will create light, noise and air pollution.

Schools

• There is not enough detail about schools, including information about how they will be funded, built and run. • There will also be an adverse impact on Newton Longville village school. • The schools will be in Buckinghamshire. Therefore, traffic will be accessing the schools from other areas of Buckinghamshire, and not from Milton Keynes. The highways impact of this has not been considered – it will increase pressure on the roads and might lead to difficulties in parking in the village, especially at peak times. • Pedestrian access to the schools from surrounding villages, including Newton Longville, has not even been considered. What do these developers think local children will do? Walk along the 60 mph Whaddon Road? If the answer to that is ‘yes’; they are failing in the duty to provide safe passage for pedestrians. If the answer to that is ‘no’, it means yet more traffic on the roads. Health

• The building of over 2,000 houses will impact severely on local health services. The local CCG (Clinical Commissioning Group) - existing local surgeries do not have any spare capacity to absorb the population increase. • The developers offer a possibility, but not a legal guarantee, of a site for a new GP surgery. What is the point of a possible site if there is no guaranteed money to build or fund it? • Although they are willing to provide some land for a health centre they are not offering any funding for the building, or to pay ongoing costs. • How will the developer guarantee to mitigate the impact of this development and ensure provision of the additional health facilities needed? Relating factors

• The application takes no account of the work being undertaken by the National Infrastructure Commission, the Oxford to Cambridge Expressway Strategic Study, and ignores the MK Futures 2050 Commission Report which identifies the 6 major development projects that will make “A Great City Greater”.

• The development will not lessen the impact on the infrastructure of Milton Keynes, particularly in the Bletchley area. If planning permission is granted, this will be the green light for further development on the lines of the original Salden Chase proposal in 2010.

Further reasons for public objections (Bletchley)

• Shopping

Bletchley will be the nearest town to the site, but currently does not have the capacity to accommodate additional shoppers due to inadequate parking & congestion on the roads.

• Flooding

Flooding is a serious consideration, particularly now that heavy snowfall & rainfall is the norm for our climate – the proposed flood prevention/drainage measures are inadequate protection for those living in the Newton Longville/Bletchley area