ANNEX A

Responses to public consultation on Planning Obligations SPD.

Contributor Comments Response

Little Brickhill and Parish Council ,Loughton and Great Holm Parish Council, Newport- Text will be added to Chapter 3 'Approach to Planning Obligations' Pagnell Town Council, Planning Obligations Protocol, approved by Cabinet in 2014, should be added to the proposal to to reflect the undertakings given in the draft Protocol that there and give Parish and Town Councils a formal role in spending S106 / tariff monies. would continue to be greater consultation with the local Council's Tattenhoe Parish Council, about impacts of development and how they are mitigated. Parish Council, CMK Town Council

The document contains numerous typographical and grammatical errors. The final document needs to be carefully proof-read. Final version will be reviewed and amended as required. Table 5 reflects current policy on affordable housing which is being Affordable housing- possible error in table 5 reviewed separately. Town Council support pepper potting but not in blocks of more than 12. Housing should have its own entrance like Dalgin Place See policy on affordable housing above. Pupil yield data has been compiled locally and used to estimate number of pupils by type and size of dwelling. Pupil yields from one Education - Welcomes change to education cost but not for studio/ one bed as this is likely to be bed properties is low but largely confined to pre-school age student accommodation. children. Developments consisting of 'studio' accommodation only or largely, such as student accommodation, would be considered separately. Employment- support new obligation for training Noted. Agreed inward investment text to be moved from chapter 8 to Should move guidance information for inward investment from social infrastructure to this section. chapter 7 (Employment chapter). CMK Town Council Latest available retail floorspace capacity figures have added to Update figures from latest retail capacity study. the document. Social infrastructure Noting that public art is site specific rather than borough wide and object to moving Public Art to LIT( if adopted) best to deliver locally is s106 as would be better for local communities LIT proposal now withdrawn by the Government. SI Suggestion- SI Suggestion- Public Art (0.5%) contributions from residential development should move to Section 9 "Leisure, Recreation and Sports Facilities" (see below). If the Council adopts LIT, these contributions should stay as s106 obligations to deliver art/culture projects for the local community. 2. Public Art (0.5%) contributions from commercial development should move to LIT to deliver Borough-wide art/culture projects. See comment above about LIT. MKC believes public art should remain in the social infrastructure Leisure, recreation and sports facilities-Public art contributions should be moved to Leisure, chapter rather than the leisure chapter because it has wider recreation and sports facilities section benefits. Local and neighbourhood play facilities address all age range of Unclear differences between “local and neighbourhood play facilities” and “neighbourhood play” children and young people, neighbourhood play is directed at the older age range of young people. Contributor Comments Response This is no longer possible as LIT proposal now withdrawn by the Want Swimming pools moved to LIT Government. Provision was taken from 2005 SPD and index for inflation, what basis for indexation. Would prefer Document updated using a range of sources indicated at the a bottom up review. bottom of table 18. See answer above. RPI now CPI is generally accepted means of More guidance needed at para 4.6 indexation. Applications have to be considered on their individual Recommend that Table 18 provides a sum total figure (£1,710) of the contribution required, it is not characteristics and it would be misleading to imply that every clear which items are counted or not. The worked example is unhelpful. It is appreciated that some housing scheme would be required to contribute £1,710 per CMK Town Council facilities may be provided on site by the developer, so the total monetary contribution may be less. person. The worked example is intended to demonstrate the Council's approach. Priority should be given to projects in Neighbourhood Plan. New text in chapter 3 makes reference to Neighbourhood Plans. Maintenance contributions are referred to in para 9.39 but new text 2005 SPD sets out commuted maintenance to adopt public open space. This does not. will be added to the document to make this point more explicitly. Other obligations- The Council's intention is that parking standards should be adhered to. Where there is a shortfall of parking provision it has recommend that where parking is under-provided an obligation is sought to fund public transport been the Council's experience, it has not proved possible (largely infrastructure projects on viability grounds) to request additional contributions. Unhappy with consultation as not directly consulted. No mention on the council’s website or from the consultation list policy have. Noted, consultation was through normal Council channels and via More comprehensive consultation should take place before adoption. Council website. This document highlights what new changes to existing policies are Unclear document as refers both to adopted and emerging policy. being made. SPD can not generate new policy, document must be prepared in accordance with the Town and SPD cannot generate new policy but the SPD does set out the Country Planning (Local Planning) () Regulations 2012, including in terms of consultation reasonable and proportionate contributions necessary to mitigate arrangements. the impact of the development.

Viability appraisal of the new SPD has been conducted and this Viability- concerned that the overall impact of the proposed planning obligations on development has also been cross referenced to the viability work underpinning viability have not been properly considered Plan:MK.

Land Value- more realistic assumptions based on evidence about the cost of land are included in the draft SPD and used to determine the viability of development Methodologies adopted in viability studies are standard. SWMK-Carter Jonas 2015 Deregulation Act mentioned under carbon off-setting at Environmental Standards- SPD does not mention Deregulation Act 2015 paragraph 10.14. amendments are made to the list of environmental related planning obligations, and in particular The Council is proposing to seek contributions to sustainable that obligations relating to sustainable construction and carbon offsetting are deleted. construction and renewable energy. It is acknowledged that Plan:MK has not yet been adopted by MKC Evidence- Public art obligation has not yet been tested and found sound through emerging however, Public Art contributions were also sought in previous Plan:MK Local Plans. MKC is seeking contributions for Public Art on the grounds that it meets all three CIL regulation 122(2) tests. Table 2 not considered to reflect complexity or simplicity of monitoring There is case law and MKC does not consider its monitoring fee a planning obligation. appeal decisions which have deleted unnecessary requests for monitoring obligations, on the basis Fee set through annual budget setting process. that relatively simple obligations should fall within the routine administration SWMK-Carter Jonas

Contributor Comments Response The applicability of any proposed obligation in chapter 7 can be assessed against individual applications and only levied where Chapter 7 does not meet any planning obligation test those obligations are considered to be reasonable ,necessary and proportionate in mitigating the impact of the development. As with obligations set under chapter 7, the impacts of a scheme Chapter 8 table 13 concerned about robustness of evidence for this contributions. The proposed will be assessed on a case by case basis as individual planning approach towards planning obligations for social infrastructure takes no account of the specific applications are received. Contributions will only be levied where impacts of a particular development on that infrastructure. and do not comply with the planning those obligations are considered to be reasonable, necessary and obligations tests. SWMK-Carter Jonas proportionate. Relationship with LIT- Planning Obligations SPD should not be adopted until the proposed local infrastructure tariff has been defined SPD will contain information which is inaccurate, and further consultation is necessary once the government has made a decision on LIT approach. LIT proposal now withdrawn by the Government.

Premature for a Local Authority to draft up guidance relying on the introduction of LIT at this stage. LIT proposal now withdrawn by the Government. Affordable Housing – A suggested approach to PRS proposals is set out in paragraphs 4.40-4.47. Table 5 reflects current policy on affordable housing which is being In these terms, it is trusted that the requirements of Chapter 5 will not apply to PRS schemes. reviewed separately. Education - Any planning obligations SPD should recognise that PRS schemes primarily attract Pupil yield data has been compiled locally and used to estimate Palmer Capital Partners younger residents, before they have children, or older residents without children. In these terms, it is number of pupils by type and size of dwelling and this would be (CBXIII)- Rapleys similar to the type of development described in paragraph 6.12. As such, planning obligations used to assess the applicability of education contributions to any relative to educational facilities should not be applied to PRS schemes. proposed development. . Employment Skills – Although the motives behind these suggested obligations are understood, Noted. A shortage of local workers however could be seen as any employment and skills plans should be flexible, and flexibly applied, to ensure a shortage of justification for the need for investment in training and skills. local workers does not prejudice, or hold up development. The Council's SPG/SPDs, which are being updated, explain and Gladmans SPDs cannot be used as a fast track mechanism to set policies give guidance on how the Council seeks planning obligations and are based on Development Plan policies. Planning obligations must comply with CILR 2010 and that obligations meet the relevant tests for planning obligations Noted Agreed the Council is seeking to achieve housing delivery and not Planning obligations should be applied flexibly to prevent planned development from being stalled. let planning obligations stall development. Viability- we support need to work with developers and for LPA to consider the impact planning obligation have on the viability of a development. Agreed Monitoring fees- Gladman object to the use of monitoring fees for planning obligations. There is established case law (Oxfordshire County Council v SSCLG [2015] EWHC 186 (Admin)) where the The Council levies a monitoring fee to ensure the smooth judge found that requesting monitoring fees was not CIL compliant as it is not necessary to make administration of planning obligations within the Borough and to the development acceptable in planning terms. employ dedicated staff who have experience of dealing with them. MKC does not consider its monitoring fee a planning obligation. Fee set through annual budget setting process. The Council has not refused planning applications for housing Education- Council must not use the lack of land for new schools or the inability to expand existing development because of a lack school places however new schools as reasons for refusing sustainable housing development. development must mitigate its impact on the Council's ability to meet its statutory duty to provide school place sufficiency. Plan:MK, reflecting the recommendations of the MK Futures 2050 Commission report, sets out the establishment of a new University Gladman object to the inclusion of an obligation for Universities as this is not considered to be CIL for as a Strategic Objective. Major development in compliant. These types of institutions are private bodies with their own funding streams. the Borough can be reasonably expected to contribute to the achievement of this objective given the necessity for the Borough to promote sustainable economic growth. Contributor Comments Response The provision of public art has been a characteristic feature of Social Infrastructure- Public art -not convinced that contributions sought in relation to this would Gladmans Milton Keynes for some time and the approach of the Council has pass the tests of being fairly and reasonably related in scale and kind to developments been supported by previous Local Plan Inspector's. The applicability of any proposed obligation can be assessed Emergency services- details provided in relation to what infrastructure/improvements would be against individual applications and only levied where those provided through this obligation in order to justify the obligation being sought. obligations are considered to be reasonable ,necessary and proportionate in mitigating the impact of the development. Environmental standards- para 10.25 -Gladman recommend that further details are provided within Further text to be added to refer to make reference to relevant the SPD in relation to this. current and proposed planning policies. . MKC does not consider its monitoring fee a planning obligation. Monitoring fees- robust justification is needed in the final proposal Fee set through annual budget setting process. Viability- EUV and AUV flexibility is welcomed Noted But Council should not therefore seek to impose a standard land owner premium of 20%. To do so Methodologies adopted in viability studies are standard however could deter land owners from making their land holdings available for development and thus stifle each viability appraisal must acknowledge the individual housing delivery. circumstances of each site.

Modelling- Any model or commercially sensitive information should not be published publicly. The Council must balance its obligations under freedom of information against commercial confidentiality. Historically the All build cost information submitted to the Council should be treated confidentially. Council has been able to achieve a balanced outcome satisfactory to all parties. Noted. Evidenced cost of capital will be acknowledged in viability Affordable housing- The inclusion of review mechanisms is likely to increase the cost of capital as it assessments but the Council will always seek to achieve an is seen as an increased risk by funders. Therefore, any review must take full account of cost affordable housing provision that comes as close to its policy increases and start at the position that the development is not in deficit. requirement as the development viability will allow. It is considered that the paragraphs 5.30 – 5.34 are overly prescriptive with regards to the tenure, Chapter 5 reflects current policy on affordable housing which is location and design of affordable housing being reviewed separately. Chapter 5 reflects current policy on affordable housing which is being reviewed separately. The final sentence of Paragraph 5.33 Paragraph 5.32 states that no more than 12 dwellings should be in a single block. This could result does acknowledge that exceptions could be appropriate in areas St William Homes LLP in an inefficient design that fails to optimise the potential of a site. where the density of development is significantly higher than average. Applications will have to be considered on their individual Education- assumptions are based on actual pupil data from recent housing developments adopting characteristics but standard methodologies are required to allow to a blanket approach fails to recognise that the characteristics of a development will determine its allow for assessment of applications where details are yet to be pupil yield determined.

Whilst the preference will always be for employment for MK Employment- Provisions should also be included to allow for jobs to be allocated to people in residents, the next best option is for those workers to be from the neighbouring local authorities in appropriate circumstances. sub-region/region.

Agreed. This approach is now being adopted by the Council as the Government is not proceeding with LIT at this time.

LIT- Part A should be brought forward as a standalone SPD. If no firm proposal comes from the government. Contributor Comments Response While every effort will be made to deliver projects early, their Kents Hill and Monkston Timing of projects and time taken to instigate project prevent delivery delivery may be effected by events which are beyond the Council's Parish Council control. Amendment to words should be as follows: The Council will maintain a public register of expressions of interest for the use of the money to meet the identified need, comprising a brief description of the project, the organisation or individuals proposing it, and an estimate of the cost and the amount of S106 funding required, and, if applicable, how any additional funding required might be raised. Only projects which meet the policy requirements and are within the scope of the Text will be added to Chapter 3 'Approach to Planning Obligations' S106 agreement on the particular site and have an outline of how they may be funded can be to reflect the undertakings given in the draft Protocol that there accepted. The estimate can be a rough order of magnitude or a range at this stage. The Council would continue to be greater consultation with the local Council's will contact the ward and parish councillors and any parties who have expressed interest annually to about impacts of development and how they are mitigated. ask them to update their expressions of interest. Applications for formal allocation of money must be accompanied by firm proposals and costings and either guarantees that any additional funding is available, or an intention to apply for a specific source of funding. Allocations may be awarded subject to conditions on gaining funding, planning permission, etc. Text will be added to Chapter 3 'Approach to Planning Obligations' When an application is received, all parties who have proposed projects for that part of the S106 to reflect the undertakings given in the draft Protocol that there allocation, and the Parish clerk and the ward councillors for the area shall be consulted. And then would continue to be greater consultation with the local Council's the existing text on resolving any conflicting applications. about impacts of development and how they are mitigated.

Agreed Parish and Town Council's will be consulted where Parish and ward councillors should be consulted in all cases where devolution is considered. 'devolution' of monies is proposed to third parties e.g. charities. The overhead involved in maintaining and communicating a formal The expressions of interest register should be added to the list of items to be communicated 'expressions of interest register' is beyond the current resourcing of quarterly. the Planning Obligations team.

Kents Hill and Monkston Affordable housing- options to reduce or opt out of the obligation should be kept to the absolute Agreed. The Council continues to seek to maximise Affordable Parish Council minimum. Housing provision in line with its policies.

The Council cannot seek contributions where this may amount to Education- there seems to be a lack of consideration of revenue or capital needs of Further and 'double taxation'. The revenue funding of H&FE is not normally a Higher Education matter for planning obligations. In section 6.2 please add: “or extensions to a school elsewhere, in an area to accommodate children who are currently Noted, however the Council believes the existing wording already using provision in the area of the development.” allows for the provision envisaged. New development must mitigate its impact on the Council's ability And in section 6.9: “Where pupils could reasonably be displaced to a different catchment school, to meet its statutory duty to provide school place sufficiency. The the capacity of the catchment schools in that area and existing and forecast school rolls” Council plans its school sufficiency on an area wide basis. New development must mitigate its impact on the Council's ability In section 6.11 after "catchment area schools" please insert "or other schools affected" to meet its statutory duty to provide school place sufficiency. The Council plans its school sufficiency on an area wide basis. Pupil yield data has been compiled locally and used to estimate In section 6.12, you assume that 1-bedroom properties will not generate a need for school places. number of pupils by type and size of dwelling. Pupil yields from one We do not believe that that is still true. Please check the recent data and amend accordingly. bed properties is low but largely confined to pre-school age children. In section 6.15 the figures are out of date, and there is a need to quote separately for flats and houses as the figures are very different. To be updated on the basis of the new pupil yield data evidence. Contributor Comments Response The footnote in 6.18 about using the most up to date data is critical. Should it not be in the main text? And refer to updates from time to time, not just the current one? To be updated on the basis of the new pupil yield data evidence.

It may be the case that the developer seeks to 'share' some of the obligations by passing them along the supply chain. It is to be Employment- is there any way that the large site obligations can be extended to businesses who expected that national companies are well versed in such are part of a chain or a national organisation? obligations and if the chain business is local then it's potential to meet local employment targets could well be easier to meet. other types of support that are sometimes badly needed, and difficult to fund. In particular, Milton Keynes has recently developed a good offering for business - Start-up business advice and support start-ups with the likes of Entrepreneurial Spark, Innovate MK and - Advice for fast-growing businesses the SEMSUP start up support programme. Business support is also available via the Velocity Growth Hub. That said, Velocity and SEMSUP are dependent upon external (European) funding and once this is no longer available there may well be a need to consider alternative sources of funding for business support. It - Advice for failing businesses may also be worth giving consideration to how developers and end users can support businesses through other means, for example local procurement or business mentoring.

In line with Milton Keynes Council’s policy, this obligation should refer to the minimum living wage Planning obligations cannot be used for operating costs normally paid by other taxes

Social infrastructure- Health Contributions cannot be sought from small scale (10 dwellings or less) and self-build development. This follows the order of the Is the proposal not to charge small developments for health facilities really maximising the amount Court of Appeal dated 13 May 2016, which give legal effect to the recoverable? policy set out in the written ministerial statement of 28 November 2014. Open Spaces and Play Areas In the past, we have always charged commuted lump sum Kents Hill and Monkston Maintenance contributions are referred to in para 9.39 but new text maintenance payments for these. Are these covered somewhere else, or how should they be Parish Council will be added to the document to make this point more explicitly. shown? The money is very important to Milton Keynes! The costings in Table 13 relate to the provision of new facilities and are extended to calculate required contributions on a per Social Care Please update the costings in the light of the national discussion over the last several person basis. New development cannot be required to remedy months and MK’s demographic. Also, actuarial data on likely care costs is available. Is it used? existing deficiencies in provision or the demand arising from the existing settlement. Voluntary Sector-In the cost table it states that no funding gap has been identified – but in the text it identifies and quantifies one! Please correct this. Noted para 8.31 and table 13 and will be corrected. Provision is made in the SPD document for the provision of Parish Buildings- Parishes are expecting to have to increase their capacity over the next few years, community facilities , which could include Parish Buildings. but no mention is made of parish offices, meeting rooms, etc. that will be needed. Where does this Parishes with significant new development within their area will come, and can we register that we expect to need offices. benefit from this funding. Emergency services - where is the fire service? The fire service is referred to in para 8.32 of the SPD document. Contributor Comments Response No supporting viability evidence has been provided for the draft SPD, and no reference is made in Viability appraisal of the new SPD has been conducted and will be O&H –David Lock the document to the draft Whole Plan Viability Study 2017 prepared by Aecom and HDH Planning referred to in the document. This work can also be cross and Development in support of the emerging Plan MK. referenced to the viability work underpinning Plan:MK.

As previously stated the evidence is available. Additionally, it would not be the Council's interest to make proposed charges for There is therefore no evidence to demonstrate that the proposed levels of charge and overall tariff development so punitive that it brings it to a halt. The Council is figures as set out in the draft SPD are viable. one of the largest landowners within the city and is promoting the development of 'surplus' employment land within its ownership.

Neither this draft SPD nor Plan:MK should be considered in isolation of each other. The viability testing should reflect the policy requirements set out in this draft SPD. Agreed

Para 4.7 of the SPD indicates that obligations up to £100,000 will normally be expected to be paid prior to the commencement of development. Many such obligations relate to the occupation or use The second sentence of this paragraph makes it clear the Council of a development, therefore front loading the cost adds a burden to the developer will consider phased payments on a case by case basis.

Para 7.33 True, the required skills may not necessarily currently be available locally. Where this is so, it can be considered a further argument in favour of planning obligations. Investing in the skills that the developer/end user requires will be beneficial particularly in the event of further development through providing access to a skilled, We take issue with the practicalities of such a proposed requirement: firstly, the skills required may employment ready cohort from which to draw employees. not be available locally; and secondly the applicant who signs up to the s106 may not be able to O&H-David Lock Note the wording 'all reasonable endeavours'. The applicant may impose an obligation upon the ‘end-state’ operator, Similarly the commitment to engage with local not be formally able to impose requirements on end users, but they businesses through the supply chain may also be out with the control of the applicant/developer. should be in a position to lead by example, to articulate the advantages that such obligations have created for them and should signpost the end user to the support that is available from the Council's Economy and Culture Team, Your MK and partners in helping to meet these obligations.

Contributions of up to £30,000 per dwelling may be required to This indicates a potential obligation per average 3 bed unit (100m2) in the order of £30,000. This mitigate the impact of development on large scale greenfield sites. excludes any University, Town Centre, employment and training costs, highways costs, However, viability testing suggests that contributions at this level environmental standards and heritage costs. can be sustained by this form of development.

Because of the lack of available viability evidence we cannot offer a definitive view as to the deliverability or implications on viability of this level of developer contribution. Noted see above

If such viability testing is not carried out and consulted on in a co-ordinated manner (including consideration of the SPD as part of the evidence base underpinning Plan:MK at the Examination due in summer 2018 rather than moving to adoption of the SPD in advance of Plan:MK’s examination) then we consider that the planning obligation requirements as currently drafted in this This comment raises the issue of further consultation on this SPD – especially if relied upon for Plan:MK - are unsound. document. Contributor Comments Response West Council That the document be noted and that no comments be submitted in response to this consultation Noted Please see Kents Hill and Monkston Parish Council response (duplication)

Plan:MK is not yet adopted and could yet change so there may be I am conscious that this SPD is repeating much of what is in Plan:MK – and some of it is definitely Cllr Jenni Ferrans a need to revise planning obligations guidance to reflect adopted not fully in step with Plan:MK Plan:MK. I am concerned that a last minute change in legislation could lead to MK Council’s SPD becoming Agreed , the Council will need to monitor what the Government unsound, or to under-recovery of what might potentially be recovered. decides to do and what legislation it decides to implement. The Council is seeking to prioritise contributions to schools and Recommend that we include an intention to charge contributions from all developments for health health together with community facilities, open space, play areas and education where possible. and affordable housing. However, it cannot seek contributions from housing developments of 10 dwellings or less.

See original document for grammatical changes in affordable housing section. Document will be proof read.

Local Employment Is the “annual return” statutory? If not, I am concerned that employers are not being asked for any This annual return is not statutory and it must be recognised there independently verified or legally accountable evidence of local employment. Can something be has to be a certain amount of trust of local employees working on devised? schemes.

Social Care The costings in Table 13 relate to the provision of new facilities and are extended to calculate required contributions on a per Cllr Jenni Ferrans I am very sceptical that the funding gap for social care is as low as is being represented! person basis. New development cannot be required to remedy existing deficiencies in provision or the demand arising from the existing settlement.

Voluntary Sector In the cost table it states that no funding gap has been identified – but in the text it identifies and quantifies one! Please correct this. Paragraph 8.31 will be amended.

Population The SPD seeks contributions for infrastructure where justified by There is fairly strong indication that the numbers of people typically residing in accommodation of a the latest evidence base. If the Council seeks to increase particular size is increasing as a result of the housing crisis and austerity measures. Is the policy contributions unilaterally as a result of new information it would using the latest data, and can it be specified so that future updates can be used immediately? need to give those effected the opportunity to comment on its proposals. AXA- David Lock Accept that may not be able to impose obligations on end users, Local Labour- We take issue with the practicalities of such a proposed requirement: firstly, the skills but would like to see applicants encourage approach and promote required may not be available locally; and secondly the applicant who signs up to the s106 may not the assistance that the council and partners can offer. Investment be able to impose an obligation upon the ‘end-state’ operator. in training is a necessary part of ensuring the availability of a local labour force with the required skills. Contributor Comments Response The Council would acknowledge commercial logistics development The following factors are important considerations in the construction of commercial logistics is often undertaken by specialist contractors. However , it would development which make such obligations unreasonable and a severe constraint to large employers like to explore the possibility of these firms taking on local people relocating or expanding existing operations in Milton Keynes: and training them. Large foot print building take specialist contractors to erect and unlikely to be found in MK. This also relates to local business in the supply chain. Noted The blanket obligation fails to recognise or differentiate between those permanently based on site This is something that would need to be identified and addressed and service engineers and other staff who visit the site infrequently. Surveys should be undertaken when creating the Employment and Skills Plan. of the number and type of frequently highly skilled employees in modern, large footprint logistic facilities in the area before this is imposed. Where supply chain requirements are already established and legally binding, we would not expect the developer to break these. Large institutional investors have specific supply chains requirements which are likely to be However, they would be expected to engage with local businesses Axa- David Lock established and legally binding and would be unsustainable to impose limitation which could drive on any other supply chain requirements and there would be an away investment. expectation that local procurement is considered when existing requirements cease or are due for renewal. Milton Keynes has enjoyed significant economic success in recent years. However, this has not been shared equitably across the city. There remain pockets of deprivation and evidence suggests that there is a growing gap between the most and least prosperous parts of MK ( Indices of Multiple Deprivation 2015). Whilst the Jobseekers Allowance claimant count stood at 1.1% in November 2017, this is above the rate for the south east region and is equal to the national rate. There are some wards in MK where the JSA claimant rate is significantly higher. To achieve sustained and inclusive growth it is essential that everyone in MK has the opportunity to benefit from good quality employment. Skills, training and ensuring local residents have the skills that businesses require is part of this. The proportion with higher level skills (NVQ 4+) is We have concerns over the lack of available evidence underpinning and justifying the proposed below the national and regional averages. In 2016, 7.6% of the developer obligations in relation to employment and training requirements. working age population had no qualifications. Local business surveys, such as that carried out by SEMLEP in 2017, highlight ongoing challenges with recruitment and finding skilled employees. Commuting figures show significant numbers of people commuting in to MK for work, and reports by the likes of Centre for Cities (see Fast Growth Cities report) highlight a dependency on high skilled workers from outside of the city. Equipping local residents with the necessary skills to secure local employment will benefit local transport infrastructure as well as retaining incomes within the city. To conclude, planning obligations have a key role to play, not only in supporting the growth of the city, but most importantly in ensuring this growth is sustainable and inclusive.

Viability appraisal of the new SPD has been conducted and this Without adequate empirical evidence to justify the scale of contribution sought, we suggest that the has also been cross referenced to the viability work underpinning SPD cannot be considered sound in this respect and would urge the Council to reconsider. Plan:MK. Contributor Comments Response

Public Art Trust- Ian The problems identified in the current SPD proposals are as we understand it; Michie/ David Stabler That the contribution towards art is reduced from 1% to 0.5% The monies will be spent on not just artworks but on ‘cultural’ activities across the city. Noted

It seems very perverse that, if Milton Keynes is genuinely hoping to be the Cultural Capital of Comments predate news that Milton Keynes is no longer able to Europe, the amount required for art and culture should be reduced by 50%! Should MK Politicians apply for European City of Culture designation. Contributions Public Art Trust- Ian not fully recognise the true worth of Public Arts we suggest the following. All of the S106 from reduced for public art because of concern about viability. While Michie/ David Stabler housing development should be committed to art works in the local area, especially if the parish or there is sympathy for the idea of a city wide pot it is considered this town council has an existing public art programme. All S106 for commercial developments should is happening as contribution towards culture can be spent on areas be allocated to a city wide cultural pot. other than public art e.g. museums